reasoning: The paragraph primarily describes the company's enterprise risk management program and information security program, making 'Risk Management Process' the most appropriate category. While it mentions the Board and Risk Committee, these are secondary to the description of the internal security program and processes.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily discusses the materiality of past incidents and provides forward-looking disclaimers regarding future risks, which aligns with Strategy Integration. While it mentions an 'IRP', this is a generic internal program reference and does not elevate the specificity beyond boilerplate.

provider: google


content_category: Management Role

reasoning: The paragraph is primarily focused on the qualifications, experience, and responsibilities of the Chief Information Officer, which aligns with the Management Role category. While it also describes the 'Risk Report' process, the foregrounding of the specific management role takes precedence.


reasoning: The paragraph focuses on the qualifications and leadership of the Chief Technology Officer, making 'Management Role' the primary category. It qualifies as 'Quantified-Verifiable' because it contains multiple hard facts, including specific years of experience, named certifications, and named internal programs/committees.


category_confidence: medium

reasoning: The paragraph describes the reporting lines and qualifications of the cybersecurity leadership team, which foregrounds the management role despite also touching on board oversight and risk processes.


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal cybersecurity measures and programs, which falls under Risk Management Process. It contains no specific dates, named tools, named third-party firms, or specific cybersecurity roles, making it generic boilerplate.


reasoning: The paragraph focuses on the specific roles, qualifications, and experience of the CISO and CCO, making 'Management Role' the primary category. It qualifies as 'Quantified-Verifiable' because it contains multiple hard facts, including specific years of experience and named certifications/degrees.


reasoning: While the paragraph mentions a risk management program, the primary substantive disclosure is the materiality conclusion regarding cybersecurity risks and incidents, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph focuses on the company's internal cybersecurity and technology risk management program, policies, and frameworks. While it mentions committees and third-party risk, these are described as components of the overarching risk management program, making 'Risk Management Process' the most appropriate category.


reasoning: The paragraph describes the company's information security program and risk assessment procedures, which falls under Risk Management Process. It contains no specific dates, named cybersecurity roles, named third-party firms, or specific tools, making it generic boilerplate.


reasoning: The paragraph explicitly lists specific management roles (CISO, CIO, Chief Transformation Officer) and details their qualifications, making 'Management Role' the primary focus despite the inclusion of process descriptions.


content_category: None/Other

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


reasoning: The paragraph primarily describes the company's internal risk management processes, including monitoring, vendor assessments, and framework adoption. It is classified as Firm-Specific because it names a specific internal committee (Information Security Risk Committee) and multiple specific frameworks.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and oversight without naming specific roles, frameworks, or unique programs. It functions as an introductory overview of the risk management strategy.


reasoning: The paragraph primarily describes the company's internal processes for risk assessment, monitoring, and incident response, which fits the Risk Management Process category. While it mentions specific roles like the Senior Director of Information Technology, these are mentioned in the context of executing these processes rather than defining the management structure itself.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management, including policies, committees, and controls, without naming specific roles, frameworks, or unique identifiers. While it mentions a 'committee' and 'third-party risk management program', these are generic descriptions rather than named, specific entities or programs.


reasoning: While the paragraph mentions board oversight, the core of the disclosure focuses on the specific management role (Director of IT) responsible for directing the cybersecurity program and the team's composition.


reasoning: The paragraph primarily describes the company's internal cybersecurity program, risk assessment approach, and monitoring functions, which fits the Risk Management Process category. While it mentions the CIO and CISO, they are mentioned in the context of reviewing the program rather than being the primary subject of the paragraph's description of roles.


reasoning: The paragraph primarily describes the company's incident response processes and risk management activities, such as the IRP and collaboration with the Department of Defense. While specific management roles (CISO, CIO) are mentioned, they are described in the context of executing these processes rather than as the primary focus of the disclosure.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and oversight without naming specific roles, committees, frameworks, or incidents. It relies entirely on boilerplate language regarding risk mitigation and investment.


reasoning: The paragraph describes the company's internal cybersecurity strategy and processes, specifically detailing their incident response planning and risk management framework, making 'Risk Management Process' the most appropriate category.


