content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: The paragraph consists entirely of a disclaimer regarding material impact and a cross-reference to other sections of the filing, which falls under the None/Other category.

provider: google


content_category: Board Governance

reasoning: The paragraph focuses primarily on the Board's oversight responsibilities and reporting structure, making 'Board Governance' the correct category. It contains no specific facts (only generic roles like President, CEO, General Counsel, and the Board), resulting in a 'Generic Boilerplate' specificity rating.


content_category: Management Role

reasoning: The paragraph focuses on the specific management role of the Information Security Officer (ISO), detailing their reporting line to the CRO and their specific qualifications and responsibilities.


content_category: Risk Management Process

reasoning: The paragraph describes the company's general approach to risk management and internal processes, mentioning third parties only as a component of these internal efforts rather than as the central topic of vendor oversight. It contains no specific names, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses primarily on the Audit Committee's oversight responsibilities and reporting structure, making Board Governance the primary category. While specific management roles are mentioned, they are presented in the context of reporting to the Board committee.


reasoning: The paragraph describes the company's internal risk management processes and programs (ERM and ERA) as the primary subject, fitting the Risk Management Process category. It is classified as Firm-Specific because it names unique internal programs and specifies the number of risk categories, though it does not reach the threshold for Quantified-Verifiable.


reasoning: The paragraph primarily describes the integration of cybersecurity into the company's ERM program and general risk management approach, which falls under Risk Management Process. While it mentions the Board and specific roles, these are secondary to the description of the risk management framework and process.


reasoning: The paragraph describes the company's internal risk management processes and the composition of the team responsible for these tasks, making 'Risk Management Process' the most appropriate category. It is 'Firm-Specific' because it identifies the specific departments (Legal, Compliance, and Finance) involved in the cybersecurity risk team.


reasoning: While the paragraph mentions the Board, the core of the disclosure focuses on the specific management role (HSE Director) responsible for overseeing the cybersecurity program and their qualifications.


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


reasoning: The paragraph describes the company's internal cybersecurity programs and risk management approach, making 'Risk Management Process' the appropriate category. It is classified as 'Sector-Adapted' because it explicitly references ISO and NIST frameworks without providing any firm-specific details or verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity program, incident response plan, and risk assessment activities, which are standard components of a Risk Management Process. It contains no specific dates, named third-party firms, named products, or unique identifiers that would elevate it beyond generic boilerplate.


reasoning: The paragraph focuses on the roles and reporting lines of specific management positions (VP, IT Data Security and CTO) and a named internal committee, which takes precedence over the brief mention of board oversight.


reasoning: The paragraph focuses on the Board's oversight role and the delegation of duties to the Audit Committee, making 'Board Governance' the primary category. While it mentions specific management roles, these are presented in the context of reporting to the Board/Committee, and the Board remains the grammatical subject of the governance structure.


reasoning: The paragraph describes the company's internal cybersecurity processes and risk assessment framework, making it a Risk Management Process disclosure. It is classified as Firm-Specific because it identifies a specific cross-functional team composition (risk management, legal, finance, accounting, operations, and information technology) involved in the assessment process.


reasoning: The paragraph describes the company's general approach to risk management and enterprise risk integration without naming specific frameworks, roles, or verifiable facts.


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


content_category: Strategy Integration

reasoning: The paragraph functions as a risk factor disclosure and includes a standalone materiality conclusion stating that cybersecurity threats have not materially affected the company's business or financial condition.


reasoning: The paragraph describes the company's internal risk management processes and the activities of an internal team, which fits the Risk Management Process category. It contains no specific dates, named tools, named third-party firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident response and escalation procedures, making it a Risk Management Process disclosure. It is Firm-Specific because it names specific internal roles (Senior Director of Information Security) and committees (Technology Risk Management Committee, Materiality Committee) unique to the company's governance structure.


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


reasoning: The paragraph describes the company's internal cybersecurity program, incident response plan, and monitoring processes, making 'Risk Management Process' the most appropriate category. It is classified as 'Sector-Adapted' because it explicitly references the NIST framework but lacks other firm-specific or verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity program and risk management processes without foregrounding a specific management role or incident. It contains no specific facts (no named frameworks, no named vendors, no specific dates, no specific tools), making it generic boilerplate.


reasoning: The paragraph focuses entirely on the oversight responsibilities of the Audit Committee and the Board of Directors regarding cybersecurity, making Board Governance the clear category. It contains no specific facts (Audit Committee and Board are generic, and reporting cadences like 'quarterly' and 'periodic' are excluded per instructions), resulting in a Generic Boilerplate classification.


reasoning: The paragraph focuses primarily on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity, making Board Governance the primary category. While it mentions specific management roles, these are secondary to the description of the board's oversight structure.


reasoning: The paragraph describes internal processes like incident response plans, tabletop exercises, and business continuity planning, which are standard components of a risk management program. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as risk assessments and control implementation, without foregrounding a specific management role or board oversight. It is classified as Sector-Adapted because it explicitly names recognized security frameworks (CIS and PCI DSS) but lacks unique, firm-specific details.


reasoning: The paragraph focuses on the qualifications, reporting lines, and specific roles of the CDIO/CISO, making 'Management Role' the correct category. It is classified as 'Quantified-Verifiable' because it contains multiple hard facts, including specific named firms where the individual previously worked and a specific start year.


reasoning: The paragraph focuses on the Board and its committees' oversight responsibilities, specifically detailing the formation of a dedicated Cybersecurity Risk Subcommittee.


reasoning: The paragraph describes the company's internal processes and tools for cybersecurity risk management, such as incident response and monitoring, without naming specific products, firms, or roles. It uses generic descriptions like 'security incident and event manager interface' and 'third-party experts' which do not qualify as specific facts.


reasoning: The paragraph focuses on the board's oversight responsibility as the primary subject, making Board Governance the most appropriate category. It contains no specific facts, named roles, or unique identifiers, resulting in a Generic Boilerplate classification.


reasoning: The paragraph focuses on the Board and its committees (specifically the Cybersecurity Subcommittee) as the primary subjects responsible for oversight, fitting the Board Governance category. It is Firm-Specific because it names a unique internal committee (Cybersecurity Subcommittee) and its establishment date.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the CIO, making 'Management Role' the most appropriate category. It is 'Firm-Specific' because it identifies the CIO and the ERM Committee, which are specific organizational details.


