content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph discusses the materiality of cybersecurity risks to financial condition without describing any incident or naming specific frameworks/roles. It references a risk factor section but provides no firm-specific or quantified details.

provider: mistralai

stage: benchmark


content_category: Risk Management Process

reasoning: The paragraph describes internal risk assessment processes and third-party involvement in cybersecurity policies/procedures, making it a Risk Management Process topic. No specific facts (e.g., named roles, dates, or quantified details) are present, and the language is boilerplate.


content_category: Board Governance

reasoning: The paragraph centers on board committee oversight of cybersecurity risks, with the Audit Committee as the grammatical subject. Specific governance structures (ERM Committee, CIO, VP Infrastructure) are named, making this Firm-Specific.


reasoning: The paragraph focuses on the company's internal risk management process, including the ERM program, annual Enterprise Risk Assessment, and risk monitoring cadence. The presence of a named firm, a named internal program, and a quantified number of risk categories qualifies as Quantified-Verifiable.


reasoning: The paragraph focuses on the company's internal information security programs and their alignment with recognized frameworks (ISO and NIST), which is a Risk Management Process. The named frameworks qualify it as Sector-Adapted.


reasoning: The paragraph focuses on the company's internal risk management process (threat identification, assessment, and monitoring) with a firm-specific team composition detail.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and their integration into enterprise risk management, with no specific facts, named entities, or verifiable details.


reasoning: The paragraph focuses on board and committee oversight of cybersecurity risk, with the Board and Cybersecurity Committee as grammatical subjects. Named roles (VP, IT Data Security; CTO) and a named non-generic committee (Cybersecurity Committee) are present.


specificity_confidence: medium

reasoning: The paragraph centers on the Board of Directors' oversight of cybersecurity risks, with the HSE Director's role and tenure as supporting firm-specific details.


reasoning: The paragraph discusses the potential financial and operational impact of cyber risks and explicitly states that such risks have not materially affected the company to date, which aligns with Strategy Integration. No specific facts (dates, named roles, frameworks, or quantified details) are present.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risk management, with the Audit Committee as the grammatical subject. The inclusion of cybersecurity-specific roles (CIO, CISO) and the named committee (Audit Committee) qualifies as firm-specific facts.


reasoning: The paragraph focuses on the Board's oversight role, including reporting cadence and discussions with management, which is clearly Board Governance. The specific cadence ('At least once each year') qualifies as a firm-specific fact.


content_category: None/Other

reasoning: The paragraph is a cross-reference to the Risk Factors section and contains no substantive cybersecurity disclosure. It is a generic risk statement without any specific facts.


content_category: Management Role

reasoning: The paragraph centers on the ISO's role, reporting line, and qualifications, making Management Role the clear category. The ISO's title, CRO's title, and 20+ years of experience provide two verifiable facts (named roles + quantified experience).


reasoning: The paragraph focuses on the Board's active involvement in oversight of the Company's risk management program, with cybersecurity as a key component. The CISO's reporting line to the CRO is a firm-specific management role detail that supports this governance context.


reasoning: The paragraph focuses on board-level oversight of cybersecurity risk, with the Audit Committee as the grammatical subject. No firm-specific facts (e.g., named roles beyond generic titles, specific dates, or unique programs) are present.


reasoning: The paragraph describes the Trustee's internal cyber risk management program and protocols, focusing on integration into overall risk management and general practices. No specific named roles, dates, third-party firms, or quantified details are included.


reasoning: The paragraph contains no substantive cybersecurity disclosure—only forward-looking disclaimers and a cross-reference to a risk factor. It does not describe any incident, process, governance, or materiality assessment.


reasoning: The paragraph focuses on the company's internal risk management processes (InfoSec team activities, threat assessment, control implementation) rather than board oversight, management roles, or incident disclosure. No specific facts (named roles, dates, frameworks, or quantified details) are present.


reasoning: The paragraph focuses on the company's internal cybersecurity processes (incident response plan, risk assessments, threat modeling, vulnerability scanning, penetration testing) without referencing a specific incident or board/management oversight. No named frameworks, roles, dates, or firm-specific details are included.


reasoning: The paragraph focuses on the board's oversight role, with the audit committee as the grammatical subject for cybersecurity risk oversight. The mention of the audit committee's responsibility for cybersecurity risks qualifies as a firm-specific fact.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes (e.g., multilayer approach, dedicated team, assessments, monitoring tools, and policy integration), which aligns with the Risk Management Process category. It names the NIST framework, making it Sector-Adapted.


reasoning: The paragraph focuses on the Audit Committee's oversight role over cybersecurity risks, which is a board governance topic. No specific facts (e.g., named committees, dates, or unique details) are present, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal cybersecurity processes (vulnerability management, monitoring, incident response plan) and references the NIST framework, which is a recognized standard. No firm-specific details or quantified facts are present.


reasoning: The paragraph describes internal cybersecurity processes (incident response plan, tabletop exercises, business continuity plans, security awareness training) without naming any specific frameworks, roles, dates, or firm-unique details. The content is generic and could apply to any company.


reasoning: The paragraph focuses on board/committee oversight of cybersecurity risks, with the Cybersecurity Subcommittee as the grammatical subject. The specific facts (named committee, establishment date, composition detail) confirm Firm-Specific classification.


reasoning: The paragraph focuses on the company's internal risk management processes, including control development, risk assessments, and framework adoption. It names specific frameworks (CIS Critical Security Control and PCI DSS), making it Sector-Adapted.


reasoning: The paragraph describes internal cybersecurity risk management processes, including specific roles (Senior Director of Information Security), named committees (Technology Risk Management Committee, Materiality Committee), and a quantified escalation timeframe (24 hours). The board's Audit Committee is mentioned but as a recipient of reports, not the primary focus.


reasoning: The paragraph focuses on the management role (CDIO/CISO) and their qualifications, reporting line, and experience. It includes multiple verifiable facts: named roles, a specific year (2021), and named firms where the CDIO/CISO previously worked.


reasoning: The paragraph focuses on the board's oversight responsibility for strategic and operational risks, including cybersecurity, which aligns with Board Governance. No specific facts (e.g., named roles, dates, or frameworks) are present, making it Generic Boilerplate.


reasoning: The paragraph focuses on the Board's oversight of cybersecurity risks, with the Audit Committee and its Cybersecurity Risk Subcommittee as the grammatical subjects. The specific facts (named committee, headcount, and expertise requirements) identify unique elements of this company's governance structure.


reasoning: The paragraph describes internal cybersecurity processes (incident identification/response, tools, and testing) without naming specific frameworks, roles, dates, or firm-unique details. The focus is on general practices rather than governance, incidents, or third-party oversight.


reasoning: The paragraph focuses on the Board of Directors' oversight of cybersecurity risks and reporting cadence, making Board Governance the clear category. No specific facts (e.g., named committees, roles, dates, or tools) are present, and the language is generic boilerplate.


reasoning: The paragraph focuses on the CIO's leadership in cybersecurity oversight and incident response, making it a Management Role category. The mention of the CIO is a firm-specific fact.


reasoning: The paragraph focuses on the Board's oversight role ('The Board and the Audit Committee ... are actively involved in oversight of our cybersecurity program'), which is the grammatical subject, making Board Governance the most applicable category. No specific facts from the ✓ IS list remain after filtering out generic terms.


content_category: Third-Party Risk

reasoning: The paragraph focuses on vendor/supplier security oversight requirements and contractual security standards, which is the central topic. No firm-specific facts, dates, or named entities are present, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management process (incident detection and response) with the NIST CSF framework as the central reference, making 'Risk Management Process' the most applicable category.


reasoning: The paragraph focuses on internal cybersecurity risk management processes, including policies, procedures, and framework adoption. The only specific fact is the named framework (NIST CSF), which qualifies as Sector-Adapted.


reasoning: The CISO is the grammatical subject and primary focus of cybersecurity risk management. The paragraph includes verifiable facts: cybersecurity-specific role (CISO), experience duration (20+ years), and education (Master's in Cybersecurity Management).


reasoning: The paragraph focuses on the leadership and structure of the cybersecurity program, with the named role (Director, IT Infrastructure & Security) as the grammatical subject. The Cyber Incident Response Plan (CIRP) and ISC2-CISSP certification are firm-specific details.


reasoning: The paragraph discusses the potential material impact of cybersecurity threats and incident response practices without describing an actual incident, focusing on strategy and financial impact. No specific facts (dates, names, numbers, or unique identifiers) are present.


content_category: Incident Disclosure

reasoning: The paragraph describes a real cybersecurity incident with specific timing (October 2023) and a named system (23andMe.com), meeting the criteria for Incident Disclosure. The facts are firm-specific but do not reach the threshold for Quantified-Verifiable.


reasoning: The paragraph describes internal cybersecurity training processes (security awareness, phishing simulations, tabletop exercises) without naming any specific frameworks, roles, dates, or verifiable details. These are common practices, not firm-specific or quantified.


reasoning: The paragraph focuses on the company's internal cybersecurity program and processes, with no board governance or incident disclosure elements. It names specific frameworks (NIST CSF, GDPR, ISO 27001) but contains no firm-unique details beyond these standards.


reasoning: The paragraph discusses the materiality of past and potential future cybersecurity incidents without describing the incident itself, focusing solely on financial impact and strategy. No specific facts remain after filtering out boilerplate language.