reasoning: The paragraph focuses on identifying specific management personnel (Luca Fabbri, Christine Garrison) and their qualifications/responsibilities regarding cybersecurity, which fits the Management Role category. It contains numerous verifiable facts, including specific dates, named firms, and years of experience, meeting the threshold for Quantified-Verifiable.


reasoning: While the paragraph discusses third-party interactions, the core of the text describes the company's internal processes (IT review, cybersecurity team assessments, incident response plan) for managing those risks, making 'Risk Management Process' the most appropriate category. The mention of the FAIR model qualifies it as Sector-Adapted.


content_category: Board Governance

reasoning: The paragraph focuses primarily on the Board's oversight responsibilities and the reporting structure to the Board and Audit Committee, making Board Governance the primary category. While management roles (CIO/CISO) are mentioned, they are described in the context of their reporting obligations to the Board.


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


reasoning: The paragraph describes the company's internal incident response plan and testing procedures, which are core components of a risk management program. It does not name specific roles, frameworks, or external entities, relying instead on generic descriptions of processes and personnel.


reasoning: The paragraph focuses on the roles and responsibilities of specific management positions (CISO, CIO) in overseeing security programs and incident response, making 'Management Role' the most appropriate category.


reasoning: The paragraph primarily describes the company's internal processes and programs (Disaster Recovery Plan, incident response policies) for managing cybersecurity risks. While it mentions the CIO and the Crisis Management Team, these are presented as components of the overall risk management process rather than the primary focus of a management role disclosure.


reasoning: The paragraph describes the company's internal security processes and programs (e.g., incident response, vulnerability management, audits) as the grammatical subject, fitting the Risk Management Process category. It contains no specific dates, named tools, named third-party firms, or other verifiable facts, making it generic boilerplate.


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


reasoning: The paragraph focuses on the materiality of cybersecurity risks and incidents, explicitly stating that no material incidents occurred in 2023 and discussing the potential impact on business strategy and financial condition, which aligns with the Strategy Integration category.


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


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


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident, including the timeline of events, the nature of the attack, and the operational impact, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the nature, scope, and operational impact of a specific cybersecurity incident, which is the definition of Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of the threat actor's communication, the nature of the threat, and the company's response actions, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the current state of the company's cybersecurity program (or lack thereof), which falls under Risk Management Process. It contains no specific facts, named roles, or frameworks, making it generic boilerplate.


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


reasoning: The paragraph describes the ongoing response to a specific cybersecurity incident, including details about the perpetrator, the scope of affected accounts, and the financial compensation program, which qualifies it as an Incident Disclosure.


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


reasoning: The paragraph primarily describes the company's internal audit and risk assessment processes, making 'Risk Management Process' the most appropriate category. While specific roles are mentioned, they are listed as part of the review process rather than the primary subject of the paragraph, and the paragraph lacks the two hard verifiable facts required for 'Quantified-Verifiable'.


reasoning: The paragraph serves as an introductory statement or header-like description of general cybersecurity risks and does not describe specific governance, management, or processes, nor does it disclose an incident.


reasoning: The paragraph explicitly focuses on the responsibilities of 'Senior management' regarding cybersecurity risk appetite, fitting the Management Role category. It contains no specific facts (dates, named roles, named committees, or tools), making it generic boilerplate.


reasoning: The paragraph describes the company's internal process for investigating and responding to cybersecurity threats, making it a Risk Management Process. It is Firm-Specific because it references a named internal committee ('ISC') which is not a generic governance body.


reasoning: The paragraph describes the company's internal risk management procedures and policies, which are generic descriptions of standard cybersecurity practices without naming specific frameworks, roles, or verifiable facts.


reasoning: The paragraph describes the company's general cybersecurity program, risk management framework, and standard practices like assessments and training, without naming specific roles, tools, or frameworks.


reasoning: The paragraph describes the company's internal cybersecurity program, safeguards, and incident response planning, which are standard components of a risk management process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph describes a standard internal security practice (training) without referencing any specific management roles, board oversight, or unique programs, making it a generic description of risk management processes.


reasoning: The paragraph focuses on the qualifications and experience of specific cybersecurity management roles (CISO and VP of Information Security), making it a clear Management Role disclosure.