reasoning: The paragraph focuses on the Board of Directors and its Audit Committee as the primary subjects overseeing cybersecurity risk management and reporting cadences. While it mentions management roles (CEO/CFO) and third-party providers, these are described in the context of the Board's oversight structure rather than as the central topic.


reasoning: The paragraph focuses primarily on the Board and Audit Committee's oversight role, making Board Governance the most appropriate category. It is classified as Sector-Adapted because it explicitly names the NIST Cybersecurity Framework but lacks firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity policies, procedures, and risk management strategies, making 'Risk Management Process' the most appropriate category. It is classified as 'Sector-Adapted' because it explicitly references the NIST Cybersecurity Framework but lacks other firm-specific or verifiable facts.


content_category: Third-Party Risk

reasoning: The paragraph focuses primarily on the company's oversight and requirements imposed on third-party vendors, which aligns with the Third-Party Risk category. It contains no specific names, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses entirely on the qualifications, responsibilities, and role of the CISO, making 'Management Role' the correct category.


reasoning: The paragraph focuses on the specific management role of the 'Director, IT Infrastructure & Security' and their responsibilities, making 'Management Role' the most appropriate category.


reasoning: The paragraph describes the company's internal cybersecurity program and incident response processes, making 'Risk Management Process' the appropriate category. It is classified as 'Sector-Adapted' because it explicitly references the NIST Cybersecurity Framework (NIST CSF) but lacks other firm-specific or verifiable facts.


reasoning: The paragraph primarily discusses the potential material impact of cybersecurity threats and includes a standard disclaimer about the lack of past material breaches. While it mentions incident response, the core focus is on the materiality and strategic acknowledgment of risk rather than the process itself or a specific incident.


reasoning: The paragraph describes the company's internal cybersecurity program and processes, including specific frameworks and certifications adopted, which aligns with the Risk Management Process category.


reasoning: The paragraph focuses on the qualifications, certifications, and reporting lines of the CISO and the Information Security team, making 'Management Role' the primary category. It qualifies as 'Quantified-Verifiable' because it lists numerous specific certifications and a specific number of years of experience.


reasoning: The paragraph focuses on the responsibilities of the Enterprise Risk Management Committee and specific management roles (CISO, CDO) in overseeing risk, making 'Management Role' the most appropriate category.


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


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity threats for the fiscal year, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year ('fiscal 2025'), which is a unique fact, but it does not meet the threshold for Quantified-Verifiable as it lacks a second hard fact.


reasoning: The paragraph focuses on the role and qualifications of the CISO and the specific committee they lead, making 'Management Role' the most appropriate category. It qualifies as 'Quantified-Verifiable' because it lists the CISO's specific years of experience and multiple professional certifications.


reasoning: The paragraph focuses on the Board and its Audit Committee's oversight responsibilities regarding cybersecurity. While it mentions the Audit Committee, this is considered a generic governance body in the context of cybersecurity oversight, and no other specific facts are present.


reasoning: The paragraph describes the company's internal processes (assessments, patch management, monitoring) as the grammatical subject, fitting the Risk Management Process category. It contains no specific dates, named tools, named third-party firms, or specific cybersecurity roles, rendering it generic boilerplate.


content_category: Incident Disclosure

reasoning: The paragraph describes a specific past cybersecurity incident, including the date and the affected system, which fits the Incident Disclosure category.


reasoning: The paragraph focuses primarily on the oversight of third-party providers, including specific contractual expectations and assessment processes, which aligns with the Third-Party Risk category. It is classified as Firm-Specific because it references a unique internal document, the 'Sustainable Purchasing Charter'.


reasoning: The paragraph discusses the materiality of cybersecurity risks and potential financial impact without describing a specific incident or internal process, which aligns with Strategy Integration. It contains no specific facts, dates, or named entities, making it Generic Boilerplate.


reasoning: The paragraph primarily describes the company's risk management processes, specifically how they align with the NIST framework and integrate into their ERM program. While it mentions the Board and management, these are introductory references rather than the central focus of the paragraph.


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


reasoning: The paragraph focuses on the qualifications, experience, and reporting lines of the Chief Information Security Officer, making 'Management Role' the primary category. It qualifies as 'Quantified-Verifiable' because it contains multiple specific, verifiable facts including named certifications (CISSP-ISSMP, CISA), a named framework (ITIL), and specific historical dates regarding the CEO's prior role.


reasoning: The paragraph primarily discusses the materiality of cybersecurity threats and incidents, including a disclaimer about future impact, which aligns with Strategy Integration. While it mentions a past incident, it does not provide a narrative of the event, serving instead as context for the materiality conclusion.


reasoning: The paragraph describes the company's general approach to using external experts and training employees as part of its cybersecurity program, which falls under Risk Management Process. It contains no specific names, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses primarily on the Board of Directors' oversight responsibilities and their interaction with the CSO, making 'Board Governance' the most appropriate category. It is classified as 'Firm-Specific' because it identifies a specific cybersecurity-focused role (CSO) involved in the governance process.


reasoning: The paragraph focuses primarily on the responsibilities, qualifications, and reporting lines of the VP of IT, making 'Management Role' the most appropriate category.


reasoning: The paragraph describes the company's intended risk management program and processes. While it mentions the Board of Directors, this is generic governance language, and the primary focus is on the description of the risk management framework and processes.


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


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


reasoning: The paragraph is a standard forward-looking disclaimer regarding the limitations of cybersecurity controls and includes a cross-reference to the Risk Factors section, containing no substantive cybersecurity disclosure.


reasoning: The paragraph describes the company's cybersecurity risk management program and explicitly references recognized frameworks (NIST CSF and Sarbanes Oxley) without providing firm-specific details.


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


reasoning: The paragraph describes the details, scope, and ongoing nature of a specific cybersecurity incident, which fits the Incident Disclosure category. It contains a specific date (late November 2023), making it Firm-Specific, but lacks a second hard verifiable fact to reach Quantified-Verifiable status.


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


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


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


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


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


reasoning: The paragraph describes the scope and nature of data involved in a specific cybersecurity incident, which is the core definition of Incident Disclosure. It contains no specific dates, named third-party firms, or other hard verifiable facts as defined in the instructions.


