content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal risk management processes and the composition of the team responsible for these activities, which falls under Risk Management Process. It is Firm-Specific because it identifies a unique team composition (Legal, Compliance, and Finance departments) involved in cybersecurity oversight.

provider: google


content_category: Strategy Integration

reasoning: The paragraph discusses the company's general risk posture and concludes with a materiality statement regarding cybersecurity threats, which falls under Strategy Integration. It contains no specific facts, roles, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk management processes, specifically how they utilize third parties as a component of their broader security strategy, rather than focusing on vendor oversight as a standalone risk management topic.


reasoning: The paragraph describes the company's internal risk management framework and processes, specifically how cybersecurity is integrated into their ERM program.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, which falls squarely under Risk Management Process. It contains no specific dates, named roles, named tools, or other verifiable facts, making it generic boilerplate.


content_category: Board Governance

reasoning: The paragraph focuses primarily on the Board's oversight responsibilities, reporting cadence, and involvement in cybersecurity risk management, making 'Board Governance' the most appropriate category. While it mentions materiality, this is framed within the context of the Board's oversight and reporting structure rather than a standalone financial or strategic assessment.


content_category: Management Role

reasoning: The paragraph focuses on the identification, reporting lines, and qualifications of the Information Security Officer (ISO), which is a management role.


reasoning: The paragraph primarily describes the company's internal risk management processes and the integration of cybersecurity into the ERM program. While it mentions the Board and specific roles, the core subject matter is the operational structure of the risk management program.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities and reporting structure, making Board Governance the primary category. It is classified as Firm-Specific because it names specific internal committees and roles (ERM Committee, CIO, VP Infrastructure) involved in this governance process.


reasoning: The paragraph focuses on the specific management role (HSE Director) responsible for cybersecurity oversight and their tenure, which takes precedence over the board oversight mentions.


reasoning: The paragraph describes the company's internal approach to managing cybersecurity risks and implementing security programs, which falls under Risk Management Process. It is classified as Sector-Adapted because it explicitly references ISO and NIST frameworks without providing firm-specific details like unique program names or specific personnel.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities and its interaction with management, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it explicitly names the CIO and CISO roles, which are cybersecurity-specific titles.


reasoning: The paragraph provides a standalone materiality conclusion regarding the impact of cybersecurity threats on the company's business and financial condition, which falls under Strategy Integration.


reasoning: The paragraph focuses on the roles and reporting lines of specific cybersecurity leadership (VP, IT Data Security and CTO) and the Cybersecurity Committee, making 'Management Role' the primary category.


reasoning: The paragraph focuses on the board's oversight structure and delegation of duties to the Audit Committee, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies specific internal roles (Vice President of Operation & Information Technology and Head of Information Technology) responsible for reporting to the committee.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including the use of assessments, monitoring, and cross-departmental collaboration. It is classified as Sector-Adapted because it explicitly references the NIST framework but lacks other firm-specific or verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity program, incident response planning, and risk assessment activities, which are core components of a risk management process. It contains no specific dates, named third-party firms, named products, or cybersecurity-specific roles (the 'IT team' is generic), resulting in a Generic Boilerplate classification.


content_category: None/Other

reasoning: The paragraph is a cross-reference to the Risk Factors section and contains no substantive cybersecurity disclosure.


reasoning: The paragraph consists entirely of forward-looking disclaimers and boilerplate statements regarding potential future risks and the absence of past material incidents, with no substantive disclosure of governance, management, or specific processes.


reasoning: The paragraph describes the company's internal incident response and escalation procedures, including specific roles and committees involved in the process.


reasoning: The paragraph focuses primarily on the board and audit committee's oversight responsibilities regarding cybersecurity, making 'Board Governance' the most appropriate category. While management roles are mentioned, they are secondary to the description of the board's oversight structure.


reasoning: The paragraph describes the company's internal risk assessment and mitigation processes, with the InfoSec team as the primary actor. It does not contain any specific dates, named frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses entirely on the Audit Committee's oversight responsibilities and reporting structure to the Board. It contains no specific facts, as 'Audit Committee', 'Board', and 'management' are generic entities, and 'quarterly' and 'periodic' are generic cadences.


reasoning: The paragraph describes the company's internal risk management processes, including how they develop controls and conduct assessments. It is classified as Sector-Adapted because it explicitly names recognized security frameworks (CIS and PCI DSS) without providing firm-specific details like named roles or unique program identifiers.


reasoning: The paragraph focuses on the Board's oversight responsibilities and the specific structure of its committees, making 'Board Governance' the primary category.


reasoning: The paragraph focuses on the identification, qualifications, and reporting lines of the CISO/CDIO, which places it squarely in the Management Role category. It contains multiple verifiable facts, including the start year of the role and the specific previous employers of the officer.


reasoning: The paragraph focuses on the Board and its specific committee's oversight responsibilities, making 'Board Governance' the primary category. It is 'Firm-Specific' because it names a unique internal entity (Cybersecurity Subcommittee) and its establishment date.


reasoning: The paragraph describes internal risk management processes like incident response planning, business continuity, and security training, but contains no specific names, dates, or unique identifiers.


reasoning: The paragraph describes the company's internal processes for cybersecurity monitoring and incident response, which falls squarely under Risk Management Process. It contains no specific dates, named third-party firms, named products, or other verifiable facts, making it generic boilerplate.


category_confidence: medium

reasoning: The paragraph primarily focuses on the materiality of past and potential future incidents, which falls under Strategy Integration. While it mentions board oversight and consultants, these are generic references that do not constitute a detailed description of governance or management roles.


reasoning: The paragraph describes the company's internal cybersecurity protocols and risk management processes without naming specific frameworks, tools, or unique identifiers.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the CIO and senior leadership regarding cybersecurity oversight, making 'Management Role' the primary category.


reasoning: The paragraph focuses on the Board of Directors and its Audit Committee as the primary subjects overseeing cybersecurity risk management. While it mentions management roles (CEO/CFO), these are standard corporate roles and the primary context is the reporting structure to the Board.


reasoning: The paragraph describes the company's internal cybersecurity processes, including vulnerability management and incident response planning, while referencing the NIST framework.


reasoning: The paragraph focuses primarily on the Board and Audit Committee's role in cybersecurity oversight, which aligns with the Board Governance category. It mentions the NIST Cybersecurity Framework, which qualifies it as Sector-Adapted.


reasoning: The paragraph focuses on the specific roles (Director, IT Infrastructure & Security) and their responsibilities, making 'Management Role' the most appropriate category. It is 'Firm-Specific' because it names a specific internal role and a specific internal program (CIRP).


reasoning: The paragraph focuses on the CISO's qualifications, experience, and responsibilities, making 'Management Role' the correct category. It qualifies as 'Quantified-Verifiable' because it provides two specific, verifiable facts: the CISO's years of experience and their specific educational degree.


content_category: Third-Party Risk

reasoning: The paragraph focuses primarily on the company's oversight and requirements for third-party service providers, which is the definition of Third-Party Risk. It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident detection and response processes and framework adoption, which falls squarely under Risk Management Process.


reasoning: The paragraph primarily discusses the potential material impact of cybersecurity threats and includes a standard disclaimer about the lack of past material incidents, which falls under Strategy Integration. While it mentions roles like CEO and CFO, these are excluded from specific facts as they are generic C-suite roles, and 'MSP' is an unnamed entity.


reasoning: The paragraph focuses on the CISO's role, reporting lines, and specific qualifications/certifications, which falls squarely under Management Role. It contains multiple verifiable facts, including specific certifications and years of experience, meeting the threshold for Quantified-Verifiable.


