content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: The paragraph consists of generic, forward-looking risk disclaimers regarding potential cyber threats and a standard negative materiality statement, which does not describe specific processes or governance structures.

provider: google


content_category: Risk Management Process

reasoning: The paragraph describes the company's specific internal team structure and operational methods for identifying and assessing cybersecurity risks, which is firm-specific information rather than generic boilerplate.


reasoning: The paragraph describes the company's internal risk management framework, specifically the 'Enterprise Risk Management Program' and 'Enterprise Risk Assessment' process. It is level 3 because it references specific internal programs ('ERM', 'ERA') and the specific cadence of quarterly reviews unique to the company's governance structure.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and integration into enterprise risk management, which is the definition of Risk Management Process. It lacks any specific frameworks, named programs, or unique company details, making it generic boilerplate.


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident that occurred on March 10, 2024, including the company's response actions and operational impact. It is classified as level 3 because it contains a specific date and the company name, but lacks a second independent verifiable fact (like a dollar amount or specific named third-party firm) required for level 4.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection (May 6, 2024) and the specific operational impacts (disruptions to financial and operating reporting systems), meeting the criteria for Incident Disclosure and level 4 specificity.


reasoning: The paragraph details a specific cybersecurity incident, including the date (April 24, 2024), the affected system (Dropbox Sign production environment), and the scope of data accessed, meeting the criteria for Incident Disclosure and level 4 specificity due to multiple verifiable facts.


reasoning: The paragraph describes the nature, scope, and ongoing impact of a specific cybersecurity incident involving a nation-state actor, including the timeline (late November 2023) and specific targets (source code repositories and internal systems).


content_category: Board Governance

reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities and reporting structure, which is the primary subject. It is firm-specific because it identifies unique internal bodies like the 'ERM Committee' and specific roles such as 'CIO' and 'VP Infrastructure'.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of determination (March 10, 2024) and the company's response actions, which qualifies as an incident disclosure. It is level 3 because it provides a specific date and details about the company's unique response, but lacks a second independent verifiable fact (like a dollar amount or specific third-party firm name) required for level 4.


reasoning: The paragraph describes the company's internal risk management process, including the frequency of reviews (biannual) and the specific roles involved (CISO, CIO, business segment representatives), which makes it firm-specific.


reasoning: The paragraph explicitly describes the board of directors' oversight role and the specific delegation of cybersecurity risk oversight to the audit committee, which is a firm-specific governance structure.


content_category: Management Role

reasoning: The paragraph identifies specific management roles (CIO and Information Security Director) and provides verifiable data points regarding their years of experience (35 and 25 years, respectively).


reasoning: The paragraph describes a specific cybersecurity incident that occurred on November 25, 2024, including the nature of the event (unauthorized access and encryption), making it firm-specific but lacking a second independent verifiable fact (like a dollar amount or named third-party firm) to reach level 4.


reasoning: The paragraph consists of a negative materiality statement and a cross-reference to the Risk Factors section, which falls under the 'None/Other' category per the provided rules.


reasoning: The paragraph explicitly details the responsibilities, qualifications, and reporting lines of the Chief Technology Officer, which is the primary focus of the Management Role category. It is firm-specific because it identifies the specific executive role and their reporting relationship with the General Counsel.


reasoning: The paragraph describes the status and potential impact of an ongoing cybersecurity incident, which is the core purpose of an 8-K Item 1.05 disclosure. The language regarding materiality and ongoing investigation is generic boilerplate commonly found in such filings.


reasoning: The paragraph describes specific response actions taken regarding a cybersecurity incident, including a concrete date (December 20, 2023) and specific remediation steps, making it firm-specific.


reasoning: The paragraph describes the integration of cybersecurity into enterprise risk management, which is a core component of risk management processes. It is classified as level 1 because it uses generic, boilerplate language without naming specific frameworks, tools, or unique company programs.