reasoning: The paragraph describes internal cybersecurity processes (vulnerability management, monitoring, risk assessments) without naming any specific frameworks, roles, dates, or firm-unique details. The focus is on generic maintenance activities rather than board oversight, incident disclosure, or third-party risk.


reasoning: The paragraph focuses on the management team's roles, qualifications, and reporting lines, particularly highlighting the CISO's experience and certifications. The presence of multiple verifiable facts (e.g., years of experience, named certifications, degrees) confirms the Management Role category and Quantified-Verifiable specificity.


reasoning: The paragraph focuses on board and committee oversight of cybersecurity risks, with the Audit Committee as the grammatical subject. No firm-specific facts (e.g., named roles, dates, or unique programs) are present.


reasoning: The paragraph primarily describes internal risk management processes (training, third-party oversight, insurance) with the Information Security Department as a firm-specific entity. Board governance and incident disclosure are not the focus.


reasoning: The paragraph focuses on board and management recognition of cybersecurity oversight, making 'Board Governance' the most applicable category. No firm-specific facts remain after filtering out generic terms (e.g., 'management', 'Board', 'ERM program').


reasoning: The paragraph focuses on the materiality assessment of cybersecurity risks to business strategy and financial condition, which is a Strategy Integration topic. The only specific fact is the fiscal year reference (fiscal 2025).


reasoning: The paragraph centers on the ERM committee's oversight role in cybersecurity risk management, with the ERM as the grammatical subject. The inclusion of cybersecurity-specific roles (CISO, CDO) further supports this categorization.


reasoning: The paragraph discusses the materiality of cybersecurity risks and financial impact without describing any incident or naming specific frameworks/roles/dates. It is a generic materiality assessment.


reasoning: The paragraph focuses on the oversight structure for cybersecurity risk management, with the ISC (a named committee) and the CISO (a cybersecurity-specific role) as the primary subjects. The named committee and role, along with specific certifications, make this Firm-Specific.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management program and explicitly names the frameworks used to design and assess it, which aligns with Risk Management Process. The named frameworks (NIST CSF and SOX) qualify it as Sector-Adapted.


reasoning: The paragraph describes internal cybersecurity risk management processes without naming specific frameworks, roles, dates, or firm-unique details. It is a generic description of risk assessment and management aligned with industry standards.


reasoning: The paragraph focuses on the CISO's qualifications, certifications, and reporting structure, making it a clear Management Role disclosure. The specific facts (named role, certifications, university) elevate it to Firm-Specific.


reasoning: The paragraph contains no substantive cybersecurity-specific content beyond generic risk language and forward-looking disclaimers. It does not describe a real incident, management roles, board oversight, or any firm-specific or quantified details.


reasoning: The paragraph describes internal cybersecurity risk management processes (identification, assessment, monitoring, penetration testing) without naming specific frameworks, roles, dates, or unique company details. All elements are generic practices.


reasoning: The paragraph describes internal cybersecurity processes (engagements with external experts, training, and policy refinements) without naming specific frameworks, roles, dates, or verifiable details. The focus is on general practices rather than board oversight, incident disclosure, or third-party risk.


reasoning: The paragraph focuses on board and committee oversight of cybersecurity risks, with the CSO as the management role being the only specific fact. The Audit Committee and Board of Directors are generic governance terms.


reasoning: The paragraph describes a real cybersecurity incident (impact on systems, data theft/destruction, operational restoration) with no firm-specific details, dates, or verifiable facts beyond generic incident language.


reasoning: The paragraph describes a real cybersecurity incident with specific dates, named systems, and a specific threat actor type, making it Incident Disclosure. It includes two verifiable facts (date + named systems) for Quantified-Verifiable specificity.


reasoning: The paragraph describes a specific incident with a date and details about the response, making it an Incident Disclosure. It contains firm-specific details (date, incident type) but lacks two hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph describes a real cybersecurity incident with specific dates, named firm, and actions taken (engaging cybersecurity expertise), making it an Incident Disclosure. The presence of a specific date and named firm qualifies as two verifiable facts.


reasoning: The paragraph focuses on the management role (VP of IT) and their responsibilities, qualifications, and team composition, making 'Management Role' the most applicable category. It contains multiple verifiable facts (named role, team composition, years of experience, headcount) qualifying as Quantified-Verifiable.


reasoning: The paragraph describes an actual cybersecurity incident with specific dates, company name, and named actions (cyber incident procedure, external experts, law enforcement). While it lacks quantified metrics, it meets Firm-Specific criteria due to the incident narrative and named entities.


reasoning: The paragraph describes a specific cybersecurity incident (data accessed by a former employee, scope of data, and regulatory involvement), making it an Incident Disclosure. It contains two verifiable facts (33 million accounts and named regulators) qualifying it as Quantified-Verifiable.


reasoning: The paragraph describes a real cybersecurity incident with specific dates, scope of access, affected functions, and response actions, making it an Incident Disclosure. It contains multiple hard verifiable facts (three specific dates + named actors/functions) meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes an actual cybersecurity incident with a specific date and details about the response and operational impact, making it an Incident Disclosure. It contains firm-specific details but lacks two independently verifiable hard facts (e.g., named third-party firms or products) to reach Quantified-Verifiable.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access, exfiltration, threat actor demands, operational impact) and includes specific time references ('first quarter of fiscal 2026'). While it lacks two hard verifiable facts, it clearly centers on an incident narrative.


reasoning: The paragraph describes a specific cybersecurity incident with clear dates, scope of data accessed, and operational impact (user accounts), meeting the Incident Disclosure criteria. It contains multiple hard verifiable facts (two specific dates and a percentage).


reasoning: The paragraph describes a specific cybersecurity incident with clear dates, named systems (Dropbox Sign), and detailed scope of access and impact. The incident narrative is the central focus, meeting the criteria for Incident Disclosure.


reasoning: The paragraph describes a specific incident with clear dates, system identifiers, and references a prior disclosure, making it an Incident Disclosure. The presence of a specific date, named system, and named filing firm provides two verifiable facts.


reasoning: The paragraph describes the scope and nature of a cybersecurity incident (unauthorized data access) with firm-specific details about affected customer groups and included data elements. It lacks quantified verifiable facts like dates or dollar amounts.


reasoning: The paragraph consists entirely of forward-looking disclaimers and legal boilerplate with no substantive cybersecurity disclosure or specific facts.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access to customer data) with scope details (types of data accessed, customer group affected) and response actions (investigation, law enforcement notification, customer notification). However, it contains no firm-specific hard facts (dates, dollar amounts, named firms/tools, headcounts) or verifiable quantified details.


reasoning: The paragraph describes a cybersecurity incident (access by a threat actor, data exfiltration, operational impact, and response actions), making it an Incident Disclosure. It contains no named entities, dates, or specific details, resulting in Generic Boilerplate.


reasoning: The paragraph describes an incident involving unauthorized access by a former executive officer, including investigation and response actions, making it an Incident Disclosure. The mention of 'former executive officer' is a firm-specific fact.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, fitting Strategy Integration. No specific facts (dates, names, numbers) are present, making it Generic Boilerplate.


reasoning: The paragraph focuses on the financial impact and materiality assessment of a disclosed cybersecurity incident (referenced as 'the Incident') without describing the incident itself, which aligns with Strategy Integration. It contains two verifiable facts: a dollar range and specific cost categories.


reasoning: The paragraph describes a real cybersecurity incident (exfiltration of client data) with specific details about the nature of the data and actions taken (engaging experts). While it lacks hard verifiable facts like exact dates or dollar amounts, it contains firm-specific details about the incident's scope and response.


reasoning: The paragraph focuses solely on financial/materiality impact of an incident (no event description) and includes boilerplate language like 'material impact on business operations' and 'reasonably likely to materially impact'.


specificity_confidence: low

reasoning: The paragraph describes the operational impacts, response actions, and system restoration following a cyber incident, making it clearly an Incident Disclosure. However, it lacks any named entities, dates, dollar amounts, or other hard verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses on the financial/materiality impact of a disclosed incident without describing the incident itself, making it Strategy Integration. It includes two specific dates that are verifiable.


reasoning: The paragraph describes a real cybersecurity incident with specific dates, named external cybersecurity experts, and detailed operational impacts, making it Incident Disclosure. It contains multiple hard verifiable facts (date, named firm, operational impacts) qualifying as Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident with clear dates, named threat actor, and quantified scope of impact, making it an Incident Disclosure with verifiable facts.


reasoning: The paragraph describes a specific incident with clear dates, actions taken by threat actors, and operational impacts, making it an Incident Disclosure. The specificity is Firm-Specific due to the inclusion of a specific date and detailed incident-related facts.


reasoning: The paragraph focuses on financial/materiality aspects of a cybersecurity incident (insurance reimbursement expectations, lack of material impact) without describing the incident itself, which aligns with Strategy Integration. No specific facts (dates, named entities, quantifications) are present.


reasoning: The paragraph describes a specific cybersecurity incident with clear dates, named entities (Targus, B. Riley Financial), and verifiable details about the event and response actions. This fits the Incident Disclosure category as it narrates what happened, when, and the operational impact.


reasoning: The paragraph describes the scope and operational impact of a disclosed cybersecurity incident (affected systems, impacted functions) and includes quantified financial impact ($388,000) and specific dates (September 9, 2025; Q3 ending September 30, 2025).