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access in October 2023) and the subsequent response actions, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes internal training programs and preparedness exercises, which are components of the company's risk management process. It contains no specific facts, named roles, or unique identifiers, relying entirely on generic descriptions of common security practices.


reasoning: The paragraph describes the company's internal cybersecurity program, tools, and processes, which falls under Risk Management Process. It is classified as Sector-Adapted because it explicitly names multiple recognized frameworks (NIST, GDPR, ISO 27001) without providing firm-specific details like named internal teams, specific dates, or unique program identifiers.


reasoning: The paragraph focuses on the management-level committee (ERM) and specific roles (CISO, CDO) responsible for risk oversight, making 'Management Role' the most appropriate category.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for the fiscal year, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year ('fiscal 2025'), which is a unique fact identifying this specific filing period.


reasoning: The paragraph focuses on the Board's oversight structure and the delegation of cybersecurity risk responsibilities to the Audit Committee. While it mentions the Audit Committee, this is considered a generic governance entity in the context of the provided instructions.


reasoning: The paragraph focuses on the CISO's qualifications and the role of the Information Security Council, which are management-related governance structures. It qualifies as Quantified-Verifiable because it lists specific professional certifications and years of experience.


reasoning: The paragraph describes the company's internal processes for assessing cybersecurity, including vulnerability management and monitoring, which falls squarely under Risk Management Process. It contains no specific dates, named third-party firms, or unique identifiers that would elevate it beyond generic boilerplate.


reasoning: The paragraph primarily discusses the materiality of cybersecurity threats and past incidents on the company's financial condition and strategy, which falls under Strategy Integration. While it mentions a past incident, it does not describe the incident itself (what happened, scope, response), but rather uses it to frame a materiality conclusion.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and the frameworks used to guide it, fitting the Risk Management Process category.


reasoning: While the paragraph mentions training (Risk Management Process), the central focus of the majority of the text is on the oversight and management of third-party providers, making Third-Party Risk the most applicable category.


reasoning: The paragraph details the company's internal cybersecurity risk management policies, procedures, and controls, and explicitly references the NIST framework.


reasoning: The paragraph primarily describes the company's internal risk management processes, specifically how they integrate cybersecurity into their ERM program and align with the NIST framework.


reasoning: The paragraph focuses on the qualifications, experience, and reporting lines of the Chief Information Security Officer, which is the primary subject of the text.


reasoning: The paragraph describes the company's general approach to using external experts and conducting training as part of its internal security processes, without naming specific firms, dates, or unique programs.


reasoning: The paragraph focuses primarily on the Board of Directors' oversight responsibilities and their interaction with the CSO, making 'Board Governance' the most appropriate category. The mention of the 'CSO' (Chief Security Officer) is a cybersecurity-specific role, which elevates the specificity to 'Firm-Specific'.


reasoning: The paragraph provides a standalone materiality assessment regarding cybersecurity risks and incidents without describing any specific events or internal processes.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of determination and the nature of the event (unauthorized access), which places it squarely in Incident Disclosure.


reasoning: The paragraph describes the company's intended internal processes for risk management and cybersecurity oversight. It contains no specific dates, named roles, named tools, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses primarily on the responsibilities, qualifications, and reporting lines of the VP of IT and the IT Executive Steering Committee, making 'Management Role' the most appropriate category. It qualifies as 'Quantified-Verifiable' because it contains multiple specific, verifiable facts, including the specific tenure of the VP of IT (three years) and their years of experience (25 years).


reasoning: The paragraph describes the company's general approach to risk management and internal processes without providing any specific details, frameworks, or unique identifiers.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the unauthorized access, and the company's response actions, which fits the Incident Disclosure category.


reasoning: The paragraph is a standard forward-looking disclaimer regarding the limitations of cybersecurity controls and references other sections of the filing, containing no substantive disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the affected system, and the scope of the unauthorized access, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the details, scope, and ongoing nature of a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of determination, the nature of the event, and the company's response actions, which places it squarely in Incident Disclosure.


reasoning: The paragraph describes the details of an ongoing cybersecurity incident, including the nature of the exfiltrated data and the threat actor's demands, which places it squarely in Incident Disclosure.


reasoning: The paragraph describes the status and impact of a specific cybersecurity incident, including remediation efforts and affected business functions, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including dates of detection, the timeframe of the breach, and the response actions taken, which fits the Incident Disclosure category.


reasoning: The paragraph describes the scope and nature of a specific cybersecurity incident, including the type of data accessed and the number of affected accounts, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the timeline, nature, and scope of a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence and the specific systems affected, which qualifies as an incident disclosure.


reasoning: The paragraph describes the scope and nature of data impacted by a specific cybersecurity incident, which is the core definition of Incident Disclosure. It contains no specific dates, dollar amounts, or named third-party firms, rendering it Generic Boilerplate in terms of specificity.


reasoning: The paragraph describes the nature and impact of a cybersecurity incident, including unauthorized access, operational limitations, and data exfiltration, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, rendering it generic boilerplate.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the scope of the data accessed and the response actions taken, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts that would elevate it beyond generic boilerplate.


reasoning: The paragraph describes the scope and nature of an ongoing cybersecurity incident, including the exfiltration of data and the company's response actions, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, rendering it Generic Boilerplate.


reasoning: The paragraph discusses the potential financial and material impact of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of occurrence, the nature of the attack (encryption, exfiltration), and the current operational impact, which fits the Incident Disclosure category.


reasoning: The paragraph is a standard legal disclaimer regarding forward-looking statements and safe harbor provisions, which contains no substantive cybersecurity disclosure.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of occurrence, the nature of the unauthorized access, and the operational impact, which aligns with the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the event (unauthorized access, encryption, data theft), and the company's response actions, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the operational impact and recovery status of a previously disclosed cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts that would elevate it beyond boilerplate incident status reporting.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of notification, the threat actor involved, and the timeline of the unauthorized access, which clearly falls under Incident Disclosure.


reasoning: The paragraph focuses exclusively on the materiality assessment and financial impact (insurance coverage) of a cybersecurity incident without describing the incident itself or the company's internal processes.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the affected entity, and the response actions taken, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the dates of occurrence and resolution, the nature of the disruption, and the response actions taken, which fits the Incident Disclosure category.


reasoning: The paragraph describes the status, operational impact, and financial consequences of a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the nature and impact of a specific cybersecurity incident involving a former executive officer, which falls under Incident Disclosure. It contains no hard verifiable facts (dates, amounts, named firms) or unique identifiers that would elevate it beyond generic boilerplate language regarding incident impact.


reasoning: The paragraph primarily focuses on the materiality assessment of the incident and insurance coverage, which falls under Strategy Integration. While it mentions remediation activities, the core substance is the financial impact conclusion.


reasoning: The paragraph focuses on the materiality assessment and financial impact of an incident, which falls under Strategy Integration. While it mentions an incident, it does not describe the event itself, but rather the financial implications and guidance.