reasoning: The paragraph explicitly identifies the board of directors as the primary subject responsible for oversight and mentions specific internal reporting structures (audit committee and executive leadership team) and a specific cadence (at least an annual basis).


reasoning: The paragraph describes a specific cybersecurity incident that occurred on May 1, 2024, and details the company's specific response actions, making it a firm-specific incident disclosure.


content_category: Third-Party Risk

reasoning: The paragraph focuses exclusively on the company's approach to evaluating third-party vendors, making Third-Party Risk the primary category. It is classified as level 1 because it uses generic language about risk-based approaches and external partners without naming specific frameworks, vendors, or unique internal programs.


reasoning: The paragraph describes the company's response actions to an incident and provides a materiality assessment, which are core components of an Item 1.05 disclosure. The language is generic and lacks specific, verifiable details such as dates, named systems, or specific regulatory bodies.


reasoning: The paragraph focuses on the oversight activities of a Board committee, specifically its receipt of reports and communication with the full Board, which is the definition of Board Governance. It is level 3 because it describes the specific reporting structure and cadence unique to this company's governance framework.


reasoning: This paragraph is a standard materiality disclaimer regarding an ongoing incident disclosure, which falls under Incident Disclosure. It is classified as level 1 because it uses generic boilerplate language regarding financial impact that could apply to any company.


content_category: Strategy Integration

reasoning: The paragraph focuses on financial recovery through insurance claims rather than the narrative of the incident itself. It is generic boilerplate language regarding insurance reimbursement that could apply to any company.


reasoning: The paragraph consists entirely of a forward-looking disclaimer and a cross-reference to the Risk Factors section, which fits the definition for None/Other.


reasoning: The paragraph describes the status of an ongoing investigation into a cybersecurity incident, which is the core purpose of an Item 1.05 disclosure. It is classified as specificity level 1 because it uses generic language regarding the investigation status without naming specific forensic firms, dates, or systems.


reasoning: The paragraph describes the company's ongoing response actions to an active cybersecurity incident, including system restoration and engagement with law enforcement. It is classified as specificity level 1 because it uses generic language ('leading experts', 'certain regulatory authorities') without naming specific firms, agencies, or dates.


reasoning: The paragraph details the company's internal cybersecurity processes, including specific practices like quarterly phishing tests and annual penetration testing. While it mentions third-party assessments and standards (NIST/ISO), these are presented as components of the company's broader internal risk management framework rather than the sole focus.


reasoning: The paragraph details the company's internal cybersecurity risk management strategy, including the adoption of the CIS Controls framework and specific organizational processes like ERM integration and internal audit reviews. It is classified as level 3 because it names specific internal structures (Technology Committee, Internal Audit team) and programs unique to the company's operations.


reasoning: The paragraph details the company's internal incident response and business continuity processes, including the specific role of the Chief Security Officer (CSO) and the existence of an 'Incident Response Program' and 'Business Continuity Plan', which are firm-specific identifiers.


reasoning: The paragraph describes general risk management activities like monitoring and infrastructure development to mitigate threats, but uses generic, boilerplate language that could apply to any company without naming specific frameworks, tools, or unique organizational structures.


reasoning: This paragraph is a standard materiality disclaimer required under Item 1.05 of Form 8-K regarding an incident, making it part of the incident disclosure narrative despite lacking specific details.


reasoning: This paragraph is a standard legal disclaimer regarding forward-looking statements and safe harbor provisions, which does not provide substantive information about cybersecurity governance, risk management, or the incident itself.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of the materiality determination (July 25, 2024), the nature of the breach (unauthorized access and exfiltration), and the specific operational impacts (system shutdowns and restoration efforts), meeting the criteria for both Incident Disclosure and high specificity.


reasoning: The paragraph explicitly identifies specific management roles (CFO, CLO, VP, Corporate Controller, Sr. Director of IT) and their collective function as the 'Risk Management Team,' which is a firm-specific organizational structure.


