reasoning: The paragraph focuses on the Board's delegation of cybersecurity oversight to the Audit Committee and the Committee's review processes, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies a specific management role (CTO) involved in these reviews.


content_category: None/Other

category_confidence: high

specificity_confidence: high

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

provider: google


content_category: Incident Disclosure

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


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the scope of affected accounts, the perpetrator's actions, and the company's response (compensation program), which fits the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence, the nature of the event (website defacement), response actions taken, and specific operational impacts like the cancellation of a seminar.


content_category: Risk Management Process

reasoning: The paragraph describes the company's current state regarding cybersecurity risk management processes (or lack thereof), which falls under the Risk Management Process category.


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 describes a specific cybersecurity incident, including the date of the threat communication, the nature of the threat, the method of unauthorized access, and the company's response actions.


content_category: Strategy Integration

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


reasoning: The paragraph primarily describes the company's internal process for conducting audits, risk assessments, and remediation, making 'Risk Management Process' the most appropriate category. It is classified as 'Firm-Specific' because it identifies specific internal roles (Chief Financial and Administrative Officer, Vice President of Risk Management) involved in the oversight process.


content_category: Management Role

reasoning: The paragraph focuses primarily on the roles and reporting lines of the CISO, CIO, and CTO, making 'Management Role' the most appropriate category despite the mention of board oversight.


reasoning: The paragraph consists entirely of generic, boilerplate language describing cybersecurity threats and risks without detailing the company's specific internal processes, governance, or incidents.


reasoning: The paragraph describes the responsibilities of senior management regarding cybersecurity risk appetite, making 'Management Role' the primary category. It contains no specific roles, dates, or unique identifiers, resulting in a 'Generic Boilerplate' specificity rating.


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


reasoning: The paragraph describes the company's internal risk management procedures and policies, 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 a standard internal security practice (security awareness training) without naming specific programs, tools, or unique identifiers, making it a generic description of a risk management process.


reasoning: The paragraph explicitly identifies the 'Software Engineer' as a key role responsible for cybersecurity, making 'Management Role' the most appropriate category.


reasoning: The paragraph focuses on the qualifications and experience of specific cybersecurity management roles (CISO and VP of Information Security), making 'Management Role' the correct category.


reasoning: The paragraph consists entirely of high-level, aspirational statements about safety and cybersecurity importance without describing specific governance, management roles, processes, or incidents.


reasoning: The paragraph describes internal operational processes and cross-departmental collaboration for risk management. It contains no specific facts, named cybersecurity roles, or unique identifiers, relying on generic organizational terminology.


content_category: Board Governance

reasoning: The paragraph focuses on the oversight responsibilities of the board-level Risk Committee, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it names a specific committee (Risk Committee), a specific role (Chief Risk Officer), and a specific internal program (Cybersecurity Incident Response Plan).


reasoning: The paragraph explains that the company is a blank check company with no operations and therefore does not have a cybersecurity program, which constitutes a disclaimer rather than a substantive disclosure of governance, management, or risk processes.


reasoning: The paragraph describes the company's internal approach to managing cybersecurity risk by utilizing various types of third-party service providers, which falls under the company's risk management process rather than vendor oversight.


reasoning: The paragraph describes the company's internal procedures for investigating and responding to cybersecurity threats, including the involvement of the ISC, which is a Risk Management Process.


reasoning: The paragraph focuses entirely on the Audit Committee's oversight role regarding cybersecurity risks and incident communication, making 'Board Governance' the primary category. It contains no specific facts (Audit Committee is explicitly excluded from the 'IS' list, and 'management' is generic), resulting in a 'Generic Boilerplate' specificity rating.


reasoning: The paragraph describes the company's internal incident response plan and procedures, which falls under Risk Management Process. It contains no specific facts, named roles (CEO is excluded per instructions), or unique identifiers, making it generic boilerplate.


content_category: Third-Party Risk

reasoning: The paragraph focuses exclusively on the company's oversight and assessment processes for third-party service providers, making 'Third-Party Risk' the appropriate category.


reasoning: The paragraph explicitly discusses the company's internal risk management processes (or lack thereof), which falls under the Risk Management Process category.


reasoning: The paragraph describes internal security training and awareness programs, which are standard components of a risk management process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: This paragraph consists entirely of forward-looking disclaimers and general statements about the limitations of security controls, which does not constitute substantive disclosure regarding governance, management, or specific processes.


reasoning: The paragraph focuses on the board of directors' oversight role and their interaction with management regarding cybersecurity risk profiles, making 'Board Governance' the primary category. It contains no specific facts, named committees, or unique identifiers, resulting in a 'Generic Boilerplate' specificity rating.


reasoning: The paragraph describes the company's internal risk management objectives and processes. It is classified as Firm-Specific because it names a specific internal body (Technology Leadership Centre) and a specific role (Chief Technology Officer) involved in the process.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents and references risk factors, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses entirely on the Board of Directors' oversight responsibilities regarding cybersecurity and data privacy, making 'Board Governance' the correct category. It contains no specific facts, named committees, or unique identifiers, resulting in a 'Generic Boilerplate' specificity rating.


reasoning: The paragraph describes internal security practices like vulnerability management and incident response planning, which falls under Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program, governance structure, and risk management processes. While it mentions governance and third-party risk, these are presented as components of the overarching internal risk management framework, making 'Risk Management Process' the most appropriate category.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats without describing any specific incident or process, which falls under Strategy Integration.


reasoning: The paragraph identifies specific management roles (Chief Information Officer, Director of IT) responsible for cybersecurity, which aligns with the Management Role category.


reasoning: This paragraph consists entirely of generic disclaimers about the limitations of security controls and risk management, offering no substantive disclosure regarding the company's specific governance, processes, or incidents.


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


reasoning: The paragraph explicitly identifies specific management roles (CISO, VP of IT, Chief Compliance and Privacy Officer) responsible for cybersecurity oversight, which aligns with the Management Role category.


reasoning: The paragraph focuses on the composition and responsibilities of specific management-level committees (Cybersecurity Executive Council and Cybersecurity Compliance Committee) and roles (CISO), making 'Management Role' the most appropriate category.


reasoning: The paragraph focuses on the due diligence and contractual requirements imposed on vendors, which is the definition of Third-Party Risk. It is Firm-Specific because it names 'PSCM' as the entity performing these actions.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the Head of Cybersecurity, making Management Role the primary category. It is Firm-Specific because it identifies a specific cybersecurity-specific role ('Head of Cybersecurity'), which is on the 'IS' list.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities regarding cybersecurity, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it names a specific cybersecurity role (CISO) and a specific internal program (Cybersecurity Incident Response Plan).


reasoning: The paragraph describes internal risk management activities (engaging third parties for evaluation and exercises) rather than focusing on vendor oversight as a central risk or governance/management roles. It contains no specific facts, named entities, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident response and vulnerability management procedures, which is the core definition of Risk Management Process. The roles and committees mentioned are generic and do not meet the criteria for specific facts.


reasoning: The paragraph describes the company's internal monitoring and vulnerability management processes, which falls under Risk Management Process. It is Firm-Specific because it references 'OCC regulatory exams', which is a specific regulatory body relevant to the company's operations, rather than just generic audit language.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment methodologies, and operational security controls (e.g., network segmentation, patch management), which falls squarely under Risk Management Process. It contains no specific dates, named third-party firms, named products, or specific cybersecurity roles, making it generic boilerplate.


reasoning: The paragraph identifies specific management roles (CIO, CTO, Information Security Officer) and describes their responsibilities, which aligns with the Management Role category.


reasoning: The paragraph describes internal security practices like penetration testing and vendor review processes, which are standard components of a risk management program. No specific facts (dates, named firms, named tools) are provided, and 'leadership' and 'third-party audit' are generic terms.


reasoning: The paragraph describes the company's internal enterprise risk management (ERM) process and how it identifies and monitors cybersecurity risks, which is the core definition of Risk Management Process.


reasoning: The paragraph describes the company's internal risk assessment and mitigation processes, including the adoption of the CIS framework.


reasoning: The paragraph describes the company's general internal processes for risk management and security controls without naming specific frameworks, roles, or unique programs. While it mentions a third-party security program, it does so as a component of the company's overall risk management approach rather than focusing on specific vendor oversight or contractual standards.


reasoning: The paragraph describes general internal security measures (firewalls, anti-malware) which are standard components of a company's risk management process, but it lacks any specific details or unique identifiers.


reasoning: The paragraph describes the company's internal risk management processes and frameworks. It is classified as Firm-Specific because it claims specific certifications (HITRUST and SOC 2 Type II), which are verifiable facts unique to the company's security posture.


reasoning: The paragraph focuses on the specific roles (SVP/IT Manager and ISO) responsible for cybersecurity and details their qualifications, making it a Management Role disclosure.