reasoning: The paragraph describes the operational impact and remediation timeline of a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph discusses the financial impact (revenue delays and one-time expenses) of a previously disclosed incident without providing a narrative description of the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph describes a specific cybersecurity incident involving a named third-party vendor (CDK Global) and provides the date of the incident, which qualifies as an Incident Disclosure.


reasoning: The paragraph describes the details of a specific cybersecurity incident (ransomware, origin, response), which falls squarely under Incident Disclosure.


reasoning: The paragraph focuses exclusively on the financial impact and cost estimates of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains a specific dollar range, which qualifies as a firm-specific fact.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including the detection date and the date the threat actor was ejected, which qualifies as an incident disclosure.


reasoning: The paragraph focuses on the materiality and financial impact of the incident on the company's earnings and operations, rather than describing the incident itself. It contains multiple specific dates, qualifying it as Quantified-Verifiable.


reasoning: The paragraph discusses the financial and operational materiality of an incident without providing a narrative description of the event itself, which aligns with the Strategy Integration category. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the financial impact and liquidity arrangements resulting from an incident rather than describing the incident itself, fitting the Strategy Integration category.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the event (unauthorized occurrences, encryption), and the operational impact on the company's facilities, which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes the scope, timeline, and impact of a specific cybersecurity incident involving a third-party provider, which qualifies as an Incident Disclosure.


reasoning: The paragraph describes an active cybersecurity incident, including the detection, response actions, and operational impact, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, rendering it Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the detection date and the company's response actions, which places it squarely in the Incident Disclosure category.


reasoning: The paragraph describes the timeline and nature of a specific cybersecurity incident, which qualifies as an Incident Disclosure.


reasoning: The paragraph describes the scope and nature of an ongoing cybersecurity incident, including the unauthorized access and data exfiltration, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, rendering it Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the nature of the unauthorized access, and the company's response actions, which fits the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the unauthorized access, and the operational impact, which fits the Incident Disclosure category.


reasoning: The paragraph describes the ongoing investigation, status of data theft, and materiality assessment of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, rendering it generic.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the scope (Canadian operations), and the company's response actions, which fits the Incident Disclosure category.


reasoning: The paragraph describes the ongoing response and impact of a specific cybersecurity incident (the cyberattack on Change Healthcare), which falls squarely under Incident Disclosure.


reasoning: The paragraph focuses on the responsibilities and qualifications of the Chief Technology Officer, making 'Management Role' the primary category. It is 'Firm-Specific' because it identifies a specific cybersecurity-related role and provides specific professional experience details.


reasoning: The paragraph focuses on the board of directors' oversight responsibilities and the delegation of risk management review to the audit committee, which falls squarely under Board Governance. It contains no specific facts, named cybersecurity roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on identifying specific management roles (CIO, Information Security Director) and their qualifications, making it a clear Management Role disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity incidents and their financial impact without describing any specific event, which aligns with the Strategy Integration category.


reasoning: The paragraph describes general internal activities related to compliance and risk management without naming specific frameworks, roles, or unique programs.


reasoning: The paragraph focuses on the specific responsibilities of a named individual (Mr. Gharib) regarding cybersecurity oversight, which falls under Management Role.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents without describing any specific event or internal process.


reasoning: The paragraph focuses on the responsibilities of the Chief Financial Officer regarding cybersecurity oversight and reporting, which places it squarely in the Management Role category.


reasoning: The paragraph describes the company's internal cybersecurity program and risk management structure, with the CDRM organization and Global CISO as the subjects. It is classified as Firm-Specific because it names a unique internal organization (CDRM) and a specific role (Global CISO).


reasoning: The paragraph describes the company's internal risk management processes and integration, with specific management roles mentioned as participants in those processes rather than as the primary subject of the disclosure.


reasoning: The paragraph focuses on the Board of Directors' oversight responsibilities, including training, policy approval, and delegation of duties to a specific committee.


reasoning: The paragraph focuses on the Audit Committee's role in cybersecurity oversight, which is the primary subject. While management roles are mentioned, they are secondary to the description of the Board's governance structure.


reasoning: This paragraph is a cross-reference to another section of the filing and does not contain substantive cybersecurity disclosure.


reasoning: The paragraph describes the company's internal processes for identifying and escalating cybersecurity incidents, which falls squarely under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph primarily focuses on a materiality conclusion regarding cybersecurity risks and their impact on financial condition, which falls under Strategy Integration. It contains no specific dates, named roles, or verifiable facts, rendering it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risk, specifically training, testing, and assessments. It is categorized as Risk Management Process because it focuses on the company's own internal procedures rather than board oversight or specific incident disclosure.


reasoning: The paragraph focuses entirely on the qualifications, tenure, and roles of the CISO and CTO, making it a clear Management Role disclosure. It contains numerous verifiable facts, including specific years of experience, certifications, and start dates.


reasoning: The paragraph describes the company's internal risk assessment and mitigation processes without referencing any specific frameworks, roles, or unique identifiers.


reasoning: The paragraph describes the company's internal risk management processes and the collaboration between internal teams, making 'Risk Management Process' the most appropriate category. It is 'Firm-Specific' because it identifies a specific cybersecurity role (Chief Security Officer) which is a unique organizational detail.


reasoning: The paragraph describes the company's internal incident response procedures and escalation paths, which falls under Risk Management Process. It is classified as Firm-Specific because it names unique internal entities like the 'Incident Management Team' and 'Privacy and Security Subcommittee'.


reasoning: The paragraph describes the company's internal risk management processes and how cybersecurity is integrated into broader organizational systems, which is the definition of Risk Management Process.


reasoning: The paragraph identifies a specific individual (Jack Wang) and their qualifications/responsibilities regarding cybersecurity, which falls squarely under Management Role.


reasoning: The paragraph focuses on the Board's oversight activities and the specific roles (CIO, CISO, CIRO) that brief the Board, making Board Governance the primary category.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for a specific fiscal year, which falls under Strategy Integration.


reasoning: The paragraph focuses on the Board's establishment of a specific committee and the qualifications of its chair, which is a core Board Governance topic.


reasoning: The paragraph provides a standalone materiality assessment regarding cybersecurity risks and mentions financial resources and insurance without describing a specific incident or internal process.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including specific committee structures and policy counts, which falls under Risk Management Process.


reasoning: The paragraph describes the company's internal approach to risk management by utilizing external experts for testing and auditing, which falls under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph primarily focuses on the board of directors' role in overseeing the risk management program, making Board Governance the most appropriate category. It is classified as Sector-Adapted because it references recognized industry frameworks (NIST and ISO) without providing firm-specific details.


reasoning: The paragraph focuses on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity, which places it squarely in Board Governance. No specific facts (dates, named cybersecurity roles, specific tools, etc.) are present; 'Audit Committee' is explicitly excluded from the specific facts list per the instructions.


reasoning: The paragraph describes the company's general approach to risk identification and cross-references other sections of the filing, which is characteristic of a Risk Management Process disclosure, but it contains no specific details or unique identifiers.


reasoning: The paragraph describes the company's internal incident response plan and associated processes, which falls squarely under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the qualifications, experience, and roles of specific management personnel (VP of Information Systems and CFO) regarding cybersecurity oversight.