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


reasoning: The paragraph describes the status and impact of a specific cybersecurity incident, including remediation efforts and operational status, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, making it generic in specificity.


reasoning: The paragraph describes the timeline, nature, and scope of a specific cybersecurity incident, which fits the Incident Disclosure category. It is Firm-Specific because it contains specific dates related to the incident, though it does not reach Quantified-Verifiable as it lacks a second category of hard facts (e.g., named third-party firms or specific dollar amounts).


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of occurrence and the specific system affected, which places it squarely in Incident Disclosure.


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


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


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


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


reasoning: The paragraph describes the details, impact, and remediation status of a specific cybersecurity incident, fitting the Incident Disclosure category. It is Firm-Specific because it includes a specific date of the incident, though it does not reach Quantified-Verifiable as it lacks a second hard fact (e.g., a named third-party firm or specific dollar amount).


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


reasoning: The paragraph focuses exclusively on the financial impact, cost estimates, and materiality assessment of an incident without describing the incident itself, which aligns with Strategy Integration. It is Firm-Specific because it provides a unique, company-specific dollar range for remediation costs.


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


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


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


reasoning: The paragraph focuses exclusively on the materiality assessment of the incident regarding financial condition and insurance coverage, which falls under Strategy Integration. It contains no specific facts (dates, named firms, specific dollar amounts, or unique programs), rendering it generic boilerplate.


reasoning: The paragraph describes the status of a specific cybersecurity incident, including remediation efforts, operational impact, and financial consequences, which places it squarely in Incident Disclosure.


reasoning: The paragraph focuses on the financial impact and materiality of the incident (insurance recovery and lack of material impact), which falls under Strategy Integration according to the tiebreakers, despite mentioning remediation activities.


reasoning: The paragraph focuses on the materiality assessment and financial impact of an incident, which falls under Strategy Integration. It contains three specific dates, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the operational impact and remediation timeline of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It is Firm-Specific because it details the specific operational halts and restoration timeline (mid-June), though it lacks the two hard verifiable facts required for Quantified-Verifiable.


reasoning: The paragraph focuses exclusively on the materiality assessment and financial impact of the incident rather than describing the incident itself, fitting the Strategy Integration category. It contains two specific dates, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident involving a named third-party vendor (CDK Global) and provides the date of the event, making it an incident disclosure.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including dates and the nature of the event, which places it squarely in the Incident Disclosure category.


reasoning: The paragraph focuses exclusively on the financial and operational materiality of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, named firms, or other verifiable facts, making it Generic Boilerplate.


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


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


reasoning: The paragraph describes an ongoing cybersecurity incident, including specific dates of the event and the disclosure, as well as the name of the third-party vendor involved.


reasoning: The paragraph describes a specific cybersecurity incident, including the dates of the disruption and restoration, the cause, and the response actions taken.


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


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


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


reasoning: The paragraph describes the ongoing investigation, the nature of the incident (access to retail environment, data exfiltration), and the response actions (notifying authorities), which fits the Incident Disclosure category. It contains no specific dates, named firms, or other verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph focuses on the financial implications and liquidity arrangements resulting from a cybersecurity incident, rather than describing the incident itself or internal governance processes.


reasoning: The paragraph describes the ongoing investigation, status of data theft, and materiality assessment of a specific cybersecurity incident, which places it squarely in Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


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


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


reasoning: The paragraph focuses on the responsibilities and qualifications of the Chief Technology Officer, making 'Management Role' the most appropriate category.


reasoning: The paragraph describes the ongoing response to a specific, named cybersecurity incident (the cyberattack on Change Healthcare), which places it squarely in Incident Disclosure.


reasoning: The paragraph describes the timing and nature of a specific cybersecurity incident and the company's initial response actions, qualifying it as an incident disclosure.


reasoning: The paragraph focuses exclusively on the financial and operational impact of the incident, specifically revenue recognition delays and one-time expenses, without describing the incident itself.


reasoning: The paragraph focuses on the roles and qualifications of specific cybersecurity leaders (CIO and Information Security Director) as the grammatical subjects, fitting the Management Role category. It reaches Quantified-Verifiable specificity because it includes two specific, verifiable facts regarding the years of experience for these named roles.


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


reasoning: The paragraph focuses on the board of directors and the audit committee's oversight responsibilities, which places it squarely in Board Governance. It contains no specific facts (Audit Committee and Board are generic entities), resulting in a Generic Boilerplate classification.


reasoning: The paragraph focuses on the materiality of past cybersecurity incidents and financial impact, which falls under Strategy Integration. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's cybersecurity program and risk management structure. While it mentions a Global CISO, the primary focus is on the operation of the CDRM organization and the program's design, making 'Risk Management Process' the most appropriate category.


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


reasoning: The paragraph focuses on the Board's oversight role via the Audit Committee. While it mentions 'Senior IT leadership' and 'Chief Financial Officer', these are generic roles and do not constitute specific management role disclosures or verifiable facts.


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


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


reasoning: The paragraph focuses primarily on the Board of Directors' oversight responsibilities, training, and policy approval, making 'Board Governance' the correct category. It is 'Firm-Specific' because it names a specific committee ('Enterprise Risk Management Committee') that is not a generic 'Audit Committee'.


reasoning: The paragraph explicitly identifies the Chief Financial Officer as the primary individual responsible for cybersecurity oversight, making 'Management Role' the correct category. It is 'Firm-Specific' because it names a specific board committee (Nomination and Corporate Governance Committee) rather than a generic one.


reasoning: The paragraph describes the company's general approach to risk management and regulatory compliance without referencing specific roles, tools, or unique programs.


reasoning: The paragraph describes the company's enterprise risk management process and the integration of cybersecurity within it, making 'Risk Management Process' the primary category. While specific roles like CISO and CIO are mentioned, they are participants in the process rather than the primary subject, and the paragraph lacks sufficient hard verifiable facts (like dates or specific tools) to reach the 'Quantified-Verifiable' level.


reasoning: The paragraph focuses on the materiality of cybersecurity risks and incidents on the company's financial condition and business strategy, which falls under Strategy Integration. It contains no specific dates, named roles, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph foregrounds the Chief Security Officer (CSO) and their collaboration with the enterprise risk management team, making 'Management Role' the most appropriate category.


reasoning: The paragraph describes the company's internal risk management processes and programs as the grammatical subject, without foregrounding a specific management role or incident. It contains no specific dates, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk assessment and mitigation processes without referencing any specific management roles, board oversight, or unique identifiers, making it a standard description of risk management activities.


reasoning: The paragraph describes internal processes like training, awareness updates, and penetration testing, which are standard risk management activities. No specific frameworks, named roles, or verifiable facts are mentioned, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes and procedures for managing cybersecurity threats and incidents without referencing specific management roles, frameworks, or verifiable facts.


reasoning: The paragraph focuses entirely on the qualifications, tenure, and certifications of the CISO and CTO, which are specific management roles.


reasoning: The paragraph focuses on the qualifications and responsibilities of a specific named individual (Jack Wang) who is tasked with managing cybersecurity risks, fitting the Management Role category.


