reasoning: This paragraph describes a specific cybersecurity incident with details on the date it was discovered, unauthorized access method (encryption and monitoring software), scope (portions of IT systems and business applications), response actions (incident response process, law enforcement notification, external experts), and impacts (disruptions and precautionary shutdowns), directly matching Incident Disclosure criteria.


content_category: Incident Disclosure

category_confidence: high

specificity_confidence: high

reasoning: Paragraph describes a specific cybersecurity incident including detection date, scope (Canadian operations), response actions (isolation, engagement of professionals), and impacts (service delays), matching Incident Disclosure criteria. Only one hard verifiable fact (date) qualifies it as Firm-Specific, not Quantified-Verifiable.

provider: x-ai


reasoning: The paragraph describes the details of a cybersecurity incident, including unauthorized access by a cybercrime organization to a limited portion of the retail business information environment, data exfiltration involving customer and employee PII, and response actions like investigation with experts and notifications to authorities, meeting the criteria for Incident Disclosure.


content_category: Strategy Integration

reasoning: The paragraph details financial arrangements (waiver of interest and lease payments providing $3.7M liquidity) to support cybersecurity incident remediation and operations, emphasizing business/financial impact without any incident narrative, response actions, or scope description, aligning with Strategy Integration per tiebreakers. It includes multiple verifiable hard facts such as specific dates, a dollar amount, and named third-party firms, exceeding the threshold for Quantified-Verifiable.


reasoning: This paragraph details the ongoing investigation into a cybersecurity incident, including scope assessment (no evidence of customer data access), response actions (reporting to law enforcement and regulators), and lack of material operational or financial impact, which matches Incident Disclosure criteria for describing a real event's response and impact.


reasoning: Paragraph describes a specific cybersecurity incident including the date of detection, unauthorized access details, response actions (incident response procedure activation, engaging experts, notifying law enforcement), and operational impacts (disruptions to business applications and reporting systems), directly matching Incident Disclosure criteria.


content_category: None/Other

reasoning: This paragraph is a cross-reference to risk factors in another section with no substantive cybersecurity disclosure, fitting 'None/Other'.


content_category: Board Governance

reasoning: The paragraph focuses on the board of directors and audit committee's oversight responsibility for cybersecurity risks, including delegation, review, and reporting cadence, making the board/committee the grammatical subjects.


reasoning: The paragraph provides a standalone materiality conclusion stating no prior cybersecurity incidents have materially affected the company and acknowledges potential future material impacts, with no incident narrative or description of events. It fits Strategy Integration as it focuses on business/financial impact assessments without detailing processes, roles, or incidents.


content_category: Risk Management Process

reasoning: The paragraph details the company's internal enterprise risk management processes, including biannual reviews of cybersecurity risks with participation from the CISO and CIO, mitigation plans, and annual Board reviews, making Risk Management Process the best fit as processes are the grammatical subject and roles are mentioned in passing.


reasoning: The paragraph outlines the company's internal processes for monitoring emerging data protection laws and implementing compliance changes to manage cybersecurity risks and respond to incidents, fitting Risk Management Process as it focuses on own internal risk management activities. No specific facts, named frameworks, roles, dates, or quantifiable details are present, making it Generic Boilerplate.


content_category: Management Role

reasoning: The paragraph focuses on identifying and describing the qualifications and responsibilities of specific management roles (CIO, Information Security Director) and their supporting team, making 'Management Role' the clear fit as these roles are the grammatical subjects. Specificity reaches Quantified-Verifiable due to two quantified experience years plus named roles and team, per calibration examples.


reasoning: The paragraph describes an actual cyberattack on Change Healthcare services, including targeted areas (pharmacy, claims, payments), response actions (mitigation, restoration, investigation with law enforcement), and scope (specific to Change Healthcare, other systems operational), fitting Incident Disclosure per tiebreakers for incident narrative and response. It contains firm-specific named systems unique to this company but lacks two hard verifiable facts like dates or named firms for higher specificity.


reasoning: The paragraph focuses on the Audit Committee's central role in the Board's oversight of cybersecurity risks, with the board/committee as the grammatical subject, fitting Board Governance. No firm-specific facts like cybersecurity roles, dates, or named programs are present, making it Generic Boilerplate.


reasoning: The paragraph details the Adviser's own internal processes for assessing, identifying, managing, and escalating cybersecurity threats and incidents, including controls for classification and reporting, which fits Risk Management Process. It contains no named frameworks, roles, dates, numbers, or other specific facts, qualifying as Generic Boilerplate.


reasoning: Paragraph provides standalone materiality conclusions on past cybersecurity incidents (none material, immaterial expenses, no penalties) and financial impacts without any incident narrative or description of events. No specific facts, named frameworks, roles, dates, or quantifiable details qualify under the ✓ IS list, resulting in Generic Boilerplate.


reasoning: The paragraph centers on the Chief Technology Officer (CTO) as the grammatical subject, detailing their qualifications, responsibilities for cybersecurity processes, and reporting to the General Counsel, which matches 'Management Role' criteria for role identification, qualifications, and reporting lines.


reasoning: The paragraph centers on the chief financial officer's primary responsibility for assessing, monitoring, and managing cybersecurity risks, with reporting to a committee, fitting Management Role as the management position is the grammatical subject and main focus per tiebreakers.


reasoning: The paragraph focuses on the Board of Directors and Enterprise Risk Management Committee oversight, training, reviews, approvals, and reporting cadence for cybersecurity, making the board/committee the grammatical subject. Named non-generic committee qualifies as a firm-specific fact, with no hard verifiable facts reaching Quantified-Verifiable and no named standards for Sector-Adapted.


reasoning: The paragraph focuses on the company's own cybersecurity program, organization (CDRM), processes, standards, and controls for identifying, assessing, managing, and mitigating risks, including leveraging the NIST framework, which aligns with Risk Management Process. The Global CISO is noted as leadership but the processes are the central topic, not management roles or qualifications.


reasoning: The paragraph centers on the AGM board of directors' oversight of the risk management program, including cybersecurity, as the grammatical subject, fitting Board Governance. It references NIST and ISO frameworks, qualifying as Sector-Adapted, with no firm-specific facts from the approved list.


reasoning: The paragraph focuses on Mr. Gharib's specific responsibilities in cybersecurity, such as hiring personnel, risk integration, budgeting, and incident preparation, making a management role (cybersecurity leader) the grammatical subject.


reasoning: The paragraph describes the company's internal cybersecurity program integration into various risk management systems and processes for threat mitigation, making Risk Management Process the best fit. Vendor/third-party risk is mentioned only as one integrated component, not the central topic.


reasoning: The paragraph provides standalone materiality conclusions regarding past cybersecurity incidents and risks, stating no material impact on business strategy, operations, or financial condition, without any incident narrative or description of events. It also mentions a general update to the information security strategy, fitting Strategy Integration rather than Incident Disclosure or other categories.


reasoning: The paragraph details the company's own internal processes for managing cybersecurity risks, including employee training, awareness updates, employee testing, penetration testing, and cybersecurity assessments, which aligns with Risk Management Process. It does not focus on board oversight, specific management roles, third-party risks, incidents, or strategy integration.


reasoning: The paragraph focuses on the identification, qualifications, tenure, and experience of the CISO and CTO, making management roles the grammatical subject and primary topic. It contains multiple hard verifiable facts including specific years (2013, 2020), quantified experience durations (20, 25, 12 years), and named certifications/institution, exceeding the threshold for Quantified-Verifiable.


reasoning: This paragraph details the company's own internal processes for threat and vulnerability assessments, risk prioritization, and mitigation strategies including incident response plans, making 'Risk Management Process' the clear fit. It contains no references to board oversight, specific roles, incidents, third-parties, or business integration.


reasoning: The paragraph describes the company's internal incident response policies, escalation procedures, and involved teams, which aligns with Risk Management Process as it focuses on IR planning and own internal processes. Named teams like Incident Management Team and Privacy and Security Subcommittee provide firm-specific details without reaching Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal risk management processes, including ERM integration and evaluation of cybersecurity risks by specific teams, with roles mentioned in passing. CSO is a cybersecurity-specific role, making it Firm-Specific, but no frameworks, dates, or other hard facts elevate it further.


reasoning: The paragraph focuses on the company's internal risk management processes, including engagement with external experts for audits, threat assessments, and penetration testing, treating third parties as a component of its own cybersecurity strategies rather than central vendor oversight.


reasoning: Paragraph addresses resource expenditure (including cyber insurance), potential materiality of cyber risks due to sensitive data, and notes no material past incidents, aligning with Strategy Integration per tiebreakers for materiality conclusions without incident narratives. No qualifying specific facts from the ✓ IS list; vague phrases like 'significant resources' do not count.


reasoning: The paragraph details the company's internal cybersecurity risk management program, including committee meetings, employee training, and security policies, making 'Risk Management Process' the best fit as it focuses on the company's own processes with roles mentioned in passing. No incident narrative, board oversight as subject, or vendor centrality present.