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


reasoning: The paragraph explains that the company is a blank check company with no operations and therefore no cybersecurity risk, which falls under the 'None/Other' category as it describes the absence of cybersecurity activity rather than a governance, management, or risk process.


reasoning: The paragraph provides a standalone materiality conclusion regarding the absence of material cybersecurity incidents, which aligns with the Strategy Integration category.


reasoning: The paragraph describes the company's internal incident response plan, which is a core component of their risk management process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses entirely on the Audit Committee's oversight responsibilities regarding cybersecurity risks and incident communication. It contains no specific facts (Audit Committee is explicitly excluded from specific facts per the instructions, and 'management' is generic).


content_category: Third-Party Risk

reasoning: The paragraph is entirely focused on the company's processes for overseeing third-party service providers, which is the definition of the Third-Party Risk category.


reasoning: The paragraph describes the company's general approach to utilizing third-party resources as part of its risk management strategy, rather than detailing specific vendor oversight or contractual standards.


reasoning: The paragraph describes the status of the company's risk management processes (or lack thereof), which falls under the Risk Management Process category. It contains no specific facts, dates, or named entities, making it generic boilerplate.


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


reasoning: The paragraph focuses on the board of directors' oversight activities and their interaction with management regarding cybersecurity risks, making 'Board Governance' the primary category. It contains no specific dates, named roles, named committees, or other verifiable facts, resulting in a 'Generic Boilerplate' specificity rating.


reasoning: The paragraph describes standard internal security practices like training and phishing simulations, which fall under Risk Management Process. It contains no specific dates, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the internal process of how security teams engage with other departments to manage risk, fitting the Risk Management Process category. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


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


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


reasoning: The paragraph describes the company's overall cybersecurity program, including its ERM framework, governance structure, and operational controls, making 'Risk Management Process' the most appropriate category. It is classified as 'Firm-Specific' because it names unique internal committees like the TRCC and ERC, as well as specific roles like the CISO.


reasoning: The paragraph focuses on the responsibilities of specific management roles (CISO, VP of IT, Chief Compliance and Privacy Officer) regarding cybersecurity oversight, making 'Management Role' the most appropriate category.


reasoning: The paragraph provides a standard 'no material incident' disclosure and discusses potential future impacts, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers.


reasoning: This paragraph provides a standalone materiality conclusion regarding cybersecurity threats without describing any specific incident or process, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it Generic Boilerplate.


reasoning: The paragraph primarily describes the company's cybersecurity risk management objectives and processes, with management roles mentioned only as participants in those processes rather than the primary subject.


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


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


reasoning: The paragraph describes general internal security processes and programs without naming specific roles, tools, or frameworks, making it a standard description of risk management activities.


reasoning: The paragraph describes the company's incident response and vulnerability management processes as the primary subject, making 'Risk Management Process' the correct category. While it mentions specific roles, the focus is on the process of escalation and mitigation rather than the qualifications or reporting lines of a specific cybersecurity leader.


reasoning: The paragraph focuses on the company's due diligence and contractual requirements for vendors, which is the definition of Third-Party Risk. It is Firm-Specific because it names 'PSCM' (Pershing Square Capital Management), which is a specific entity managing the company's operations.


reasoning: The paragraph discusses the materiality of cybersecurity risks and provides a cross-reference to the Risk Factors section, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities regarding cybersecurity, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it references the company's specific 'Cybersecurity Incident Response Plan' and the role of the 'CISO' in reporting to the committee.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the Head of Cybersecurity, making 'Management Role' the primary category. While it mentions the Board and Audit Committee, these are secondary to the description of the management role's function in the incident response process.


reasoning: The paragraph describes the company's general approach to using third-party providers for program evaluation and exercises, which falls under Risk Management Process. It contains no specific names, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk management processes, such as vulnerability testing, patching, and monitoring, without foregrounding a specific management role or board oversight.


reasoning: The paragraph describes internal processes for vulnerability management and vendor review, which falls under Risk Management Process. It contains no specific dates, named tools, named firms, or specific cybersecurity roles, making it generic boilerplate.


reasoning: The paragraph explicitly identifies specific cybersecurity management roles (CIO, CTO, Information Security Officer) as the grammatical subjects responsible for the company's security program.


reasoning: The paragraph describes the company's enterprise risk management (ERM) process and how it identifies and monitors cybersecurity risks, making it a clear description of the risk management process.