reasoning: The paragraph details a specific cybersecurity incident (website defacement), including the exact date (August 25, 2025), the specific domain affected (wytecintl.com), the response actions taken (FBI report, forensic specialists), and the specific operational impact (cancellation of a seminar on September 2, 2025).


reasoning: The paragraph details the status, scope, and remediation of a specific cybersecurity incident, including multiple verifiable facts such as specific dates, the number of affected accounts (33 million and 3,000), and the exact value of the compensation program (1.685 trillion won).


reasoning: The paragraph details a specific cybersecurity incident, including the date (May 11, 2025), the nature of the threat, the method of unauthorized access, and the company's specific response actions, meeting the criteria for Incident Disclosure and level 4 specificity.


reasoning: The paragraph describes the company's processes for assessing, identifying, and managing cybersecurity risks and integrating them into enterprise risk management, which is the primary focus of risk management.

provider: openai


reasoning: The paragraph describes a specific cybersecurity event that occurred on March 10, 2024, the unauthorized access, response actions, and ongoing investigation, which is the primary purpose of an incident disclosure.


reasoning: The paragraph narrates a real cybersecurity event, detailing the detection date, activation of incident procedures, involvement of external experts, and impact on business applications.


reasoning: The paragraph describes a specific cybersecurity event, including the date it was discovered and details of the unauthorized access, which matches the definition of Incident Disclosure.


reasoning: The paragraph describes the CTO’s responsibilities and reporting line, making the management role the primary focus.


reasoning: The paragraph describes a real cybersecurity event with a specific date (Nov 25, 2024), the nature of the breach (illegal access and encryption), and the company’s response actions.


reasoning: Paragraph describes a real cybersecurity event (unauthorized activity), includes actions taken, and provides a specific date (December 20, 2023) of system isolation.


reasoning: The paragraph focuses on evaluating third‑party vendors and mentions external partner reviews, making vendor oversight the primary topic.


reasoning: The paragraph focuses on seeking reimbursement from cyber insurers and notes uncertainty about timing and amount, emphasizing financial consequences rather than describing the incident itself.


reasoning: Paragraph discusses an ongoing forensic analysis of a specific cybersecurity incident, indicating an actual event rather than policy or future risk.


reasoning: The paragraph describes the company's response to a cybersecurity incident (restoring systems, retained experts, law enforcement) indicating an actual event.


reasoning: The paragraph outlines the company's internal processes for assessing, identifying, and managing cybersecurity risks, listing threat assessment, layered security, training, standards, and third‑party assessments, making risk management the primary focus.


reasoning: The paragraph outlines Wendy's cybersecurity risk management strategy, detailing frameworks (CIS Controls), regular risk assessments, infrastructure, dedicated personnel, and training, which is the primary focus of risk management processes.


reasoning: The paragraph centers on the internal management team (CFO, CLO, Sr. Director of IT, etc.) and its role in monitoring risks and briefing the Audit Committee, making the primary focus the management role in cybersecurity oversight.


reasoning: The paragraph describes the company's processes for evaluating incidents, escalation procedures, and its Incident Response and Business Continuity programs, which is the primary focus of risk management.


reasoning: The paragraph narrates a specific cybersecurity event (defaced website), gives dates, actions taken, and impact (canceled seminar).


reasoning: The paragraph details the actual cybersecurity incident, including dates of updates, number of accounts accessed, data saved, and the compensation program, which is the primary purpose of an incident disclosure.


reasoning: The paragraph is a forward‑looking risk disclaimer describing potential cyber threats without detailing any board, management, risk‑management processes, third‑party programs, incidents, or strategy integration.


reasoning: Paragraph describes the company's internal risk assessment, mitigation, monitoring, and reporting processes integrated into ERM, indicating a risk management process. It mentions company‑specific program names (ERM, ERA) and reporting cadence, making it firm‑specific (level 3).