reasoning: The paragraph focuses on the reporting lines and responsibilities of the CISO and CTO, making 'Management Role' the primary category. It is classified as 'Firm-Specific' because it identifies specific cybersecurity-related roles (CISO, CTO) within the company's organizational structure.


reasoning: The paragraph identifies the specific management role (CFO) responsible for cybersecurity oversight and describes the IT department's qualifications, making 'Management Role' the primary focus.


reasoning: The paragraph describes the company's internal risk assessment process and audit program, which falls squarely under Risk Management Process. It contains no specific facts (dates, named roles, named programs, or tools) that would elevate it beyond generic boilerplate.


reasoning: The paragraph describes the company's internal approach to risk management and incident response procedures, which falls under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents without describing any specific incident narrative, which aligns with the Strategy Integration category.


reasoning: This paragraph is a cross-reference to another section of the filing and contains no substantive cybersecurity disclosure.


reasoning: The paragraph describes the company's internal risk management activities, specifically the engagement of third parties for simulation exercises and ongoing monitoring, which falls under Risk Management Process. It is Firm-Specific because it cites a specific timeframe ('fiscal 2024') for these engagements, though it does not name the specific firms, preventing it from reaching Quantified-Verifiable status.


reasoning: The paragraph describes internal risk management activities (penetration testing and program reviews) performed by unnamed third parties. It contains no specific names, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph discusses the potential financial impact of cybersecurity incidents and the limitations of insurance coverage without describing a specific event or internal process, which aligns with Strategy Integration.


reasoning: The paragraph focuses exclusively on the company's approach to managing risks associated with third-party vendors and service providers, making 'Third-Party Risk' the most appropriate category. It contains no specific names, dates, or verifiable facts, resulting in a 'Generic Boilerplate' specificity rating.


reasoning: The paragraph identifies a specific management role (Vice President of Operations) responsible for the cybersecurity program, which aligns with the Management Role category.


reasoning: The paragraph focuses entirely on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity. It contains no specific facts (Audit Committee is explicitly excluded from the 'specific facts' list per the instructions).


reasoning: The paragraph focuses on the Board's delegation of cybersecurity oversight to the audit committee, which is the primary subject of the text. All entities mentioned (Board, management, audit committee) are generic governance structures, and the reporting cadence is described as 'quarterly,' which is also generic.


reasoning: The paragraph focuses on the Board's oversight responsibilities and the delegation of cybersecurity risk to the Audit Committee, which is a standard governance structure.


reasoning: The paragraph describes the company's internal security tools, policies, and testing procedures, which falls squarely under Risk Management Process. It contains no specific facts (dates, named firms, named products, or unique identifiers), relying entirely on generic descriptions of common security practices.


reasoning: The paragraph provides a standalone materiality conclusion regarding past cybersecurity incidents without describing any specific events, which falls under Strategy Integration.


reasoning: The paragraph focuses on the responsibilities and qualifications of the Director of Cybersecurity, which is a management role.


reasoning: The paragraph describes how the company integrates third-party risk assessment into its broader internal cybersecurity risk management processes, making it a component of the overall risk management strategy rather than a standalone third-party oversight discussion.


reasoning: The paragraph focuses on the company's cyber insurance strategy and the role responsible for it, which falls under Strategy Integration. It is Firm-Specific because it identifies a specific corporate role (Vice President of Finance and Treasurer) involved in this oversight.


reasoning: The paragraph describes the company's adoption of a cybersecurity framework (NIST) as part of its internal risk management processes.


reasoning: The paragraph describes internal operational processes for incident detection and response (Security Operations Center, severity matrix, triage). It contains no specific facts (dates, named tools, named firms, or unique identifiers) that would elevate it beyond generic boilerplate.


reasoning: This paragraph is a generic risk factor disclosure describing common threats and potential impacts without detailing specific governance, processes, or incidents.


reasoning: The paragraph describes the company's internal vulnerability assessment program and risk management approach, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named third-party firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for overseeing cybersecurity risks, which falls under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk management processes and integration with ERM, which fits the Risk Management Process category. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's general approach to risk management processes, with board and committee oversight mentioned only in a generic, introductory capacity.


reasoning: The paragraph describes the company's internal cybersecurity measures and processes, which falls under Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph discusses the materiality of an incident without providing specific details about the event itself, which aligns with the Strategy Integration category. It contains only boilerplate language regarding materiality and impact.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of discovery and the nature of the event (unauthorized access and encryption), which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the scope and impact of a previously disclosed cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic.


reasoning: The paragraph describes specific response actions taken during a cybersecurity incident, including the date systems were isolated, which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes the company's internal cybersecurity measures and processes, such as vulnerability management and incident response, which falls squarely under Risk Management Process. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the financial and operational materiality of a cybersecurity incident rather than describing the incident itself, fitting the Strategy Integration category.


reasoning: The paragraph describes the status and findings of an ongoing cybersecurity incident investigation, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic in specificity.


reasoning: The paragraph describes the scope and impact of a specific cybersecurity incident, confirming that systems were not compromised and no unauthorized transactions occurred, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the timeline and response actions related to a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the timeline, scope, and nature of a specific cybersecurity incident, including dates and affected systems, which fits the Incident Disclosure category.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of detection and the response actions taken, which classifies it as an Incident Disclosure.


reasoning: The paragraph describes the operational impact and status of a specific cybersecurity incident, including the scope of affected systems and recovery status, which falls squarely under Incident Disclosure.


reasoning: The paragraph identifies a specific management role (Senior Vice President, IT Operations) responsible for overseeing the information security team and incident response processes, which aligns with the Management Role category.


reasoning: The paragraph describes a specific cybersecurity incident, including the detection of unauthorized activity and the specific response action taken on a specific date.


reasoning: The paragraph focuses exclusively on the financial impact and materiality of a previously disclosed incident without describing the incident itself, fitting the Strategy Integration category.


reasoning: The paragraph describes the operational impact and status of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts that would elevate its specificity beyond boilerplate.


reasoning: The paragraph describes the scope and nature of data exfiltrated during a previously disclosed cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other hard verifiable facts that would elevate it beyond boilerplate incident description.


reasoning: The paragraph focuses exclusively on the materiality assessment and operational impact of an incident without providing a narrative description of the event itself, which aligns with the Strategy Integration category.


reasoning: The paragraph focuses on the materiality assessment of an incident without providing specific details about the nature or scope of the event itself, which aligns with the Strategy Integration category.


reasoning: The paragraph describes the timeline and status of a specific cybersecurity incident, including law enforcement involvement and the status of the data, which falls squarely under Incident Disclosure.


reasoning: The paragraph focuses on the financial impact (accrued expenses) and insurance coverage related to an incident, rather than describing the incident itself or the internal response processes. Per the tiebreakers, standalone financial/materiality discussions without incident narrative are categorized as Strategy Integration.


reasoning: The paragraph focuses on the materiality assessment and financial impact of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: This paragraph is a standard legal disclaimer regarding forward-looking statements and contains no substantive cybersecurity disclosure.


reasoning: The paragraph describes the scope of data exfiltrated during a cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph describes the scope and impact of a specific cybersecurity incident, including the number of affected consumers, which classifies it as an Incident Disclosure.