reasoning: This paragraph delivers a standalone materiality assessment, confirming no material cybersecurity incidents or expenses (including no penalties/settlements) over the last three fiscal years, which aligns with Strategy Integration per the guidelines for materiality conclusions without incident narratives. It contains no specific facts from the ✓ IS list or named standards, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the Audit Committee's reporting to the Board on cybersecurity activities and the Board's receipt of briefings and presentations from management and specific officers, with the board and committee as the primary grammatical subjects, aligning with Board Governance. Specific cybersecurity roles (CIO, CISO, CIRO) qualify as firm-specific facts, but no hard verifiable facts like dates or named firms reach Quantified-Verifiable.


reasoning: This paragraph provides a standalone materiality conclusion stating no cybersecurity threats in 2023 materially affected or are likely to affect business strategy, operations, or financial condition, fitting Strategy Integration. It includes no incident narrative or description of processes, focusing on financial/business impact assessment.


reasoning: The paragraph details the company's incident response plan, including specific processes for handling cybersecurity incidents, which aligns with Risk Management Process as it focuses on the company's own internal procedures. Third-party providers are mentioned only as part of the coordinated activities, not as the central topic.


reasoning: The paragraph focuses on the Board of Directors assigning the Audit Committee responsibility for cybersecurity risk oversight, including annual reviews and incident reporting, with the board/committee as the grammatical subject. No specific facts qualify under the ✓ IS list, as Audit Committee is standard/generic and IRP is a generic program name.


reasoning: The paragraph describes the company's own internal processes for continuously assessing, identifying, and managing cybersecurity risks, which aligns with Risk Management Process. It contains no specific details, roles, frameworks, or incidents, making it generic boilerplate with cross-references to risk factors.


reasoning: The paragraph focuses on the Board establishing and overseeing via the Cybersecurity Committee, including the chair's cyber expertise, making Board Governance the clear fit as the board/committee is the grammatical subject. It contains firm-specific facts like the 2023 establishment date, named committee, and chair's specific certification, qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard verifiable fact (date).


reasoning: The paragraph centers on the CISO and CTO as grammatical subjects, detailing their reporting lines, oversight responsibilities, and leadership in cybersecurity, aligning with Management Role per guidelines. Specific cybersecurity roles (CISO, CTO) qualify as firm-specific facts, but no hard verifiable facts (dates, amounts, named firms/tools) reach Quantified-Verifiable.


reasoning: This paragraph describes the company's own internal processes for vulnerability testing (ethical hacks, penetration tests) and program reviews using third parties, making Risk Management Process the best fit; third-party engagement is a component of internal processes, not the central vendor oversight topic.


reasoning: Paragraph states no material past cybersecurity incidents or risks identified in the fiscal year and notes forward-looking risks that could materially impact the company, aligning with standalone materiality conclusions in Strategy Integration. No incident narrative or process details present.


reasoning: The paragraph describes the company's internal cross-functional processes for identifying risks, developing strategies, and maintaining incident controls and escalation procedures, making Risk Management Process the best fit. Board and management are mentioned only briefly in passing for disclosure decisions, not as the primary subject.


reasoning: The paragraph details the company's internal audit program, including annual business risk assessments that evaluate cybersecurity risks and report to business leaders for prioritization, fitting the Risk Management Process category as it focuses on the company's own internal processes.


reasoning: This paragraph is a cross-reference to the Risk Factors section, providing no substantive cybersecurity disclosure, which fits 'None/Other' per guidelines.


reasoning: The paragraph describes the company's engagements with third-party firms to enhance its own monitoring, incident response, detection, forensics, and crisis simulation exercises, which are components of its internal risk management processes rather than central focus on vendor oversight. Vendors are mentioned as augmenting internal efforts, fitting Risk Management Process per tiebreakers.


reasoning: The paragraph centers on identifying Jack Wang's role, qualifications, and reporting responsibilities for cybersecurity risks, with management roles as the grammatical subject, fitting Management Role over others like Board Governance (board only receives reports) or Risk Management Process (focuses on personnel, not processes). It contains firm-unique facts like the named individual/role and quantified experience but lacks two or more hard verifiable facts (e.g., dates, dollars, named external firms/tools) for Quantified-Verifiable.


reasoning: This paragraph consists of forward-looking disclaimers about potential cybersecurity incidents, insurance limitations, and a cross-reference to risk factors, providing no substantive disclosure on governance, processes, incidents, or strategy.


reasoning: The paragraph focuses on identifying specific management roles (Vice President of Information Systems and CFO) and their qualifications related to cybersecurity risk management, making 'Management Role' the most applicable category. Multiple specific numbers (19 years, 6 years, 25 years) and named certifications/GIAC Board qualify as two or more hard verifiable facts for Quantified-Verifiable specificity.


reasoning: Paragraph discusses generic cybersecurity threats common to fintech, potential impacts on operations, and need for resources, fitting forward-looking disclaimers and boilerplate with no substantive disclosure on governance, processes, incidents, or other categories.


reasoning: The paragraph focuses on the Board of Directors and Audit Committee's oversight of cybersecurity risks, including update cadences, making the board/committee the grammatical subject. Audit Committee is standard and cadences are generic, fitting Board Governance without qualifying for other categories.


content_category: Third-Party Risk

reasoning: The paragraph centers on the company's processes for assessing third-party risks, including selection, oversight, and mitigation during third-party incidents, making vendor/supplier oversight the primary topic rather than a mere component of broader internal processes.


reasoning: The paragraph focuses on the Board's oversight of enterprise risk management, delegation to the audit committee for cybersecurity risk assessment, and the committee's responsibilities for reviewing programs and receiving reports, with the board and committee as primary grammatical subjects. Management is mentioned briefly but not as the main focus.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including assessment of third-party risks as a component, rather than third-party oversight as the central standalone topic. No specific facts, named standards, roles, or quantifiable details are present, making it generic boilerplate.


reasoning: The paragraph focuses on the Board's responsibility for risk oversight, delegation to the Audit Committee for cybersecurity matters, and the committee's reviews and members' experience, with the board/committee as the grammatical subject. No firm-specific facts qualify under the ✓ IS list, as Audit Committee is standard/generic.


reasoning: The paragraph describes the company's own internal processes for monitoring, vulnerability remediation, incident response exercises, penetration testing, and employee training, aligning with Risk Management Process; third-party involvement is a minor component, not central. No specific facts from the ✓ IS list (no named roles, committees, dates, programs with unique IDs, tools, firms, or quantified metrics) or named standards, confirming Generic Boilerplate.


reasoning: This paragraph describes the company's own internal technical, physical, and organizational measures, processes, and policies for managing cybersecurity risks, such as incident response plans, risk assessments, encryption, and monitoring, making Risk Management Process the most applicable category.


reasoning: The paragraph describes the company's internal Enterprise Risk Management process integrating cybersecurity and a cybersecurity risk management program to protect systems and information, making 'Risk Management Process' the most applicable category as it focuses on the company's own processes without referencing board, management roles, vendors, incidents, or strategy.


reasoning: The paragraph describes the company's adoption of cybersecurity risk management processes using a risk-based approach to assessing, identifying, and managing risks, integrated into overall risk management strategy, which fits Risk Management Process; board oversight is mentioned briefly but the internal processes are the central topic.


category_confidence: medium

reasoning: The paragraph focuses on the IT department's (under CFO) responsibilities, qualifications (experience), and reporting for cybersecurity risk management, fitting Management Role as it identifies and qualifies the team handling cyber risks rather than detailing the processes themselves (which are cross-referenced as described above). Some ambiguity with Risk Management Process due to mention of monitoring activities, but the grammatical subject is the IT department's role.


reasoning: The paragraph primarily details the board of directors' overall oversight responsibility for cybersecurity risk management, including reporting of significant incidents to the audit committee and board, aligning with Board Governance. Management and the VP of Operations are mentioned in support of this oversight structure.


reasoning: The paragraph focuses on the company's implementation of the NIST Cybersecurity Framework and adoption of internal policies to align with regulatory requirements, which describes their own internal risk management processes.


reasoning: The paragraph describes the company's internal processes for monitoring systems, assessing incidents, and following escalation procedures in the incident response plan, with roles mentioned in support of these processes. Per tiebreakers, processes/procedures are the main topic with roles in passing, fitting Risk Management Process.


reasoning: The paragraph focuses on the Director of Cybersecurity's responsibilities, qualifications, and reporting lines to the Head of IT and executive committee, making the management role the grammatical subject. No hard verifiable facts (dates, dollars, headcounts, named firms/tools) reach the Quantified-Verifiable threshold, but cybersecurity-specific roles qualify as Firm-Specific.


reasoning: The paragraph details the company's internal vulnerability assessment program, risk management framework, and vulnerability management practices, fitting 'Risk Management Process' as it focuses on their own processes without referencing board, management roles, vendors centrally, incidents, or strategy integration. No qualifying specific facts from the ✓ IS list or named standards are present, confirming Generic Boilerplate.


reasoning: Paragraph details a specific cybersecurity incident including the date it was detected, unauthorized access by a threat actor, data encryption, and immediate response actions like containment, investigation, and engaging specialists, directly matching Incident Disclosure criteria.