reasoning: The paragraph discusses the financial/materiality impact of a cybersecurity incident without describing the incident itself, fitting Strategy Integration. It contains three specific dates that are hard verifiable facts.


reasoning: The paragraph describes a specific cybersecurity incident with clear dates, named external firm involvement, and a named internal system, all central to the disclosure. The content category is Incident Disclosure as it details what happened, when, response actions, and scope.


reasoning: The paragraph discusses the financial impact (revenue delay, lost revenue, one-time expenses) of a cybersecurity incident without describing the incident itself, making it Strategy Integration. It contains two specific dates that are verifiable.


reasoning: The paragraph discusses the financial/material impact of a cybersecurity incident without describing the incident itself, which aligns with Strategy Integration. There are no specific facts (dates, named entities, numbers, etc.) to elevate specificity beyond Generic Boilerplate.


reasoning: The paragraph describes a real cybersecurity incident with operational impact (halted operations, restoration timeline, remediation actions), making it an Incident Disclosure. It contains multiple verifiable facts (two-week disruption, mid-June restoration) that meet the Quantified-Verifiable threshold.


reasoning: The paragraph describes a specific incident (date, systems affected, operational disruptions) with multiple verifiable facts (June 19, 2024 date, named systems DMS and CRM). This clearly falls under Incident Disclosure.


reasoning: The paragraph describes a real cybersecurity incident with specific dates, actions taken, and operational impacts, making it clearly an Incident Disclosure. It contains multiple verifiable facts (date, operational impacts) that meet the Quantified-Verifiable threshold.


reasoning: The paragraph describes a specific incident with dates, incident type, and named third-party support, making it an Incident Disclosure. The two specific dates and named firm qualify it as Quantified-Verifiable.


reasoning: The paragraph discusses the financial/material impact of a cybersecurity incident (liquidity waivers, capital provision) without describing the incident itself, fitting Strategy Integration. It contains multiple verifiable facts (named firms, dates, dollar amount).


reasoning: The paragraph describes a real cybersecurity incident with specific dates (June 30, 2024 and July 5, 2024) and details about unauthorized access and response actions, making it an Incident Disclosure. The two specific dates qualify as hard verifiable facts.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation, including actions taken (reporting to law enforcement, informing regulators) and the current status of findings (no evidence of data access, no material operational impact). Specific dates ('to date', 'As of the date of this Report') qualify as firm-specific facts.


reasoning: The paragraph describes a real cybersecurity incident with specific details (date, engagement of a cybersecurity firm, and notification of regulators/law enforcement), making it an Incident Disclosure. The facts include a specific date, a named third-party firm, and a specific action (notifications), meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes an actual cybersecurity incident (access and exfiltration of data) with firm-specific details about the nature of the breach and affected data types. While it lacks hard verifiable facts (e.g., dates, dollar amounts), it contains sufficient firm-specific incident details to qualify as Firm-Specific.


reasoning: The paragraph describes a real cybersecurity incident with actions taken (containment, response, investigation, law enforcement notification, operational impact), meeting the Incident Disclosure category. No firm-specific, quantified, or named standard facts are present, making it Generic Boilerplate.


reasoning: The paragraph describes a specific incident with a named date, named internal system, named external firm, and operational impact details, making it an Incident Disclosure with verifiable facts.


reasoning: The paragraph describes a real cybersecurity incident affecting Change Healthcare services, including specific impacted services (pharmacy, medical claims, payment services). This meets the criteria for Incident Disclosure. The specificity is Firm-Specific due to named services, though it lacks quantified or verifiable facts for Quantified-Verifiable.


reasoning: The paragraph describes a real cybersecurity incident with specific dates, named third-party involvement, and operational impact details, making it an Incident Disclosure. It contains multiple verifiable facts (date, named firms, timeline) meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes a specific cybersecurity incident with a clear date, company name, and detailed incident narrative (unauthorized access, encryption/monitoring software deployment, system disruptions, containment efforts). This fits Incident Disclosure as the central topic.


reasoning: The paragraph describes a real cybersecurity incident with specific dates (June 19, 2024; June 21, 2024), named entities (CDK Global, DMS, CRM), and verifiable status updates (DMS functionality restored). This clearly fits Incident Disclosure.


reasoning: The paragraph focuses on the company's internal risk management processes (integration, biannual review cadence, participation by CISO/CIO and business segments) without naming specific frameworks, dates, or firm-unique details. The mention of CISO/CIO is generic as these roles are standard across companies.


reasoning: The paragraph focuses on the CTO's role and qualifications as the grammatical subject, making it a Management Role category. The inclusion of a cybersecurity-specific title and a quantified experience metric qualifies it as Quantified-Verifiable.


reasoning: The paragraph focuses on board oversight of cybersecurity risks, with the board and audit committee as grammatical subjects. No firm-specific facts, dates, or named entities are present.


reasoning: The paragraph discusses materiality conclusions about cybersecurity risks without describing any specific incident or naming frameworks/roles/dates. It references a risk factor section but does not provide substantive details.


reasoning: The paragraph is a cross-reference to another section (Item 1A) and does not contain substantive cybersecurity disclosure. It is purely a directive to another part of the filing.


reasoning: The paragraph describes internal cybersecurity risk management activities (monitoring laws, process changes) without naming any specific frameworks, roles, dates, or firm-unique details. It is a generic description of risk management processes.


reasoning: The paragraph focuses on the management roles (CIO and Information Security Director) and their responsibilities, making it a clear Management Role category. It includes multiple verifiable facts (named roles, team name, and quantified experience years).


reasoning: The paragraph describes a specific cybersecurity incident with clear dates, the company's name, and detailed narrative of the event, scope, and response actions. The two specific dates and the named firm meet the Quantified-Verifiable threshold.


reasoning: The paragraph focuses on the management role (CFO) as the primary subject for cybersecurity risk oversight, making it a Management Role category. The CFO is a cybersecurity-specific role in this context.


reasoning: The paragraph focuses on the responsibilities of a named management role (Mr. Gharib) in cybersecurity, making it a clear Management Role category. The named role is a specific fact unique to the company.


reasoning: The paragraph focuses on the Audit Committee's oversight role, which is a generic governance structure. No firm-specific facts (e.g., named roles beyond generic 'Senior IT leadership', no dates, no quantified details) are present.


reasoning: The paragraph describes internal cybersecurity risk management processes (identification, classification, escalation) without naming specific frameworks, roles, dates, or firm-unique details. The subject is the Adviser's program, not the board or a specific incident.


reasoning: The paragraph focuses on board-level oversight of cybersecurity, with the Board and a named committee (Enterprise Risk Management Committee) as the grammatical subjects. The named committee is a firm-specific detail.


reasoning: The paragraph focuses on the board of directors' oversight of cybersecurity as part of the ERM program, making Board Governance the most applicable category. The specificity is Generic Boilerplate as it contains no firm-specific facts, only general references to frameworks (NIST, ISO) and generic governance language.


reasoning: The paragraph discusses the financial/material impact of cybersecurity risks and incidents without describing any specific incident details or internal processes. No firm-specific or verifiable facts are present.


reasoning: The paragraph focuses on the company's internal cybersecurity program and risk management processes, with the CDRM organization and Global CISO as the grammatical subject. The inclusion of the named team, role, and framework makes it Firm-Specific.


reasoning: The paragraph describes internal cybersecurity processes (training, awareness updates, testing, penetration testing, assessments) without naming any frameworks, roles, dates, or firm-specific details. The focus is on generic risk management activities.


reasoning: The paragraph focuses on the company's internal cybersecurity program integration with other risk management systems, making it a Risk Management Process category. It contains no specific facts (no named roles, dates, frameworks, or quantified details), so it is Generic Boilerplate.


reasoning: The paragraph focuses on the internal risk management process, with the CSO as a key participant. The CSO role is a firm-specific cybersecurity management title.


reasoning: The paragraph focuses on cybersecurity-specific management roles (CISO and CTO) and their qualifications, making it a clear Management Role category. It contains multiple verifiable facts (dates, years of experience, certifications) that meet the Quantified-Verifiable threshold.


reasoning: The paragraph describes internal cybersecurity risk management processes (Security Committee meetings, Information Security policies, and employee training) with firm-specific roles (Security Committee, head of Information Security).


reasoning: The paragraph describes internal risk assessment and mitigation processes without naming specific frameworks, roles, dates, or firm-unique details. The language is generic and could apply to any company's cybersecurity practices.


reasoning: The paragraph discusses the financial/materiality impact of cybersecurity risks without describing any incident, making it Strategy Integration. It contains no specific facts (no dates, roles, numbers, or named entities), so it is Generic Boilerplate.


reasoning: The paragraph describes internal risk management processes (evaluating/testing systems, audits, threat assessments) with no board or management focus, incident details, or third-party oversight requirements. No firm-specific facts (e.g., named roles, dates, tools) are present.


reasoning: The paragraph discusses materiality of cyber risks to business strategy and financial condition without describing an incident, fitting Strategy Integration. It contains no specific facts (no dates, roles, named entities, or quantified details), making it Generic Boilerplate.


reasoning: The paragraph discusses the financial/materiality impact of cybersecurity incidents (or lack thereof) without describing any actual incident details, making it Strategy Integration. No specific facts (dates, names, numbers) are present, resulting in Generic Boilerplate.