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


reasoning: The paragraph primarily establishes the Board's role in overseeing cybersecurity risk and its integration into the company's enterprise risk management framework, while referencing recognized industry standards.


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


reasoning: The paragraph focuses on the establishment and composition of a board-level committee, making 'Board Governance' the correct category. It is classified as 'Firm-Specific' because it names a unique committee and specific board member credentials, but it does not meet the 'Quantified-Verifiable' threshold as it lacks two or more hard facts like dollar amounts, headcounts, or named third-party security firms.


reasoning: The paragraph describes the company's general approach to using external experts for risk assessment and testing, which is a component of their internal risk management process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's general approach to risk identification and management processes without naming specific roles, frameworks, or unique programs.


reasoning: The paragraph describes the company's internal incident response processes and escalation procedures, making 'Risk Management Process' the appropriate category. It is 'Firm-Specific' because it names a specific internal committee ('Privacy and Security Subcommittee') that is not a standard generic committee.


reasoning: The paragraph focuses on the Board of Directors and the Audit Committee's oversight role regarding cybersecurity, which aligns with the Board Governance category. It contains no specific facts (Audit Committee and Board are generic, 'annually' is a generic cadence, and 'IRP' is a generic program name), resulting in a Generic Boilerplate classification.


reasoning: The paragraph focuses on the qualifications and experience of specific management roles (Vice President of Information Systems and Chief Financial Officer), making 'Management Role' the correct category.


reasoning: The paragraph focuses on the Board's oversight activities and the cadence of their cybersecurity briefings. While specific management roles are mentioned, they are cited as the presenters to the Board, confirming Board Governance as the primary category.


reasoning: The paragraph provides a standalone materiality assessment regarding cybersecurity risks and explicitly states that no material incidents have occurred, which aligns with the Strategy Integration category.


reasoning: The paragraph identifies the specific management role (CFO) responsible for cybersecurity oversight, making 'Management Role' the primary category. It is 'Firm-Specific' because it cites a specific, verifiable headcount/experience metric ('over 70 years of combined work experience'), which is a unique fact about this company's IT department.


reasoning: While the paragraph mentions board oversight and general risk management, the central focus is on the specific management role (Vice President of Operations) responsible for the cybersecurity program, which takes precedence under the provided tiebreakers.


reasoning: The paragraph describes the company's general approach to risk management and incident response procedures without foregrounding a specific management role or board committee. It contains no specific facts, dates, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the components and activities of the company's cybersecurity risk management program, such as training and policy development. It is classified as Firm-Specific because it identifies a specific cybersecurity-related role ('head of Information Security').


reasoning: The paragraph describes the company's risk management activities (simulation exercises, monitoring, threat intelligence) and the engagement of external resources to support these processes. It is classified as Firm-Specific because it cites a specific timeframe ('fiscal 2024') and specific types of engagements, though it does not name the specific firms, preventing it from reaching Quantified-Verifiable status.


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


reasoning: The paragraph focuses on the specific roles and reporting lines of the CISO and CTO, making Management Role the most appropriate category.


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


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


reasoning: The paragraph describes standard risk management activities (penetration testing, third-party reviews) without naming specific firms, tools, or frameworks, making it a generic description of internal processes.


reasoning: The paragraph discusses the potential material adverse effect of cybersecurity incidents and the limitations of cybersecurity insurance, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph describes the company's internal security tools, policies, and testing procedures (tabletop exercises, penetration testing, training), which are standard components of a risk management program. No specific management roles, named third-party firms, or unique identifiers are mentioned, making it generic boilerplate.


reasoning: The paragraph focuses on the Board's delegation of cybersecurity oversight to the audit committee, making Board Governance the primary category. It contains no specific facts (Audit Committee and generic management/board references are excluded per instructions), resulting in Generic Boilerplate.


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


reasoning: The paragraph focuses entirely on the Board and the Audit Committee's oversight responsibilities regarding cybersecurity. It contains no specific facts, named cybersecurity roles, or unique programs, making it generic boilerplate.


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


reasoning: The paragraph focuses on the responsibilities and qualifications of a specific management role, the Director of Cybersecurity, making 'Management Role' the primary category.


reasoning: The paragraph consists entirely of generic risk factor boilerplate describing common threats and the general importance of cybersecurity without detailing specific governance, management, processes, or incidents.


reasoning: The paragraph describes the company's internal audit process for assessing cybersecurity risks, which falls under Risk Management Process. It contains no specific facts, named roles, or frameworks, making it Generic Boilerplate.


reasoning: The paragraph focuses on the purchase of cyber insurance and the management of that policy, which falls under Strategy Integration. While it mentions a specific role (VP of Finance and Treasurer), this role is not a cybersecurity-specific role (like CISO or CIO), and the rest of the paragraph describes generic business continuity and testing practices.


reasoning: The paragraph describes the company's internal vulnerability assessment program and risk management processes, which fits the Risk Management Process category. It contains no specific dates, named tools, named roles, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's adoption of a cybersecurity framework to guide its internal policies, which falls under Risk Management Process. It is classified as Sector-Adapted because it explicitly names the NIST Cybersecurity Framework without providing any firm-specific details.


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


reasoning: The paragraph describes the company's general approach to risk management and cybersecurity integration without naming specific roles, tools, or frameworks.


reasoning: The paragraph describes the company's internal processes for incident detection and response (Security Operations Center, incident severity matrix), which falls under Risk Management Process. It contains no specific dates, named third-party firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal security measures and processes, which falls under Risk Management Process. It contains only generic security practices and no specific, verifiable facts.


reasoning: The paragraph describes the company's general approach to overseeing cybersecurity risks, which falls under Risk Management Process. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph foregrounds the Senior Vice President, IT Operations as the leader directing the information security team's activities, which aligns with the Management Role category.


reasoning: Although the paragraph mentions an incident, it focuses entirely on the materiality assessment and the uncertainty of financial/operational impact rather than describing the incident itself, which triggers the Strategy Integration tiebreaker.


reasoning: The paragraph primarily describes the company's risk management processes and approach, while the mention of the board and audit committee is standard boilerplate governance language that does not constitute a specific governance disclosure.