reasoning: The paragraph details the company's own internal processes and measures for managing cybersecurity risks, such as vulnerability management, incident response, monitoring, and vendor risk processes as one component, fitting Risk Management Process. It contains no named frameworks, specific roles, dates, numbers, or other firm-unique facts from the ✓ IS list, resulting in Generic Boilerplate.


reasoning: The paragraph describes the company's internal processes for cybersecurity, including cyber insurance review, business continuity/disaster recovery plans, and annual testing via tabletop exercises, which aligns with risk management and IR planning. While cyber insurance could suggest Strategy Integration, the focus on plans and testing procedures makes Risk Management Process the most applicable.


reasoning: This paragraph details the company's internal processes for cybersecurity incident detection, severity assessment, triage, notification, and escalation through its Security Operations Center, which aligns with Risk Management Process as it focuses on the company's own monitoring and IR planning. It contains no named frameworks, specific roles, dates, tools, firms, or quantifiable facts, making it Generic Boilerplate.


reasoning: Paragraph describes a specific cybersecurity incident including the detection date, unauthorized access to IT systems, and detailed response actions such as investigation, incident response plan activation, system shutdown, and law enforcement notification, fitting Incident Disclosure. It contains one verifiable specific date, qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: The paragraph details the detection of unauthorized activity, containment and remediation steps, a specific date of system isolation, and notifications to experts/law enforcement/regulators, directly describing an actual cybersecurity incident and response. It contains one verifiable specific date, qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: Paragraph assesses material impact on business operations and financial condition/results without describing the incident event, scope, or response actions, aligning with Strategy Integration per tiebreakers for materiality conclusions. Contains only boilerplate language with no specific facts, named standards, or verifiable details.


reasoning: The paragraph focuses on the lack of material impact on operations and financial condition from 'the incident,' without describing the event itself, aligning with Strategy Integration per tiebreakers for materiality conclusions without incident narrative. No specific facts, dates, names, or quantifiable details are present, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident including the detection date, response actions (incident response protocols, investigation, engaging a firm, notifications), and containment, matching Incident Disclosure criteria. It contains one hard verifiable fact (specific date), qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second verifiable fact.


reasoning: Paragraph describes investigation findings and ongoing response to a specific cybersecurity incident (no malware/ransomware found, no current access, assessing extent/impact), fitting Incident Disclosure as it references a real event with scope and response details. No specific facts from the ✓ IS list (no dates, roles, names, numbers), resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes what happened in a cybersecurity incident (threat actor access and exfiltration of limited data including some PII) and response actions (notifications to affected parties and regulators), referencing a real event tied to the Original Report. No specific facts qualify under the ✓ IS list, with all details being vague or boilerplate (e.g., 'limited data', 'some PII', standard notifications).


reasoning: Paragraph describes the operational scope, impacts, and recovery status of a specific cybersecurity incident, including affected products and revenue percentage, directly matching Incident Disclosure criteria over Strategy Integration as it provides incident details rather than standalone financial/materiality conclusions.


reasoning: This paragraph describes response actions (contain and remediate the incident) and scope/operational impact (Bank's systems not compromised, no unauthorized transactions or transfers, members continued transactions), referencing a real incident, fitting Incident Disclosure. No specific facts from the ✓ IS list or named standards, making it Generic Boilerplate.


reasoning: This paragraph is a standard forward-looking statement disclaimer with no reference to cybersecurity or any substantive disclosure, fitting the 'None/Other' category.


reasoning: Paragraph discusses materiality of the incident on operations and financial results without describing the event itself, fitting Strategy Integration per tiebreakers for financial impact and materiality conclusions. Two specific dates (quarter ended December 31, 2024; full year 2024) qualify as hard verifiable facts for Quantified-Verifiable.


reasoning: Paragraph details a real cybersecurity incident with date, unauthorized access, data encryption, and response actions (containment, investigation, external specialists), directly matching Incident Disclosure criteria. Includes one verifiable specific date, qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard fact.


reasoning: Paragraph discusses only the financial materiality and impact of 'the Incident' on Q2 results with specific EPS figures, without describing the incident event itself, fitting Strategy Integration per tiebreakers. Contains multiple hard verifiable facts: specific quarter-end date and dollar amounts for EPS.


reasoning: This paragraph describes a specific cybersecurity incident, including dates (May and June 2023), unauthorized access and exfiltration of SharePoint files, investigation with external experts, and response measures, directly matching Incident Disclosure criteria with event narrative, scope, and actions.


reasoning: This paragraph details the detection of unauthorized activity on IT systems, containment and remediation steps, and a specific action on December 20, 2023, clearly describing a real cybersecurity incident with response actions.


reasoning: Paragraph describes the scope of operational impacts from a specific incident (shipping, manufacturing, etc.), evidence of files taken, and response actions (interim measures, investigation, notifications), fitting Incident Disclosure as it references a real event with narrative details. No specific facts from the ✓ IS list (no dates, roles, names, numbers, etc.), and standard incident language aligns with Generic Boilerplate per calibration examples.


reasoning: Paragraph assesses the materiality of an incident on operations and financial condition without any incident narrative, dates, scope, or response details, aligning with Strategy Integration per tiebreakers. Contains only boilerplate language with no qualifying specific facts.


reasoning: The paragraph describes the company's internal processes for overseeing and identifying cybersecurity risks associated with third-party service providers, fitting Risk Management Process per tiebreakers for internal processes mentioning vendors; materiality statements are boilerplate and secondary.


reasoning: The paragraph solely discusses the immateriality of a cybersecurity incident on business operations and financial condition without describing the event, scope, or response, fitting Strategy Integration per tiebreakers for materiality conclusions without incident narrative.


reasoning: Paragraph discusses financial expenses, materiality assessment, and ongoing risks from 'this incident' without any narrative of the event itself, fitting Strategy Integration per tiebreakers for materiality conclusions without incident description. No specific facts like dates, amounts, roles, or named entities qualify under the ✓ IS list, confirming Generic Boilerplate.


reasoning: This paragraph describes the scope of a real cybersecurity incident, specifying the volume of stolen personal data (35.5 million consumers) and data not affected (no SSNs, bank info, payment cards, or passwords), directly matching Incident Disclosure criteria.


reasoning: The paragraph details a specific ransomware incident including the date, what happened (ransomware on internal IT systems), initial response actions (containment, taking platforms offline), and engagement of experts for investigation, clearly fitting Incident Disclosure as it describes what happened in a real event.


reasoning: Paragraph discusses financial costs (material expenses in first quarter), cyber insurance, and materiality of impacts from an incident without any description of the event itself, fitting Strategy Integration per tiebreakers. No specific facts from the ✓ IS list (no dates, numbers, roles, or named entities qualify after filtering), resulting in Generic Boilerplate.


reasoning: The paragraph focuses on financial impacts (expenses and lost revenue) from a cybersecurity incident without describing the event itself, aligning with Strategy Integration per tiebreakers. It contains multiple hard verifiable facts including specific fiscal periods and dollar amounts, qualifying as Quantified-Verifiable.


reasoning: This paragraph details the scope of exfiltrated data (PII and PHI from a patient support subsidiary) discovered during an investigation of a real cybersecurity incident, fitting Incident Disclosure criteria for descriptions of affected data. No specific facts from the ✓ IS list (e.g., dates, named roles, quantified metrics, named firms) are present after filtering, resulting in Generic Boilerplate specificity.


reasoning: The paragraph details DOJ approvals for disclosure delays, law enforcement collaboration, suspect apprehension, and data availability status, which constitute incident response actions and affected data scope updates for a referenced cybersecurity incident.


reasoning: This paragraph details the scope of data exfiltrated in a cybersecurity incident, specifying the types of information (IT and financial data for 10-K preparation) and tying it to a real event, which matches Incident Disclosure criteria for affected data scope.


reasoning: This paragraph details response actions to a specific cybersecurity incident, including launching an investigation with forensic investigators, notifying law enforcement, regulatory authorities, and affected users about unauthorized access to personal information, which matches Incident Disclosure criteria for incident response and scope.


reasoning: Paragraph describes a specific cybersecurity incident including unauthorized access, misdirected wire payment of $250,000, deletion of emails, and non-recovery of funds, fitting Incident Disclosure as it details what happened in a real event. Specificity is Firm-Specific due to one verifiable quantified fact ($250,000), but not Quantified-Verifiable as there is only one such hard fact.


reasoning: This paragraph describes a specific cybersecurity incident including dates of awareness, access period, data exfiltration timeframe, and initial response actions, directly matching Incident Disclosure criteria with a real event narrative.


reasoning: The paragraph assesses the materiality and business/financial impact of a past incident, including scope limited to Dropbox Sign infrastructure, without narrating the event details, aligning with Strategy Integration per tiebreakers for materiality conclusions.


reasoning: Paragraph focuses on financial expenses, operational impact, and materiality assessment of 'the Incident' without any narrative description of the event itself, aligning with Strategy Integration per tiebreakers. No qualifying specific facts from the ✓ IS list or named standards are present.


reasoning: This paragraph details the cybersecurity incident including unauthorized activity, detection, containment actions on a specific date, remediation, engagement of experts/law enforcement, and resumption of operations, directly matching Incident Disclosure criteria for describing what happened, when, and response.