reasoning: The paragraph describes the specific details of a cybersecurity incident, including the nature of the unauthorized access and the specific financial impact, which classifies it as an Incident Disclosure.


reasoning: The paragraph describes the company's response actions to a specific incident (investigation, law enforcement notification), which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the financial impact (expenses and revenue) of a cybersecurity incident without providing a narrative description of the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph describes a specific cybersecurity incident (ransomware), including the date of occurrence and the company's response actions, which places it squarely in the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence, the nature of the event (unauthorized access), and the company's response actions, which fits the Incident Disclosure category.


reasoning: The paragraph discusses the financial impact and materiality of an incident without providing any specific details about the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph focuses on the materiality assessment of an incident regarding financial condition and business operations, which falls under Strategy Integration. It is Firm-Specific because it identifies the specific product infrastructure affected (Dropbox Sign).


reasoning: The paragraph describes the ongoing response to a specific cybersecurity incident, including the scope of the disruption and the actions taken, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the timeline of the unauthorized access, and the scope of the affected data, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the discovery and initial response to a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the ongoing investigation and status of a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the specific response actions taken during a cybersecurity incident, including a specific date of action, which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes the timeline, detection, and response actions related to a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery and the company's response actions, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the scope and nature of a specific cybersecurity incident, including the type of data accessed and the number of affected users, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection and the company's immediate response actions, which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery and the nature of the event (data exfiltration), which places it squarely in Incident Disclosure.


reasoning: The paragraph provides an update on a specific, previously disclosed cybersecurity incident (the Change Healthcare cyberattack), referencing a specific date and the affected entity, which qualifies as incident disclosure.


reasoning: This paragraph is a standard legal disclaimer regarding forward-looking statements and contains no substantive cybersecurity disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph focuses exclusively on the materiality and financial impact of an incident without describing the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph describes the immediate response actions taken following a specific cybersecurity incident, which falls squarely under Incident Disclosure. It is Firm-Specific because it identifies a specific geographic location (Singapore) involved in the incident response, which is a unique fact.


reasoning: The paragraph describes the company's ongoing response actions and operational status following a previously disclosed cybersecurity incident, placing it squarely in Incident Disclosure.


reasoning: The paragraph describes the company's response actions to an unauthorized activity (incident), which fits the Incident Disclosure category. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the timeline, nature (ransomware), and impact (encryption, unauthorized disclosure) of a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the timeline and nature of a specific cybersecurity incident (data exfiltration), which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the remediation status and outcome of a previously disclosed incident, which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic.


reasoning: The paragraph describes the company's response actions to a cybersecurity incident, including containment and investigation steps, which falls under Incident Disclosure.


reasoning: The paragraph describes the status of an ongoing incident investigation, including the exfiltration of files and the evaluation of notification requirements, which falls squarely under Incident Disclosure.


reasoning: The paragraph focuses exclusively on the materiality assessment of a previously disclosed incident without describing the incident itself or providing new operational details.


reasoning: The paragraph focuses exclusively on the financial impact, costs, and materiality of the incident rather than describing the incident narrative itself.


reasoning: The paragraph provides a standalone materiality assessment regarding a cybersecurity incident without describing the incident itself, which falls under Strategy Integration.


reasoning: The paragraph describes the status of an incident (contained) and ongoing response actions, which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic.


reasoning: The paragraph focuses on the materiality of the incident and its financial impact on the company's results, which falls under Strategy Integration. While it mentions an incident, the primary purpose is to provide a materiality conclusion regarding financial condition.


reasoning: The paragraph focuses on the board's oversight responsibilities and reporting structure, which falls under Board Governance. It contains no specific facts (Audit Committee, Board of Directors, and annual reporting are all considered generic/standard per the instructions).


reasoning: The paragraph describes the integration of cybersecurity into the company's enterprise risk management program, which is a core component of risk management processes. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal process for evaluating vendors as part of their broader risk management framework. While it mentions third-party vendors, the focus is on the company's internal risk-based approach rather than specific vendor oversight standards or contractual requirements.


reasoning: The paragraph focuses on the Board/Committee's oversight role and reporting structure, which falls under Board Governance. It contains no specific facts (e.g., named committees, specific roles, or dates), making it generic boilerplate.


reasoning: The paragraph consists entirely of forward-looking disclaimers and a cross-reference to the Risk Factors section, containing no substantive disclosure regarding governance, management, or processes.


reasoning: This paragraph is a standard legal disclaimer regarding the filing status of the report and contains no cybersecurity-related information.


reasoning: The paragraph focuses on the board of directors and the audit committee's oversight role regarding cybersecurity, which falls under Board Governance. It contains no specific facts, as 'board of directors' and 'audit committee' are explicitly excluded from the specific facts list.


reasoning: The paragraph is a generic introductory statement about reliance on technology and third parties, lacking any substantive disclosure regarding specific risk management processes, governance, or incidents.


reasoning: The paragraph focuses on the qualifications and tenure of a specific cybersecurity management role, making it a clear Management Role disclosure. It contains multiple verifiable facts (years of experience, specific hire year, and a specific job title), qualifying it as Quantified-Verifiable.


reasoning: The paragraph describes oversight responsibilities, which is the primary function of board governance, and explicitly mentions a specific internal body, the 'Cybersecurity Committee'.


reasoning: The paragraph describes general internal efforts to improve cybersecurity and controls without referencing specific roles, frameworks, or unique programs, making it a standard description of risk management processes.


reasoning: This paragraph describes the professional background of an individual (Mr. Tao) and does not contain any information related to cybersecurity governance, risk management, or incident disclosure.


reasoning: The paragraph describes the company's internal risk management program and processes, which falls squarely under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph identifies a specific management role (head of the ITS Department) responsible for cybersecurity risk management, which places it in the Management Role category.


reasoning: The paragraph focuses on the Board of Directors' oversight and reporting cadence, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it explicitly names the CISO and CIO roles, which are cybersecurity-specific titles.


reasoning: The paragraph describes the general purpose of the company's cybersecurity program, which falls under internal risk management processes, but contains no specific details, frameworks, or unique identifiers.


reasoning: The paragraph describes the company's internal incident response and testing processes, which falls under Risk Management Process. It contains no specific facts (dates, named tools, named firms, or unique roles), making it generic boilerplate.


reasoning: The paragraph focuses on identifying specific management roles (CIO, Director of IT Security) and their qualifications, making it a Management Role disclosure.


reasoning: The paragraph describes the company's approach to integrating cybersecurity into its enterprise risk management program, which falls under Risk Management Process. It contains no specific facts, dates, or named frameworks, making it generic boilerplate.


reasoning: The paragraph focuses on the board of directors and the audit committee's oversight role regarding cybersecurity, which falls under Board Governance. It contains no specific facts, as 'audit committee' and 'board of directors' are considered generic governance terms per the instructions.


reasoning: The paragraph describes internal security policies and training procedures, which are core components of a company's risk management process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: This paragraph is a generic disclaimer about cybersecurity threats and vulnerabilities, which does not describe specific governance, management, processes, or incidents.


reasoning: The paragraph contains only generic statements about board and management responsibilities without referencing specific cybersecurity governance structures, roles, or processes.