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


reasoning: The paragraph describes general risk management activities like penetration testing and information sharing without naming specific frameworks, tools, or third-party firms, making it a generic description of internal processes.


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


reasoning: The paragraph describes general technical safeguards (firewalls, anti-malware) as part of the company's internal security program, which falls under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph focuses on the specific management roles (SVP/IT Manager and ISO) responsible for cybersecurity, making 'Management Role' the correct category. It qualifies as 'Quantified-Verifiable' because it provides specific numerical data regarding the ISO's years of experience (22 years, 18 years).


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


reasoning: The paragraph focuses on the roles and qualifications of specific management personnel (the CCO and CISO) and their responsibilities, making 'Management Role' the correct category. It qualifies as 'Quantified-Verifiable' because it contains multiple hard facts, including specific dates (May 2024) and multiple quantified durations of experience.


reasoning: The paragraph focuses on the qualifications, responsibilities, and reporting lines of the CISO, making 'Management Role' the primary category.


reasoning: The paragraph focuses entirely on the risks posed by third-party service providers and the company's reliance on them, which fits the Third-Party Risk category. It contains no specific names, dates, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph is classified as Management Role because it explicitly details the specific roles (Cybersecurity Incident Manager, VP Security) responsible for evaluating, escalating, and managing cybersecurity incidents.


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


reasoning: The paragraph focuses on the role, reporting lines, and responsibilities of the CIO, which is a specific cybersecurity management role.


reasoning: The paragraph describes the company's internal cybersecurity program, processes, and defense-in-depth strategies without foregrounding a specific management role or board oversight.


reasoning: The paragraph focuses on the reporting responsibilities of a specific cybersecurity-related management role (Senior Director of Information Technology), which places it in the Management Role category.


reasoning: The paragraph describes the general responsibility of executive management for cybersecurity strategy without naming specific roles or committees, making it a description of the risk management process/governance structure rather than a specific management role or board oversight.


reasoning: The paragraph describes the internal incident response process and the specific committee responsible for initial assessments, making it a Risk Management Process disclosure. It is Firm-Specific because it names a unique internal committee (Cyber Security Subcommittee) and a cybersecurity-specific role (CTO).


reasoning: The paragraph focuses on the composition and function of the 'Cybersecurity Council' and the specific roles (CISO, CIDO, etc.) that comprise it, making 'Management Role' the most appropriate category.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including its reliance on the NIST framework, without foregrounding a specific management role or incident.


reasoning: The paragraph focuses on the oversight responsibilities of the Technology Committee, which is a named, non-generic committee, placing it squarely in Board Governance.


reasoning: The paragraph explicitly identifies a specific management role (VP of IT and Facilities) as the subject responsible for cybersecurity oversight and processes, fitting the Management Role category.


reasoning: The paragraph focuses entirely on the Board's oversight role and the Audit Committee's responsibilities. It contains no specific facts (Audit Committee and Board are generic entities, and periodic updates are a generic cadence).


reasoning: The paragraph describes general risk management activities (monitoring threats, using tools, mitigating risks) without foregrounding a specific management role or board oversight. It contains no specific facts, named tools, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph describes general risk management activities like monitoring, testing, and threat awareness without naming specific roles, frameworks, or unique programs.


reasoning: The paragraph describes the company's current lack of a formal risk management process and outlines a hypothetical framework for how they might approach it in the future.


reasoning: The paragraph focuses on the CISO's reporting lines and interactions with the IOC, making 'Management Role' the most appropriate category. It is classified as 'Firm-Specific' because it identifies a specific management role (CISO), a specific committee (IOC), and a specific team composition, which are unique organizational details.