reasoning: The paragraph details a real event on March 10, 2024, describing unauthorized third‑party access, response actions, and remediation, which is the hallmark of Incident Disclosure; it includes a specific date and company‑specific description of the incident, making it firm‑specific.


reasoning: The paragraph describes the company's internal team and processes for identifying, assessing, and managing cybersecurity threats, which is the primary focus of risk management. It contains no unique company identifiers or quantified data, making it generic boilerplate.


reasoning: The paragraph describes the Audit Committee of the Board overseeing cybersecurity risk and receiving reports, making the board the primary subject. It names the Audit Committee, ERM Committee, CIO, and VP Infrastructure, which are specific to the company, but provides no quantifiable data.


reasoning: Paragraph identifies the CIO and Information Security Director, their experience and role leading the cybersecurity program, making management role the dominant focus; includes firm‑specific titles and experience years, qualifying as level 3 specificity.


reasoning: The paragraph describes a real event: detection of a nation‑state actor, dates, exfiltration, ongoing unauthorized access, and investigation.


reasoning: The paragraph describes the ongoing cyber incident, its unknown scope, and its material impact on business operations, which is characteristic of Incident Disclosure. It contains only generic language with no dates, names, or quantifiable details, fitting specificity level 1.


reasoning: Paragraph describes how cybersecurity risk management is integrated into overall risk processes, review frequency, participants (CISO, CIO, business segment reps) and board oversight, indicating a risk management process. It mentions company‑specific roles (CISO, CIO) and review cadence, making it firm‑specific (level 3).


reasoning: The paragraph describes the ongoing cybersecurity incident, mentions cooperation with law enforcement, and states that it has not had a material impact—clearly an incident disclosure.


reasoning: The paragraph describes the board’s overall oversight and delegation to the audit committee, making the board the grammatical subject of the governance discussion.


reasoning: The paragraph only provides a generic disclaimer that no material cybersecurity risks have been identified and references the risk factors section, without describing any board, management, risk processes, incidents, or vendor matters. It contains no company‑specific facts or frameworks, making it generic boilerplate.


reasoning: The paragraph describes how cybersecurity risk management procedures are incorporated into enterprise risk management, focusing on processes and governance, without naming frameworks, roles, or company‑specific details.


reasoning: Paragraph describes a real event on May 1, 2024, detailing detection, response actions, and external experts, making it an incident disclosure. It includes a specific date and company‑specific actions, qualifying as firm‑specific (level 3).


reasoning: The paragraph centers on the Committee receiving reports and reporting to the full Board, making the board/committee oversight the primary focus. It mentions a committee and reporting cadence but does not name any unique entity or provide quantifiable details, fitting sector‑adapted level.


reasoning: The paragraph only provides a boilerplate materiality disclaimer and does not describe an incident, process, or governance detail; such statements are classified as None/Other and are generic.


reasoning: Paragraph only provides a boilerplate materiality disclaimer without describing an incident or any process, thus falls under None/Other and is generic boilerplate (level 1).


reasoning: The paragraph is a generic disclaimer stating possible failure to prevent incidents and refers to Risk Factors, with no specific process, role, or incident details.


reasoning: The paragraph states the board is responsible for oversight and receives updates, making board governance the dominant theme. It mentions the company's board, audit committee and annual reporting, which are firm‑specific details (level 3).


reasoning: Paragraph outlines general cyber risk exposure and the company's ongoing monitoring and mitigation efforts without describing a specific incident, board or management role, and uses generic language without named frameworks or firm‑specific details.


reasoning: The paragraph is a forward‑looking safe‑harbor disclaimer that does not describe an actual incident or any governance, risk‑management, or strategy details; it is merely a non‑cybersecurity disclaimer.


reasoning: Paragraph details a specific event on May 11, 2025, describing the threat actor, data accessed, termination of personnel, and law‑enforcement cooperation, which is a clear incident narrative.