reasoning: The paragraph focuses on board-level oversight of cybersecurity risks, with the Board's Cybersecurity Committee as the grammatical subject. The specific facts (named committee, year, and unique training) identify the company uniquely.


reasoning: The paragraph describes internal cybersecurity risk assessment processes without naming specific frameworks, roles, dates, or unique company details. It focuses on general risk management rather than board oversight, incident disclosure, or third-party risk.


reasoning: The paragraph describes internal incident response processes (triage, assess, investigate, etc.) without naming any specific frameworks, roles, dates, or firm-unique details. It is a generic description of incident response planning.


reasoning: The paragraph focuses on the Board of Directors' oversight of cybersecurity risk management through the Audit Committee, making 'Board Governance' the most applicable category. No specific facts (e.g., named roles, dates, or unique identifiers) are present, and the language is generic boilerplate.


reasoning: The paragraph centers on board oversight of cybersecurity, with the Audit Committee and full Board as grammatical subjects. Named cybersecurity-specific roles (CIO, CISO, CIRO) are firm-unique facts.


reasoning: The paragraph focuses on the cybersecurity management role (Jack Wang) and his responsibilities, qualifications, and reporting lines, which aligns with the Management Role category. The facts are firm-specific (named role, subsidiary, degrees, years of experience).


reasoning: The paragraph discusses the financial/materiality impact of cybersecurity incidents (no material incidents, immaterial expenses) without describing any actual incident details, making it Strategy Integration. No specific facts (dates, names, numbers) are present, so specificity is Generic Boilerplate.


reasoning: The paragraph discusses generic IT department responsibilities and governance structures (Audit Committee, CFO) without substantive cybersecurity disclosure. No cybersecurity-specific roles, committees, dates, or verifiable facts are present.


reasoning: The paragraph focuses on the roles and responsibilities of cybersecurity leadership (CISO and CTO), which are management roles. The named roles are firm-specific facts.


reasoning: The paragraph describes internal cybersecurity processes (risk identification, stakeholder meetings, incident controls) without naming specific frameworks, roles, dates, or unique company details. The focus is on general risk management practices rather than board governance, incident disclosure, or other categories.


reasoning: The paragraph describes internal audit processes (risk assessment, reporting) without naming specific frameworks, roles, dates, or unique company details. The focus is on generic internal audit practices.


reasoning: The paragraph describes internal cybersecurity processes (penetration testing, program reviews) without naming specific frameworks, roles, dates, or firm-unique details. The focus is on generic risk management activities rather than board governance, incident disclosure, or third-party oversight.


reasoning: The paragraph is a cross-reference to another section ('Risk Factors') and contains no substantive cybersecurity-specific disclosure, incident details, or governance/process information.


reasoning: The paragraph contains only generic risk language and forward-looking disclaimers with no substantive cybersecurity-specific facts, incident details, or governance/process descriptions.


reasoning: The paragraph contains no substantive disclosure about cybersecurity governance, incidents, or firm-specific details. It is a generic statement about the importance of cybersecurity without any named entities, dates, or verifiable facts.


reasoning: The paragraph describes the company's internal processes for assessing and managing third-party risks as part of its broader cybersecurity roadmap, making it a Risk Management Process. There are no specific facts (e.g., named roles, dates, or unique identifiers) to elevate the specificity beyond Generic Boilerplate.


reasoning: The paragraph describes internal incident response processes (escalation to management, Incident Management Team, and committees) without naming specific entities, dates, or verifiable details. The focus is on generic procedures rather than board governance, third-party risk, or an actual incident.


reasoning: The paragraph describes internal cybersecurity risk management activities (crisis simulation, monitoring, incident response, threat intelligence) with multiple named third-party firms and a specific fiscal year, fitting Risk Management Process. The four named firms and one specific date qualify as Quantified-Verifiable.


reasoning: The paragraph describes internal cybersecurity risk management processes related to third-party oversight, with third-party risks being a component of the company's own processes. No specific facts (dates, named roles, frameworks, or unique identifiers) are present.


reasoning: The paragraph focuses on management roles (Vice President of Information Systems and Chief Financial Officer) and their qualifications/experience, making it a clear Management Role category. Specificity is Firm-Specific due to named roles, quantified years of experience, and a named committee (GIAC Board).


reasoning: The paragraph focuses on board and committee oversight of cybersecurity risks, with the Audit Committee as the grammatical subject. No specific facts (e.g., named roles, dates, or unique identifiers) are present.


reasoning: The paragraph focuses on board oversight of cybersecurity risk, with the Board and Audit Committee as grammatical subjects. No firm-specific facts (e.g., named roles, dates, or unique details) are present.


reasoning: The paragraph focuses on board/committee oversight of cyber risk, with the Board and Audit Committee as grammatical subjects. No specific facts (named roles, dates, frameworks, etc.) are present beyond generic governance language.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and ERM integration, with no named entities, dates, or specific details. The grammatical subject is the company's own processes, fitting Risk Management Process.


reasoning: The paragraph describes the company's OWN internal security processes (tools, policies, exercises, training) as the topic, with no named entities, dates, or firm-specific details beyond generic practices.


reasoning: The paragraph describes internal cybersecurity risk management processes (incident response, disaster recovery, risk assessments, encryption, etc.) without naming any specific frameworks, roles, dates, or firm-unique details. The listed measures are generic and could apply to any company.


reasoning: The paragraph discusses cyber insurance and business continuity plans without describing an actual incident or naming any specific entities, dates, or metrics. The content focuses on financial protection and general preparedness, which aligns with Strategy Integration.


reasoning: The paragraph focuses on the cybersecurity-specific management role (Director of Cybersecurity) and its responsibilities, aligning with the Management Role category. The inclusion of quantified experience (over twenty years) and the named role qualifies it as Quantified-Verifiable.


reasoning: The paragraph discusses the materiality of cybersecurity risks to financial condition and operations without describing any incident, framework, or firm-specific detail. It is a generic statement about risk materiality.


reasoning: The paragraph describes internal cybersecurity risk management processes (vulnerability assessment program) without naming any specific frameworks, roles, dates, or firm-unique details. The language is generic and could apply to any company's cybersecurity practices.


reasoning: The paragraph discusses the potential financial/material impact of cybersecurity risks without describing any specific incident or naming any frameworks, roles, or dates. It is a forward-looking materiality statement with no substantive facts.


reasoning: The paragraph describes internal cybersecurity measures and processes without naming specific frameworks, roles, dates, or unique firm details. It is a generic list of controls and practices.


reasoning: The paragraph focuses on the board's oversight responsibility for cybersecurity risk management, making Board Governance the primary category. The named role (Vice President of Operations) is a firm-specific fact.


reasoning: The paragraph describes an ongoing incident and its material impact on business operations, which is central to Incident Disclosure. No specific facts (dates, named entities, or verifiable details) are present, making it Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident with clear dates and references to prior disclosures, meeting the criteria for Incident Disclosure. It includes two verifiable facts (date + named filing type), qualifying as Quantified-Verifiable.


reasoning: The paragraph describes a real cybersecurity incident with specific dates and named third-party involvement, which is central to the disclosure. The two hard verifiable facts (date + named firm) meet the Quantified-Verifiable threshold.


reasoning: The paragraph describes a real cybersecurity incident with specific actions taken (system isolation) and a specific date (December 20, 2023), making it clearly an Incident Disclosure. The two hard facts (date + specific action) qualify it as Quantified-Verifiable.


reasoning: The paragraph describes an ongoing incident investigation with no evidence of specific threats or confirmed access, focusing on the investigation process rather than firm-specific details or quantifiable facts. It lacks named entities, dates, or verifiable metrics.


reasoning: The paragraph discusses financial/materiality impact and operational consequences of a cybersecurity incident without describing the incident itself, fitting Strategy Integration. No firm-specific facts (e.g., dates, names, numbers) are present.


reasoning: The paragraph describes a real cybersecurity incident with specific details (date, entity involved) and incident response actions, making it Incident Disclosure. It contains two hard verifiable facts (specific date and named entity).


reasoning: The paragraph describes an actual cybersecurity incident (access and exfiltration of data) with scope details (limited data, PII), making it an Incident Disclosure. However, it lacks any firm-specific, verifiable, or named details, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes internal cybersecurity risk management processes without naming any specific frameworks, roles, dates, or unique company details. The focus is on general oversight and strategy.


reasoning: The paragraph describes a cybersecurity incident's operational impact (distribution delays, partial online limitations, revenue percentage) and includes a specific date and quantified revenue figure, making it an Incident Disclosure with Quantified-Verifiable specificity.


reasoning: The paragraph discusses the financial impact of an incident (materiality conclusion) with quantified earnings per share figures and a specific date, fitting Strategy Integration. The presence of two verifiable facts ($1.18 and $0.64) confirms Quantified-Verifiable specificity.


reasoning: The paragraph describes a real cybersecurity incident with specific dates (May 2023, June 2023) and a named system (SharePoint files), making it an Incident Disclosure with Quantified-Verifiable specificity.


reasoning: The paragraph describes internal incident response processes (Security Operations Center activities, severity matrix, notification protocols) without naming any firm-specific entities, dates, or verifiable details.