reasoning: The paragraph describes general risk management activities like penetration testing and information sharing, but lacks any specific names, dates, or unique identifiers that would elevate it beyond boilerplate.


reasoning: The paragraph focuses on the roles and qualifications of the CCO and CISO, making 'Management Role' the appropriate category. It qualifies as 'Quantified-Verifiable' because it contains multiple specific dates and quantified years of experience.


reasoning: The paragraph focuses on the specific roles (Cybersecurity Incident Manager, VP Security) and their responsibilities in the incident response and materiality assessment process, making Management Role the primary category.


reasoning: The paragraph focuses on the company's approach to third-party procurement and contracting, which falls under Third-Party Risk. It contains no specific facts, named entities, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses exclusively on the risks posed by third-party service providers and the company's reliance on them, which is the central topic of Third-Party Risk.


reasoning: The paragraph focuses on the CISO's qualifications, reporting lines, and responsibilities, making 'Management Role' the primary category. It is Firm-Specific because it identifies the CISO role and specific experience duration, though it does not reach the threshold of two independent verifiable facts (e.g., named third-party firms or specific dates).


reasoning: The paragraph focuses on the reporting responsibilities and activities of the Senior Director of Information Technology, which is a cybersecurity-specific role, making 'Management Role' the primary category.


reasoning: The paragraph focuses on the leadership of the Information Security Department, specifically identifying the CIO and their reporting lines and responsibilities, which aligns with the Management Role category.


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


reasoning: The paragraph focuses on the responsibilities of 'executive management' regarding cybersecurity oversight, which falls under the Management Role category. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including assessments, policies, and controls, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it explicitly references the NIST framework but lacks other firm-specific or verifiable facts.


reasoning: The paragraph focuses on the composition, leadership, and function of the 'Cybersecurity Council,' which is a management-level body. While it mentions the Board, the primary subject is the Council's internal management role and its specific membership.


reasoning: The paragraph focuses on the oversight responsibilities of the Technology Committee, which is a board-level committee, making it a clear example of Board Governance.


reasoning: The paragraph is a standard forward-looking disclaimer regarding potential cybersecurity risks and contains no substantive disclosure about governance, processes, or specific incidents.


reasoning: The paragraph discusses the company's internal approach (or lack thereof) to risk assessment processes, which falls under Risk Management Process. It contains no specific facts, roles, or frameworks, making it generic boilerplate.


reasoning: The paragraph explicitly defines the responsibilities of a specific management role (VP of IT and Facilities) regarding cybersecurity, making it a clear Management Role disclosure.


reasoning: The paragraph describes internal security training and policy review processes, which falls under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph outlines the internal procedural steps for assessing and escalating potential cybersecurity incidents, which falls under Risk Management Process. It qualifies as Quantified-Verifiable because it names a specific internal committee and a cybersecurity-specific role (CTO).


reasoning: The paragraph focuses on the oversight responsibilities of the Audit Committee and the Board of Directors regarding cybersecurity. It contains no specific facts, named cybersecurity roles, or unique programs, relying entirely on generic governance terminology.


reasoning: The paragraph outlines the company's internal cybersecurity risk management and mitigation strategies, which falls under Risk Management Process, and contains no specific details, named frameworks, or unique identifiers.


reasoning: The paragraph describes the company's general approach to monitoring threats and mitigating risks, which falls under internal risk management processes. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident response process and governance structure. While it lists several C-suite roles, these are generic and do not qualify as cybersecurity-specific roles or firm-specific facts according to the provided guidelines.


reasoning: The paragraph describes general internal processes for threat monitoring, testing, and response without naming specific tools, frameworks, or roles, making it a description of the company's risk management process.


reasoning: The paragraph describes standard internal security procedures such as monitoring, backups, and physical protection, which are core components of a risk management process. It contains no specific frameworks, named tools, or unique identifiers that would elevate it beyond generic boilerplate.


reasoning: The paragraph focuses on the CISO's reporting lines and interactions with a specific committee (IOC), making 'Management Role' the most appropriate category. It is classified as 'Firm-Specific' because it names a specific committee and a specific internal team structure, but lacks the two hard verifiable facts required for 'Quantified-Verifiable'.


category_confidence: low

reasoning: The paragraph is forward-looking boilerplate about potential cybersecurity risks and impacts, with no description of the company’s specific internal processes or oversight, and no incident narrative or named roles/standards.

provider: openai


reasoning: The paragraph is primarily boilerplate about cyber risk not having materially affected the company to date and directs readers to another section (Part 1, Item 1A). It does not describe an incident or provide firm-specific governance/process details.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment and management processes and how they integrate into enterprise risk management. It does not disclose an incident or provide firm-unique facts such as named roles, tools, dates, or standards.


reasoning: The paragraph is explicitly about the Board’s oversight, reporting, and annual discussions on cybersecurity risk management. It does not name any specific cybersecurity roles, committees, internal programs, dates, standards, or tools unique to FPI.


specificity_confidence: medium

reasoning: The paragraph describes the company’s internal process for identifying, assessing, and managing cybersecurity threats (team composition, monitoring, scans, and assessments). Although it mentions third-party IT service providers, the central subject is the company’s risk management approach rather than vendor security requirements.


reasoning: This paragraph centers on the Information Security Officer’s role, reporting line to the Chief Risk Officer, responsibilities, and qualifications, which is characteristic of management-role disclosure rather than describing incident events or internal risk processes independently.


category_confidence: medium

reasoning: The paragraph centers on how the company conducts cybersecurity risk assessment and safeguards management, including using third parties to help design/implement/monitor/testing its policies. While it mentions security requirements for providers, they are part of the company’s internal risk management process rather than a standalone third-party oversight program.


reasoning: This paragraph is a cross-reference to risk factors (Item 1A) and contains no substantive description of cybersecurity governance, incidents, or internal risk-management processes beyond generic forward-referencing language.


reasoning: The paragraph describes the company’s own information security programs and risk management objectives (confidentiality/integrity/availability, access limits, identify/protect/detect/respond/recover). It is aligned to ISO and NIST frameworks, but contains no firm-unique details beyond those named standards.


reasoning: The paragraph centers on the Audit Committee’s oversight responsibilities and reporting flows for cybersecurity risk (board-level governance focus). It also includes firm-specific committee and role references (ERM Committee and CIO), making it more than generic boilerplate.


reasoning: The paragraph describes Emergent’s internal cybersecurity program integration into its Enterprise Risk Management Program, including risk assessment (ERA), risk acceptance/mitigation, monitoring, and reporting cadence to leadership and the Board.


reasoning: The paragraph centers on the Board of Directors’ oversight responsibilities for cybersecurity risk, including assessments, reviews, and regular information sharing with the Board by the HSE Director.


reasoning: The paragraph describes the Company’s internal risk management and information security processes (ERM integration, policies/standards/processes, and review by the CISO) rather than a disclosed incident or third-party oversight.


reasoning: The paragraph is explicitly about board/committee oversight of cybersecurity risk and describes reporting to the Audit Committee from specific roles.


reasoning: The paragraph describes Alternus’s internal approach to identifying, assessing, monitoring, and incorporating cybersecurity risks into its information security policy and enterprise risk management process. While it mentions external firms, vendor engagement is not the central focus; it is one component of the company’s own risk management process.


reasoning: The paragraph is primarily forward-looking and risk-factor boilerplate about potential cybersecurity risk and effectiveness of controls. It does not describe an incident, identify roles/frameworks, or include firm-unique, verifiable cybersecurity details.


reasoning: The paragraph is centered on the Audit Committee and Board oversight of cybersecurity risks and reporting/briefing activities; however, it uses generic placeholders (Audit Committee, quarterly/periodic) without any firm-specific dates, named roles beyond standard entities, or tools/frameworks.


reasoning: The paragraph describes the company’s internal cybersecurity risk identification and assessment activities (threat intelligence review, control evaluation, and mitigation) as part of its risk management system, including how it addresses third-party provider-related cyber risks.


reasoning: The paragraph describes the company’s internal procedures for notifying roles, investigating, assigning risk levels, escalating, and reporting high-risk incidents. It focuses on ARROWHEAD’s cybersecurity risk management workflow rather than an incident that actually occurred.


reasoning: The paragraph describes board-level oversight of cybersecurity risk by the Audit Committee and how it engages management (including the CIO and CISO) on cybersecurity topics, which is classic board governance.


reasoning: The paragraph describes ABERCROMBIE & FITCH CO’s internal cybersecurity control development, risk assessments, and how risks are evaluated and prioritized to update its security programs. It is not an incident description or a board/management role statement, and third parties are mentioned only as part of internal assessment activity.


reasoning: The paragraph describes the company’s own cybersecurity risk management activities (incident response plan scope, testing/training, mitigation measures, monitoring/reporting, and annual risk assessments including threat modeling and vulnerability scanning). It does not disclose a specific incident, vendor oversight, board/committee governance, or named personnel/frameworks with firm-specific identifiers.