reasoning: The paragraph narrates a real cybersecurity event (unauthorized third‑party access, data exfiltration, system shutdowns) and its operational impact, which is the hallmark of Incident Disclosure. It provides concrete details such as the exact date (July 25, 2024) and specific actions taken (shutting down systems, limiting access to financial reporting systems), meeting the criteria for a Level 4 specificity.


reasoning: The paragraph primarily describes the company's processes for assessing, identifying, and managing cybersecurity risks, including asset identification, threat assessment, and control mitigation, with ERM integration, fitting Risk Management Process; third-party mentions are subsidiary. It uses generic boilerplate language like 'developing processes,' 'seek to assess,' and standard risk steps without named frameworks, roles, or firm-specific facts, making it Level 1.

provider: x-ai


reasoning: Paragraph details company's internal risk management processes including ERM program with 12 risk categories (one Cybersecurity), annual ERA for identification/assessment/response/monitoring, quarterly reviews, and reporting to leadership/Board, making Risk Management Process dominant (SEC Item 106(b)). Specificity level 4 due to multiple verifiable facts: '12 categories', 'annually' ERA, 'quarterly' monitoring/reviews, named programs 'ERM' and 'ERA' unique to Emergent.


reasoning: Paragraph describes the company's multi-stakeholder team (with reps from third-party IT admin, Legal/Compliance, Finance) and specific risk assessment methods (automated tools, subscriptions, scans, reviews, third-party assessments), which are internal processes making Risk Management Process dominant; third-parties are components, not central. Firm-specific due to unique team composition and IT investments, but lacks two+ verifiable facts like quantities or named firms for level 4.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risks, quarterly reports from the ERM Committee and direct periodic reports from the CIO or VP Infrastructure, matching Board Governance (board/committee oversight and briefing cadence). It includes firm-specific facts like named committees (ERM Committee, Audit Committee) and roles (CIO, VP Infrastructure) with concrete reporting lines, qualifying as level 3 specificity without quantified metrics or dates for level 4.


reasoning: Paragraph details an actual incident with specific date ('April 24, 2024'), named product ('Dropbox Sign'), scope of access ('emails and usernames... phone numbers, hashed passwords'), and remediation ('activated our cybersecurity incident response process'), fitting Incident Disclosure perfectly. Multiple verifiable facts (date, product, data types, limitations) exceed level 4 threshold.


category_confidence: medium

reasoning: Paragraph consists of forward-looking hypothetical risks ('could lead to', 'may not be sufficiently protected') and a negative materiality statement ('risks... have, to date, not materially affected') without describing any processes, roles, or structures, fitting None/Other; no actual processes or frameworks mentioned despite admitting lack of investments, which is generic boilerplate.


reasoning: Paragraph describes an actual cybersecurity incident with timeline ('On May 6, 2024, detected'), scope ('portions of its IT systems', 'financial and operating reporting systems'), response actions ('activated cyber incident procedure', 'external cybersecurity experts', 'notifying law enforcement'), fitting Incident Disclosure. Specificity level 4 due to two verifiable facts: exact date (May 6, 2024) and specific impacted systems (financial and operating reporting systems).


reasoning: Paragraph details an actual cybersecurity incident with timeline ('late November 2023'), scope ('very small percentage of employee email accounts including members of our senior leadership team and employees in our cybersecurity, legal'), and ongoing access to 'source code repositories and internal systems,' fitting Incident Disclosure. Multiple verifiable facts (specific date, named employee groups/functions, source code repositories) justify level 4 specificity.


reasoning: Paragraph describes an actual cybersecurity incident with specific timing ('March 10, 2024'), nature ('third party gained unauthorized access to portions of its information environment'), response actions ('initiated incident response protocols, containment measures'), and impact ('disruption to a portion of the Company’s business, operations continued in all material respects'), making it dominant Incident Disclosure. Specificity level 3 due to firm-specific facts like the exact date and company-unique incident details, but lacks two+ independently verifiable facts (e.g., no named systems, quantified impacts, or named experts) for level 4.