reasoning: This paragraph describes a specific cybersecurity incident, including the date of identification (June 9, 2025), unauthorized access to information systems, discovery via employee communications from a threat actor, and activation of the incident response plan, directly matching Incident Disclosure criteria.


reasoning: Paragraph describes a specific cybersecurity incident including date, unauthorized access, response actions (activation of plan, external experts, remediation, restoration), scope (limited portion), and operational impact (restored quickly, no material impact). This matches Incident Disclosure as it provides a narrative of what happened in a real event.


reasoning: Paragraph details response actions to an ongoing cybersecurity incident (system restoration, retaining experts, law enforcement coordination, notifications) and specifies the scope (limited to Change Healthcare systems, others operational), directly matching Incident Disclosure criteria for incident narrative, response, and affected systems scope.


reasoning: This paragraph describes the ongoing investigation into a specific cybersecurity incident, including details on exfiltrated files, potential sensitive/personal information, scope of unauthorized access, and response actions like evaluating notifications, fitting the Incident Disclosure category. No firm-specific or verifiable facts are present, making it Generic Boilerplate.


reasoning: This paragraph is a standard forward-looking statement disclaimer with no reference to cybersecurity, board oversight, management roles, processes, incidents, or any substantive disclosure, fitting 'None/Other'.


reasoning: Paragraph describes a specific cybersecurity incident including date of awareness, unauthorized access to data/systems, and response actions (investigation, law enforcement notification, containment), directly matching Incident Disclosure criteria. One verifiable specific date qualifies it as Firm-Specific with no other hard facts reaching Quantified-Verifiable.


reasoning: This paragraph describes a specific cybersecurity incident including the detection date, suspicious activity in IT systems, and initial response actions like isolation and investigation, directly matching Incident Disclosure criteria. It includes one verifiable specific date, making it Firm-Specific but not Quantified-Verifiable due to only one hard fact.


reasoning: Paragraph describes a specific cybersecurity incident including detection date, unauthorized access to IT systems, immediate response actions (investigation, incident response plan activation, system shutdown), and containment outcome on the same date, directly matching Incident Disclosure criteria with event narrative and response details.


reasoning: Paragraph discusses financial and operational materiality of an incident without describing the event, scope, or response, matching Strategy Integration per tiebreakers. Contains one specific date as a verifiable fact, qualifying as Firm-Specific.


reasoning: This paragraph describes a specific cybersecurity incident, including the detection date, unauthorized data exfiltration from information systems (potentially containing personal information), and immediate response actions like containment and investigation, directly matching Incident Disclosure criteria.


reasoning: Paragraph focuses on financial costs ($600k), operational impacts (two weeks lost production), and materiality conclusion for Q4 ending June 29, 2024, without any incident narrative or event description, aligning with Strategy Integration per tiebreakers.


reasoning: Paragraph describes the specifics of a cybersecurity incident, including the scope of unauthorized access to a dataset with named personal information types affecting 8.4 million users, directly matching Incident Disclosure criteria for event narrative and affected data scope.


reasoning: The paragraph assesses the materiality and operational impact of 'the incident' on financial systems, operations, and condition without describing the event, dates, scope details, or response actions, matching the tiebreaker for Strategy Integration when only financial/materiality is discussed without incident narrative.


reasoning: The paragraph provides a materiality assessment of a cybersecurity incident without describing the event itself, aligning with Strategy Integration per tiebreakers for financial/materiality discussions lacking incident narrative. No specific facts qualify under the ✓ IS list, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes a real cybersecurity incident including specific dates, ransomware encryption of files, escalation, and unauthorized data disclosure, directly matching Incident Disclosure criteria over Strategy Integration as it provides event narrative rather than just materiality conclusions.


reasoning: This paragraph describes the company's response actions to a cybersecurity incident, including activating its response plan, internal investigation with external advisors, taking systems offline, notifying law enforcement, and ongoing restoration and data assessment, which matches Incident Disclosure as it covers incident response actions for a real event.


reasoning: This paragraph describes response actions taken to contain and investigate a specific cybersecurity incident, including safeguards, monitoring enhancements, expert engagement, and notifications, which aligns with Incident Disclosure criteria for incident narratives and response actions. No qualifying specific facts (e.g., dates, named firms, roles, or quantifiable details) are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes response actions to a specific cybersecurity incident, including activation of protocols, containment measures, investigation assistance, and notifications, fitting the Incident Disclosure category. No specific facts from the ✓ IS list are present, and no hard verifiable facts or named standards qualify it beyond Generic Boilerplate.


reasoning: Paragraph details a specific cybersecurity incident including the date it was learned (February 21, 2024), the event (data exfiltration from information systems, potentially including personal information), and response actions (containment, investigation with law enforcement and experts), directly matching Incident Disclosure criteria. One verifiable specific date qualifies it as Firm-Specific, with no second hard fact for Quantified-Verifiable.


reasoning: This paragraph details the exfiltration of certain files, ongoing investigation into sensitive and personal information in accessed systems, and evaluation of regulatory notifications, directly describing aspects of a real cybersecurity incident including scope and response actions.


reasoning: This paragraph is a standard legal disclaimer regarding the non-filed status of Item 7.01 and incorporation by reference, containing no substantive cybersecurity disclosure or content.


reasoning: This paragraph details the company's remediation actions and post-incident status, including removal of the unauthorized third party, restoration of access, and confirmation of data integrity, which qualifies as incident response actions referencing a real event under Incident Disclosure. No qualifying specific facts (e.g., dates, names, roles, or quantifiables) are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes ongoing response actions (communicating with stakeholders, following standards, identifying effects) and operational impact (continued global provision of products/services) related to a referenced incident, fitting Incident Disclosure despite lacking event narrative or scope details. No other category better matches, as it lacks governance, roles, processes, or financial materiality focus.


reasoning: This paragraph provides a materiality assessment of the cyber incident's impact on business operations and financial condition, referencing prior disclosures without narrating the incident details, which aligns with Strategy Integration per tiebreakers for financial/materiality discussions without event description. No qualifying specific facts are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph focuses on the materiality assessment and financial/operational impact of the incident without describing the event itself, aligning with Strategy Integration per tiebreakers for financial cost or materiality without incident narrative. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes the scope of affected data and elements not compromised (passwords, private keys, customer funds) in a specific incident, directly matching Incident Disclosure criteria for incident narrative and affected data scope. No facts from the ✓ IS list (e.g., dates, named roles, quantified metrics, named firms/tools) are present, and no recognized standards are named, resulting in Generic Boilerplate specificity.


reasoning: The paragraph discusses incorporation of cybersecurity risk management procedures into the company's overall enterprise risk management programs, sharing methodologies, reporting, and governance, which aligns with Risk Management Process (ERM integration). It contains no specific facts, named standards, roles, or details from the ✓ IS list, resulting in Generic Boilerplate.


reasoning: Paragraph discusses financial and operational materiality of a cybersecurity incident without any narrative description of the event, aligning with Strategy Integration per tiebreakers for materiality conclusions. No specific facts, named standards, or verifiable details present, confirming Generic Boilerplate.


reasoning: This paragraph details response actions to a specific cybersecurity incident, including containment, ongoing remediation efforts, and collaboration with experts, which aligns with Incident Disclosure as it references incident response for a real event without describing the event itself.


reasoning: This paragraph is a forward-looking disclaimer about potential cybersecurity incidents and a cross-reference to Risk Factors, containing no substantive disclosure on governance, processes, incidents, or strategy, thus fitting 'None/Other'.


reasoning: The paragraph focuses on the board of directors' oversight of cybersecurity risks and its receipt of updates from the audit committee and executive team on an annual basis, with the board as the grammatical subject. No firm-specific facts or named standards are present, confirming generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management process, including a risk-based approach to evaluating third-party vendors as a component, which fits Risk Management Process per tiebreakers (vendors mentioned as part of internal processes, not central standalone topic). No specific facts, named standards, roles, or details qualify it beyond generic boilerplate.


reasoning: The paragraph focuses on 'The Committee' as the grammatical subject receiving reports from management on cybersecurity risks and incidents, and reporting to the Board, which directly matches Board Governance for committee oversight of cyber risk.


reasoning: The paragraph focuses on the board of directors and its audit committee as the subjects overseeing cybersecurity risk management and assessment, directly matching Board Governance. No qualifying specific facts from the ✓ IS list are present (Audit Committee is explicitly generic), confirming Generic Boilerplate specificity.


reasoning: The paragraph discusses the company's investments in enhancing internal controls and processes to protect systems and infrastructure, focusing on its own internal risk management practices without referencing board, management roles, incidents, or third parties.


reasoning: The paragraph outlines the company's internal cyber risk management program for identifying, assessing, managing, mitigating, and responding to threats, integrated with enterprise risk management, fitting Risk Management Process. It contains no named standards, roles, dates, or other specific facts, making it Generic Boilerplate.


reasoning: The paragraph consists of a section header and generic boilerplate statements about dependency on software infrastructure and third-party systems, with no substantive cybersecurity disclosure on processes, roles, incidents, or strategies.