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


reasoning: The paragraph focuses on the materiality assessment of the incident and regulatory obligations without describing the incident itself, which aligns with Strategy Integration. It contains no specific facts, dates, or named entities, making it Generic Boilerplate.


reasoning: The paragraph describes the company's general cybersecurity program and internal processes using standard, non-specific terminology without naming any frameworks, specific tools, or unique identifiers.


reasoning: The paragraph describes the scope and impact of a previously disclosed incident (data exfiltration and PII involvement), which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic.


reasoning: The paragraph describes the timeline and nature of a specific cybersecurity incident, including the date of discovery and the nature of the unauthorized access.


reasoning: The paragraph describes the timeline and response actions related to a specific cybersecurity incident, which falls squarely under Incident Disclosure. It is Firm-Specific because it includes a specific date (February 6, 2024) identifying the event, but does not meet the threshold for Quantified-Verifiable as it lacks a second hard fact (e.g., a named third-party firm or specific dollar amount).


reasoning: The paragraph describes the timeline and response actions related to a specific cybersecurity incident, which is the definition of Incident Disclosure.


reasoning: The paragraph describes the response actions taken following a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named tools, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the operational impact and recovery status of a specific cybersecurity incident, fitting the Incident Disclosure category. It contains two hard verifiable facts (a specific date and a percentage), qualifying it as Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident, including the detection and the company's response actions (isolating systems), which fits the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery and the nature of the event (unauthorized access and encryption), which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes the timeline, scope, and nature of a specific cybersecurity incident, including references to past activity and affected systems, which clearly falls under Incident Disclosure.


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


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


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


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


reasoning: The paragraph focuses exclusively on the materiality and financial impact of a cybersecurity incident without describing the event itself, which aligns with Strategy Integration. It contains multiple specific dates and time periods, meeting the threshold for Quantified-Verifiable.


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


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


reasoning: The paragraph focuses exclusively on the financial materiality and impact of a cybersecurity incident without describing the incident itself, fitting the Strategy Integration category. It contains multiple verifiable financial figures and a specific date, meeting the criteria for Quantified-Verifiable.


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


reasoning: The paragraph describes a specific cybersecurity incident, including the nature of the unauthorized access and the financial impact, which places it squarely in Incident Disclosure.


reasoning: The paragraph focuses exclusively on the financial impact (expenses and revenue) of a previously disclosed incident without describing the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph describes a specific cybersecurity incident (ransomware) and the company's immediate response actions, which falls squarely under Incident Disclosure. It contains one hard verifiable fact (the date), making it Firm-Specific.


reasoning: The paragraph provides specific details regarding the scope and impact of a cybersecurity incident, including the number of affected consumers.


reasoning: The paragraph focuses on the materiality assessment of an incident, which falls under Strategy Integration. It is Firm-Specific because it names a specific product/system ('Dropbox Sign') affected by the incident.


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


reasoning: The paragraph describes the scope and nature of an ongoing incident investigation, specifically identifying the types of data involved, which qualifies as Incident Disclosure. It lacks specific dates, named entities, or verifiable metrics, resulting in a Generic Boilerplate classification.


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


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


reasoning: The paragraph describes the company's response actions to a cybersecurity incident, which is the core definition of Incident Disclosure.


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


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


reasoning: The paragraph describes the scope of data exfiltrated during a cybersecurity incident, which qualifies as an Incident Disclosure. It includes a specific fiscal year-end date, which is a firm-specific fact.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of identification and the nature of the event, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the ongoing investigation and response actions related to a specific cybersecurity incident, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses exclusively on the financial and materiality implications of an incident, including insurance and expenses, without providing any descriptive details about the incident itself.


reasoning: The paragraph focuses on the financial impact (expenses, profit margins, material impact) of a cybersecurity incident rather than describing the incident itself or the response process. It qualifies as Quantified-Verifiable because it contains multiple hard facts: a specific dollar amount, a specific duration, and a specific date.


reasoning: The paragraph describes the timeline, detection, and response actions related to a specific cybersecurity incident, which fits the Incident Disclosure category. It is Firm-Specific because it includes a specific date of the incident, though it does not reach Quantified-Verifiable as it lacks a second hard fact (e.g., a named third-party firm or specific dollar amount).


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


reasoning: The paragraph focuses on the materiality assessment and financial impact of an incident rather than describing the incident itself, which aligns with Strategy Integration. It is Firm-Specific because it references a specific fiscal period end date (March 31, 2026).


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


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the nature of the event (data exfiltration), and the immediate response actions taken.


reasoning: The paragraph provides an update on a specific, named cybersecurity incident (the Change Healthcare cyberattack) and references specific actions taken in response, fitting the Incident Disclosure category.


reasoning: The paragraph describes the company's ongoing response actions and operational status following a previously mentioned incident, which falls under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, making it generic.


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


reasoning: The paragraph describes the company's response actions to a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


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


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


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


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


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


reasoning: The paragraph focuses exclusively on the materiality assessment of a previously disclosed incident without describing the incident itself or its specific response actions.


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


reasoning: The paragraph describes the status of an ongoing investigation into a cybersecurity incident, including the exfiltration of files and the assessment of regulatory obligations, which falls squarely under Incident Disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident without describing the event itself, which is classified as Strategy Integration.


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


reasoning: The paragraph describes the scope and nature of a specific cybersecurity incident, including the number of affected users, which qualifies as an incident disclosure.