reasoning: The paragraph identifies the Chief Technology Officer by name and role, details their qualifications ('over 15 years of experience'), responsibilities ('establishment and maintenance of our cybersecurity risk management processes'), and reporting lines ('provides reports to and meets periodically with our General Counsel'), making 'Management Role' the dominant category. It is firm-specific (level 3) due to named roles (CTO, General Counsel) and concrete reporting structure unique to this company, but lacks two or more quantified verifiable facts like dates or amounts for level 4.


reasoning: The paragraph describes the board's oversight of strategic/operational risks including cybersecurity, delegation to the audit committee for review/discussion, and regular reporting back, making Board Governance the dominant category (SEC Item 106(c)(1)). It uses generic language applicable to any company ('board of directors', 'audit committee', 'regularly reports') with no frameworks, unique roles, or verifiable facts, fitting level 1 boilerplate.


reasoning: Paragraph details an actual incident with specific timing ('March 10, 2024'), nature ('third party gained unauthorized access to portions of our information environment'), response ('initiated incident response... containment measures'), impact ('disruption to a portion of the Company’s business'), and remediation ('affected information environment is remediated'), making Incident Disclosure the dominant category. Specificity level 3 due to firm-specific facts like the exact incident date and company-unique event details, but lacks a second independently verifiable fact like named systems or quantified impacts for level 4.


reasoning: Paragraph describes integration of cybersecurity into ERM, biannual risk reviews involving CISO/CIO and executive management, mitigation plans, and annual board review, which matches Risk Management Process (ERM integration, risk assessment cadence). Names specific roles (CISO, CIO) and cadences (biannual, annual) unique to the company for level 3 specificity.


reasoning: Paragraph states no material past cybersecurity risks or incidents identified, notes hypothetical future risks 'if realized,' and cross-references to Risk Factors, fitting None/Other as a negative disclosure without describing any processes, structures, or actual events.


reasoning: Paragraph details an actual incident with specific timing ('November 25, 2024'), nature ('threat actor illegally accessed... encrypted some of its data files'), and remediation steps ('internal investigation, engaging external cybersecurity specialists'), fitting Incident Disclosure. Specificity level 4 due to verifiable facts: exact date and firm-specific IT system access with encryption.


reasoning: Paragraph identifies specific management roles (CIO, Information Security Director, Cybersecurity Team) with their responsibilities for the cybersecurity program and provides quantified experience (over 35 and 25 years), fitting Management Role; two+ verifiable facts (named roles/team + experience quantifiables) make it level 4.


reasoning: Paragraph describes an actual ongoing cybersecurity incident, its unknown full scope/nature/impact, material effect on business operations, and undetermined financial impact, aligning directly with Incident Disclosure for 8-K Item 1.05; language is generic boilerplate with no named entities, dates, or unique facts applicable to any company.


reasoning: Paragraph describes an actual cybersecurity incident with specific timing ('on May 1, 2024'), nature ('unauthorized occurrences by a third party on portions of the Company’s IT systems'), and remediation steps ('initiated response protocols', 'investigation with leading external cybersecurity experts', 'shutting down portions of the IT systems', 'notifying law enforcement'), fitting Incident Disclosure. Specificity level 3 due to firm-specific date and incident details unique to this company, but lacks a second independently verifiable fact like a named system or firm for level 4.


reasoning: The paragraph describes cybersecurity risk management procedures incorporated into enterprise risk management programs with shared methodologies, reporting channels, and governance processes, directly matching 'ERM integration' under Risk Management Process. It contains no named frameworks, roles, or firm-specific details, making it generic boilerplate applicable to any company (level 1).


reasoning: Paragraph describes actual incident with nature ('unauthorized activity on certain... systems'), timeline ('recently identified', 'On December 20, 2023'), and remediation ('took steps... contain, assess and remediate', 'isolate systems from the Internet', 'retained leading experts, worked with law enforcement'). Two verifiable facts: exact date 'December 20, 2023' and specific action 'elected to isolate systems from the Internet' justify level 4.