reasoning: The paragraph describes the Trustee’s own cybersecurity risk management program and protocols (identify/assess/manage/mitigate/respond, and integration into overall risk management), including an annual assessment. It does not narrate an incident or focus primarily on board/committee oversight or a named third-party/vendor/security product.


reasoning: The paragraph centers on board and Audit Committee oversight of cybersecurity risk, including creation and charter requirements for a named subcommittee.


reasoning: This paragraph is centered on identifying the company’s cyber-security leader (CDIO/CISO), their reporting line, tenure, prior experience, and briefing/participation with a named committee (TCRC). Those are management-role details rather than an incident or an internal risk process description.


reasoning: The paragraph describes the company’s own internal cybersecurity preparedness and program elements (incident response plan, tabletop exercises, business continuity/disaster recovery, and risk-based selection of controls). It is forward-looking and does not include incident-specific disclosure or named firm-specific programs/roles beyond generic statements, so it fits Risk Management Process at a generic level.


reasoning: The paragraph primarily makes generalized materiality/impact statements about prior and potential cybersecurity incidents without describing any specific incident details (what happened, scope, systems, or response). It concludes that incidents have not materially affected results and that there is no reasonably likely risk based on currently available information, which fits strategy/financial impact integration rather than incident disclosure or internal risk-process specifics.


reasoning: The paragraph describes the company’s internal cybersecurity detection/response processes, monitoring data sources, and testing approach. It is focused on the company’s risk management practices rather than an actual disclosed incident narrative or centralized third-party vendor requirements.


reasoning: The paragraph primarily describes the board and its audit committee providing oversight for cybersecurity risks and reporting to the full board. While it also mentions management responsibilities, the governance/oversight structure is the dominant subject.


reasoning: The paragraph describes the company’s own cybersecurity and incident response processes (vulnerability/risk management, incident response planning, and role responsibilities), rather than an incident disclosure or purely vendor-centric oversight. It also explicitly references the NIST framework and 24/7/365 monitoring.


reasoning: The paragraph focuses on onboarding and managing security obligations for third-party providers/vendors (security standards assessment, required contractual security terms, and vendor adherence to incident notification, encryption, and data disposal). It is therefore best categorized as Third-Party Risk rather than the company’s internal risk management process.


reasoning: The paragraph is explicitly framed around the Board of Directors and its Audit Committee overseeing cybersecurity risk reporting to the board, making Board oversight the grammatical and substantive focus.


reasoning: The paragraph describes the company’s internal cybersecurity risk management activities (assessments, monitoring metrics, and an internal response/notification plan) and how they are governed, rather than narrating a specific incident. While it mentions escalation to board-level committees, the core focus is the firm’s processes and procedures for preventing, detecting, mitigating, and remediating incidents.


reasoning: The paragraph primarily describes specific management roles and their responsibilities/reporting lines (VP, IT Data Security; CTO; Information Security department), with board oversight mentioned in support context. The named Cybersecurity Committee further supports that this is governed by specific management/committee structures rather than incident/process-only risk management.


reasoning: The paragraph is centered on specific cybersecurity leadership roles (the Director) and their responsibilities/reporting and associated oversight activities, rather than describing the company’s risk processes in isolation.


reasoning: The paragraph describes the company’s internal cybersecurity incident detection and response program and how it is reviewed and exercised, which is an internal risk management process. It explicitly references the NIST Cybersecurity Framework (NIST CSF) but contains no incident narrative or firm-unique operational details beyond that framework.


specificity_confidence: low

reasoning: The paragraph focuses on potential business/financial impact (materiality) and references costs/breaches without describing any actual incident. It also provides a general process statement but the dominant content is strategy/financial impact and materiality disclosure, not an incident narrative.


reasoning: The paragraph describes OFS Advisor/IT Department cybersecurity risk management policies and procedures (controls, vulnerability management, due diligence/monitoring, risk assessments) and how they are informed by a named framework (NIST). It is not centered on a specific incident, board committee, or a named CISO/CIO.


reasoning: The paragraph describes the company’s internal cybersecurity training and preparedness activities as part of its risk management approach. It does not name any firm-specific roles, programs, dates, tools, frameworks, or quantified details.


reasoning: The paragraph describes the Company’s internal cybersecurity program, including controls and processes (e.g., monitoring, incident response policies, access controls, assessments) to mitigate cyber risk. The only firm-specific fact is the claim that the Company maintains ISO 27001 certification, while other mentions (NIST, GDPR, controls) are not uniquely identifying in this context.


reasoning: The paragraph is focused on how the Board and specifically the Audit Committee oversee cybersecurity risk and receive incident updates, making board governance the grammatical and substantive subject.


reasoning: The paragraph is centered on the CISO as the responsible party for cybersecurity risk and describes the CISO’s qualifications and responsibilities, making it a management-role disclosure rather than a process or incident description.


reasoning: The paragraph primarily describes the company’s CISO and Information Security team leadership, including qualifications, certifications, education, and reporting lines, which are management-role details rather than an incident or internal process description.


reasoning: The paragraph narrates a past cybersecurity incident (unauthorized access and downloading), provides response/changes made afterward, and includes incident-specific details about affected user accounts and systems.


reasoning: The paragraph centers on the cybersecurity role (CISO) and describes the CISO’s leadership of the Information Security Council, plus the CISO’s experience and certifications. It is primarily about the management role responsible for cybersecurity risk management rather than the company’s incident or a stand-alone internal risk process.


reasoning: The paragraph centers on a materiality conclusion that cybersecurity risks did not materially affect (and are not reasonably anticipated to materially affect) the company’s strategy, results, or financial condition, with no incident scope/details. That makes it primarily Strategy Integration.


reasoning: The paragraph centers on board and Audit Committee oversight of the company’s cybersecurity program. It also states the cybersecurity approach is based on the NIST Cybersecurity Framework, which makes the disclosure sector-standard rather than company-specific.


reasoning: The paragraph describes the company’s internal risk management process through its ERM committee and how it incorporates information security action plans into risk decision-making. Named cybersecurity roles (CISO, CDO) and the ERM committee indicate firm-specific internal governance of cyber risk, rather than an incident, third-party oversight, or board-only governance.


reasoning: The paragraph discusses materiality of cybersecurity risks and asserts no material cyber incident occurred, without describing any incident details or internal/process governance.


reasoning: The paragraph discusses a prior incident only to support a materiality/assurance conclusion about potential future impacts on strategy and financial condition, with no description of what happened. The only concrete fact is the month/year of the prior incident, making it firm-specific but not incident-disclosure.


reasoning: The paragraph centers on board-level and committee-level oversight of cybersecurity/privacy risk and describes a specific board subcommittee’s structure and charter.


reasoning: The paragraph describes the company’s own cybersecurity measures and how risk is assessed and managed through its ERM process, including coordination between its information security and ERM teams. It also specifies alignment to the NIST Cybersecurity Framework, but contains no incident or specific firm-unique operational details.


reasoning: The paragraph describes the company’s own cybersecurity risk management program and the frameworks it uses to identify, assess, and manage risks, which makes it a risk management process disclosure. The only specific details are named frameworks (NIST Cybersecurity Framework and Sarbanes Oxley), so specificity is sector-adapted rather than firm-specific.


reasoning: This paragraph is generic forward-looking risk-factor language referencing cybersecurity risks without describing any company-specific process, role, framework, incident, or named facts.


reasoning: The paragraph describes the company’s own cybersecurity risk management processes (assess/identify/manage risks on IT systems) without any board/role/incident/materiality or vendor focus. It uses generic language and does not name standards, tools, dates, or unique program identifiers.


reasoning: The paragraph focuses primarily on how Aptar oversees third-party providers (assessments before engagement, ongoing compliance monitoring, and charter-based security expectations), which is central to third-party risk management.


reasoning: The paragraph focuses on the company’s (Longbridge’s) ongoing internal cybersecurity assessments and maintenance processes (patching/vulnerability management, access controls, disaster recovery/business continuity considerations, and threat monitoring). Although it mentions an external firm, it is described as part of Longbridge’s internal posture-maintenance activities rather than vendor oversight as the central topic.


reasoning: The paragraph describes a real cybersecurity incident, including unauthorized access by a third party, detection/response actions, and operational disruption, which fits Incident Disclosure.


reasoning: The paragraph describes the company’s intended internal risk management program for cybersecurity (identification, assessment, management/treatment of risks), including monitoring and assessment activities and integration into overall risk management. It does not describe a specific incident or name unique roles/committees/tools/firms or an external standard.


reasoning: The paragraph centers on named management roles (VP of IT / information security officer) describing their responsibilities and reporting relationships, plus specific committee composition and tenure/experience metrics.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized third-party access) with a named detection date and details about incident response and operational impact (disruptions and limited access to financial/operating reporting systems).