reasoning: The paragraph describes the company's internal cybersecurity program, specifically training and policy review processes, without referencing any specific management roles or board oversight.


reasoning: The paragraph describes general internal security processes and controls, with the company's processes serving as the grammatical subject. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph outlines the company's incident response process and the involvement of general executive leadership, which are standard descriptions of risk management procedures. It lacks specific cybersecurity roles, named frameworks, or verifiable facts.


reasoning: The paragraph describes the scope and impact of a cybersecurity incident, including the types of data affected, which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or other hard verifiable facts that would elevate it beyond boilerplate incident reporting.


reasoning: The paragraph makes a materiality conclusion about cybersecurity impacts and directs readers to risk factors for further detail, without describing any specific incident or naming cybersecurity roles or internal security processes.

provider: openai


reasoning: The paragraph describes developing and integrating cybersecurity risk assessment/management processes and how they evaluate likelihood/impact and associated controls, without foregrounding any specific named management role or board committee.


reasoning: The paragraph describes the Board as the subject overseeing cybersecurity risk, receiving updates, and discussing the company’s cybersecurity risk management approach. No cybersecurity-specific named roles, committees, teams, tools, dates, or other firm-specific facts are provided beyond generic governance language.


specificity_confidence: medium

reasoning: The paragraph focuses on oversight requirements imposed on third-party service providers to support cybersecurity risk assessment and safeguards, which fits the Third-Party Risk category. It also includes a materiality-type statement about no material operational/financial impairment, but the central content is third-party security certifications and reporting obligations.


category_confidence: low

specificity_confidence: low

reasoning: The paragraph discusses general cybersecurity risk, including threats to third-party and cloud systems, but it does not describe a specific company process/program or concrete oversight structure. With no specific roles, dates, standards, tools, or firm-unique program names, it is effectively boilerplate risk language.


reasoning: The paragraph primarily describes the company's risk management/ERM-based cybersecurity processes and how cybersecurity is integrated into ERM. While the CISO and reporting line are mentioned, the dominant grammatical subject is the risk management program and its integration and review practices, not a personal management biography.


reasoning: This paragraph is a cross-reference to Item 1A risk factors and repeats generic cybersecurity risk language without describing any specific governance, roles, processes, third-party controls, or an incident.


reasoning: The paragraph describes the company’s cybersecurity threat identification, assessment, and management approach (monitoring, scans, internal/external reviews, periodic assessments) rather than oversight by the board or a named cybersecurity leader. Third parties are mentioned as part of the process, not as the central focus, so it fits Risk Management Process.


reasoning: The paragraph is centered on a specific cybersecurity leader (the Information Security Officer) and describes reporting lines and qualifications, making management role the primary focus.


reasoning: The paragraph describes internal cybersecurity processes (incident response plan scope, testing, training, mitigation measures, monitoring/reporting, and risk assessments) without foregrounding a specific cybersecurity leader or board/committee oversight.


reasoning: The paragraph is primarily about the board and its audit committee overseeing cybersecurity risk, including delegated committee oversight and reporting to the committee. Management roles are mentioned mainly as the sources of committee reports, so the focus remains board governance.


reasoning: Most sentences are centered on the Audit Committee’s oversight responsibilities and its charter-driven review/discussion role regarding cybersecurity risk management. The paragraph also names specific management cybersecurity-related roles (CIO and CISO) only as subjects discussed with the committee.


reasoning: The paragraph is written around the Audit Committee’s oversight responsibilities and its receipt of cybersecurity-related reports, making the board committee the grammatical center of the disclosure.


reasoning: The paragraph is generalized forward-looking risk/disclaimer language about potential cybersecurity impacts and references a risk factor, with no incident description, no named cybersecurity roles/programs/frameworks, and no firm-specific cyber facts.


reasoning: The paragraph describes the company’s risk identification, threat-intelligence review, control evaluation, and a process for third-party provider-related cybersecurity risks, with the InfoSec team driving the process rather than a named individual or board oversight.


reasoning: The paragraph describes the company’s cybersecurity processes (vulnerability/risk management, monitoring, and an incident response plan) rather than focusing on a specific cybersecurity leader or a central board/committee oversight function. It contains only generic practices and a referenced NIST framework without any firm-unique details from the ✓ list.