reasoning: Paragraph describes response actions to an actual incident (notifying law enforcement, cooperating, assessing notifications) and current impact assessment, fitting Incident Disclosure per 8-K Item 1.05 and rules prioritizing incident narrative over passing financial mentions. Content is generic boilerplate with no named entities, frameworks, dates, or unique firm facts, matching Level 1 example of materiality statements.


reasoning: The paragraph describes the board's oversight responsibility for cybersecurity risks and its annual briefing cadence via the audit committee and executive team, directly matching 'Board Governance' criteria. It names the specific 'audit committee' and 'annual basis' reporting, making it firm-specific (level 3) without quantified verifiable facts like dollars or dates for level 4.


reasoning: Paragraph uses hypothetical conditional language ('may not be successful', 'could have a material adverse effect') and cross-references to Item 1A Risk Factors without describing any processes, fitting None/Other rule for negative disclosures. Specificity_level=1 as required for None/Other.


reasoning: The paragraph focuses on 'The Committee' receiving periodic reports from management on cybersecurity risks and reporting to the full Board, making board/committee oversight the primary topic (Board Governance). Language is generic boilerplate with vague terms like 'periodic reports' and 'as necessary,' applicable to any company without firm-specific details like named committees, roles, or cadences.


reasoning: The paragraph describes an ongoing investigation into 'the incident,' including forensic analysis of its nature, scope, and impact, directly matching Incident Disclosure for an 8-K Item 1.05. It lacks any named entities, dates, frameworks, or firm-specific facts, making it generic boilerplate applicable to any company.


reasoning: Paragraph centers on 'risk-based approach to the evaluation of third-party vendors based on the criticality and size,' making vendor oversight the dominant topic per rules distinguishing it from general Risk Management Process; generic phrasing like 'as appropriate' and no named entities confirm level 1 boilerplate.


reasoning: Paragraph describes ongoing remediation efforts ('restore those systems,' 'retained leading experts,' 'working with law enforcement,' 'notified certain regulatory authorities') for an actual cybersecurity incident in an 8-K Item 1.05, focusing on response actions rather than strategy or finances. Content is generic boilerplate with no named entities, dates, frameworks, or quantifiable facts, applicable to any company.


reasoning: The paragraph's primary purpose is a materiality conclusion on financial impact ('not determined the incident is reasonably likely to materially impact the Company’s financial condition or results of operations'), fitting Strategy Integration for business/financial consequences disconnected from any incident narrative; no description of the incident itself rules out Incident Disclosure. It is generic boilerplate language applicable to any 8-K Item 1.05 filing, with no frameworks, unique facts, or quantifiable details.


reasoning: Paragraph focuses on seeking insurance reimbursements for costs from 'the cyber incident,' emphasizing financial recovery via 'VF’s cybersecurity insurers' with uncertain timing/amount, making business/financial consequences (cyber insurance) the primary topic rather than incident details. No firm-specific facts like named insurers, amounts, or dates beyond generic uncertainty, fitting generic boilerplate.


reasoning: The paragraph's primary purpose is a materiality assessment of the Incident's impact on financial condition, business, and operations ('not reasonably likely to have a material impact'), matching Strategy Integration for business/financial consequences without incident narrative; it is generic boilerplate materiality language applicable to any 8-K, with no named frameworks, unique facts, or quantifiable details (level 1).