reasoning: This paragraph is centered on board and Audit Committee oversight of cybersecurity risk, including the stated briefing/review roles and cadence involving the company’s CSO.


reasoning: The paragraph describes an actual cybersecurity incident, including when it was determined, the unauthorized access event, containment actions with business disruption, and remediation status.


reasoning: The paragraph describes a real cybersecurity incident, including the start date, what was accessed, the affected system (Dropbox Sign production environment), the types of data exposed, and remediation/investigation activities.


reasoning: The paragraph narrates a specific cybersecurity incident with dates of detection and access removal, describes unauthorized access and exfiltration of employee email accounts, and notes ongoing investigation and materiality status.


reasoning: The paragraph describes an actual cybersecurity incident’s status (third party removed, systems restored, impacted functions like billing/label making, potential data theft/destruction, contingency plan execution, and operational continuity). It contains no firm-specific names, tools, dates, amounts, or external organizations to qualify for Firm-Specific or Quantified-Verifiable details.


reasoning: The paragraph describes a real incident, including the detection date, unauthorized access, response actions (incident response procedure, external experts, law enforcement), and operational/data-system scope (financial and operating reporting systems).


reasoning: The paragraph describes an actual ongoing cybersecurity incident, including start timing (late November 2023), what was accessed/exfiltrated, affected systems (email accounts, source code repositories, internal systems), and subsequent unauthorized-access attempts.


reasoning: The paragraph centers on the Chief Information Security Officer’s role, qualifications, and reporting/oversight structure, making it a management-role description rather than an incident or process narrative.


reasoning: The paragraph describes how the company evaluates and tests its own information security processes (including using external experts) and uses results to refine cybersecurity policies and conduct training. It does not describe a specific incident or impose a vendor-focused security requirement.


reasoning: The paragraph describes an actual incident involving a former employee obtaining specific customer data, includes scope (“up to 33 million customer accounts”), states what was and was not compromised, and describes ongoing investigation/regulatory actions.


reasoning: The paragraph describes a specific cybersecurity incident (unlawful access and exfiltration), includes response actions taken, and discusses threatened public release and operational/financial impact tied to the incident.


reasoning: The paragraph describes an actual cybersecurity incident (data exfiltration), including investigation findings and customer data impact (personal information), along with response actions such as continued analysis and client notifications.


reasoning: The paragraph narrates an actual cybersecurity incident (illegal access, temporary access limitations, halted production operations, and data exfiltration) and describes follow-on actions like evaluating impacted data and notifications.


reasoning: The paragraph is standard forward-looking statements safe-harbor and updating disclaimer language. It does not disclose substantive incident details (scope, systems, dates, impacts) beyond generic references to the Incident.


reasoning: The paragraph provides a real incident narrative with specific unauthorized-access/exfiltration timing, investigation findings, affected data types, and response actions.


reasoning: The paragraph describes a specific cybersecurity incident (defaced website), including when it was discovered, the affected web address, and response actions taken (restoring from backups, taking the site down, temporary page, continued review).


reasoning: The paragraph describes a specific cybersecurity incident, including the unauthorized access to customer personal information, the scope (limited to the third-party provider’s environment), response actions, and notification/misuse status.


reasoning: The paragraph describes what the involved data records do and do not contain (e.g., call/text record scope, telephone numbers, interaction counts, aggregate call duration, and inclusion of cell site identification numbers), which is substantive incident-related disclosure of data scope rather than internal process or general governance.


reasoning: The paragraph describes an actual cybersecurity-related outage, including what occurred (unauthorized access, encryption, exfiltration) and the operational impacts (delayed billing/collections/payments), with a specific incident date. That makes it an Incident Disclosure rather than a general risk or strategy statement.


reasoning: The paragraph narrates a real cybersecurity incident (unauthorized access), including when it was discovered, what actions were taken (incident response/business continuity), and operational impact (temporary interruption). It therefore fits Incident Disclosure rather than risk/process or strategy language.


reasoning: The paragraph describes a real cybersecurity incident, including detection, containment/remediation actions, encryption and data theft, and resulting operational disruption.


reasoning: The paragraph describes a real incident with notification timing, the nature of unauthorized access (cloud email), and the response actions, plus when the actor accessed/exfiltrated data (May 2023). It also names specific threat actors, making it incident-specific rather than generic risk management.


reasoning: The paragraph focuses on the incident’s expected financial/material impact (earnings/results of operations) and timing (Q2 ended June 30, 2024; since June 19, 2024) without describing what the incident was or its technical/operational mechanics.


reasoning: The paragraph narrates the effects of a cyber incident and the company’s operational impacts (interrupted inventory replenishment and delayed order fulfillment) along with restoration status (resumed fulfillment and substantially restored impacted IT systems/data). It does not provide qualifying firm-unique specifics from the ✓ list (e.g., dates, named tools/firms/roles).


reasoning: This paragraph discusses materiality and expected financial impact/costs from the incident without describing what happened or affected systems/data, so it fits financial/materiality integration rather than incident disclosure or internal risk processes.


reasoning: The paragraph describes a real incident (website/email disruption), provides specific dates and details on cause, scope/impact, and remediation actions (restoration, reinstatement, ongoing mitigation). The presence of two verifiable dates and concrete system/scope details supports quantified specificity.


reasoning: The paragraph discusses materiality to business/financial condition and financial impact handling (including that it believes it has adequate cyber insurance and may have uninsured losses), without describing the incident itself.


reasoning: The paragraph discusses an ongoing investigation and assesses the impact of unauthorized access tied to the stated incident (e.g., website being offline, no apparent material impact to IP or customer/stakeholder proprietary information). However, it provides no firm-specific identifiers, dates, scope, or named tools/roles beyond generic descriptors, so specificity remains boilerplate.


reasoning: The paragraph focuses on expected insurance reimbursements and materiality/financial impact conclusions, without describing a concrete incident narrative or specific cybersecurity controls/framework details unique to the company.


reasoning: The paragraph narrates a specific cybersecurity incident, including detection, containment/remediation actions, and the asserted ejection date, along with ongoing coordination with law enforcement/regulators.


reasoning: The paragraph describes a real cybersecurity incident (ransomware), includes the date of occurrence, and explains key characteristics and investigation/recovery actions taken.


reasoning: The paragraph does not describe what happened in the incident; it focuses on expected financial/business impacts, recovery period effects, related costs, and the offset from cybersecurity insurance, including a conclusion about long-term materiality.


reasoning: The paragraph discusses financial/materiality expectations and guidance ranges tied to the incident, without describing what the cybersecurity incident actually involved. It is therefore best categorized as strategy/financial integration (materiality and outlook).


reasoning: The paragraph describes a real cybersecurity incident affecting the Company’s access to CDK-provided systems, including the incident date, affected systems (DMS/CRM), and resulting operational disruptions and restoration of access.


reasoning: The paragraph focuses on the financial/materiality assessment of an incident (estimated expense range and that the full financial impact is still being assessed) without describing the underlying incident events or technical scope.


reasoning: The paragraph describes an actual cybersecurity incident’s status (contained/remediated), operational impact (communications, shipping/receiving, manufacturing, support functions), and incident-related cost estimates tied to specific dates and an amount.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity), includes actions taken (investigation, incident response plan activation, system shutdowns), and provides incident impact and scope (encrypted data files; manufacturing facilities offline; e-commerce/retail operational but fulfillment impacted; no belief consumer personal information compromised).


reasoning: The paragraph describes a real cybersecurity incident, including the detection date, incident response actions, network isolation causing disruption, and ongoing investigation/regulator notification.


reasoning: The paragraph describes ongoing investigation into an actual cybersecurity incident, including whether additional systems/data were accessed and whether there has been any material operational/financial impact, which is incident-focused disclosure.


reasoning: The paragraph describes an actual cybersecurity incident’s scope (access and exfiltration), data types affected (customer/employee PII), and response actions (notifications and law enforcement), which are hallmarks of incident disclosure.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized third-party access), the response actions taken (containment, remediation/recovery, activating an incident response plan, notifying law enforcement), and operational impact (temporary halt of production with restarting in progress). However, it contains no firm-specific identifiers, named experts/firms/tools, or verifiable hard facts such as dates or amounts.


reasoning: The paragraph does not describe the cybersecurity incident itself; it focuses on liquidity/financing terms (waived interest/lease payments) and the resulting amount of additional capital to support remediation.


reasoning: The paragraph describes a real cybersecurity incident with a specific date, unauthorized access, the types of activity alleged (including deployment of encryption/monitoring software), and operational impacts (business application disruption and taking systems offline), along with response actions taken.


reasoning: The paragraph describes an actual cybersecurity incident, including the detection date, unauthorized access, response actions (incident response procedure, engaging external experts, notifying law enforcement), and operational impact (disruptions and limited access to business applications such as financial and operating reporting systems).