reasoning: The paragraph focuses on the oversight of third-party service providers and their cybersecurity measures, making 'Third-Party Risk' the most appropriate category. It is classified as 'Firm-Specific' because it names a specific tool ('Security Scorecard') used by the company.


reasoning: The paragraph describes the specific scope and impact of a cybersecurity incident, including the types of data compromised.


reasoning: The paragraph focuses on the roles of the CSO and CISO and their reporting structure, making Management Role the primary category. It is Firm-Specific because it names a specific internal committee (Global Security Steering Committee) and cybersecurity-specific roles.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents without describing any specific event, which falls under Strategy Integration.


reasoning: The paragraph describes the company's internal risk management process and cybersecurity program in general terms without providing specific details, frameworks, or unique identifiers.


reasoning: The paragraph discusses the qualifications of the IT team, which falls under Management Role, but it contains no specific details, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes generic business services (email and cloud storage) and makes a vague, non-substantive claim about their security, which does not constitute a specific cybersecurity disclosure.


reasoning: The paragraph introduces the company's risk management approach and cybersecurity program, which falls under the Risk Management Process category. It contains no specific details, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph provides a materiality conclusion regarding the absence of cybersecurity incidents and financial impact for specific fiscal periods, which falls under Strategy Integration.


reasoning: The paragraph describes a standard step in an incident response process (eradication) without referencing a specific incident or unique company details.


reasoning: The paragraph identifies a specific cybersecurity-related role (internal cybersecurity coordinator) and describes their responsibilities and reporting lines, making it a Management Role disclosure.


reasoning: The paragraph describes general risk management activities such as threat intelligence and external assessments, which are standard components of a cybersecurity program. It contains no specific named entities, dates, or unique identifiers that would elevate it beyond boilerplate.


reasoning: The paragraph focuses on the Board's oversight and reporting cadence, making 'Board Governance' the primary category. It contains no specific facts (Audit Committee is generic, 'Cybersecurity team' is generic, and 'regular updates' is a generic cadence), resulting in a 'Generic Boilerplate' specificity rating.


reasoning: The paragraph identifies specific management roles (CFO serving as CISO) responsible for cybersecurity, making 'Management Role' the primary focus.


reasoning: The paragraph explicitly identifies the specific management roles (CIO and VP of Information Security) responsible for cybersecurity oversight, making 'Management Role' the correct category.


reasoning: The paragraph describes the company's internal process for reviewing and refining its incident response plan, which falls under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal process for monitoring cybersecurity incidents and receiving notifications, which falls under Risk Management Process. It contains no specific roles, dates, named frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight role regarding cybersecurity risks. It is classified as Generic Boilerplate because it relies entirely on generic entities (Board, Audit Committee, management) and vague cadences (regular, as necessary) without naming specific committees or roles.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents and financial impact without describing any specific incident, which falls under Strategy Integration.


reasoning: This paragraph serves as a section header and introductory boilerplate statement regarding the importance of cybersecurity, containing no substantive disclosure about processes, governance, or incidents.


reasoning: The paragraph describes standard security awareness training and phishing simulations, which are common internal risk management practices. No specific roles, dates, or unique identifiers are mentioned.


reasoning: The paragraph discusses cyber insurance as a financial mitigation strategy, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for identifying and managing cybersecurity risks, which falls squarely under Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes management roles (CFO, COO, CEO) and their responsibilities regarding cybersecurity. It is classified as Generic Boilerplate because CFO, COO, and CEO are generic C-suite roles and do not count as cybersecurity-specific roles under the provided guidelines.


reasoning: The paragraph describes the functions of cybersecurity professionals, which falls under Management Role, but it does not name specific roles (like CISO) or provide any unique identifiers, making it generic.


reasoning: The paragraph describes an internal program and team established by the company to manage cybersecurity awareness and training, which falls under Risk Management Process.


reasoning: The paragraph describes the company's internal approach to risk management and cybersecurity threats, which falls squarely under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the Board of Directors' oversight role regarding the cybersecurity program. It contains no specific facts, as 'Board of Directors' and 'quarterly/annual' cadences are considered generic/boilerplate per the instructions.


reasoning: The paragraph describes internal risk management processes, specifically training and vendor oversight, without naming specific programs, roles, or frameworks.


reasoning: The paragraph describes a standard internal security practice (employee training) without referencing specific roles, frameworks, or unique programs.


reasoning: The paragraph describes the company's internal risk management system in general terms without referencing specific frameworks, roles, or unique processes.


reasoning: This paragraph is a generic statement of intent or goal regarding cybersecurity, lacking any substantive disclosure about governance, processes, or specific incidents.


reasoning: The paragraph explicitly discusses the management of cybersecurity and the roles responsible for it, fitting the Management Role category. It contains no specific facts, named roles, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident response planning and testing procedures, which falls under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the qualifications of a specific individual and the reporting lines of key management roles (CTO and senior director of cybersecurity), which places it squarely in the Management Role category.


reasoning: The paragraph describes the company's intent to implement a process for identifying and managing cybersecurity risks, which falls under Risk Management Process. It is Firm-Specific because it references a unique internal system, 'BDTP TM'.


reasoning: The paragraph describes the company's internal cybersecurity program and incident response processes, which falls under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program and general risk management activities, which falls under Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for a specific fiscal year, which falls under Strategy Integration.


reasoning: The paragraph identifies specific management roles (Senior Director of IT) responsible for cybersecurity processes, making 'Management Role' the primary focus.


reasoning: The paragraph discusses financial recovery (insurance claims) related to an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific dates, dollar amounts, or named insurers, making it generic boilerplate.


reasoning: The paragraph describes the company's response to an ongoing incident (restoration efforts, law enforcement engagement), which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph describes the ongoing status of an incident investigation, which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph discusses the potential material impact of an incident on financial condition without describing the incident itself, which aligns with the Strategy Integration category tiebreaker for materiality conclusions.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph discusses the potential financial and operational impact of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or unique identifiers, making it Generic Boilerplate.


reasoning: The paragraph discusses cybersecurity insurance and financial coverage without describing a specific incident narrative or internal risk management process, fitting the Strategy Integration category.


reasoning: The paragraph discusses the potential financial and business impacts (litigation, insurance costs) of a cybersecurity incident without describing the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph describes the scope and impact of a previously disclosed cybersecurity incident, specifically mentioning data exfiltration and notification processes, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the operational impact of an ongoing incident and directs readers to a specific incident tracking URL, which constitutes an incident disclosure.


reasoning: The paragraph describes the company's response actions (notifying law enforcement and regulators) following an incident, which falls under Incident Disclosure. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: This paragraph discusses legal waivers related to credit and lease agreements, which is standard legal boilerplate and does not pertain to cybersecurity governance, risk management, or incident disclosure.


reasoning: The paragraph discusses the materiality and potential financial/operational impact of an incident without describing the incident itself, which aligns with the Strategy Integration category.


reasoning: This paragraph describes executive leadership changes at a subsidiary, which is a corporate governance matter unrelated to cybersecurity disclosures.


reasoning: The paragraph describes a specific cybersecurity incident involving a third-party provider, including dates of notification and confirmation, which qualifies as an incident disclosure.


reasoning: The paragraph discusses the financial impact (insurance recovery) of an incident without describing the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph describes specific response actions taken in relation to a disclosed cybersecurity incident, fitting the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, resulting in a Generic Boilerplate classification.