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management strategy, including adoption of CIS Controls framework, annual assessments reviewed by Internal Audit and shared with the Technology Committee, regular risk assessments integrated with ERM, infrastructure details, dedicated personnel teams with insourcing, and training programs—aligning with Risk Management Process (Item 106(b)). Specificity level 3 due to firm-specific elements like 'Technology Committee of our Board of Directors,' 'Internal Audit team,' and 'significant investments in technology insourcing and reassumed direct ownership of certain information security related teams,' which are unique to Wendy's without quantified metrics or dates for level 4.


reasoning: Paragraph details company's internal cybersecurity processes including ongoing threat assessment, layered security, quarterly phishing tests, annual third-party penetration testing, NIST/ISO standards, and SOC-1/2 compliance for specific providers like banking and payroll, making Risk Management Process dominant as third-party elements are components of overall processes. Multiple verifiable facts (quarterly phishing tests, annual pen testing and audits, specific SOC-compliant services) justify level 4 specificity.


reasoning: Paragraph details company's internal incident evaluation criteria, CSO role in assessment, escalation procedures, Incident Response Program (with training/testing), and Business Continuity Plans including for third-parties, making Risk Management Process dominant as it describes processes with third-parties as a component. Firm-specific elements like 'Chief Security Officer (CSO)' and 'S&T's Incident Response Program/Business Continuity Plan' qualify as level 3, with no quantified verifiable facts for level 4.


reasoning: This paragraph is a standard forward-looking statement disclaimer referencing 'the Incident' only in the context of future expectations, investigation results, and potential impacts, matching the 'None/Other' category for forward-looking disclaimers and cross-references; it does not describe the incident itself or any processes.


reasoning: The paragraph details an actual cybersecurity incident including specific timing ('On July 25, 2024'), nature ('third party’s unauthorized access... exfiltration of certain files, including files potentially containing sensitive personal information'), scope ('portion of the Company’s internal information systems'), impact ('material impact on the Company’s business operations', disruptions to 'financial and operating reporting systems'), and remediation ('shutting down certain of its systems', 'substantially restored'), fitting Incident Disclosure perfectly. Multiple verifiable facts like the exact date, named system types, and restoration status justify level 4 specificity.


reasoning: Paragraph details actual incident updates including specific dates (Dec 24/28/16 2025, Jan 15 2026), named subsidiary (Coupang Corp.), scope (33M accounts accessed, 3K saved/deleted), and remediation ($1.2B vouchers), making it dominant Incident Disclosure; multiple verifiable facts (dates, quantities, amounts) exceed level 4 threshold.


reasoning: Paragraph details an actual incident with timeline ('On August 25, 2025'), scope ('defaced website at wytecintl.com'), impact ('cancel a seminar scheduled for September 2, 2025', 'financial losses...significant'), and remediation ('working with forensic specialists', 'reported...to the Federal Bureau of Investigations'), fitting Incident Disclosure. Multiple verifiable facts (specific dates August 25 and September 2, 2025; named URL wytecintl.com; FBI involvement) justify level 4.


reasoning: The paragraph primarily describes the composition of the 'Risk Management Team' with specific named roles (CFO, CLO, VP Corporate Controller, Sr. Director SEC Reporting, Sr. Director of IT), their monitoring activities, quarterly meetings, and reporting to the Audit Committee, fitting Management Role as the dominant topic despite mentions of board briefings. It includes firm-specific details like named positions and concrete cadences (quarterly meetings, minimum annual briefings), qualifying as level 3 but lacking quantified metrics like dollars or headcounts for level 4.


reasoning: The paragraph details an actual incident including specific date (May 11, 2025), nature (threat actor email claiming customer account info and internal docs via paid contractors/employees), scope (customer-service systems), detection (security monitoring in previous months), and remediation (terminated personnel, heightened protections, customer warnings, no ransom paid, law enforcement cooperation), fitting Incident Disclosure perfectly. Multiple verifiable facts like the date, subsidiary (Coinbase, Inc.), data types, and response actions confirm level 4 specificity.


reasoning: The paragraph primarily describes the company's internal processes for monitoring and developing IT networks to 'prevent, detect, address and mitigate' cyber risks, fitting Risk Management Process; no board, management roles, incidents, or third-party focus. It is generic boilerplate (level 1) with conditional language ('may be vulnerable,' 'could compromise'), common threats (malware, ransomware, phishing), and no named frameworks, roles, dates, or firm-unique facts.