reasoning: The paragraph describes a specific cybersecurity incident, including the detection date, unauthorized access, and immediate response/remediation activities. It also provides concrete filing/detection dates and focuses on incident details rather than purely financial/materiality conclusions.


reasoning: This paragraph is general forward-looking/boilerplate materiality language about cybersecurity risks and includes a cross-reference to Item 1A, but it does not describe any incident, specific processes, roles, or firm-specific details.


reasoning: The paragraph describes how the company integrates cybersecurity into its own enterprise risk management process, including review cadence and participation by internal cybersecurity/IT leadership and mitigation planning. While it mentions the Board, the dominant focus is the company’s internal risk management process.


reasoning: The paragraph is entirely about board and audit committee oversight of cybersecurity risk management. It contains no firm-specific details (no unique roles beyond the generic audit committee, no dates, programs, or named cybersecurity roles/systems).


reasoning: The paragraph describes an actual cybersecurity incident, including detection, incident response and containment actions, and resulting customer service delays and recovery status for Canadian operations.


reasoning: The paragraph’s grammatical subject is the Chief Technology Officer, describing that role’s responsibilities and reporting interactions around information security and cybersecurity risk processes.


reasoning: The paragraph describes an ongoing cybersecurity incident (an “unprecedented cyberattack”), its operational impact (services targeted including pharmacy/claims/payment), and response activities (restoration efforts and data-impact investigation). It does not include any qualifying firm-specific facts from the ✓ IS list (e.g., dates, named tools/firms, quantified scope).


reasoning: This paragraph is a cross-reference to the risk factors section and contains no substantive cybersecurity governance, incident, or process disclosure itself.


reasoning: The paragraph’s main subject is the identification and qualifications of named cybersecurity management roles (CIO and Information Security Director) and the cybersecurity team supporting them.


reasoning: The paragraph narrates an actual cybersecurity-related disruption, identifying affected systems, the party (CDK), restoration status, and incident timing (since June 19, 2024). It also states ongoing investigation/testing with partial restoration.


reasoning: The paragraph describes the company’s internal cybersecurity-related activities (process compliance and incident/threat protection) but contains no firm-specific identifiers, named roles, tools, dates, or standards.


reasoning: The paragraph focuses on board/audit committee oversight of cybersecurity risk and reporting to the committee and senior leadership, but it does not provide any firm-specific, dated, tool/product, or quantified details beyond generic governance language.


reasoning: The paragraph focuses on the absence of material cybersecurity incidents, immaterial related expenses/penalties, and materiality conclusions rather than describing any actual incident. It also includes general forward-looking intent to engage an investigation firm if needed, without an incident narrative.


reasoning: The paragraph explains financial/revenue impacts (delayed recognition, moved transactions, one-time expenses) resulting from the incident, without providing a narrative of what occurred technologically or operationally. This aligns with strategy/financial integration rather than incident disclosure.


reasoning: The paragraph’s grammatical subject is the Board and describes board/committee oversight activities (delegation, reporting, and approvals) of cybersecurity policies and the information security program.


reasoning: The paragraph describes HPE’s own cybersecurity risk management program and how it is structured under its Global CISO, including use of industry frameworks like NIST. This is internal process/risk management rather than incident details or third-party oversight.


reasoning: The paragraph describes the company’s internal controls, procedures, and escalation process for assessing and managing cybersecurity threats/incidents, which is an internal risk management activity. It does not name specific roles, frameworks, dates, systems, or other firm-unique details.


reasoning: The paragraph describes concrete, incident-driven operational disruption (halted operations, time to restart/return to capacity) and restoration timing, along with a remediation outcome regarding continued access.


reasoning: The paragraph is centered on an identified individual’s responsibilities for cybersecurity hiring, risk integration, budget approvals, incident preparation, and security review/approvals. It does not include any qualifying firm-specific facts from the allowed ✓ IS list (e.g., CISO/CTO title, named committee/team, named tool/standard, or specific date/amount).


reasoning: The paragraph is focused on the lack of material impact and discusses updates to the information security strategy in response to increasing threats, without describing a specific incident event or providing concrete firm-unique details.


reasoning: The paragraph’s grammatical subject is the AGM board of directors and it describes board-level oversight of cybersecurity within the company’s ERM. It also references recognized frameworks (NIST and ISO) without other firm-unique cybersecurity details.


reasoning: The paragraph describes the company’s internal cybersecurity risk management activities (training, awareness updates, testing, penetration testing, and assessments) rather than a specific incident. It contains no cybersecurity-specific roles, named programs, dates, frameworks/standards, tools, or other firm-unique details.


reasoning: The paragraph describes the company’s internal cyber risk assessment and mitigation processes (risk measurement/prioritization, treatment, and incident response planning). It contains no firm-specific roles, dates, tools, named standards, or other verifiable details.


reasoning: The paragraph centers on named cybersecurity and technology management roles (CISO and CTO) and describes their qualifications and tenure, not on governance or internal risk processes.


reasoning: The paragraph is a forward-looking discussion of potential materiality of cybersecurity risks and references spending including cyber insurance, but it does not describe an actual incident or incident scope.


reasoning: The paragraph describes the company’s internal cybersecurity risk management program activities (committee briefings, employee training, and security policies), which is central to risk management rather than incident disclosure or third-party oversight.


reasoning: The paragraph discusses materiality of cybersecurity threats to the company’s strategy/financial condition and includes forward-looking risk language, but contains no incident narrative or firm-specific cyber governance/process details.


reasoning: The paragraph is centered on named individual (Jack Wang) describing his responsibilities and reporting responsibilities for cybersecurity risks and incidents, which is a management-role disclosure rather than a company process or incident narrative.


reasoning: The paragraph focuses on a named management role (chief financial officer) and describes that role’s responsibilities for assessing and monitoring cybersecurity risks, with only brief mention of a committee update. No firm-specific cybersecurity details (e.g., CISO/Cybersecurity Committee, named tools, dates, or internal programs) are provided.


reasoning: The paragraph is expressly about the Board of Directors establishing a standing Cybersecurity Committee and how it provides oversight of cybersecurity risk. It also includes firm-specific governance and the chair’s specific cybersecurity oversight certification.


reasoning: The paragraph describes how the company’s cybersecurity program is integrated into its internal risk management and related programs (ERM, business continuity, crisis management, third-party risk management, insurance risk management, and employee compliance). It does not describe a specific incident, board/management roles, or impose central vendor security requirements.


reasoning: The paragraph describes the company’s own ongoing processes for identifying and managing cybersecurity-related material risks, but it provides no firm-specific details, roles, dates, named frameworks, or other verifiable facts.


reasoning: The paragraph’s grammatical focus is on named cybersecurity management roles (CISO and CTO), their reporting line, and what they oversee and lead in the security organization.


reasoning: The paragraph is a materiality/impact statement (no material cybersecurity incidents; immaterial related expenses/penalties) and points to Item 1A risk factors, but it does not describe any incident event or specific company cyber processes.


reasoning: The paragraph describes how cybersecurity risk management is embedded into enterprise risk management and supported by CSO/IT risk management teams, which is internal process-focused rather than incident or third-party governance.


reasoning: The paragraph describes the company’s own incident response plan and procedures (triage, severity assessment, investigation, escalation, containment, remediation). Third-party providers are mentioned only as part of coordination, not as the central topic, and there are no firm-specific identifiers or named standards.


reasoning: The paragraph’s primary focus is using external cybersecurity experts to evaluate and test the company’s cybersecurity risk management activities, which fits third-party risk oversight. However, it provides no firm-specific details (no named firms, dates, or tools), making it generic.


reasoning: The paragraph is about Board/committee oversight: the Board assigns responsibility for reviewing cybersecurity risk management and strategy, including incident review cadence and escalation to upper management. However, it uses only generic entities/phrases (e.g., “Audit Committee,” “IRP”) without any firm-unique, named, or dated specifics.


reasoning: The paragraph centers on named management roles (Vice President of Information Systems and CFO) describing their tenure, oversight responsibilities for cyber risk management, and cyber-related credentials/affiliations, which is characteristic of management-role disclosure rather than process or incident reporting.


reasoning: The paragraph describes the company’s internal cybersecurity incident response and handling/escalation procedures, including the Incident Management Team and specific internal committees involved in escalation.


reasoning: The paragraph describes the Board’s (and its Audit Committee) activities and continuing education, including cybersecurity briefings and presentations delivered by named cybersecurity-related executive roles (CIO, CISO, CIRO).


reasoning: The paragraph centers on governance/oversight by the board (and reporting of significant incidents to a committee and then the board) rather than describing the company’s own cybersecurity procedures as the primary subject.


reasoning: The paragraph describes the company’s own internal cybersecurity governance/processes (identification, prevention/mitigation, incident controls, and escalation for disclosure decisions). It does not describe a specific incident and contains no firm-specific roles, dates, tools, or named standards.