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


reasoning: The paragraph focuses on the materiality assessment of an incident and its financial impact on the company, which falls under Strategy Integration. It is Firm-Specific because it names a specific subsidiary (Targus) affected by the incident.


reasoning: The paragraph describes how cybersecurity risk management is integrated into the company's broader enterprise risk management program, which is a process-oriented disclosure. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph consists entirely of forward-looking disclaimers and a cross-reference to another section of the filing, containing no substantive cybersecurity disclosure.


reasoning: The paragraph describes the company's internal risk management process regarding vendor evaluation. While it mentions third-party vendors, the central topic is the company's internal risk-based approach, and it lacks any specific details or named entities.


reasoning: The paragraph focuses on the board's oversight role and reporting structure, making 'Board Governance' the correct category. It contains no specific facts (only generic references to the board, audit committee, and executive leadership), resulting in 'Generic Boilerplate' specificity.


reasoning: The paragraph focuses entirely on the Committee's oversight role and reporting structure to the Board, making Board Governance the primary category. It contains no specific facts (e.g., named committees, specific dates, or named roles), resulting in a Generic Boilerplate classification.


reasoning: The paragraph focuses entirely on the board of directors and the audit committee's oversight role, making 'Board Governance' the correct category. It contains no specific facts (Audit Committee is explicitly excluded from the 'IS' list, and 'board of directors' is generic), resulting in 'Generic Boilerplate' specificity.


reasoning: The paragraph describes oversight responsibilities and explicitly names a 'Cybersecurity Committee,' which is a non-generic committee, placing it in Board Governance and Firm-Specific.


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


reasoning: This paragraph describes the general professional background of an individual (Mr. Tao) and does not discuss cybersecurity governance, management roles in cybersecurity, or any specific cybersecurity processes.


reasoning: The paragraph describes general internal controls and investment in cybersecurity without referencing specific management roles, board oversight, or unique programs, making it a standard description of risk management processes.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management without referencing specific management roles, board oversight, or unique programs, making it a standard description of risk management processes.


reasoning: The paragraph provides a materiality assessment regarding a cybersecurity incident without describing the incident itself, which is the defining characteristic of Strategy Integration. It contains no specific facts, dates, or named entities, making it Generic Boilerplate.


reasoning: The paragraph focuses on the qualifications and tenure of a specific cybersecurity management role, meeting the criteria for Management Role. It contains multiple verifiable facts, including the specific role title, years of experience, and the year the individual joined the company.


reasoning: The paragraph explicitly identifies the 'head of the ITS Department' as the primary individual responsible for cybersecurity risk management, which aligns with the Management Role category.


reasoning: The paragraph describes the general purpose of the company's cybersecurity program without referencing specific management roles, board oversight, or unique processes, making it a standard description of risk management intent.


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


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


reasoning: The paragraph focuses on the qualifications and roles of specific cybersecurity management personnel (CIO and Director of IT Security, Risk and Compliance). It qualifies as Quantified-Verifiable because it lists two specific cybersecurity-related roles and a specific number of years of experience.


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


reasoning: The paragraph provides a generic, high-level statement about board and management responsibilities regarding risk in general, not specifically cybersecurity risk, and lacks any specific details.


reasoning: The paragraph focuses on the Board of Directors' oversight activities and reporting cadence, making Board Governance the primary category. It is classified as Firm-Specific because it identifies specific cybersecurity-related management roles (CISO and CIO) involved in the reporting process.


reasoning: This paragraph is a generic disclaimer about cybersecurity threats and vulnerabilities, lacking any substantive disclosure regarding governance, management, or specific processes.


reasoning: The paragraph describes the company's general approach to risk management and cybersecurity programs without referencing specific roles, frameworks, or unique identifiers.


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


reasoning: This paragraph describes generic business services (email, cloud storage) and does not provide substantive disclosure regarding cybersecurity governance, risk management, or specific incidents.


category_confidence: medium

reasoning: The paragraph discusses the qualifications of the IT team, which aligns with Management Role, but it lacks any specific details, named roles, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a generic step in an incident response process ('Eradication') without referencing any specific management roles, incidents, or unique company programs.


reasoning: This paragraph serves as a section header or introductory sentence leading into a list, containing no substantive disclosure or specific details.


reasoning: The paragraph focuses on the activities and reporting lines of specific cybersecurity management roles (CSO and CISO), making 'Management Role' the primary category.


reasoning: The paragraph describes the company's general approach to integrating cybersecurity into its enterprise risk management program, which is a description of the risk management process. It contains no specific facts, named roles, or verifiable details, qualifying it as generic boilerplate.


reasoning: The paragraph focuses on the Board's oversight activities and the information flow to the Board, making 'Board Governance' the primary category. It contains no specific dates, named roles, or unique identifiers, relying entirely on generic terms like 'Audit Committee' and 'Cybersecurity team'.


reasoning: The paragraph explicitly identifies a specific management role (CFO serving as CISO) as the primary subject responsible for cybersecurity, which aligns with the Management Role category.


reasoning: The paragraph explicitly identifies specific management roles (CIO and VP of Information Security) as the primary subjects responsible for cybersecurity oversight, fitting the Management Role category.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight role regarding cybersecurity risks. It contains no specific facts, as 'Board', 'Audit Committee', and 'management' are explicitly excluded from the specific facts list.


reasoning: The paragraph identifies a specific cybersecurity role (internal cybersecurity coordinator) and describes their responsibilities and reporting line, which aligns with the Management Role category.


reasoning: The paragraph describes general risk management activities (threat intelligence, external experts, testing) without naming specific roles, frameworks, or verifiable facts. It focuses on the company's internal processes rather than board oversight or management roles.


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


reasoning: The paragraph describes the general process of monitoring and incident response, with 'Management' as the subject, but lacks any specific management roles, named committees, or unique programs, making it a generic description of risk management activities.


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


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


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


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents without describing any specific event, which falls under Strategy Integration. It is Quantified-Verifiable because it cites two specific calendar dates.


reasoning: The paragraph focuses on the responsibilities of specific management roles (CFO, COO, CEO) regarding cybersecurity. However, these roles (CEO, CFO, COO) are explicitly excluded from the 'specific facts' list as they are generic C-suite titles present at every company, resulting in a Generic Boilerplate classification.


reasoning: The paragraph describes the company's internal process for maintaining and updating its incident response plan, which is a core component of risk management, but it lacks any specific details or unique identifiers.


reasoning: The paragraph describes the company's general approach to risk management and cybersecurity strategies without naming specific roles, frameworks, or unique programs.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity incidents and financial impact for specific fiscal periods, which falls under Strategy Integration. It qualifies as Quantified-Verifiable because it cites two specific, verifiable fiscal year-end dates.


reasoning: The paragraph focuses on the Board of Directors' oversight role, making 'Board Governance' the correct category. It contains no specific facts (only generic references to the Board and periodic/quarterly cadences), resulting in 'Generic Boilerplate' specificity.


reasoning: The paragraph describes an internal cybersecurity program and team structure, which falls under Risk Management Process. It is Firm-Specific because it names a unique internal program ('CyberSmart Defender Network') and a specific year of establishment.