reasoning: This paragraph describes the company's implementation of a cybersecurity program within its enterprise risk management process to assess, identify, and manage cybersecurity risks, which aligns with 'Risk Management Process' as it focuses on internal processes. It lacks any specific facts, named frameworks, roles, dates, or unique details, qualifying as Generic Boilerplate.


reasoning: The paragraph outlines oversight duties on cybersecurity policies, procedures, compliance, and annual evaluation of the Cybersecurity Committee, with board/committee oversight as the grammatical subject, aligning with Board Governance. No other category fits as centrally.


reasoning: The paragraph describes an individual's non-cybersecurity professional experience in business consultation, operations, and marketing, containing no cybersecurity content or disclosure.


reasoning: The paragraph describes the company's own cybersecurity program and its general protective design, which aligns with Risk Management Process as it focuses on internal processes without referencing board, management roles, vendors, incidents, or strategy integration. It contains no specific facts, named standards, or unique details, making it Generic Boilerplate.


reasoning: The paragraph discusses cybersecurity risk management as an integral part of the company's overall enterprise risk management program, focusing on the company's own internal processes and ERM integration. No specific facts, frameworks, roles, or details are mentioned, making it generic boilerplate.


reasoning: The paragraph details the company's own internal incident response and recovery frameworks and testing practices, fitting Risk Management Process as the central topic. It contains no named standards, specific roles, dates, numbers, or other firm-unique facts from the ✓ IS list, resulting in Generic Boilerplate.


reasoning: The paragraph identifies the 'head of the ITS Department' and executive management as primarily responsible for assessing and managing cybersecurity risks, making management roles the grammatical subject. This fits 'Management Role' per guidelines, as it names a specific cybersecurity-related title and describes their responsibilities.


reasoning: This paragraph updates on the real Change Healthcare cyberattack, describing response actions like ongoing data assessment, support for impacted individuals, notifications to providers/customers, and service restoration progress, which matches Incident Disclosure criteria including incident response and operational impact. It qualifies as cross-referencing prior disclosures but provides substantive details on the event's handling.


reasoning: The paragraph centers on the Board of Directors as the grammatical subject receiving quarterly reports from the CISO and CIO on cybersecurity threats, risks, and mitigation processes, directly matching Board Governance criteria for board oversight and briefing cadence.


reasoning: The paragraph describes the company's internal policies and employee training programs for protecting information, which falls under its own risk management processes. No board, management roles, incidents, or third-party oversight is the focus; training and policy adherence are standard internal practices without specifics.


reasoning: This paragraph provides generic descriptions of cybersecurity vulnerabilities and common threats like malware, ransomware, and phishing without referencing any company-specific processes, governance, incidents, or strategies, making it non-substantive boilerplate content classified as None/Other.


reasoning: The paragraph describes the audit committee reporting to the board on cybersecurity activities and the board receiving briefings from management, making the board and committee the grammatical subjects, which fits Board Governance. No firm-specific facts or named standards are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes general oversight of strategic and material risks by the board and executive officers without any mention of cybersecurity, qualifying as non-cybersecurity content with no substantive disclosure.


reasoning: This paragraph states a standalone materiality conclusion that no cybersecurity incidents have materially affected the company's business, results of operations, or financial position, which aligns with Strategy Integration per the guidelines for materiality assessments without incident narrative.


reasoning: The paragraph focuses on the identification and qualifications of a specific cybersecurity management role (Group Head, Cybersecurity/Information Security Officer), including experience and joining date, making 'Management Role' the clear fit. No other categories apply as there is no mention of board, processes, incidents, or third parties.


reasoning: The paragraph centrally describes the company's process for reviewing and monitoring key third-party IT service providers' cybersecurity measures, including use of a specific third-party tool, making vendor oversight the primary topic rather than a component of internal processes.


reasoning: The paragraph describes a step in the company's incident response process (eradication phase), focusing on internal risk management procedures without referencing specific incidents, roles, or third parties. It contains no firm-specific facts, named standards, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the company's own cybersecurity program as a critical element of its overall risk management approach, focusing on key areas, which aligns with internal risk management processes. It contains no specific details, roles, frameworks, or incidents, making it generic boilerplate.


reasoning: The paragraph vaguely describes generic third-party services with cybersecurity protections but provides no substantive disclosure on processes, oversight, roles, or incidents, fitting None/Other. No specific facts, frameworks, or details are present, confirming Generic Boilerplate.


reasoning: The paragraph focuses on the qualifications and experience of the company's information technology team in cybersecurity, making the team the grammatical subject, which aligns with Management Role; no processes or board oversight is described.


reasoning: The paragraph describes how the CSO and CISO stay informed on risks and communicate updates, with these management roles as the primary grammatical subjects. The reporting to the committee and board is secondary, aligning with tiebreakers prioritizing management roles when they are the focus.


reasoning: The paragraph focuses on the 'internal cybersecurity coordinator' as the grammatical subject, describing its responsibilities, collaboration with IT, and reporting to the CEO, which aligns with Management Role for role identification and reporting lines. No board or broad processes are the main topic.


reasoning: This paragraph provides a standalone materiality conclusion stating no significant cybersecurity breach or associated financial impacts occurred in specified periods, with no incident narrative. It fits Strategy Integration per tiebreakers for materiality without event description.


reasoning: The paragraph centers on the Board receiving regular updates on cybersecurity risks, key indicators, test results, and threat management from the Audit Committee and Cybersecurity team, with the Board as the grammatical subject, aligning directly with Board Governance criteria.


reasoning: The paragraph discusses the company's internal processes for reviewing and updating its incident response plan based on lessons learned and best practices, fitting Risk Management Process. No specific facts, roles, dates, or named elements are present, making it generic boilerplate.


reasoning: The paragraph focuses on specific management roles (CIO and VP of Information Security) as the grammatical subjects, describing their primary responsibility and supervision duties in cybersecurity risk management, aligning directly with 'Management Role' per guidelines and tiebreakers.


reasoning: The paragraph focuses on specific management roles (CIO and Director of IT Security, Risk and Compliance) as the grammatical subjects, detailing their qualifications and experience in cybersecurity areas. This aligns with 'Management Role' criteria for role identification and qualifications.


reasoning: The paragraph focuses on management roles, specifically identifying the CFO as serving as CISO and describing the CISO's use of resources, with the roles as the grammatical subject per tiebreakers.


reasoning: The paragraph describes the Board and Audit Committee's receipt of regular reports and updates from management on cybersecurity risks and incidents, making board oversight the central topic with the board/committee as the grammatical subject.


reasoning: The paragraph describes elements of the company's own cybersecurity programs, including investment in threat intelligence, engagement in forums, and use of external experts for assessments and testing, which aligns with Risk Management Process as the focus is on internal processes rather than board oversight, specific roles, incidents, or third-party risk centrally.


reasoning: The paragraph describes how management monitors cybersecurity incident prevention, detection, mitigation, and remediation, including reliance on service provider notifications, which is the company's internal risk management process with vendors as a component. No specific facts from the ✓ IS list are present, making it generic boilerplate.


reasoning: The paragraph details the company's internal practices for phishing simulations and cybersecurity training, which are components of its risk management processes. It contains no named frameworks, roles, dates, or other specific facts, making it generic boilerplate.


reasoning: The paragraph describes the company's own internal processes for identifying, assessing, and managing cybersecurity risks to its systems and data, making 'Risk Management Process' the most applicable category. Third-party services are mentioned only as a component within the systems, not as the central topic.


reasoning: Paragraph states no material cybersecurity incidents as of specific dates, which is a standalone materiality conclusion without incident narrative, fitting Strategy Integration. Two specific dates qualify as hard verifiable facts for Quantified-Verifiable specificity.


reasoning: The paragraph contains a generic boilerplate statement on the importance of cybersecurity measures with no substantive details, section header-like phrasing, and no reference to specific processes, roles, incidents, or other categories.


reasoning: The paragraph describes cyber insurance coverage as a measure to mitigate financial losses from cyber incidents, fitting Strategy Integration which includes cyber insurance. No incident narrative or other processes are detailed.


reasoning: This paragraph describes the company's own internal strategies for assessing, identifying, and managing cybersecurity risks, including generic monitoring tools and user training, aligning with Risk Management Process. No specific facts, named standards, roles, or unique details are present, resulting in Generic Boilerplate.


reasoning: The paragraph identifies specific C-suite executives (CFO, COO, CEO) and describes their responsibilities for managing cybersecurity risks, policies, strategic decisions, and communications, making management roles the grammatical subject and primary focus.


reasoning: This paragraph states a standalone materiality conclusion regarding no material cybersecurity incidents or expenses in the last three fiscal years, without any incident narrative or description of events, aligning with Strategy Integration per tiebreakers. No qualifying specific facts from the ✓ IS list (no dates, roles, numbers, or named entities), resulting in Generic Boilerplate.


reasoning: The paragraph focuses on the Board of Directors providing oversight of the cybersecurity program through periodic quarterly updates and annual discussions in enterprise risk management, directly matching Board Governance criteria where the board is the grammatical subject.