reasoning: The paragraph is primarily boilerplate materiality/risk disclosure language and refers generally to cybersecurity threats and prior incidents, but it does not describe any internal risk management process, governance, roles, vendor oversight, or a specific incident narrative. It most closely resembles risk-related disclosure rather than incident reporting or strategy impact details.


reasoning: The paragraph describes the company’s internal cybersecurity risk assessment and incident prevention/mitigation/detection/remediation and reporting as part of its cybersecurity risk management process. Although it mentions reporting to an Audit Committee, that committee reference is standard/boilerplate and not a cybersecurity-specific governance fact.


reasoning: This paragraph is forward-looking and focuses on potential financial/material impact and insurance coverage limits, without describing any actual incident or company-specific cyber processes.


reasoning: This paragraph is a cross-reference to another section discussing cybersecurity risks, with no substantive disclosure of incident details, internal processes, governance, roles, or third-party controls.


reasoning: The paragraph describes the company’s internal third-party risk management activities (assessment, evaluation, mitigation) as part of its cybersecurity roadmap. It mentions third parties only as an input to the company’s own risk processes, not as a standalone contractual/vendor-oversight topic.


reasoning: The paragraph contains general, forward-looking statements about the importance of cybersecurity and potential impacts, without describing any incident, governance, named roles/committees, specific frameworks/programs, or other firm-specific details.


reasoning: The paragraph is explicitly about Board and Audit Committee oversight of cybersecurity risk, including update/briefing flow from management and the committee. However, it does not include any firm-unique details beyond standard committee/board language, so it remains generic.


reasoning: The paragraph centers on board and Audit Committee oversight of cybersecurity risk. It also provides specific governance details (delegation to the Audit Committee and that the committee reviews risk assessment/ERM policies including cybersecurity).


reasoning: The paragraph focuses on the Board’s oversight responsibilities for enterprise risk and specifically states delegation of cybersecurity oversight to an audit committee. It does not include any firm-specific cybersecurity roles, named programs, standards, dates, or verifiable details beyond generic governance language.


reasoning: The paragraph describes the company’s internal cybersecurity controls and activities (monitoring tools, DLP, remediation, tabletop exercises, security training, and third-party penetration testing), which are part of its own risk management processes. It does not describe a specific incident or provide firm-unique, verifiable details.


reasoning: The paragraph describes the company’s own cybersecurity risk management processes and how they are integrated into its enterprise risk management program, but it contains no firm-specific details or named frameworks/implementations.


reasoning: The paragraph describes how the company uses third parties (ethical hacks/penetration testing and program reviews) as part of its cybersecurity program effectiveness and control improvement. It does not contain incident details or vendor contractual/security standards as the central focus, and it includes no firm-specific or hard verifiable facts.


reasoning: The paragraph describes the company’s internal audit risk assessment process and how cybersecurity risks are evaluated and reported. It does not include any firm-specific details (no named roles, programs, dates, tools, or systems), so it remains generic boilerplate.


reasoning: The paragraph describes the company’s internal cybersecurity measures and processes to manage and mitigate risks (e.g., incident response and risk assessments) rather than an incident or board/management role.


reasoning: The paragraph describes the company’s internal efforts to implement a recognized cybersecurity framework (NIST) and align internal policies to regulatory guidance, which fits risk management processes rather than incident disclosure or third-party oversight.


reasoning: The paragraph describes the company’s internal cybersecurity processes (monitoring, severity assessment, and escalation procedures) rather than an incident event. It also specifies an internal governance structure tied to the Senior Vice President, IT Operations, making it firm-specific.


reasoning: The paragraph describes the company’s own vulnerability assessment and evaluation activities as part of its cybersecurity risk management processes (scope, procedures, prioritization, and preventative measures). It does not name any specific roles, programs with unique identifiers, tools/vendors, standards, dates, or quantified details.


reasoning: The paragraph describes how the company’s internal cybersecurity risk management processes incorporate third-party-related threat risk assessment and due diligence, as part of its own processes (not requirements imposed solely on vendors). It does not provide firm-specific details, named frameworks, roles, dates, tools, or quantified facts.


reasoning: The paragraph is centered on a named cybersecurity management role (Director of Cybersecurity) and describes that role’s responsibilities and reporting into other internal leadership.


reasoning: The paragraph discusses uncertainty about incident impact and potential materiality to business operations/financial condition without providing incident details (e.g., what happened, affected systems, or response actions).


reasoning: The paragraph describes the company’s own cybersecurity risk management approach (adopted risk-based processes; part of overall risk management strategy). Board/committee oversight is mentioned, but the main subject is the company’s processes, and it contains no firm-specific cybersecurity details beyond generic governance language.


reasoning: The paragraph describes the company’s own cybersecurity measures and processes (e.g., detection/response, vulnerability management, DR/BCP, encryption, monitoring, and vendor risk management processes) rather than a board/management role or a disclosed incident.


reasoning: The paragraph narrates a specific cybersecurity incident, including the date of discovery, unauthorized access by a threat actor, encryption of data files, and response actions (containment, assessment, remediation, internal investigation, external specialists, and access restriction).


reasoning: The paragraph focuses on regulatory notification handling and states there is no material impact on operations or financial condition, without describing the incident’s substantive details or scope.


reasoning: The paragraph describes an ongoing cybersecurity incident (threat actor accessed and exfiltrated data, including some personally identifiable information) and response steps (notifications to affected parties and regulators). However, it contains no verifiable specifics like dates, amounts, named systems/tools, or third-party firms beyond generic descriptions.


reasoning: The paragraph discusses expected material financial/operational impact and related risks/costs from a cybersecurity incident, but does not describe what happened. It frames materiality and implications for results rather than incident details or response actions.


reasoning: The paragraph describes internal preparedness and security capabilities (crisis simulation and augmenting monitoring/incident response/detection/forensics) supported by external parties, rather than a vendor/third-party oversight requirement as the central topic. It does not disclose an actual incident.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized occurrences), when it was detected, and the response actions taken (containment/remediation steps, external experts, activating an incident response plan, shutting down systems, notifying law enforcement). It therefore falls under Incident Disclosure rather than risk processes or strategy.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized activity) and key response actions, including a specific action taken on a specific date (isolate systems from the Internet).


reasoning: The paragraph describes the company’s own processes for overseeing/identifying cybersecurity risks (including threats and incidents) rather than detailing vendor requirements or a specific incident.


reasoning: The paragraph describes the company’s internal cybersecurity operations processes for detecting incidents, determining severity, and triggering notification/escalation and triage. It does not include incident event disclosure details, board/management roles, third-party oversight, or any firm-unique, verifiable facts.


reasoning: The paragraph describes the company’s internal risk controls for cybersecurity, including cyber insurance responsibility, and business continuity/DR/incident response readiness testing (tabletop exercises). It does not describe a specific incident, and contains no qualifying firm-specific cybersecurity role/title, date, product, or other verifiable detail.


reasoning: The paragraph describes a specific cybersecurity incident with a concrete detection date, the company’s response actions (incident response/business continuity protocols), and containment of impact.


reasoning: The paragraph does not describe what occurred in the incident; it only provides materiality/financial impact estimates (GAAP EPS effects) related to the Incident for a specific quarter.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized activity), the containment/assessment/remediation actions taken, and includes a specific incident-related date and system isolation step.


reasoning: This paragraph is a standard forward-looking statements disclaimer and contains no cybersecurity-specific content, incidents, governance/process descriptions, or other substantive disclosures.


reasoning: This paragraph does not describe the incident itself; it only provides forward-looking statements about the unknown scope and concludes there is no material operational or financial impact. That makes it strategy/materiality integration rather than incident disclosure.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access and exfiltration), including the timeline (May 2023 and notification in June 2023), scope (limited SharePoint files), and response actions taken (investigation with external experts, containment and remediation).


reasoning: The paragraph describes the status/results of an ongoing cybersecurity investigation (no evidence of malware/ransomware/data alteration and whether the threat actor has access) and continues to assess extent/impact. It does not provide firm-unique details like dates, amounts, named tools/firms, or systems.


reasoning: The paragraph describes an actual cybersecurity incident and provides incident-scope outcomes (no compromise of IT systems/networks, no unauthorized transactions/monies transferred, and continued member transaction execution). It also notes remediation steps, which are core incident-disclosure elements.


reasoning: The paragraph describes a real cybersecurity incident, including unauthorized access and encryption, and the company’s response actions. It clearly meets the Incident Disclosure category based on an incident narrative with response steps and scope (IT system and data files).


reasoning: The paragraph discusses ongoing expenses and a materiality conclusion (no reasonably likely material financial impact) and general downstream business risks, without describing the incident’s events, scope, or response actions.


reasoning: The paragraph describes an actual cybersecurity incident outcome (additional data exfiltrated) and provides incident scope details by confirming that the exfiltrated data included PII and PHI maintained by a subsidiary.