reasoning: Paragraph contains no substantive cybersecurity disclosure, only forward-looking disclaimers and legal boilerplate. No facts from the ✓ IS list or named standards.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized file access) with operational impact (shipping, receiving, manufacturing) and response actions (investigation, review, notifications). Specific operational functions and the nature of the incident qualify as firm-specific facts.


reasoning: The paragraph describes an ongoing incident investigation and materiality assessment, which is central to Incident Disclosure. No specific facts (dates, named entities, or verifiable details) are present, making it Generic Boilerplate.


reasoning: The paragraph describes the scope and nature of a cybersecurity incident (exfiltration of PII and PHI), which is the central topic. No specific facts (dates, named entities, numbers) are present, making it generic boilerplate.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized activity) with specific actions taken (system isolation on a named date), meeting the criteria for Incident Disclosure. The two verifiable facts (date + action) qualify it as Quantified-Verifiable.


reasoning: The paragraph describes a real cybersecurity incident with specific dates and a named external entity (U.S. Department of Justice) involved in the disclosure delay determination, meeting the criteria for Incident Disclosure and Quantified-Verifiable.


reasoning: The paragraph describes a real cybersecurity incident with specific details (date, nature of access, and encryption of data files), making it clearly an Incident Disclosure. It also contains two verifiable facts (specific date and company name), qualifying as Quantified-Verifiable.


reasoning: The paragraph focuses on the financial/materiality assessment of an incident (strategy integration) rather than describing the incident itself or board/management oversight. No specific facts (dates, amounts, named roles, or unique details) are present, making it generic boilerplate.


reasoning: The paragraph discusses financial impact (non-recurring expenses) and cyber insurance related to a cybersecurity incident, but does not describe the incident itself. No specific facts (dates, names, numbers) are provided.


reasoning: The paragraph describes a specific incident (data theft) with quantified impact (35.5 million consumers) and firm-specific facts about data types not collected, which fits Incident Disclosure. The quantified fact and explicit data scope qualify as hard verifiable facts.


reasoning: The paragraph discusses the materiality of a cybersecurity incident without describing the incident itself, making it a materiality assessment (Strategy Integration). There are no specific facts (dates, names, numbers, or frameworks) present.


reasoning: The paragraph describes an incident (referenced as 'the incident') and mentions actions (notifications, cooperation with law enforcement, regulatory obligations) and materiality conclusions, which aligns with Incident Disclosure. However, it lacks any specific facts (dates, named entities, or verifiable details), making it Generic Boilerplate in terms of specificity.


reasoning: The paragraph describes the outcome of a cybersecurity incident (containment, remediation, and lack of compromise/impact), which is the central focus. No specific facts (dates, named entities, or verifiable details) are provided.


reasoning: The paragraph describes an incident (data exfiltration) with specific dates tied to the company's financial reporting timeline, making it an Incident Disclosure. The two specific dates (fiscal year end and expected release) qualify as hard verifiable facts.


reasoning: The paragraph describes a real cybersecurity incident with specific actions (illegal access, misdirected wire payment, deleted emails) and a quantified financial impact ($250,000). This clearly fits the Incident Disclosure category.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, making it Strategy Integration. No specific facts (dates, names, numbers) are present, resulting in Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident with a clear date, type of incident, and engagement of external experts, making it an Incident Disclosure. It lacks two hard verifiable facts (e.g., named firms or tools) to reach Quantified-Verifiable.


reasoning: The paragraph discusses the financial impact of a cybersecurity incident (expenses and lost revenue) without describing the incident itself, making it Strategy Integration. It contains multiple verifiable facts (dollar amounts and fiscal quarters/years).


reasoning: The paragraph describes actions taken in response to an incident (investigation, law enforcement notification, regulatory/user notifications) but lacks any specific details (dates, named firms, tools, or quantified impacts) that would make it firm-specific or quantified-verifiable.


reasoning: The paragraph describes a cybersecurity incident (network interruption) with specific details about affected systems (Change Healthcare) and response actions (retained security experts, law enforcement, customer notification). The mention of 'Change Healthcare systems' is a firm-specific fact.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, which aligns with Strategy Integration. No specific facts (dates, names, numbers) are present, making it Generic Boilerplate.


reasoning: The paragraph describes a real cybersecurity incident with specific actions (system isolation on a date) and response measures, fitting Incident Disclosure. It contains two verifiable facts (date + action) qualifying as Quantified-Verifiable.


reasoning: The paragraph describes a real cybersecurity incident with specific details (date, firm name, named internal system) and focuses on the event itself rather than governance or financial impact.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access, exfiltration of files) with ongoing investigation and potential regulatory notifications, fitting Incident Disclosure. No firm-specific, quantified, or framework facts are present, making it Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident with multiple verifiable dates (April 19, 2024; April 14–25, 2024; May 1–October 31, 2022; January 2, 2023) and details about the incident's scope and response actions.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, fitting Strategy Integration. It includes a specific date ('three months ended March 31, 2026') as a firm-specific fact.


reasoning: The paragraph describes an actual cybersecurity incident with a specific date and company name, making it an incident disclosure. It includes one hard verifiable fact (date), so it is Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph discusses financial impact, costs, and materiality of a cybersecurity incident without describing the incident itself, fitting Strategy Integration. It includes two verifiable facts ($600,000 and a specific date).


reasoning: The paragraph describes a real cybersecurity incident with a specific date and the company's name, which qualifies it as Incident Disclosure. The specificity is Firm-Specific due to the inclusion of the specific date and company name, though it lacks two hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph contains only forward-looking statement disclaimers and no substantive cybersecurity content.


reasoning: The paragraph describes a specific cybersecurity incident with clear scope (8.4 million users) and types of compromised data, meeting the criteria for Incident Disclosure. The quantified fact and specific data types qualify as two verifiable facts.


reasoning: The paragraph describes an actual cybersecurity incident with specific details (date, firm name, exfiltration of data, and response actions), making it an Incident Disclosure. The specificity is Quantified-Verifiable due to the specific date and named firm.


reasoning: The paragraph describes a specific incident with a clear date, company name, and named third-party advisors, making it an incident disclosure with verifiable facts.


reasoning: Paragraph describes a real cybersecurity incident with specific dates, actions taken (containment, remediation, investigation), and named external firms ('leading external cybersecurity specialists' implies a named firm like Mandiant or CrowdStrike). Two hard verifiable facts (specific dates) are present.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, making it Strategy Integration. No specific facts (dates, names, numbers) are present, so specificity is Generic Boilerplate.


reasoning: The paragraph focuses on the management role (Senior Vice President, IT Operations) as the subject directing the information security team and receiving escalation reports, making it a Management Role category. The named role qualifies as a firm-specific fact.


reasoning: The paragraph discusses the company's internal risk management process by mentioning the adoption of the NIST Cybersecurity Framework, which is a recognized standard. The focus is on internal policies and alignment with requirements, not board governance or incident details.


reasoning: The paragraph describes a specific cybersecurity incident (Change Healthcare cyberattack) with a named event and a specific date, making it an incident disclosure. The two verifiable facts (date + named incident) qualify it as Quantified-Verifiable.


reasoning: The paragraph describes actions taken in response to a cybersecurity incident (activation of protocols, containment measures, investigation, law enforcement notification, system restoration, and affected parties notification), which is the defining characteristic of Incident Disclosure. No specific facts (dates, named entities, quantified details) are present, making it Generic Boilerplate.


reasoning: The paragraph describes ongoing communications and operational impacts related to an incident, which is central to Incident Disclosure. No firm-specific facts remain after filtering out generic phrases like 'the Company' and 'incident'.


reasoning: The paragraph describes actions taken in response to an incident (containment, monitoring, third-party engagement, regulatory notification), which is the central focus. No specific facts (dates, named entities, numbers) are present.


reasoning: The paragraph discusses the materiality assessment of a cybersecurity incident without describing the incident itself, making it Strategy Integration. No specific facts (dates, names, numbers) are present, so it is Generic Boilerplate.


reasoning: The paragraph describes actions taken in response to a cybersecurity incident (activating response plan, investigation, systems offline, law enforcement notification, restoration, and data assessment), which is the central focus of Incident Disclosure. No specific facts (dates, named entities, numbers) are present, making it generic boilerplate.


reasoning: The paragraph describes actions taken to remediate a cybersecurity incident (removal of a third party, restoration of access, and confirmation of data integrity), which is the central focus of an incident narrative. No specific facts (dates, named entities, or verifiable details) are included, making it generic boilerplate.


reasoning: The paragraph is a standard legal disclaimer about Form 8-K filings and does not contain any substantive cybersecurity-related content or specific facts.


reasoning: The paragraph describes a specific incident with a clear date, the nature of the incident (exfiltration), and scope (personal information). These are hard verifiable facts.


reasoning: The paragraph discusses materiality conclusions about a cyber incident without describing the incident itself, which aligns with Strategy Integration. No specific facts (dates, names, numbers) are present, making it Generic Boilerplate.


reasoning: Paragraph is a section header ('General operating procedures...') with no substantive disclosure. Headers are classified as None/Other.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, making it Strategy Integration. No specific facts remain after filtering out generic language.


reasoning: The paragraph describes an actual cybersecurity incident (exfiltration of files) and ongoing response actions (investigation, regulatory notifications), making it an Incident Disclosure. It lacks any firm-specific facts (no dates, named tools, or unique identifiers), resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes actions taken in response to a cybersecurity incident (containment, remediation efforts, engagement of cybersecurity experts), which is the central topic. No specific facts (dates, named entities, quantified details) are present.