reasoning: The paragraph describes the internal processes and activities of cybersecurity professionals in threat analysis, policy definition, implementation, monitoring, and incident response, which aligns with Risk Management Process as the company's own internal procedures. No board, management roles, vendors, incidents, or strategy elements are the focus.


reasoning: The paragraph describes the company's own internal cybersecurity risk management system and processes for identifying, assessing, mitigating risks, and protecting information assets, aligning with Risk Management Process. No specific facts, roles, frameworks, or details are mentioned, making it generic boilerplate.


reasoning: This paragraph describes the company's internal process of providing regular cybersecurity training to employees and contractors to address threats and communicate policies, which is a core element of Risk Management Process as it focuses on the company's own internal practices.


reasoning: The paragraph describes the company's establishment of an internal multi-disciplinary team for cybersecurity awareness, training, and information sharing, which is part of its own risk management processes. No board, management roles, incidents, or third-parties are the focus.


reasoning: The paragraph is explicitly titled 'Management's Role' and describes the day-to-day handling of cybersecurity by IT staff, their lack of specialized training, and considerations for enhancement or outsourcing, making management roles and qualifications the grammatical subject and central topic.


reasoning: This paragraph outlines components of the company's internal cybersecurity processes, including employee awareness training and a risk management process for third-party providers involving due diligence and monitoring; vendors are a component of internal processes rather than the central topic. No named standards, roles, dates, or other specific facts are present, confirming generic boilerplate.


reasoning: The paragraph describes the company's own internal Incident Response Plan (IRP) and its testing through annual tabletop exercises, which directly aligns with Risk Management Process focusing on IR planning and internal processes.


reasoning: This paragraph provides a generic statement of high-level cybersecurity goals without referencing any specific processes, roles, incidents, board oversight, or strategies, qualifying as non-substantive disclosure under None/Other.


reasoning: The paragraph describes the company's own multi-layered cybersecurity program, including administrative, physical, technical measures and an incident response plan, focusing on internal processes to protect systems and inform management, which aligns with Risk Management Process. It contains no specific facts, named standards, roles, or unique details, making it Generic Boilerplate.


reasoning: The paragraph details the company's own internal information technology and cybersecurity programs, including policies, procedures, assessments, monitoring, response plans, and testing for controls, which aligns with Risk Management Process as it focuses on internal processes without mentioning board, management roles, vendors, incidents, or strategy.


reasoning: This paragraph states a materiality conclusion about an incident's impact on financial condition or results of operations without any incident narrative or description, aligning with Strategy Integration per tiebreakers for financial/materiality discussions lacking event details.


reasoning: The paragraph describes the company's planned internal processes for identifying, assessing, and managing cybersecurity risks as part of its broader risk management system, which fits Risk Management Process. It contains no references to board oversight, specific management roles, incidents, third-party risks, or strategy integration.


reasoning: The paragraph describes ongoing incident response actions (forensic analysis and investigation) for a specific cybersecurity incident, fitting Incident Disclosure criteria which includes response actions referencing a real event. No descriptive narrative of the event itself, but response details qualify it over other categories like Strategy Integration, which requires financial or materiality focus.


reasoning: The paragraph focuses on seeking insurance reimbursement for costs related to a cyber incident, discussing financial strategy without any description of the incident itself, event details, or materiality assessment beyond insurance claims. This aligns with Strategy Integration per tiebreakers for financial/insurance topics without incident narrative.


reasoning: Paragraph provides a standalone materiality conclusion stating no cybersecurity threats materially affected the company in 2024, with a cross-reference to Risk Factors, fitting Strategy Integration per tiebreakers. Contains one firm-specific date ('2024'), qualifying as Firm-Specific but not reaching Quantified-Verifiable threshold.


reasoning: Paragraph discusses potential material financial impact of an incident without any incident narrative or description, aligning with Strategy Integration per tiebreakers for materiality conclusions. No specific facts, standards, or details qualify it beyond generic boilerplate.


reasoning: The paragraph discusses the lack of material operational disruption and potential financial impacts (revenue loss, expenses, penalties, litigation) from 'the Incident' without describing the event itself, fitting Strategy Integration per tiebreakers for financial/materiality focus without incident narrative.


reasoning: This paragraph provides a standalone materiality conclusion regarding the financial impact of 'the incident' without any description of the event itself, fitting Strategy Integration per tiebreakers. It contains no specific details, dates, or named entities, making it pure boilerplate.


reasoning: Paragraph describes ongoing incident response actions (system restoration, retaining experts, law enforcement collaboration, regulatory notifications) and operational disruption in the context of a disclosed cybersecurity incident, fitting Incident Disclosure. No specific facts from the ✓ IS list; 'leading experts' is generic and excluded per ✗ NOT list, resulting in Generic Boilerplate.


reasoning: The paragraph discusses cybersecurity insurance coverage for various costs, which aligns with Strategy Integration as it covers cyber insurance without any incident narrative or description of events. No specific facts qualify under the ✓ IS list, resulting in Generic Boilerplate specificity.


reasoning: The paragraph identifies specific management roles (Senior Director of IT and CFO) as responsible for implementing and maintaining cybersecurity risk assessment and management processes, making management roles the grammatical subject per category guidelines and tiebreakers.


reasoning: The paragraph describes the details of a cybersecurity incident, including unauthorized access, data exfiltration, scope involving personally identifiable information, and ongoing response actions like notifications, fitting the Incident Disclosure category. No specific verifiable facts, named standards, roles, or unique details are present, making it Generic Boilerplate.


reasoning: This paragraph states a materiality conclusion for 'the Incident' without any description of the event, scope, response, or financial details, aligning with Strategy Integration per tiebreakers for materiality assessments lacking incident narrative.


reasoning: The paragraph discusses the lack of material impact from a cybersecurity incident on operations and financial condition without any incident narrative or description of events, aligning with Strategy Integration per tiebreakers for materiality conclusions. It contains only boilerplate language with no qualifying specific facts.


reasoning: The paragraph provides a materiality assessment of a past cybersecurity incident without describing the event itself, aligning with Strategy Integration per tiebreakers for financial/materiality discussions lacking incident narrative. No specific facts are present, confirming Generic Boilerplate specificity.


reasoning: Paragraph discusses ongoing business and financial risks (litigation, customer behavior, regulatory scrutiny, insurance costs) from a past cybersecurity incident without describing the event itself, fitting Strategy Integration per tiebreakers for financial/insurance impacts without incident narrative.


reasoning: The paragraph focuses on specific management roles including the chief technology officer and senior director of cybersecurity and compliance, their professional certifications, and reporting to the Audit Committee, aligning with Management Role criteria where roles are the grammatical subject. The brief mention of the risk management program is secondary.


reasoning: This paragraph discusses a legal waiver period under credit and lease agreements, with no reference to cybersecurity, incidents, governance, or risk management, making it non-substantive cyber disclosure.


reasoning: This paragraph provides a standalone materiality conclusion regarding an incident without any description of the event itself, aligning with Strategy Integration per the tiebreakers for financial/materiality discussions lacking incident narrative.


reasoning: This paragraph provides a materiality assessment of a cybersecurity incident's impact on operations and financial condition without any incident narrative or description of events, aligning with Strategy Integration per tiebreakers. It contains no specific facts from the ✓ IS list, only boilerplate language, resulting in Generic Boilerplate specificity.


reasoning: This paragraph details incident response actions, including notifications to law enforcement and regulatory bodies about 'the matter' in an Item 1.05 filing, which qualifies as Incident Disclosure.


reasoning: This paragraph details response actions to a cybersecurity incident, including notifications to law enforcement and regulators, which qualifies as Incident Disclosure per the category definition that includes incident response actions referencing a real event ('the matter'). No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph discusses materiality conclusion for an incident (no impact on operations or financial condition) without any incident narrative, description, or event details, per tiebreakers assigning such content to Strategy Integration. No qualifying specific facts from the ✓ IS list; company self-references and boilerplate materiality language do not count.


reasoning: This paragraph describes executive personnel changes at a subsidiary with no reference to cybersecurity risks, incidents, governance, or processes, making it non-cybersecurity content classified as None/Other.


reasoning: The paragraph discusses the lack of material operational disruption and ongoing evaluation of financial, legal, reputational impacts and remediation costs from 'the incident,' without describing the event itself, aligning with Strategy Integration per tiebreakers for materiality conclusions without incident narrative. No specific facts, named standards, or unique details are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph discusses the materiality assessment of a cybersecurity incident on operations and financial condition without describing the event itself, fitting Strategy Integration per tiebreakers for materiality conclusions without incident narrative.


reasoning: This paragraph describes a specific cybersecurity incident involving a third-party provider, including exact dates of notification and confirmation, and the scope of exposure (customer information), fitting Incident Disclosure. It provides two specific dates as hard verifiable facts, qualifying as Quantified-Verifiable.


reasoning: The paragraph describes response actions taken in response to a specific cybersecurity incident, including closing the point of access and notifying impacted customers, which fits Incident Disclosure as it references real event response without financial or materiality focus.


reasoning: This paragraph addresses financial aspects (insurance recoveries for incident costs) of a cybersecurity incident without any narrative description of the event, fitting Strategy Integration per tiebreakers. It contains no specific facts, named standards, or verifiable details, making it Generic Boilerplate.