reasoning: The paragraph describes operational impact from a cybersecurity incident (delays/limitations in distribution, online operations, billing/collections/vendor payments) and provides specific recovery status tied to a concrete date plus a quantified revenue share.


reasoning: The paragraph discusses financial impact (additional expenses and lost revenue) tied to a cybersecurity incident, but does not describe what occurred in the incident itself; this is best categorized as strategy/financial integration rather than incident disclosure.


reasoning: The paragraph describes a real cybersecurity event (a ransomware incident) with an incident date, scope (internal IT systems), and response actions (protocol activation, containment, platform shutdown) plus investigation and notification steps.


reasoning: The paragraph describes an actual cybersecurity incident’s operational impacts (shipping, manufacturing, support functions), ongoing restoration uncertainty, evidence that files were taken, and planned notifications to individuals/regulators—core incident-disclosure elements.


reasoning: The paragraph describes an ongoing cybersecurity investigation and provides an estimated scope of stolen personal data (what the threat actor took). It also discusses whether specific types of consumer credentials/data (SSNs, bank/payment card info, passwords) were acquired, which is incident-impact detail.


reasoning: The paragraph references an incident disclosure delay tied to DOJ determinations and provides current status (data not believed publicly available, apprehensions). While it does not describe technical details or affected systems, it is still substantively incident-disclosure related.


reasoning: The paragraph describes actions taken in response to a cybersecurity incident (investigation, mitigation, notification of law enforcement, regulators, and users regarding unauthorized access), which constitutes incident disclosure even though it lacks firm-unique details like dates or systems affected.


reasoning: This paragraph narrates a specific cybersecurity incident, including unauthorized access, misdirection of a wire payment, deletion of email messages, and whether the payment was recovered.


reasoning: The paragraph discusses materiality/financial impact conclusions and ongoing remediation in the context of an incident, but it does not describe the incident events or scope beyond a vague limitation to an infrastructure component; the main content is the expected business/financial impact assessment.


reasoning: The paragraph discusses financial/material impact, non-recurring expenses, and cyber insurance related to an event, but does not describe the incident itself or affected systems/data. It is therefore focused on strategy/financial implications rather than cyber risk processes or incident details.


reasoning: The paragraph provides materiality/financial impact conclusions about a cybersecurity incident, without describing what occurred or the affected systems/data. This fits strategy/financial impact (materiality) integration rather than incident disclosure.


reasoning: The paragraph describes active disruption and response actions (restoring systems, retaining security experts, working with law enforcement) and provides incident scope by asserting the interruption is specific to Change Healthcare systems.


reasoning: The paragraph describes a specific cybersecurity event (operational disruption and unauthorized access), the response actions taken, and the resulting operational impact (restored within days/hours and no material impact).


reasoning: The paragraph describes a real cybersecurity incident (unauthorized activity), includes response actions (containment, assessment, remediation, isolating systems), and provides an incident date (December 20, 2023).


reasoning: The paragraph describes a real cybersecurity incident, including when it was identified, the nature of unauthorized access, and immediate response actions (activation of an incident response plan). It is not framed as materiality/financial impact only.


reasoning: The paragraph discusses materiality/financial impact of an incident and expresses expectations about disruption and effects on results for a defined quarter, without describing what happened in the incident.


reasoning: The paragraph describes a specific unauthorized-access/exfiltration incident with dates, the alleged source (third-party cloud workspace), and the scope of affected records (customer call/text interactions over defined time windows).


reasoning: The paragraph describes an ongoing cybersecurity incident investigation, including exfiltration of files, assessment of whether sensitive/personal information was taken, and evaluation of required legal/regulatory filings.


reasoning: The paragraph describes the results of analysis of exfiltrated data—its primary categories (IT-related and financial information)—and ties it to the company’s SEC filing timeline, indicating scope of an actual cybersecurity incident.


reasoning: The paragraph describes a specific cybersecurity incident, including detection date (July 10, 2024), investigation/containment/remediation actions (external specialists, incident response plan, shutting down systems), and a stated outcome (threat actor ejected).


reasoning: This paragraph is a standard forward-looking statements disclaimer with no cybersecurity-specific content, incident description, internal process, or named roles/frameworks.


reasoning: The paragraph discusses expenses from an incident and ongoing evaluation of whether the incident will have a material financial impact, but it does not describe what happened or provide incident scope/response details.


reasoning: The paragraph updates disclosures about the Change Healthcare cyberattack and describes ongoing assessment/restoration actions, making it incident-related. It also includes a specific date (April 22, 2024), supporting firm-specific specificity.


reasoning: The paragraph describes a real cybersecurity incident (data exfiltration), includes a specific date, and states containment and investigation actions along with potential personal information impact.


reasoning: The paragraph discusses materiality/financial impact and likelihood of impact from an (unspecified) incident, without describing what occurred, affected systems, or response actions. That makes it strategy/financial materiality integration rather than incident disclosure or risk/process description.


reasoning: The paragraph narrates an actual cybersecurity incident response (activation of response protocols, containment measures like taking the network offline, investigation with third-party professionals, and notification actions). However, it does not include extractable firm-specific identifiers, dates, amounts, named tools/firms, or specific technical scope details beyond general response actions.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access) and provides affected scope and data types, including an approximate user count and what was (and was not) compromised.


reasoning: This paragraph discusses financial costs and expected materiality impacts (including lost production and incremental recovery/remediation expenses) rather than describing the incident’s technical details or scope. It explicitly quantifies costs and ties the expected impact to a specific fiscal period.


reasoning: This paragraph provides a materiality/financial impact assessment of a cybersecurity incident, without describing what happened, what systems/data were affected, or any incident-specific details.


reasoning: The paragraph describes an actual cybersecurity incident, including when it was discovered (March 27, 2024), the unauthorized access to Company data, and the company’s response actions (response protocols, investigation with cybersecurity experts and external counsel, and notification of law enforcement).


reasoning: The paragraph describes internal process-based actions (safety standards under the Halliburton Management System) and ongoing steps to identify incident effects, without providing a concrete incident narrative or detailed scope. A named internal system is included, making it firm-specific.


reasoning: The paragraph describes a realized cybersecurity event (unauthorized activity) and specific incident response actions, including activating a cybersecurity response plan, taking systems offline, notifying law enforcement, and assessing/restoring impacted data and systems.


reasoning: The paragraph describes a real cybersecurity event (detection of suspicious activity), the timing, and immediate response actions (assessing, containing/remediating, isolating systems and launching an investigation).


reasoning: The paragraph describes a real cybersecurity incident (data exfiltration), including when it was discovered and initial response actions (containment and investigation). It contains at least one firm-specific incident detail (February 21, 2024).


reasoning: The paragraph describes an ongoing cybersecurity incident investigation (files exfiltrated, assessing sensitive/personal information scope) and evaluating whether regulatory/legal notifications are required based on findings.


reasoning: This paragraph is a legal “shall not be deemed filed” disclaimer with no cybersecurity content or substantive disclosure.


reasoning: The paragraph describes actions taken in response to an identified incident (containment, monitoring, access control review, notification/cooperation), but it does not provide any firm-unique or verifiable details such as dates, affected systems/data, or named vendors/tools.


reasoning: The paragraph describes actions taken to remediate and contain an already-occurring cybersecurity incident (remediation ongoing, working with cybersecurity experts, reinforcing systems, and strengthening surveillance). It provides no firm-unique, named, or date/scope specifics, so it remains generic boilerplate in specificity.


reasoning: The paragraph narrates a real cybersecurity incident with a timeline (March 11 and March 18, 2026), describes effects (ransomware encryption and unauthorized disclosure of Company data), and includes management’s materiality reassessment based on incident escalation.


reasoning: The paragraph provides a materiality determination about the impact of a cybersecurity incident on financial condition/results, without describing what happened or any incident scope or response actions.


reasoning: The paragraph describes an actual incident’s impact and scope (e.g., whether passwords/private keys were compromised, whether customer funds could be accessed, and the types of affected data). However, it contains no qualifying ✓ IS facts (no dates, named roles/teams/committees, named tools/firms, or verifiable quantities) for specificity extraction under the provided rules.


reasoning: The paragraph describes board oversight of cybersecurity risk and that updates are provided via an audit committee and executive leadership, but it contains no firm-specific details (no named roles beyond standard governance bodies, no dates or unique identifiers).


reasoning: The paragraph provides a materiality/financial impact conclusion (“does not currently believe that this incident will materially impact…financial condition or results of operations”) without describing incident specifics or response actions.


reasoning: The paragraph describes the company’s own cybersecurity risk management approach to evaluating third-party vendors, but it does not name any specific roles, programs, dates, tools, vendors, or standards.


reasoning: The paragraph describes the status and outcome of remediation activities after a cybersecurity event (third party removed, access restored, and integrity/completeness confirmed). It does not provide concrete identifiers or hard verifiable facts, so it remains generic.