reasoning: The paragraph describes a real cybersecurity incident with specific dates, locations, and event details (ransomware, encryption, unauthorized disclosure), making it clearly an Incident Disclosure. The two specific dates and multiple verifiable facts (e.g., Singapore location, ransomware type, encryption, unauthorized disclosure) qualify it as Quantified-Verifiable.


reasoning: The paragraph discusses the financial/materiality impact of a cybersecurity incident without describing the incident itself, making it Strategy Integration. No specific facts (dates, names, numbers) are present, so specificity is Generic Boilerplate.


reasoning: The paragraph focuses on the Committee's oversight role (Board Governance) as the grammatical subject. No specific facts from the ✓ IS list are present, and the language is generic boilerplate.


reasoning: The paragraph explicitly assigns cybersecurity risk oversight to the board of directors, making Board Governance the clear category. No firm-specific facts (e.g., named roles, dates, frameworks) are present, and the language is generic boilerplate.


reasoning: The paragraph describes the scope and nature of a disclosed cybersecurity incident, including the types of data accessed and the fact that customer funds were not compromised. This fits the Incident Disclosure category as it details the incident's impact and characteristics.


reasoning: The paragraph describes the company's internal cybersecurity risk management process (evaluation of third-party vendors) without naming any specific frameworks, roles, dates, or unique firm details. The mention of 'external partners' is generic and does not qualify as a specific fact.


reasoning: The paragraph explicitly assigns cybersecurity oversight to the board and its Audit Committee, making 'Board Governance' the clear category. No firm-specific facts (e.g., named roles, dates, or standards) are present.


reasoning: The paragraph contains no substantive content about cybersecurity governance, incidents, or processes—only a generic risk disclaimer referencing another section.


reasoning: The paragraph discusses internal risk management processes (dependency on systems/networks) but does not center on vendor oversight, board governance, or incident disclosure. No specific facts (e.g., frameworks, roles, dates) are present.


reasoning: The paragraph contains no substantive cybersecurity disclosure, no named entities, no dates, and no specific details. It is a generic statement about ongoing investments and controls.


reasoning: The paragraph describes the company's internal cyber risk management program and its integration with enterprise risk management processes, making it a Risk Management Process category. It contains no named entities, dates, or specific details, resulting in Generic Boilerplate specificity.


reasoning: The paragraph is a generic statement about cybersecurity program objectives with no substantive details, named entities, or specific facts. It does not fit any cybersecurity-specific content category.


reasoning: The paragraph explicitly assigns oversight duties to the Board (grammatical subject) and names a non-generic committee ('Cybersecurity Committee'), making Board Governance the clear category. The named committee qualifies as a firm-specific fact.


reasoning: The paragraph describes a person's professional background without any cybersecurity-specific content or relevance to the filing's Item 1C requirements.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach without naming any specific frameworks, roles, dates, or firm-unique details. It focuses on the general process rather than board oversight, incident disclosure, or third-party risk.


reasoning: The paragraph describes internal risk management processes (incident response and recovery frameworks, testing cadence) without naming any specific frameworks, roles, dates, or firm-unique details. The content is generic and could apply to any company.


reasoning: The paragraph is a generic statement about cybersecurity risk management being part of enterprise risk management, with no substantive disclosure or specific facts. It does not reference any incident, governance, management roles, or firm-specific details.


reasoning: The paragraph focuses on management's responsibility for cybersecurity risk, with 'head of the ITS Department' being a generic role (not cybersecurity-specific like CISO/CTO). No specific facts remain after filtering.


reasoning: The paragraph focuses on the cybersecurity management role (CISO equivalent) and provides verifiable facts about experience, tenure, and role title.


reasoning: The paragraph focuses on the Board of Directors receiving reports, making it a board governance topic. The presence of cybersecurity-specific roles (CISO and CIO) qualifies as firm-specific facts.


reasoning: The paragraph focuses on board oversight of cyber risk ('board of directors receives briefings...on our cyber risk management program'), making Board Governance the clear category. No firm-specific facts are present.


reasoning: The paragraph describes internal cybersecurity training and education processes, which are part of the company's risk management practices. No specific facts (e.g., named roles, dates, frameworks) are present, and the language is generic boilerplate.


reasoning: The paragraph describes generic cybersecurity threats without referencing any board governance, management roles, internal processes, incidents, or firm-specific details. It is boilerplate risk language.


reasoning: The paragraph focuses on board oversight of strategic risk, with the board as the grammatical subject. No firm-specific or verifiable facts are present.


reasoning: The paragraph contains no substantive cybersecurity disclosure, no named roles, committees, dates, or verifiable facts. It is a generic statement about qualifications without specific details.


reasoning: Paragraph describes generic cybersecurity protections in third-party products without substantive disclosure. No grammatical subject relevant to cybersecurity disclosures.


reasoning: The paragraph focuses on third-party risk management practices, specifically vendor cybersecurity oversight. The mention of 'Security Scorecard' as a named third-party tool identifies a firm-specific detail.


reasoning: The paragraph discusses the materiality of cybersecurity incidents to financial outcomes without describing any incident details, aligning with Strategy Integration. It contains no specific facts (no dates, names, or quantifiable details), making it Generic Boilerplate.


reasoning: The paragraph discusses the company's cybersecurity program as part of its risk management approach, which aligns with the Risk Management Process category. There are no specific facts (e.g., named roles, dates, frameworks, or quantified details) present.


reasoning: The paragraph focuses on the role of an internal cybersecurity coordinator and their reporting structure, which is a management function. No specific facts (e.g., named roles, dates, or unique details) are present.


reasoning: The paragraph describes a generic incident response action (eradication) without any specific facts, dates, named entities, or company-unique details. It is a standard phrase used in incident response contexts.


reasoning: The paragraph focuses on the Board receiving updates, with 'Board' as the grammatical subject and 'Cybersecurity team' as a minor component. No firm-specific facts remain after filtering.


reasoning: The paragraph focuses on board oversight of cybersecurity risks via a named committee (Global Security Steering Committee) reporting to the Board and Audit Committee, making Board Governance the clear category. No specific facts remain after filtering out generic terms like 'quarterly' and 'Audit Committee'.


reasoning: The paragraph discusses the financial/material impact (expenses, penalties, settlements) of cybersecurity without describing an incident, fitting Strategy Integration. No specific facts remain after filtering out generic phrases.


reasoning: The paragraph describes internal incident response plan refinement processes without naming specific frameworks, roles, dates, or unique company details. It focuses on generic cybersecurity practices.


reasoning: The paragraph focuses on management roles (CIO and VP of Information Security) as the grammatical subjects with primary responsibility for cybersecurity, fitting the Management Role category. The named roles are firm-specific facts.


reasoning: The paragraph focuses on the management role and responsibilities of the CISO (who also serves as CFO), making it a Management Role category. The presence of a cybersecurity-specific title (CISO) and the unique reporting structure (CFO as CISO) are firm-specific facts.


reasoning: The paragraph describes internal cybersecurity processes (threat intelligence, external expert engagement) without naming specific frameworks, roles, dates, or unique firm details. The focus is on generic program activities rather than board oversight, incident disclosure, or third-party risk.


reasoning: The paragraph focuses on board/committee oversight of cybersecurity risks and incidents, with the Board and Audit Committee as the grammatical subjects. No firm-specific or verifiable facts are present.


reasoning: The paragraph focuses on the composition of the ISC (Incident Response Committee or similar) and its members' cybersecurity-related experience, making it a board governance oversight topic. The named roles (CIO and Director of IT Security, Risk and Compliance) are firm-specific facts.


reasoning: The paragraph discusses the financial/materiality impact of cybersecurity incidents (expenses, penalties, settlements) without describing any actual incident. No specific facts remain after filtering out generic language.


reasoning: The paragraph discusses the materiality of cybersecurity incidents (or lack thereof) without describing any actual incident details, which aligns with Strategy Integration. No specific facts (dates, roles, frameworks, etc.) are present, making it Generic Boilerplate.


reasoning: The paragraph describes internal cybersecurity training and simulation processes, which are part of the company's risk management activities. No named entities, dates, or firm-specific details are present, making it generic boilerplate.


reasoning: The paragraph focuses on management's role in overseeing cybersecurity incident processes, with 'Management' as the grammatical subject. No specific facts (e.g., named roles, dates, or unique details) are present.


reasoning: The paragraph contains no substantive cybersecurity-specific facts, roles, dates, or frameworks. It is a generic statement about the importance of cybersecurity without any identifiable details.


reasoning: The paragraph describes internal cybersecurity risk management processes without naming any specific frameworks, roles, dates, or firm-unique details. It is a generic statement about processes.


reasoning: The paragraph discusses financial mitigation via cyber insurance without describing an incident or providing specific details (e.g., coverage amounts, insurer names, or dates). No substantive facts remain after filtering.


reasoning: The paragraph focuses on management roles (CFO, COO, CEO) responsible for cybersecurity, which aligns with the Management Role category. No firm-specific facts (e.g., named programs, dates, or unique roles) are present, and the language is generic.


reasoning: The paragraph describes internal cybersecurity risk management strategies (traffic monitoring tools, user training) without naming specific frameworks, roles, dates, or unique company details. The focus is on generic processes rather than board governance, incident disclosure, or third-party risk.