reasoning: The paragraph describes general cybersecurity functions and activities performed by unnamed staff, which falls under the Risk Management Process category as it describes the company's operational approach to security.


reasoning: The paragraph describes the company's general approach to risk management without referencing specific management roles, board oversight, or unique programs, making it a standard description of a risk management process.


reasoning: The paragraph describes internal security training and awareness practices, which falls under Risk Management Process. It contains only common security practices and no unique or verifiable facts.


reasoning: The paragraph describes the company's general approach to risk management and cybersecurity processes without referencing specific management roles, frameworks, or unique company details.


reasoning: The paragraph describes the company's internal incident response process and testing procedures, which falls under Risk Management Process. It contains no specific facts (IRP is a generic term, and tabletop exercises are explicitly listed as a common practice/not a specific fact), making it generic boilerplate.


reasoning: The paragraph explicitly discusses the management of cybersecurity and the qualifications of the personnel responsible, fitting the Management Role category. It contains no specific names, dates, or verifiable facts, making it generic boilerplate.


reasoning: This paragraph is a generic statement of purpose or goal regarding cybersecurity and does not describe a specific process, governance structure, or incident.


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


reasoning: The paragraph describes the company's general cybersecurity program and internal reporting processes without foregrounding a specific management role or incident, making it a Risk Management Process disclosure. It contains no specific dates, named tools, or unique identifiers, qualifying it as generic boilerplate.


reasoning: The paragraph focuses on the qualifications of a specific individual and the reporting lines of named cybersecurity management roles (CTO and Senior Director of Cybersecurity and Compliance).


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


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


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


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for a specific fiscal year, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific year (2024), but does not meet the threshold for Quantified-Verifiable as it lacks a second hard fact.


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


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


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


reasoning: The paragraph describes a standard internal security practice (training) as part of the company's broader risk management efforts, without naming specific roles, frameworks, or unique programs.


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


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


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


reasoning: The paragraph discusses cybersecurity insurance and financial/operational impact (guidance) without describing a specific incident or internal process, fitting the Strategy Integration category. It contains no specific dates, dollar amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph describes internal cybersecurity practices, including training and vendor risk management, which are components of the company's broader risk management process.


reasoning: The paragraph describes the nature of a cybersecurity incident (data exfiltration and PII involvement) and the ongoing response actions, which fits the Incident Disclosure category. It contains no specific dates, named firms, or other verifiable facts, making it generic.


reasoning: The paragraph describes the operational impact of an ongoing incident and directs readers to a specific company-hosted status page, which constitutes an incident disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules. It contains only standard boilerplate language regarding financial impact.


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


reasoning: The paragraph describes incident response actions (notifying law enforcement and regulators) related to a previously mentioned matter, which falls under Incident Disclosure. It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


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


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


reasoning: This paragraph discusses legal waivers related to credit and lease agreements, which is standard legal boilerplate and does not contain substantive cybersecurity disclosure.


reasoning: This paragraph discusses executive leadership changes at a subsidiary, which is unrelated to cybersecurity governance, risk management, or incident disclosure.


reasoning: The paragraph describes incident response actions (notifying law enforcement and regulators) related to a disclosed incident, which falls under Incident Disclosure. It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality assessment regarding a cybersecurity incident without describing the event itself, which aligns with the Strategy Integration category.


reasoning: The paragraph discusses the financial impact (insurance recovery) of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, dollar amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph discusses the materiality of an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules. It contains only standard boilerplate language regarding financial impact and materiality.


reasoning: The paragraph describes the timeline and nature of a specific cybersecurity incident involving a third-party provider, which qualifies as an Incident Disclosure. It is Firm-Specific because it contains specific dates related to the event, but does not reach Quantified-Verifiable as it lacks a second category of hard facts (e.g., named third-party firm, dollar amounts, or named products).


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


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


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


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


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


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


reasoning: The paragraph describes the company's ongoing response to a previously disclosed incident and provides a materiality conclusion, which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the operational impact of an ongoing cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, making it Generic Boilerplate.


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


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


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


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


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


reasoning: The paragraph discusses the ongoing monitoring of materiality regarding an incident without describing the incident itself, which aligns with the Strategy Integration category for standalone materiality/status statements.


reasoning: The paragraph describes a specific response action (mailing notification letters) taken in the context of an incident investigation, which falls under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, making it generic.


reasoning: The paragraph describes the status and resolution of a previously disclosed incident, including system restoration and the conclusion of an investigation, which falls squarely under Incident Disclosure.


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


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


reasoning: The paragraph describes a specific cybersecurity incident (systems outage caused by an attack) and the immediate response actions taken, which fits the Incident Disclosure category.


reasoning: The paragraph describes the timing and nature of a specific cybersecurity incident, which falls under Incident Disclosure. It contains one specific date, making it Firm-Specific but not Quantified-Verifiable.


reasoning: The paragraph describes the ongoing status and response actions related to a previously disclosed cybersecurity incident, which fits the Incident Disclosure category.


reasoning: The paragraph describes the cause and response actions related to a specific cybersecurity incident, placing it squarely in Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph describes the nature of a cybersecurity incident (unauthorized access to systems containing personal information) and the company's response (notification plans), which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


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


reasoning: The paragraph discusses the materiality of an incident on financial results without describing the incident itself, which falls under Strategy Integration. It is Firm-Specific because it references a specific fiscal period ('fourth quarter of 2023').


reasoning: The paragraph describes the operational impact of an incident and the company's specific response action (creating a dedicated communication website), which falls under Incident Disclosure.


reasoning: The paragraph describes the operational impact of a specific cybersecurity incident, which falls under Incident Disclosure. It contains one hard verifiable fact (the duration of the impact), making it Firm-Specific.


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


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


reasoning: The paragraph describes actions taken in response to an incident (notifying authorities, working with law enforcement), which falls under Incident Disclosure. It contains no specific dates, named tools, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity on IT systems) and provides the date of notification, which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes the operational impact and response actions related to a cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection and the nature of the event, which qualifies it as an Incident Disclosure.