reasoning: This is a forward-looking disclaimer with a cross-reference to Risk Factors and contains no incident description, governance/role details, or specific cybersecurity processes or standards.


reasoning: The paragraph provides a materiality assessment of the cyber incident’s impact on financial condition and results of operations, with no additional incident-specific facts or process descriptions.


reasoning: This paragraph describes board-level oversight and reporting on cybersecurity risks and incidents, but it contains no cybersecurity-specific roles, named committees, dates, or other firm-unique details beyond generic governance language.


reasoning: The paragraph discusses general dependence on internal and third-party systems but does not describe a specific cybersecurity risk-management process, program, framework, or requirements in a way that is central or substantive beyond boilerplate.


reasoning: The paragraph describes board/audit committee oversight of cybersecurity risk management, but it uses generic terms (board, audit committee) without any firm-specific details, named roles beyond the standard committee reference, dates, or other verifiable specifics.


reasoning: The paragraph describes governance and oversight responsibilities, including an annual evaluation of a named Cybersecurity Committee.


reasoning: The paragraph describes general efforts to invest in cybersecurity, resiliency, and internal controls, but it does not reference any specific incident, framework/standard, named roles, dates, or other firm-unique details.


reasoning: The paragraph identifies a named cybersecurity leadership role (Group Head, Cybersecurity/Information Security Officer) and describes her qualifications and tenure, which is management-role information rather than an internal risk process or incident narrative.


reasoning: The paragraph describes the company’s own cyber risk management program and how it integrates with enterprise risk management, outlining internal processes for identifying and responding to cyber threats. It contains no incident description and no named roles, dates, tools, standards, or other firm-specific identifiers.


reasoning: This sentence provides general biographical experience (marketing, operations, management) and does not describe cybersecurity roles, processes, risks, governance, or incidents.


reasoning: This paragraph is a general description of a cybersecurity program and its purpose, with no incidents, frameworks, named roles, systems, dates, tools, or firm-specific details. It is boilerplate and does not disclose a specific risk management process, incident, or strategy impact.


reasoning: The paragraph describes the company’s cybersecurity program as part of its enterprise risk management approach (assess/identify/manage cyber risks). It does not name any specific roles, frameworks, dates, tools, or other firm-unique facts.


reasoning: The paragraph describes that cybersecurity operating procedures are incorporated into the company’s enterprise risk management, but it does so using generic language without naming frameworks, roles, committees, dates, or unique programs.


reasoning: The paragraph’s subject is the Board/Directors and describes its reporting and information flow on cybersecurity matters. It names the CISO and CIO and ties them to quarterly Board reporting, making it firm-specific governance content rather than an internal risk process or incident narrative.


reasoning: The paragraph generally describes cybersecurity risk management being integrated into the enterprise risk management program, but it does not describe a specific internal process, incident, governance body, named roles, or any unique firm details. It reads as broadly applicable boilerplate rather than firm-specific cybersecurity program detail.


reasoning: The paragraph discusses general cybersecurity risks (malware, ransomware, phishing) and defenses in a generic way, but it does not describe any firm-specific process, framework, roles, or incident details.


reasoning: The paragraph discusses the company’s own incident response and recovery planning, including how preparedness is improved via regular testing/simulations. It does not describe an actual incident or name any firm-specific roles, programs, dates, frameworks, or tools.


reasoning: This is generic governance language about “strategic risk” and “material risks” without any cybersecurity-specific oversight, processes, committees, roles (e.g., CISO/CIO), or incident/cyber details.


reasoning: The paragraph provides a general statement about the IT team being qualified, without naming any specific cybersecurity role, committee, program, framework, institution, or any verifiable fact.


reasoning: This sentence is a materiality/business impact statement denying a cyber incident but contains no incident details, governance, roles, or process descriptions.


reasoning: The paragraph describes the company’s internal cybersecurity practices (PII policy compliance and training/testing cadence), but it does not reference a specific named framework, program identifier, role, or verifiable company-specific detail.


reasoning: This sentence is generic about e-mail and cloud storage providers and broadly references cybersecurity protections without any specific company practices, roles, frameworks, named providers/tools, or incident details.


reasoning: The paragraph describes the cybersecurity program as part of the company’s risk management approach, but it only lists generic “key areas” without any firm-specific process details, named roles, dates, tools, or standards.


reasoning: The paragraph’s subject is the company’s internal security oversight group (ISC) membership and it specifically identifies cybersecurity-related management roles (CIO and Director of IT Security, Risk and Compliance) and their experience.


reasoning: The paragraph describes oversight and briefings between the board (including an audit committee) and management regarding cybersecurity and cyber risk management, which is board-level governance. However, it contains no firm-specific entities, roles, dates, tools, or other hard details.


reasoning: This paragraph provides a financial/materiality-style statement about the absence of a significant cybersecurity breach and related expenses/penalties over a time period, without describing any incident details or governance/process information.


reasoning: The paragraph describes the company’s internal responsibility for assessing and managing cybersecurity-related material risks, which aligns with risk management processes. It does not identify a specific cybersecurity role (e.g., CISO) or provide firm-unique details, dates, tools, or named programs.


reasoning: The paragraph is centered on an identified cybersecurity role (“internal cybersecurity coordinator”) and its reporting line and responsibilities. However, it contains no qualifying firm-specific, dated, quantified, or tool/standard facts to raise specificity beyond generic boilerplate.


reasoning: The paragraph centers on the company’s engagement/review process for third-party IT service providers’ cybersecurity measures and monitoring, which is specifically third-party oversight. It also names a specific third-party scoring source (Security Scorecard).


reasoning: The paragraph describes the company’s own incident response plan being reviewed and updated over time, but it does not disclose an actual incident. It contains no firm-specific identifiers, named programs, dates, roles, or external frameworks, so it is generic boilerplate.


reasoning: The paragraph addresses materiality and financial impact of cybersecurity incidents (no material incidents; immaterial expenses; no penalties/settlements) without describing any incident events or systems impacted.


reasoning: The paragraph describes internal incident remediation activities (remove malware, identify root cause, prevent recurrence) without referencing any firm-specific details, roles, dates, tools, or standards.


reasoning: The paragraph describes internal monitoring and handling of cybersecurity incidents (prevention/detection/mitigation/remediation) and relies on service provider notifications and ISP communications as part of the process. However, it provides no firm-specific roles, products, dates, standards, or named parties beyond generic references to management and service providers.


reasoning: The paragraph is centered on management roles (CIO and VP of Information Security) and describes their responsibility for cybersecurity risk management, making it management-focused rather than process- or incident-focused.


reasoning: The paragraph focuses on who implements and maintains cybersecurity risk assessment/management processes and how the CISO manages overall risks, which is an internal risk management process description rather than incident disclosure or board oversight.


reasoning: The paragraph describes oversight and reporting by the Board and Audit Committee regarding cybersecurity risks and material incidents, which is board governance rather than a specific risk process or incident narrative. It contains no company-specific or verifiable details beyond generic committee/reporting language.


reasoning: The paragraph provides a materiality-based statement about the absence of cybersecurity incidents materially impacting the company, without describing any incident facts, systems, or response actions.


reasoning: This paragraph only discusses cyber insurance coverage and intent to mitigate financial losses, without describing any incident or other company-specific governance or processes.


reasoning: The paragraph describes internal cybersecurity training and phishing-simulation activities as part of the company’s risk management practices, but it contains no company-specific identifiers, named frameworks/standards, roles, dates, or tools.


reasoning: The paragraph describes the company’s general need to develop and maintain cybersecurity measures to protect its systems and data, which is part of internal risk management and security process framing. It contains no named roles, frameworks, dates, tools, standards, or other firm-specific details.


reasoning: The paragraph is centered on the CSO/CISO’s role in staying informed and reporting progress. It also references a named internal committee (Global Security Steering Committee) and subsequent board reporting, but the grammatical and substantive focus remains the cybersecurity executives’ activities.


reasoning: The paragraph describes the company’s internal cybersecurity risk assessment and management approach (monitoring and user training) but does not provide any firm-specific details or named standards/tools. The grammatical subject is the company’s strategy/process, indicating an internal risk management process rather than governance, third-party risk, or an incident.


reasoning: The paragraph describes the company’s own processes for identifying, assessing, and managing cybersecurity-related material risks. It contains no named roles, frameworks, dates, products, or other firm-specific details, so it is generic boilerplate.


reasoning: This sentence describes generic responsibilities of cybersecurity professionals (an internal process/control description) but contains no company-specific roles, programs, dates, tools, or standards.


reasoning: The paragraph’s subject is the Board receiving cybersecurity-related updates, indicating oversight/briefings. It references a specific team (Cybersecurity team) but otherwise uses largely generic governance language (updates, risk indicators, remediation).


reasoning: The paragraph describes general components of cybersecurity programs (threat intelligence, forums, external experts testing/assessing controls) but contains no incident and no firm-unique identifiers, named roles, tools, dates, standards, or external firms.