reasoning: The paragraph describes a management-initiated program (CyberSmart Defender Network) but does not assign responsibility to a specific named role or committee. The content focuses on internal process structure rather than board oversight or incident details.


reasoning: The paragraph describes the responsibilities of cybersecurity professionals without naming specific roles, teams, or other firm-specific details. It focuses on generic management functions rather than board oversight or a specific incident.


reasoning: The paragraph describes the company's internal cybersecurity risk management system without naming any specific frameworks, roles, dates, or unique details. It is a generic description of processes.


reasoning: The paragraph describes internal risk management processes (employee training, incident response personnel, third-party due diligence) but contains no firm-specific details, named entities, or verifiable facts.


reasoning: The paragraph's grammatical subject is the Board of Directors, focusing on oversight of cybersecurity. No specific facts (e.g., named committees, dates, roles, or frameworks) are present.


reasoning: The paragraph describes internal cybersecurity training processes, which are part of the company's risk management practices. No specific facts (e.g., named roles, dates, frameworks, or firm-unique details) are present.


reasoning: The paragraph describes internal cybersecurity processes (IRP and tabletop exercises) without naming any firm-specific details, standards, or verifiable facts. The content focuses on generic risk management practices.


reasoning: The paragraph focuses on the management of cybersecurity, specifically the lack of specialized training in the IT staff handling day-to-day management. This aligns with the 'Management Role' category as it discusses internal management structure and capabilities.


reasoning: The paragraph discusses internal cybersecurity risk management processes without naming any specific frameworks, roles, dates, or firm-unique details. It is generic boilerplate language about risk management.


reasoning: The paragraph contains no substantive cybersecurity-specific facts, named entities, or verifiable details. It is a generic statement of intent with no company-specific or quantifiable information.


reasoning: The paragraph describes the company's internal cybersecurity program and incident response processes, with 'management' as the grammatical subject. No specific facts, frameworks, or firm-unique details are present.


reasoning: The paragraph discusses the materiality of cybersecurity risks to business strategy and financial condition without describing any incident or naming specific frameworks/roles. It is a standalone materiality conclusion with no incident narrative or firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity processes (policies, procedures, assessments, monitoring, response plans, and testing) without referencing any specific frameworks, roles, dates, or firm-unique details. The grammatical subject is the company's internal programs.


reasoning: The paragraph focuses on management roles (C-level and senior director) reporting lines, which is the grammatical subject. The named roles are cybersecurity-specific and qualify as firm-specific facts.


reasoning: The paragraph discusses the financial/materiality assessment of a cybersecurity incident without describing the incident itself, making it Strategy Integration. It contains no specific facts (no dates, roles, frameworks, or verifiable details), so it is Generic Boilerplate.


reasoning: The paragraph focuses on management roles responsible for cybersecurity processes, with specific named roles (Senior Director of IT, CFO) as the grammatical subjects. The roles are cybersecurity-relevant and firm-specific.


reasoning: The paragraph discusses financial reimbursement for a cyber incident without describing the incident itself, fitting Strategy Integration. No specific facts (dates, amounts, named entities) are present, making it Generic Boilerplate.


reasoning: The paragraph describes an ongoing forensic investigation following a cybersecurity incident, which is the central topic. No specific facts (dates, named firms, tools, or quantified details) are included.


reasoning: The paragraph discusses the financial and operational impact of an incident (materiality assessment) without describing the incident itself, which aligns with Strategy Integration. No specific facts (dates, names, numbers) are present.


reasoning: The paragraph is a standalone materiality conclusion about a cybersecurity incident without describing the incident itself, fitting Strategy Integration. It contains no specific facts (no dates, names, numbers, or unique identifiers), making it Generic Boilerplate.


reasoning: The paragraph discusses the potential financial impact of an incident without describing the incident itself, which aligns with Strategy Integration. There are no specific facts (e.g., dates, named roles, or verifiable details) to elevate specificity beyond Generic Boilerplate.


reasoning: The paragraph discusses the materiality assessment of a cybersecurity incident without describing the incident itself, which aligns with Strategy Integration. No specific facts (dates, roles, named entities) are present.


reasoning: The paragraph discusses the financial aspect of cybersecurity (insurance coverage) without describing an incident or naming specific policy details, amounts, or dates. It lacks any firm-specific or quantified facts.


reasoning: The paragraph describes an ongoing incident (disruption, restoration efforts, law enforcement engagement, regulatory notification) without providing any specific dates, named entities, or quantifiable details, making it a clear Incident Disclosure with Generic Boilerplate specificity.


reasoning: The paragraph describes an actual cybersecurity incident (data access/exfiltration) with no firm-specific details, dates, or named entities beyond generic terms like 'limited data' and 'personally identifiable information'.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, making it Strategy Integration. It contains no specific facts (dates, names, numbers, or frameworks).


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, fitting Strategy Integration. No specific facts remain after filtering out boilerplate phrases.


reasoning: The paragraph discusses the materiality assessment of an incident without describing the incident itself, making it Strategy Integration. There are no specific facts (dates, names, numbers, or unique identifiers) to elevate specificity beyond Generic Boilerplate.


reasoning: The paragraph discusses the materiality assessment of a cybersecurity incident without describing the incident itself, which aligns with Strategy Integration. There are no specific facts (dates, names, numbers, etc.) to elevate the specificity beyond Generic Boilerplate.


reasoning: The paragraph describes actions taken in response to a cybersecurity incident (notifying law enforcement and regulators), which is the grammatical subject and central topic. No specific facts (names, dates, numbers) are present, making it generic boilerplate.


reasoning: The paragraph discusses executive leadership changes and does not pertain to cybersecurity, risk management, governance, or any cybersecurity-related topic.


reasoning: The paragraph discusses legal agreements and waiver periods, which is unrelated to cybersecurity disclosures. It contains no cybersecurity-specific content or facts.


reasoning: The paragraph discusses the materiality conclusion of an incident without describing the incident itself, fitting Strategy Integration. No specific facts remain after filtering out boilerplate language.


reasoning: The paragraph discusses the financial/material impact of an incident without describing the event itself, making it Strategy Integration. No specific facts remain after filtering out boilerplate language.


reasoning: The paragraph describes actions taken in response to a cybersecurity incident (notifying law enforcement and regulatory bodies), which is the central topic. No specific facts (dates, named entities, or quantified details) are present.


reasoning: The paragraph discusses financial/material impact of a cybersecurity incident (insurance costs, litigation, regulatory scrutiny) without describing the incident itself, making it Strategy Integration. No specific facts (dates, names, numbers) are present, so specificity is Generic Boilerplate.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, fitting Strategy Integration. No named entities, dates, or verifiable facts are present, making it Generic Boilerplate.


reasoning: The paragraph discusses financial impact (insurance recoveries) related to a cybersecurity incident without describing the incident itself, making it Strategy Integration. No specific facts (dates, numbers, named entities) are present, so it is Generic Boilerplate.


reasoning: The paragraph centers on third-party vendor oversight and disclosure of a cybersecurity incident affecting customer information, meeting the criteria for Third-Party Risk. It includes two specific dates and a named firm, satisfying Quantified-Verifiable specificity.


reasoning: The paragraph describes actions taken in response to a specific incident (closing off access, providing notice to impacted customers), making it an Incident Disclosure. The mention of 'AT&T' and 'current and former impacted customers' makes it Firm-Specific, though only one verifiable fact remains after filtering.


reasoning: The paragraph describes actions taken in response to a cybersecurity incident (containment, restoration of IT environment, and business operations recovery), which is the central topic of an Incident Disclosure. No specific facts (dates, named entities, or verifiable details) are present, making it Generic Boilerplate.


reasoning: The paragraph describes the status of a cybersecurity incident (containment and restoration efforts), which is the central topic. No firm-specific or verifiable facts are present.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation and mentions working with a cyber insurance provider, which is central to incident response. No specific facts (dates, named entities, or quantified details) are present, making it generic boilerplate language.


reasoning: The paragraph discusses the financial/materiality impact of a cybersecurity incident without describing the incident itself, making it Strategy Integration. It contains no specific facts (no dates, named entities, or verifiable details), so it is Generic Boilerplate.


reasoning: The paragraph discusses operational disruptions and business continuity but contains no cybersecurity-specific content, incidents, governance, or risk management details. It is purely operational and thus falls under None/Other.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, making it Strategy Integration. No specific facts (dates, roles, numbers, etc.) are present, so specificity is Generic Boilerplate.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation and planned notifications, which qualifies as an incident narrative. However, it contains no firm-specific details, dates, named entities, or quantified facts, making it Generic Boilerplate.


reasoning: The paragraph describes an ongoing investigation into whether PII was accessed by threat actors, which is a real incident narrative. No specific facts (dates, named firms, tools, etc.) are provided.


reasoning: The paragraph describes an ongoing incident investigation and law enforcement notification, which fits the Incident Disclosure category. However, it contains no specific facts (e.g., dates, named entities, or verifiable details), making it Generic Boilerplate.


reasoning: The paragraph discusses materiality of an incident without describing the incident itself, making it a Strategy Integration category. No specific facts are present, so specificity is Generic Boilerplate.