reasoning: The paragraph describes the status of an incident (containment and restoration), which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph discusses the materiality of an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph describes the status of an ongoing cybersecurity incident, including the investigation and the involvement of insurance, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the status of an ongoing incident (containment and restoration), which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the status of an ongoing investigation into a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: While the paragraph mentions an incident, the primary substantive point is the materiality conclusion regarding financial condition, which triggers the Strategy Integration category per the tiebreaker rules.


reasoning: The paragraph describes the operational impact and current status of an ongoing cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph provides a standalone materiality assessment regarding a cybersecurity incident without describing the incident itself or providing specific details.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph discusses the materiality of an incident without providing any details about the incident itself, which falls under Strategy Integration.


reasoning: The paragraph describes the status of an ongoing investigation into a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic.


reasoning: The paragraph discusses the materiality of an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or entities, making it generic boilerplate.


reasoning: The paragraph discusses the ongoing monitoring of materiality regarding an incident without describing the incident itself, which aligns with the tiebreaker rule for Strategy Integration.


reasoning: The paragraph describes the nature of an ongoing cybersecurity incident (unauthorized access, data exfiltration, and encryption), which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, rendering it generic.


reasoning: The paragraph discusses the potential financial impact and materiality of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence and the company's immediate response actions, which places it squarely in Incident Disclosure.


reasoning: The paragraph describes a specific response action (mailing notification letters) taken in the context of an ongoing incident investigation, which falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence and the company's immediate response actions, which places it squarely in the Incident Disclosure category.


reasoning: The paragraph provides an update on the status of a previously disclosed cybersecurity incident, including remediation efforts and the conclusion of an investigation, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the occurrence of a specific cybersecurity incident, including the date of discovery, which classifies it as an Incident Disclosure.


reasoning: The paragraph describes the nature of a cybersecurity incident (unauthorized access to systems containing personal information) and the company's response actions, which fits the Incident Disclosure category.


reasoning: The paragraph describes the operational impact of an ongoing cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named systems, or other verifiable facts, making it generic.


reasoning: The paragraph describes the cause and nature of a specific cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph discusses the financial/operational impact of an incident without providing a narrative of the event itself, which aligns with the Strategy Integration category. It contains no specific dates, dollar amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph describes actions taken in response to an ongoing cybersecurity incident, specifically the creation of a dedicated communication channel, which falls under incident disclosure.


reasoning: The paragraph provides a materiality assessment regarding a cybersecurity incident without describing the incident itself, which falls under Strategy Integration. It is Firm-Specific because it references a specific fiscal period (fourth quarter of 2023).


reasoning: The paragraph discusses the materiality and financial impact of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph describes the operational impact and duration of a specific cybersecurity incident, which falls under Incident Disclosure.


reasoning: The paragraph discusses the materiality of an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes response actions taken in relation to a specific incident (unauthorized access), which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic.


reasoning: The paragraph describes operational response actions taken during an ongoing incident, which falls under Incident Disclosure. It contains no specific dates, named tools, or other verifiable facts, making it generic.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of notification and the company's immediate response actions, which fits the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident (attempted fraud) and provides the date of detection, which qualifies as an incident disclosure.


reasoning: The paragraph references an ongoing cybersecurity incident and the company's response actions, specifically regarding the restoration of systems, which falls under Incident Disclosure.


reasoning: The paragraph describes the company's internal processes for evaluating incidents, escalation procedures, and specific internal programs (Incident Response Program, Business Continuity Plan), making it a Risk Management Process disclosure.


reasoning: This paragraph is a standard risk factor disclosure describing general cybersecurity threats and potential consequences, without detailing specific governance, management, or internal processes.


reasoning: The paragraph details the company's internal cybersecurity processes, including threat assessment, layered security, and training, which falls squarely under Risk Management Process. While it mentions specific frameworks like NIST, ISO, and SOC, it lacks unique firm-specific identifiers like named tools, specific dates, or unique internal program names.


reasoning: The paragraph explicitly defines a specific internal management team ('Risk Management Team') and names specific roles (Sr. Director of IT) responsible for cybersecurity oversight, making 'Management Role' the primary focus.


reasoning: The paragraph primarily describes the company's internal processes for managing cybersecurity, including team structure, monitoring, and vendor assessment procedures. While it mentions third-party providers, the central topic is the company's own internal risk management and oversight processes.


reasoning: The paragraph focuses primarily on the Board and its Risk Committee's oversight responsibilities regarding cybersecurity, making 'Board Governance' the most appropriate category.


reasoning: The paragraph focuses primarily on the roles, responsibilities, and professional backgrounds of the CISO and CTO, making 'Management Role' the most appropriate category.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity risks for the fiscal year, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year (fiscal 2024) in the context of its materiality assessment.


reasoning: The paragraph focuses on the specific roles (IT Manager, General Counsel, IT Steering Committee) responsible for administering the cybersecurity program and their qualifications, making 'Management Role' the primary category. It qualifies as 'Quantified-Verifiable' because it contains multiple specific durations of experience (10, 16, 12, and 20 years) and names specific internal programs/committees.


reasoning: The paragraph describes the company's internal risk management processes, including security controls, awareness training, and monitoring, making 'Risk Management Process' the most applicable category. It is classified as 'Sector-Adapted' because it explicitly references the NIST CSF framework but lacks other firm-specific details like named tools, specific dates, or unique internal program names.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and regulatory compliance. While it mentions specific regulators, these are standard for a financial institution and do not constitute unique internal cybersecurity program details or specific verifiable facts about their internal processes.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as incident response planning, technical safeguards, and employee training, without naming specific tools, frameworks, or unique identifiers.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including the adoption of the NIST framework and the specific management roles responsible for oversight.


reasoning: This paragraph is a general description of the company's reliance on IT infrastructure and a standard list of potential cyber threats, which constitutes boilerplate risk disclosure rather than a specific description of governance, management, or internal processes.


reasoning: The paragraph outlines the company's overall cybersecurity program and internal risk management framework, making 'Risk Management Process' the most appropriate category. It is classified as 'Firm-Specific' because it identifies specific cybersecurity roles (CIO, Global Head of IT Security) unique to the company's organizational structure.


reasoning: The paragraph focuses on the identification and qualifications of the cybersecurity team (vCISO, analysts, etc.), which falls under Management Role. It contains multiple verifiable facts, including specific job titles, years of experience, and professional certifications.


reasoning: This paragraph is a standard, generic risk factor disclosure describing potential cybersecurity threats and their potential impacts without referencing any specific internal processes, governance, or actual incidents.


reasoning: The paragraph primarily describes the company's internal risk management processes, including the use of specific frameworks and internal plans (IRP, BCP, Disaster Recovery Plan) to manage cybersecurity risks.


reasoning: The paragraph describes the company's internal cybersecurity tools (EDR, SIEM, firewalls) and operational processes (incident reporting, threat detection strategy), which falls squarely under Risk Management Process. It is classified as Firm-Specific because it includes a specific strategic timeline ('strategy for 2025'), which is a unique fact about this company's disclosure.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including monitoring, training, and policy development. It contains no specific dates, named tools, named third-party firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph primarily describes the company's internal cybersecurity program, processes, and risk management strategies, making 'Risk Management Process' the most applicable category. It mentions a specific certification (CISSP), which qualifies it as Sector-Adapted, but lacks sufficient unique firm-specific facts or multiple verifiable facts to reach a higher specificity level.