reasoning: The paragraph describes the company’s internal cybersecurity integration into its Enterprise Risk Management Program, including enterprise risk assessment, risk prioritization into categories, and monitoring/reporting processes.


reasoning: The paragraph describes the company’s information security programs and how they function to assess and manage risks (i.e., a process/program description), rather than naming specific cyber leaders or an actual incident.


reasoning: The paragraph primarily describes the company’s procedures for notifying roles, conducting investigations, assigning risk levels, escalating, and reporting within a defined timeline, which is a risk management process. Although named cybersecurity roles/committees are mentioned, they function as parts of the company’s process rather than the paragraph focusing on the qualifications or reporting lines of a specific individual.


reasoning: The paragraph describes the Audit Committee and the full Board as the subjects overseeing and receiving reports on cybersecurity risk management. However, it does not provide any firm-specific or verifiable details beyond generic governance and cadence language.


reasoning: Most sentences are framed around the Board of Directors’ responsibility and activities for cybersecurity risk oversight (assessing risks, reviewing processes, and meeting to discuss incidents). The paragraph also names the HSE Director, but the board is the dominant grammatical subject and focus.


reasoning: The paragraph describes Alternus’s cybersecurity risk approach (a multilayer program with monitoring, assessments, and incorporation into its policies and enterprise risk management process). No named cybersecurity leader or board/committee is the grammatical subject, so it fits Risk Management Process; it also references the NIST framework, making it Sector-Adapted rather than firm-specific.


reasoning: The paragraph describes the company’s internal cybersecurity measures—how controls are developed, maintained, reviewed, and updated using risk assessments and risk-based analysis. While it references third parties as part of conducting assessments, the central focus is the company’s risk management process and control framework adoption.


reasoning: The paragraph describes the company’s security/process controls (incident response planning, tabletop exercises, business continuity/disaster recovery, risk-based control selection and limitations) rather than any specific management role, board oversight, named framework, third-party vendor requirement, or an actual incident event.


reasoning: The paragraph foregrounds specific cybersecurity management roles (VP, IT Data Security; CTO) and describes their reporting line and operational responsibilities, even though it also mentions board/committee oversight.


reasoning: The paragraph focuses on materiality/financial impact conclusions about prior and potential cybersecurity incidents, without describing incident details or naming specific cybersecurity management roles or processes. It is primarily forward-looking risk/material-effect language rather than governance or a specific internal risk program.


reasoning: The paragraph is primarily about board/committee governance: the Board, Audit Committee, and Cybersecurity Subcommittee roles, delegation, reporting, and oversight responsibilities for cyber/privacy risk.


reasoning: The paragraph describes the Trustee’s cybersecurity/risk management program and protocols (identify/assess/manage/mitigate/respond) and an annual assessment process, with no specific cybersecurity leader or board committee as the grammatical subject. It therefore fits the risk management process category, and contains no uniquely identifiable firm facts or named standards/tools/dates.


reasoning: The paragraph is centered on a specific management cybersecurity leader (CDIO/CISO) as the subject, including tenure, reporting, and responsibilities (briefing the TCRC). It includes multiple firm-verifiable facts such as the since-2021 role tenure and prior employers.


reasoning: The paragraph centers on the Board and Audit Committee (including a named Cybersecurity Risk Subcommittee) as the grammatical subjects governing cybersecurity oversight activities.


reasoning: The paragraph is focused on the company’s cybersecurity processes for identifying/responding to incidents (tools, monitoring outputs, and testing) rather than on any named leadership or a specific incident event narrative.


reasoning: The paragraph’s grammatical emphasis is on the Board and the Audit Committee being involved in oversight of the cybersecurity program, indicating board-level governance. While it mentions NIST, the rest is generalized risk-management language with no firm-specific operational details.


reasoning: The paragraph describes OFS Advisor/IT Department cybersecurity policies, procedures, and control processes (risk management, vulnerability management, due diligence/monitoring of providers) rather than focusing on a named management individual or board oversight.