reasoning: The paragraph describes an actual cybersecurity incident (access, exfiltration, encryption) with no firm-specific details, dates, or named entities. The content is incident-focused, making it Incident Disclosure, and lacks any verifiable facts, resulting in Generic Boilerplate.


reasoning: The paragraph discusses the timing and materiality of an incident without describing the incident itself, fitting Strategy Integration. No specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph discusses financial impact and materiality of an incident WITHOUT describing the event itself, making it Strategy Integration. No specific facts (e.g., dates, roles, named systems) are present.


reasoning: The paragraph describes actions taken following a cybersecurity incident (mailing notification letters), which is the core of an Incident Disclosure. No specific facts (dates, named entities, or quantified details) are present, making it generic boilerplate.


reasoning: The paragraph describes a cybersecurity incident (disruption of networks and transactional services) and provides a specific URL for incident updates, which is a firm-unique fact. The incident narrative is the central topic.


reasoning: The paragraph describes a real cyber incident (systems/data impacted, investigation closure) with no firm-specific or verifiable details, making it Incident Disclosure despite lacking specifics. No named entities, dates, or quantified facts exist.


reasoning: The paragraph describes an actual cybersecurity incident with a specific date and mentions a named team (incident response team), making it Incident Disclosure. The two verifiable facts (date + named team) qualify it as Quantified-Verifiable.


reasoning: The paragraph describes a specific incident with a clear date of discovery, meeting the criteria for Incident Disclosure. The date qualifies as a firm-specific fact, but there is only one hard verifiable fact, so specificity is Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes a real cybersecurity incident with a specific date and company name, meeting the criteria for Incident Disclosure. It also contains two verifiable facts (date + named firm), qualifying as Quantified-Verifiable.


reasoning: The paragraph discusses the financial impacts (costs) of a cyber incident without describing the incident itself, which aligns with Strategy Integration. No specific facts (dates, names, numbers) are present.


reasoning: The paragraph describes an actual cybersecurity incident involving a compromised fourth-party vendor and the activation of the Bank's response process, which is central to Incident Disclosure. The mention of 'fourth-party vendor' is a firm-specific detail.


reasoning: The paragraph describes the operational impact of a cybersecurity incident (shipping/receiving, manufacturing, back office functions) and response actions (temporary measures), which is central to Incident Disclosure. No specific facts (dates, named roles, firms, or quantified details) are present, making it Generic Boilerplate.


reasoning: The paragraph describes operational impact (website inaccessibility) and provides a firm-specific URL for incident communications, which qualifies as an incident disclosure with firm-specific details.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, making it Strategy Integration. No specific facts (dates, roles, numbers, or named entities) are present.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, making it Strategy Integration. No specific facts (dates, names, numbers) are present, so it is Generic Boilerplate.


reasoning: The paragraph describes a cybersecurity incident (access to IT systems containing sensitive personal information) and response actions (notifications to affected parties and regulators), which is the central topic. No specific facts (dates, named entities, or quantified details) are present.


reasoning: The paragraph discusses the financial/materiality impact of an incident without describing the incident itself, making it Strategy Integration. No specific facts (dates, roles, named entities) are present.


reasoning: The paragraph discusses the financial/materiality assessment of a cybersecurity incident without describing the incident itself, making it Strategy Integration. No specific facts (dates, names, numbers) are present, so specificity is Generic Boilerplate.


reasoning: Paragraph discusses Targus (a third party) and its actions regarding an incident, but contains no substantive cybersecurity disclosure from BRC Group Holdings, Inc. itself. No firm-specific facts about BRC's governance, management, processes, incidents, or strategy are present.


reasoning: The paragraph describes operational impacts and response actions following a cybersecurity incident (system restoration efforts), which is the core of an Incident Disclosure. No firm-specific or quantified facts are present.


reasoning: The paragraph describes internal cybersecurity risk management practices (monitoring, prevention, detection) without naming frameworks, roles, dates, or firm-specific details. It is generic boilerplate language about IT dependency and cyber risks.


reasoning: The paragraph focuses on internal cybersecurity processes (monitoring, training, penetration testing, layered defenses) and vendor oversight as a component of internal risk management, not as the central topic. No firm-specific facts or verifiable details are present.


reasoning: The paragraph focuses on the Audit Committee and Board receiving updates and oversight of cybersecurity risks, with the Risk Management Team as the grammatical subject informing the Audit Committee. The named roles and team composition qualify as firm-specific facts.


reasoning: The paragraph describes the restoration progress of systems affected by a cybersecurity incident (Change Healthcare systems), which is a central topic of incident disclosure. It includes a specific date and a named system, meeting the criteria for Quantified-Verifiable.


reasoning: The paragraph focuses on internal cybersecurity processes (risk evaluation, escalation procedures, incident response, and business continuity plans) with specific named roles and programs unique to the company.


reasoning: The paragraph focuses on the company's internal cybersecurity processes (threat assessment, layered security, training, tool/process use, third-party assessments) rather than board oversight, management roles, or incident disclosure. Named frameworks (NIST, ISO) and compliance standards (SOC-1/SOC-2) drive the Sector-Adapted specificity.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes (CIS Controls adoption, risk assessments, infrastructure design, dedicated personnel, and training). The Technology Committee and Internal Audit team are named non-generic committees/teams, making it Firm-Specific.


reasoning: The paragraph focuses on board-level oversight of cybersecurity risks, with the Risk Committee as the grammatical subject performing specific oversight activities. The named committee qualifies as a firm-specific fact.


reasoning: The paragraph describes the operational impact of a cybersecurity incident (limited access to business applications for six weeks), which is central to Incident Disclosure. No firm-specific facts (e.g., dates, named tools, or teams) are present, and the language is generic.


reasoning: The paragraph describes a specific incident with a clear date and identifies the company, meeting the criteria for Incident Disclosure. The date and named entity qualify as two hard verifiable facts.


reasoning: The paragraph describes a specific incident with a clear date and named entities (company and cybersecurity experts), making it an Incident Disclosure. The presence of two verifiable facts (date + named firms) qualifies it as Quantified-Verifiable.


reasoning: The paragraph focuses on the roles, qualifications, and experience of the CISO and CTO, making it a clear Management Role category. It contains multiple verifiable facts (dates, named firms, roles) that meet the Quantified-Verifiable threshold.


reasoning: The paragraph centers on Board oversight of cybersecurity risk management, with the Audit Committee and management roles as grammatical subjects. The named roles (Global Head of IT Security reporting to CIO) are firm-specific facts.


reasoning: The paragraph discusses potential financial/material impact of cyber risks and incidents without describing any actual event or named internal processes. The main focus is on strategic/financial implications (materiality assessment) rather than governance, management roles, or specific processes.


reasoning: The paragraph discusses general technology infrastructure and generic cyber risks without referencing any specific incidents, frameworks, roles, dates, or firm-unique details. It is purely descriptive of common business dependencies and threats.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including security controls, awareness programs, third-party oversight, monitoring, and resiliency plans. The only specific fact is the named framework (NIST CSF), which qualifies as Sector-Adapted.


reasoning: The paragraph discusses general cybersecurity risks, regulatory compliance, and materiality conclusions without describing any specific incident or naming unique firm details. The focus on financial/material impact and lack of verifiable facts or named entities aligns with Strategy Integration (materiality assessment) and Generic Boilerplate specificity.


reasoning: The paragraph describes internal cybersecurity processes (risk management strategy, technical safeguards, incident response planning, third-party risk management, and education) without referencing any firm-specific details, dates, named roles, or verifiable facts. The focus is on generic program descriptions rather than governance, incidents, or strategy integration.


reasoning: The paragraph focuses on the internal cybersecurity program, risk management processes, and administrative oversight structures (e.g., IT Steering Committee, crisis response team). The content is clearly about Risk Management Process rather than board governance or management roles alone.


reasoning: The paragraph focuses on the management structure and qualifications of the outsourced cybersecurity team, including specific roles and certifications, making it a Management Role category. It contains multiple hard facts (roles, certifications, years of experience) qualifying as Quantified-Verifiable.


reasoning: The paragraph contains no substantive disclosure about governance, management roles, risk processes, third-party oversight, incidents, or strategy integration. It is generic risk language about cybersecurity threats and potential impacts.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, including the adoption of a specific framework (NIST) and the leadership of cybersecurity efforts by named management roles. The board or management is not the grammatical subject of oversight.


reasoning: The paragraph focuses on the Chief Information Officer's role, qualifications, and reporting cadence, which aligns with the Management Role category. The named role (CIO), certifications, and the Risk Report (a firm-specific program) make it Firm-Specific.


reasoning: The paragraph discusses cybersecurity risks in a generic, forward-looking manner without describing any specific incident, named roles, frameworks, or firm-specific details. It references a risk factor section rather than substantive cybersecurity disclosures.


reasoning: The paragraph focuses on the company's internal cybersecurity processes (defense layers, policies, training, supplier engagement) with firm-specific details like ISAC participation and cross-business unit collaboration. The supplier engagement section describes internal processes for third-party oversight, not vendor requirements imposed by the company.


reasoning: The paragraph focuses on internal cybersecurity processes and tools (EDR, SIEM, network security, Zero Trust, encryption methods, etc.), which are central to the company's own risk management. The inclusion of firm-specific strategies (Zero Trust, quantum-resistant encryption) and a specific timeframe (24 hours) confirms Firm-Specific.