reasoning: The paragraph outlines the company's internal cybersecurity program and risk management framework, including specific roles and cross-functional teams involved in the process.


reasoning: The paragraph discusses the potential business and financial impact of cybersecurity risks and includes a standalone materiality conclusion regarding past incidents, which aligns with Strategy Integration. It contains no specific facts, roles, or frameworks, making it generic boilerplate.


reasoning: The paragraph details the company's internal cybersecurity risk management strategy, including the use of specific frameworks and internal oversight structures.


reasoning: The paragraph describes the company's internal incident response and risk management processes, specifically naming their internal 'Agility Plan' and 'Crisis Management Team'.


reasoning: The paragraph describes the company's internal cybersecurity program, including incident response, technical safeguards, and risk management processes, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses primarily on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity, which aligns with the Board Governance category. It contains no specific facts, named cybersecurity roles, or unique identifiers, rendering it generic boilerplate.


reasoning: The paragraph focuses on identifying specific management roles (CISO, CIO, CDO) and their qualifications, which is the primary subject of the text.


reasoning: The paragraph describes general cybersecurity threats and provides a cross-reference to the Risk Factors section, which is standard boilerplate language for 10-K filings.


reasoning: The paragraph primarily focuses on the Board of Directors and the Risk Committee's oversight responsibilities regarding cybersecurity, making Board Governance the most appropriate category.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents for the fiscal year, which falls under Strategy Integration. It is Firm-Specific because it includes a specific fiscal year-end date.


reasoning: The paragraph describes the company's internal processes for monitoring, incident response, and risk management, including the use of a specific internal program (Cybersecurity Incident Response Plan).


reasoning: The paragraph describes the company's internal cybersecurity measures, processes, and policies, which falls squarely under Risk Management Process. It contains no specific dates, named third-party firms, named products, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the qualifications and responsibilities of the Chief Technology Officer and the internal committee structure, which falls under Management Role. It contains multiple verifiable facts, including specific certifications, years of experience, and named internal committees/programs.


reasoning: The paragraph describes the company's internal risk assessment program and general cybersecurity threats, which falls under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses primarily on the qualifications, responsibilities, and reporting lines of the Chief Information Officer, making Management Role the most appropriate category.


reasoning: The paragraph describes the internal risk management processes of the manager (USCF) regarding cybersecurity and third-party oversight. While it mentions third-party service providers, the central topic is the implementation of the manager's own information security program and risk assessment procedures, making 'Risk Management Process' the most appropriate category.


reasoning: The paragraph primarily describes the company's internal risk management processes, including monitoring, vendor assessments, and framework adoption. While it mentions third-party risk, it is framed as a component of the broader internal risk management program, and the mention of the 'Information Security Risk Committee' makes it firm-specific.


reasoning: The paragraph focuses on the company's internal cybersecurity and technology risk management program, policies, and frameworks. While it mentions third-party vendors, it does so as a component of the internal risk management process rather than as the central topic.


reasoning: The paragraph explicitly identifies specific management roles (CISO, CIO, CTO) and details their qualifications, making 'Management Role' the primary focus despite the mention of monitoring processes and board reporting.


reasoning: The paragraph focuses on the roles, responsibilities, and qualifications of the CISO and CCO, making 'Management Role' the correct category. It contains multiple quantified facts (years of experience) and specific certifications/degrees, meeting the threshold for 'Quantified-Verifiable'.


reasoning: The paragraph describes the company's internal security measures, tools, and risk management processes, which falls squarely under Risk Management Process. It contains no specific dates, named products, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph serves as an introductory overview of the company's general approach to cybersecurity risk management and strategy, without detailing specific processes, roles, or incidents.


reasoning: The paragraph consists entirely of definitions of cybersecurity terms and a cross-reference to another section of the filing, containing no substantive disclosure about the company's specific governance, management, or processes.


reasoning: The paragraph primarily describes the company's internal incident response processes and risk management framework, with roles mentioned as part of that process. While it mentions specific roles and frameworks, it does not reach the threshold of two hard verifiable facts (like specific dates or dollar amounts) required for Quantified-Verifiable.


reasoning: The paragraph primarily describes the company's internal processes for risk assessment, incident management, and monitoring, which falls under Risk Management Process. While it mentions third-party providers, they are discussed as a component of the broader internal risk management strategy rather than the central topic.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and oversight without naming specific frameworks, roles, or unique programs, making it a generic description of internal processes.


reasoning: While the paragraph mentions board oversight, the core of the disclosure focuses on the specific management role (Director of IT) responsible for the cybersecurity program and the reporting structure, making Management Role the most applicable category.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment approach, and monitoring functions, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it names specific internal roles (CIO, CISO) and a specific internal unit (SOC) involved in the process.


reasoning: The paragraph describes the company's internal approach to managing cybersecurity risks, including the implementation of an Information Security Program and various monitoring/assessment controls. While it mentions a committee and third-party risk management, these are described in generic, non-specific terms without naming the committee or specific tools/firms, making it a description of internal processes.


reasoning: The paragraph primarily describes the company's internal processes for managing cybersecurity risks, including vendor reviews and incident response protocols, rather than focusing exclusively on third-party oversight or a specific incident.


reasoning: The paragraph details the company's internal cybersecurity strategy, processes, and specific internal programs (ICSIRP), which falls squarely under Risk Management Process.


reasoning: The paragraph focuses on identifying the specific management personnel responsible for cybersecurity oversight and details their qualifications, which falls squarely under Management Role.


reasoning: The paragraph describes the company's internal incident response plan and testing procedures, which falls squarely under Risk Management Process. It contains no specific facts (dates, named firms, named tools, or unique identifiers), relying entirely on generic descriptions of standard cybersecurity practices.


reasoning: The paragraph primarily describes the company's internal security programs, incident reporting structures, and risk management processes, making 'Risk Management Process' the most applicable category. It is classified as 'Firm-Specific' because it identifies specific cybersecurity roles (CISO, CIO) involved in these processes.


reasoning: The paragraph focuses primarily on the reporting lines, responsibilities, and activities of the CIO and CISO, which places it squarely in the Management Role category despite the mention of board oversight.


reasoning: The paragraph describes the company's internal security measures and risk management processes. It contains no specific dates, named tools, named third-party firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal vendor management program and risk assessment processes. While it mentions third-party providers, the focus is on the company's internal process for managing those risks, rather than specific vendor oversight or contractual standards.


reasoning: The paragraph focuses on the materiality of cybersecurity risks and incidents, including a statement about the lack of material impact in 2023 and references to insurance coverage, which aligns with Strategy Integration.


reasoning: The paragraph primarily describes the company's internal processes for incident response and risk management, including the use of a Disaster Recovery Plan and the Crisis Management Team. While it mentions the CIO and CMT, these are organizational details that support the description of the risk management process rather than defining the management role itself.


reasoning: The paragraph focuses on the CIO's responsibilities and qualifications, making 'Management Role' the primary category. While it mentions third-party risk and internal processes, these are secondary to the description of the management role and the specific qualifications of the CIO.