reasoning: The paragraph is primarily about board/board committee oversight and receiving management reports on cybersecurity risks and incidents, with the board described as the grammatical subject of the oversight statements.


reasoning: Most of the paragraph is framed around board and audit committee oversight responsibilities and reporting related to cybersecurity risks and incidents. A cybersecurity-specific management role (Chief Information Security Officer) is mentioned, but the governance/oversight focus remains on the board/committee.


reasoning: The paragraph centers on the named cybersecurity management role (CISO) as the grammatical subject and describes qualifications and responsibilities, making it Management Role rather than a company-wide process description. It also includes hard verifiable facts ("over 20 years" and a specific degree).


reasoning: Most sentences are centered on the CIO and other senior leaders performing reviews and leading the incident response/notification plan, indicating management responsibility rather than board-led oversight.


reasoning: The paragraph describes the company’s incident detection/response and recovery processes (including plans, reviews, and exercises) as programmatic processes rather than naming a specific cybersecurity leader or board subject. It also anchors the program to NIST CSF, making it Sector-Adapted.


reasoning: The paragraph is centered on third-party/vendor security oversight (assessing providers, requiring security contract terms, and imposing encryption/incident notification requirements), which is the hallmark of Third-Party Risk.


reasoning: The paragraph describes the company’s cyber risk mitigation program and the security tools/processes it uses (e.g., controls, monitoring, incident response policies), rather than focusing on a specific cybersecurity leader or a board committee. Although it mentions third-party assessments, those are part of the internal risk management program, not a vendor-centric oversight disclosure.


reasoning: The paragraph describes an ongoing company training and testing program (awareness training, simulations, tabletop exercises, and preparedness/incident response readiness), which are internal risk management/process activities. It does not foreground a specific cybersecurity management role or identify a board/committee or an incident.


reasoning: The paragraph describes an actual cybersecurity incident (when it occurred and what was accessed/downloaded) and then outlines post-incident remediation measures. This is therefore incident disclosure rather than a general risk or governance description.


reasoning: The paragraph centers on named cybersecurity leadership (CISO) and describes reporting lines and the individuals’/team’s qualifications, certifications, education, and experience. This is primarily a management-role disclosure rather than a process or incident description.


reasoning: The paragraph makes a materiality-style conclusion that no cybersecurity risks were identified in fiscal 2025 as materially affecting business strategy, results of operations, or financial condition, without describing a specific incident’s what/when/scope. It also contains forward-looking, non-specific limitation language about preventative measures.


reasoning: The paragraph is centered on the cybersecurity leader (AAM’s CISO) and describes their leadership and qualifications, making the CISO the grammatical subject focus.


reasoning: The paragraph focuses on materiality/financial impact of cybersecurity threats and states there are no known material security breaches, without describing a specific incident. It also references incident assessments involving generic roles (CEO/CFO) and an MSP, which do not provide firm-specific cybersecurity governance details.


reasoning: The paragraph is centered on named cybersecurity/IT leadership roles (Director, IT Infrastructure & Security and reporting to the Vice President of Information Technology) and describes their responsibilities and reporting lines, making management-role content the primary focus.


reasoning: The paragraph is entirely materiality/assurance language about potential future cybersecurity incidents and references risk factor disclosure, without describing incident details or cybersecurity processes. It briefly mentions a past incident (August 2020) but the main substance is that cyber issues have not materially affected results and that future incidents could, which fits strategy/financial integration.


reasoning: The paragraph describes internal cybersecurity awareness/training and an ongoing process for assessing and monitoring third-party providers, but it is primarily framed as company processes (no board/committee subject, no named cybersecurity leader). It also references cybersecurity insurance generally without event specifics or hard verifiable details.


reasoning: The paragraph is focused on materiality/financial impact conclusions (no material cyber incident; immaterial expenses; not aware of material risks) and forward-looking uncertainty, without describing any actual incident or cybersecurity process/program details.


reasoning: The paragraph is centered on the ERM committee’s risk processes (policies/procedures, self-assessments, remediation action plans) and how cybersecurity inputs are incorporated into risk decision-making. Although CISO/CDO are mentioned, the primary grammatical subject is the ERM committee and its process, not a named cybersecurity leader’s individual role.