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


reasoning: The paragraph foregrounds the Chief Security Officer (CSO) as the primary evaluator of incident criticality, which aligns with the Management Role category. It is classified as Firm-Specific because it names a specific cybersecurity role and internal program names.


reasoning: The paragraph discusses the ongoing response and restoration efforts related to a specific cybersecurity incident (the Change Healthcare event), which qualifies as Incident Disclosure. It contains two hard verifiable facts (a specific date and a named system), meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's cybersecurity risk management strategy, including frameworks used and internal oversight processes, making 'Risk Management Process' the most appropriate category. It is 'Firm-Specific' because it names a specific board committee (Technology Committee) and a specific framework (CIS Controls), but does not meet the threshold for 'Quantified-Verifiable' as it lacks two hard, verifiable facts like dates or dollar amounts.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as threat assessment, layered security, and training, making 'Risk Management Process' the correct category. It is classified as 'Sector-Adapted' because it explicitly references NIST, ISO, SOC-1, and SOC-2, but lacks unique firm-specific facts like named tools, specific dates, or named third-party firms.


reasoning: The paragraph describes the company's general reliance on IT and its ongoing efforts to monitor and protect its networks, which falls under Risk Management Process. It contains no specific names, dates, roles, or frameworks, making it generic boilerplate.


reasoning: The paragraph explicitly defines a specific internal management team (the 'Risk Management Team') and identifies the specific roles (including the Sr. Director of IT) that comprise it, making Management Role the primary focus.


reasoning: The paragraph primarily describes the company's internal risk management processes, such as vendor oversight and security investments, while mentioning specific roles and frameworks. Although it mentions management roles, the focus is on the operational processes (monitoring, vendor reviews, training) rather than the qualifications or reporting lines of the individuals themselves.


reasoning: The paragraph focuses on the materiality of cybersecurity risks and incidents, explicitly stating that no risks from cybersecurity threats materially affected the company during fiscal 2024.


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


reasoning: The paragraph describes the company's internal cybersecurity program, processes, and controls, making 'Risk Management Process' the most appropriate category. It is classified as 'Sector-Adapted' because it explicitly references the NIST CSF framework but lacks other firm-specific or verifiable facts.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and regulatory compliance, which falls under Risk Management Process. It contains no specific, verifiable facts or named cybersecurity-specific roles/programs, making it generic boilerplate.


reasoning: The paragraph focuses primarily on the qualifications, experience, and reporting lines of the CISO and CTO, making 'Management Role' the most appropriate category. It contains multiple verifiable facts, including specific years of experience and named third-party organizations/programs, qualifying it as 'Quantified-Verifiable'.


reasoning: The paragraph focuses on the qualifications, roles, and experience of the specific individuals (vCISO, analysts, engineers) managing the company's cybersecurity, which aligns with the Management Role category. It qualifies as Quantified-Verifiable because it lists multiple specific professional certifications and a specific number of years of experience.


reasoning: This paragraph describes general reliance on IT systems and lists common cybersecurity threats (malware, phishing, ransomware) without detailing specific governance, management, or risk management processes. It functions as a standard risk factor disclosure rather than a substantive description of the company's cybersecurity program or governance.


reasoning: The paragraph outlines the components of the company's cybersecurity program, making 'Risk Management Process' the most appropriate category. It is classified as 'Firm-Specific' because it identifies specific cybersecurity leadership roles (CIO and Global Head of IT Security) within the organization.


reasoning: The paragraph focuses on identifying specific management roles (IT Manager, General Counsel, CEO, COO) and detailing their qualifications and experience, which aligns with the Management Role category. It qualifies as Quantified-Verifiable because it contains multiple specific, verifiable facts regarding years of experience and named internal committees/programs.


reasoning: The paragraph primarily describes the company's internal processes for managing cybersecurity risk, including the adoption of the NIST framework and the oversight by specific management roles. While management roles are mentioned, they are described in the context of managing the processes, making Risk Management Process the primary category.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including incident response, technical safeguards, and third-party oversight, without foregrounding a specific management role or board committee.


reasoning: The paragraph primarily describes the company's internal risk management processes, including specific internal programs like the IRP, BCP, and Disaster Recovery Plan, which elevates it beyond a generic description.


reasoning: The paragraph describes the company's internal cybersecurity program and risk management processes, such as monitoring, training, and policy development, without foregrounding a specific management role or board oversight.


reasoning: The paragraph describes the company's internal cybersecurity tools (EDR, SIEM), processes, and strategic initiatives, making it a clear example of Risk Management Process. It is Firm-Specific because it includes a specific timeframe for incident reporting (24 hours) and a specific strategic outlook for 2025, though it lacks the two hard verifiable facts required for Quantified-Verifiable.


reasoning: The paragraph outlines the company's overall cybersecurity program and risk management approach, foregrounding the program itself rather than a specific board or management role as the primary subject. While it mentions the CISO and specific departments, these are presented as components of the broader risk management program structure.


reasoning: The paragraph is a standard risk factor disclosure describing potential threats and the lack of material impact to date, without detailing specific governance, management, or processes.


reasoning: The paragraph focuses on the company's internal processes and programs (Agility Plan, incident response policies) for managing cybersecurity risks. While it mentions the CIO and CMT, these are presented as components of the overall risk management framework rather than the primary subject of a management role disclosure.


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


reasoning: The paragraph describes the company's internal cybersecurity programs, processes, and safeguards (incident response, technical controls, risk management) without foregrounding a specific management role or board committee. It contains no specific dates, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for monitoring, incident response, and engagement with external experts, making it a clear example of Risk Management Process. It is classified as Firm-Specific because it names a specific internal program, the 'Cybersecurity Incident Response Plan'.


reasoning: The paragraph focuses on identifying specific cybersecurity leaders (Joel Austin, Malia Hodges, and the CISO), their qualifications, and their roles, making 'Management Role' the primary category. It contains multiple quantified facts regarding their years of experience, meeting the threshold for 'Quantified-Verifiable'.


reasoning: The paragraph focuses primarily on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity, making Board Governance the most applicable category. It contains no specific facts (Audit Committee and Board of Directors are considered generic governance entities per the instructions), resulting in a Generic Boilerplate classification.


reasoning: The paragraph describes the company's internal cybersecurity processes, programs, and tools (e.g., monitoring, encryption, disaster recovery, vulnerability scanning). It does not foreground a specific management role or board oversight, nor does it describe a specific incident or third-party vendor relationship as the central topic.


reasoning: The paragraph primarily discusses the materiality of cybersecurity risks and explicitly states that no material incidents occurred during the fiscal year, which aligns with Strategy Integration. It is classified as Firm-Specific because it includes a specific fiscal year-end date.