reasoning: This paragraph details response actions to a specific cybersecurity incident, including containment, restoration of the core IT environment, and progress on business operations, which matches Incident Disclosure criteria for incident response and operational impact.


reasoning: The paragraph describes operational impact of a disclosed incident (inaccessibility of certain networks and transactional services during the disruption) and references a specific status page for updates, aligning with Incident Disclosure criteria for scope and impact; it is not merely a cross-reference or boilerplate.


reasoning: The paragraph focuses on the materiality assessment and potential financial impact of 'the incident' without describing the event itself, aligning with Strategy Integration per tiebreakers for materiality conclusions without incident narrative. No specific facts or named standards are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes response actions to a specific cybersecurity incident, including containment and system restoration efforts, fitting the Incident Disclosure category as it references a real event and incident response without financial or materiality details.


reasoning: Paragraph describes ongoing investigation, scope assessment of exfiltrated personal information, and planned notifications for a specific cybersecurity incident, fitting Incident Disclosure as it references response actions and affected data scope for a real event. No specific facts, dates, names, or quantifiable details present, making it generic boilerplate.


reasoning: The paragraph references 'the incident' but provides no description of the event itself, focusing instead on ongoing generic investigation actions and a materiality conclusion regarding financial impact, which fits Strategy Integration per tiebreakers. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph discusses the immaterial impact of 'the incident' on operations and financial condition without describing the event itself, fitting Strategy Integration per tiebreakers for materiality conclusions without incident narrative. No specific facts, frameworks, or details are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes ongoing incident response actions (investigation and forensic analysis) related to a real cybersecurity incident involving threat actors and potential PII theft, fitting Incident Disclosure. No specific details like dates, scope, or named entities qualify it beyond generic boilerplate.


reasoning: The paragraph discusses the materiality assessment of an incident on financial condition and results of operations without any incident narrative or description, aligning with Strategy Integration per tiebreakers for financial/materiality focus without event details.


reasoning: The paragraph discusses ongoing monitoring of the incident's timing and materiality without describing the event itself, fitting Strategy Integration per tiebreakers for materiality assessments without incident narrative. No specific facts or standards are mentioned, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes the specifics of what occurred during a cybersecurity incident, including unauthorized access, data exfiltration, and encryption of non-production systems, matching the Incident Disclosure category. No verifiable facts, named entities, or standards are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes aspects of an actual cybersecurity incident, including the undetermined scope of affected data, ongoing investigation, and response actions like working with a cyber insurance provider. It fits Incident Disclosure as it references real event details and response without focusing solely on financial/insurance matters.


reasoning: Paragraph assesses potential material financial impact of 'the incident' without any description of the event, scope, or response, aligning with Strategy Integration tiebreaker for materiality discussions lacking incident narrative.


reasoning: Paragraph describes operational impacts (shops open, online ordering disruptions in parts of US, uninterrupted deliveries) of a disclosed cybersecurity incident in an Item 1.05 filing, fitting the scope and operational impact criteria for Incident Disclosure without detailing the incident narrative itself.


reasoning: The paragraph describes a specific cybersecurity incident including the date it occurred (March 1, 2025), the nature of the event (system outage), and initial response actions (activating incident response team), fitting the Incident Disclosure category per tiebreakers for incident narratives with dates and response details.


reasoning: The paragraph describes incident response actions (mailing notification letters) and scope of potentially affected data (personal information) following an investigation, fitting Incident Disclosure as it references a real event's response without focusing on financial impacts or processes.


reasoning: This paragraph describes post-incident response actions (restoration of IT systems and data), ongoing operational impacts, and investigation outcomes for a specific cyber incident, fitting Incident Disclosure. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes a specific cybersecurity incident, including the exact date (February 3, 2025), the event (systems outage caused by a cybersecurity attack), and response actions (activating incident response team), directly matching Incident Disclosure criteria.


reasoning: This paragraph describes a specific cybersecurity incident, including the exact date of awareness and unauthorized access to systems, directly matching the Incident Disclosure category criteria for referencing a real event with details like dates and access.


reasoning: This paragraph describes the operational scope and impact of a specific cybersecurity incident (shipping, receiving, manufacturing, back office functions) along with response actions (temporary measures, restoration), fitting Incident Disclosure. No specific facts like dates, names, or quantifiables are present, making it Generic Boilerplate.


reasoning: The paragraph describes the nature of a cybersecurity incident (threat actor access to IT systems containing sensitive personal information) and response actions (planned notifications), fitting Incident Disclosure as it references a real event with scope and response details. No firm-specific or verifiable facts are present, making it Generic Boilerplate.


reasoning: The paragraph discusses the ongoing assessment of the incident's potential material impact on financial condition and results of operations without describing the event itself, fitting Strategy Integration per tiebreakers for materiality conclusions. No incident narrative or other process details are present.


reasoning: The paragraph discusses the immaterial financial and operational impact of a cybersecurity incident without describing the event itself, aligning with Strategy Integration per tiebreakers for materiality conclusions lacking incident narrative. No specific facts qualify under the ✓ IS list, confirming Generic Boilerplate specificity.


reasoning: This paragraph discusses the materiality assessment of an incident on operations and financial condition without any incident narrative or description of events, aligning with Strategy Integration per tiebreakers. It contains no specific facts from the ✓ IS list, only boilerplate language, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes response actions taken during a specific cybersecurity incident (activating response process and identifying the cause as a fourth-party vendor compromise), directly matching Incident Disclosure criteria for incident narrative and response. No qualifying specific facts (e.g., dates, named firms, roles, or numbers) are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph discusses the financial impacts and costs of a cyber incident without describing the event itself, aligning with Strategy Integration per tiebreakers for financial cost discussions lacking incident narrative. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: Paragraph discusses financial and materiality impacts of an incident without any event description, narrative, or response details, matching Strategy Integration per tiebreakers. Contains one specific date (Q4 2023), qualifying as Firm-Specific but not reaching Quantified-Verifiable threshold.


reasoning: This paragraph describes the operational impact and scope of a specific cybersecurity incident, including disruption to business applications and financial reporting systems lasting approximately six weeks, which matches Incident Disclosure criteria for incident narrative and affected systems scope.


reasoning: This paragraph describes a specific cybersecurity incident, including the exact date of detection and the nature of unauthorized activity (attempt to fraudulently obtain funds), directly matching Incident Disclosure criteria.


reasoning: This paragraph describes a specific cybersecurity incident, including the exact date of notification, unauthorized activity on IT systems, and immediate response actions to investigate, contain, and remediate, directly matching the Incident Disclosure category criteria.


reasoning: The paragraph describes the operational impact on the primary website during the incident (inaccessibility) and a specific response action (creation of a special communications website), referencing a real event, which fits Incident Disclosure. The named URL is a firm-specific named system, qualifying as Firm-Specific with one verifiable fact but not reaching Quantified-Verifiable.


reasoning: This paragraph describes specific response actions taken during a cybersecurity incident, including temporary measures like manual processing and alternative channels while restoring systems, fitting Incident Disclosure as it details incident response without financial or materiality focus.


reasoning: This paragraph details response actions to a cybersecurity incident (notifying regulators and working with law enforcement regarding unauthorized access), which qualifies as Incident Disclosure including incident response actions for a real event. No qualifying specific facts (e.g., dates, named firms, roles, or numbers) are present after filtering per guidelines.


reasoning: The paragraph focuses on the company's own internal processes for monitoring and developing IT networks and infrastructure to prevent, detect, and mitigate cybersecurity risks, fitting Risk Management Process. It contains no specific facts, named frameworks, roles, or details, qualifying as Generic Boilerplate.


reasoning: The paragraph details the company's internal processes for evaluating, escalating, responding to, and learning from cybersecurity incidents, including the Incident Response Program and Business Continuity Plan, which aligns with Risk Management Process. Vendors and third-party incidents are mentioned only as components of these internal processes, not as the central topic.


reasoning: This paragraph is a cross-reference to a press release (Exhibit 99.1) with no substantive description of the incident, response, or processes itself.


reasoning: The paragraph details the company's internal cybersecurity processes including threat assessment, layered security, training, tools referencing industry standards, third-party assessments, and vendor risk management, making Risk Management Process the best fit; third-party elements are components of these processes, not the central topic. It names recognized standards (NIST, ISO, SOC-1, SOC-2) but lacks any firm-specific facts from the ✓ IS list, confirming Sector-Adapted specificity.


reasoning: The paragraph describes the Board's oversight of cybersecurity risks, including members' expertise, ERM integration, and the Risk Committee's specific responsibilities like quarterly reviews and incident reporting, with the Board and committee as the grammatical subjects.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including adoption of the CIS Controls framework, regular risk assessments integrated with ERM, infrastructure design, dedicated personnel, and training programs, making Risk Management Process the best fit. Board oversight via the Technology Committee is mentioned briefly in passing, not as the primary focus.


reasoning: The paragraph describes the company's own cybersecurity program and its key internal processes across governance, collaboration, technical safeguards, incident response planning, third-party risk management, and training, making Risk Management Process the most applicable category. Vendor risk is mentioned only as one component, not centrally.


reasoning: The paragraph primarily identifies and details the qualifications, reporting lines, and experience of the CISO and CTO, making management roles the grammatical subject and central focus. Processes are described in the context of these roles' responsibilities.


reasoning: The paragraph focuses on the internal management team's composition, roles, and activities in managing and reporting on cybersecurity risks, with specific roles like Sr. Director of IT as key subjects; board/Audit Committee oversight is secondary and informed by management. Specific team composition and named IT role qualify as firm-specific facts without reaching two verifiable hard facts for higher specificity.


reasoning: The paragraph details the company's internal risk management processes such as monitoring, training, penetration testing, and investments, with third-party oversight mentioned as an integrated component rather than the central focus. Specific management roles are noted briefly at the start but do not dominate the content.


reasoning: The paragraph states no material cybersecurity risks or incidents in fiscal 2024 affected the company's business strategy, results of operations, or financial condition, which is a materiality assessment fitting Strategy Integration; it includes forward-looking potential impacts but no incident narrative or process descriptions.


reasoning: The paragraph describes the company's own internal cybersecurity risk management program, including policies, standards, processes for assessing and managing risks, and resource allocation, which aligns with 'Risk Management Process'. No qualifying specific facts from the ✓ IS list (no named roles, committees, dates, programs, products, firms, or quantified metrics), resulting in Generic Boilerplate.


reasoning: This paragraph provides generic boilerplate description of reliance on IT systems and broad cybersecurity risks without referencing board oversight, management roles, internal processes, incidents, third-party risks, or strategy integration, qualifying as None/Other with no substantive disclosure.


reasoning: The paragraph describes the company's own internal cybersecurity processes, including identification/escalation, technical safeguards, incident response planning, third-party risk as a component, and employee training, aligning with Risk Management Process. Vendor oversight is mentioned but not central, and no board/management roles or incidents are the focus.


reasoning: Paragraph consists of generic boilerplate language describing common cybersecurity threats, vulnerabilities, and potential adverse impacts without referencing any specific company processes, roles, incidents, or events, making it non-substantive disclosure.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including framework adoption (NIST CSF), security controls, awareness training, third-party oversight as a program component, monitoring, and resiliency planning. Third-party risk is mentioned as part of the overall risk management program, not as the central topic.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, including adoption of the NIST framework, monitoring by an IT team, specific measures like penetration testing and vendor audits, and employee training, with management roles mentioned in passing. Vendor oversight is a component of these processes, not the central topic.


reasoning: This paragraph details the company's own internal cybersecurity processes, including multi-layered defense, monitoring, policies, training, information sharing, and supplier engagement as components of risk management. Third-party aspects are integrated into internal processes rather than being the central topic, aligning with Risk Management Process per tiebreakers.


reasoning: The paragraph centers on the Chief Information Officer’s identification, qualifications, experience, certifications, reporting lines, and role in the Risk Report process, with management roles as the primary grammatical subjects. Board and Audit Committee oversight is mentioned but secondary, aligning with tiebreakers favoring Management Role when roles are the main focus.


reasoning: The paragraph details the company's internal processes for risk identification, mitigation using the NIST Framework, monitoring tools, protective measures, incident response plans, enterprise risk assessments, and ongoing monitoring, making Risk Management Process the central topic. Board sharing is mentioned briefly but not the focus.


reasoning: The paragraph focuses on identifying and describing specific cybersecurity roles (vCISO, analysts, engineers, director) in the outsourced team, their responsibilities, qualifications, and oversight by management, making management roles the grammatical subject per tiebreakers. It does not center on board oversight or internal processes independent of these roles.


reasoning: The paragraph outlines the company's cybersecurity program as part of its ERM approach, detailing internal processes across governance, collaboration, safeguards, incident response, third-party management, and training, making Risk Management Process the best fit. Vendor risks are mentioned as one component, not the central topic.


reasoning: The paragraph describes the company's own internal cybersecurity processes, including monitoring tools, strategies like Zero Trust and AI/ML, backup processes, training, and a specific incident reporting timeline, fitting Risk Management Process. It mentions third-party services only as utilized tools, not as central vendor oversight.


reasoning: The paragraph primarily identifies and describes the qualifications, reporting lines, and responsibilities of management roles like the IT Manager, General Counsel, and IT Steering Committee in administering and overseeing the Cybersecurity Program. It contains firm-specific facts such as named roles, committees, and internal programs but lacks two or more hard verifiable facts (e.g., dates, dollars, named external firms) required for Quantified-Verifiable.


reasoning: This paragraph outlines the company's internal processes for cybersecurity threat identification, prevention, mitigation, technical safeguards, incident response planning, third-party risk as one component, and employee training, aligning with Risk Management Process as the company's own processes are the central topic. Third-party risk is mentioned but not central, and no incidents, board, or management roles are described.


reasoning: The paragraph details the company's internal cybersecurity processes, including monitoring, use of a third-party service as part of monitoring, incident response planning, and external consultations for vulnerability management, making Risk Management Process the best fit; third-party elements are components of internal processes, not the central topic.


reasoning: The paragraph describes the company's internal incident response processes, including the Agility Plan, CMT coordination, training, assessments, and tools provided to the security team, making Risk Management Process the best fit. Brief mentions of board coordination and third-party consultants are components of these internal processes, not central topics.


reasoning: The paragraph focuses on the Board of Directors and Audit Committee's oversight, review, and assessment of cybersecurity risks, making the board/committee the grammatical subjects, which aligns with Board Governance. It includes generic disclaimers and cross-references but no incident details or other category foci.


reasoning: Paragraph assesses materiality of past incidents ('these incidents have not had a material impact') without any incident narrative or description, aligning with Strategy Integration for materiality conclusions; includes generic risk discussion and cross-reference, creating some ambiguity with None/Other.


reasoning: The paragraph details the company's internal cybersecurity processes, including monitoring, detection, vulnerability scanning, penetration testing, third-party risk management via a risk register, employee training, and disaster recovery, making 'Risk Management Process' the best fit. Third-party risk is mentioned as a component of these internal processes, not the central topic, per tiebreakers.


reasoning: The paragraph provides a standalone materiality conclusion stating no cybersecurity incidents during the year ended December 31, 2024 had a material impact, with discussion of potential business and financial effects, aligning with Strategy Integration per tiebreakers. It contains one specific date as a firm-specific fact but lacks a second verifiable fact for higher specificity.


reasoning: Paragraph provides a materiality conclusion on past generic incidents (no event descriptions, dates, or specifics) and forward-looking assurances, fitting Strategy Integration per tiebreakers for materiality without incident narrative. No qualifying specific facts from the ✓ IS list; IRP is a generic program name and excluded.


reasoning: The paragraph describes the company's own internal technical, physical, and organizational cybersecurity measures, processes, and policies, such as monitoring, incident response, training, and risk assessments, which aligns with Risk Management Process. Vendor mentions are incidental components, not central, and no board/management roles or incidents are the focus. No qualifying specific facts or named standards are present, resulting in Generic Boilerplate.


reasoning: The paragraph focuses on the company's internal cybersecurity program, including processes for assessing, identifying, managing risks and incidents, monitoring, training, third-party oversight as a component, and ERM integration, making Risk Management Process the best fit. Board and management roles are described briefly in the context of these processes rather than as the primary subjects.


reasoning: The paragraph primarily describes the company's own risk assessment and cybersecurity risk management programs, including processes to identify and manage threats, fitting 'Risk Management Process'; the materiality statement is a minor component without incident details or business strategy focus.


reasoning: The paragraph identifies specific management roles (CIO, chief digital officer, CISO) and details their qualifications, experience, and oversight responsibilities, making 'Management Role' the primary focus. No board oversight, processes, incidents, or third-parties are central.


reasoning: The paragraph primarily describes the company's internal cybersecurity and technology risk management program, including its structure, policy, framework adoption (NIST, CRI), governance processes, ERM integration, employee responsibilities, and brief vendor control reviews as a component of internal processes. Vendor oversight is not central, fitting Risk Management Process over Third-Party Risk.


reasoning: The paragraph identifies specific management roles (CISO, CCO) and their qualifications, experience, reporting, and expertise in cybersecurity, making management roles the grammatical subject and primary focus per category guidelines.


reasoning: The paragraph primarily describes the company's comprehensive approach to cybersecurity risk management, including policies, standards, processes for assessing and managing risks, with brief generic mentions of board and management oversight. No incident narrative or specific details qualify it for other categories; it fits Risk Management Process as the company's own internal processes are the central topic.


reasoning: The paragraph details USCF's information security program, annual risk profile evaluations, policy enforcement, and third-party due diligence as components of the company's internal cybersecurity risk management processes, with third-party oversight not being the central topic.


reasoning: The paragraph primarily identifies and details the qualifications of specific management roles (CTO, CIO, CISO) responsible for cybersecurity risks, fitting 'Management Role'; processes and board reporting are secondary. Multiple cybersecurity-specific roles and quantified years of experience (three instances) exceed the threshold for Quantified-Verifiable.