reasoning: The paragraph describes the company’s cybersecurity risk management program and how it is designed using specific frameworks, without foregrounding a particular cybersecurity leader or an incident. Because it names NIST Cybersecurity Framework and Sarbanes Oxley, it is Sector-Adapted rather than firm-unique.


reasoning: The paragraph describes company/vendor processes and ongoing activities for assessing cybersecurity and infrastructure posture (patch/vulnerability management, access controls, disaster recovery/business continuity, and threat monitoring) without focusing on a specific named cybersecurity leader or a board/committee. No firm-unique, verifiable details (named roles, committees, tools, dates, or firms) are provided.


reasoning: This is forward-looking, boilerplate risk-factor language about cybersecurity threats and inability to prevent all breaches, with a cross-reference to another section but no incident description or named roles/processes/tools.


reasoning: The paragraph describes company processes for assessing and managing cybersecurity risks from unauthorized occurrences on IT systems, but it does not foreground any named management role or board oversight and contains no incident narrative. All details are generic (aligned with industry standards/best practices) and no specific frameworks, roles, dates, tools, or firm-specific identifiers are provided.


reasoning: The paragraph primarily describes the company’s cybersecurity measures and processes (alignment to a named framework and incorporation into ERM) rather than focusing on a specific cybersecurity leader’s role. Although the Board/management are mentioned, the main grammatical focus is the company’s risk processes and teams coordinating to review risks.


reasoning: The paragraph is primarily about the company’s intended cybersecurity risk management program, processes, and monitoring activities, which makes it a Risk Management Process. Board oversight is mentioned, but the main subject is the risk management program and its operational/process components rather than detailed board/committee governance or specific cybersecurity leadership roles.


reasoning: The paragraph is centered on oversight by the Board and its committee(s), specifically describing how the Audit Committee and the Board handle cybersecurity and incident information flow.


reasoning: The paragraph is centered on the Chief Information Security Officer—his role, qualifications, tenure, certifications, and reporting/oversight lines—making it primarily a Management Role disclosure rather than a process description.


reasoning: The paragraph primarily identifies the VP of IT / information security officer and describes that individual’s responsibilities and reporting relationships, with additional detail about an IT steering committee and the VP’s tenure and experience.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access by a third party), the company’s detection/containment actions, disruption to business operations, and continuing investigation/notifications. It is therefore incident disclosure rather than general risk or governance.


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


reasoning: The paragraph describes an actual cybersecurity incident, including when it was discovered, what was accessed, the affected scope (Dropbox Sign users/data), and ongoing response/investigation actions.


reasoning: The paragraph narrates a specific cybersecurity incident, including a detection date, unauthorized access, response actions (activate incident response, engage experts, notify law enforcement), and operational impact (disruptions/limited access to business applications and reporting systems).


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access and exfiltration of video meeting images/screens, extortion threat, and response actions like closing off access) along with operational and financial impact from being offline. No extractable hard verifiable facts (e.g., dates, specific tools/firms/amounts) or cybersecurity-specific roles/committees/frameworks are included.


reasoning: The paragraph describes a real cybersecurity incident and its impact (types of data accessed, up to 33 million accounts, and what was not obtained), along with investigation and regulator actions and inability to estimate penalty losses.


reasoning: The paragraph is framed around board and Audit Committee oversight, briefing cadence, and reporting regarding cybersecurity risk. Although it references the CSO, the grammatical focus is the Board/Audit Committee’s governance activities.


reasoning: The paragraph describes a specific cybersecurity incident with dates (late Nov 2023, Jan 12/13 2024), the threat actor’s actions (access and exfiltration), and response steps (removal of access, ongoing investigation, notification to law enforcement/regulators). Although the paragraph includes a materiality conclusion, the core content is an incident narrative.


reasoning: The paragraph describes ongoing information security processes (external expert engagements for testing/audits, threat assessments, training, and refinement based on results). It does not name specific cybersecurity roles, committees, programs, tools, standards, or a disclosed incident, and third-party use is not the central topic (it supports internal security processes).


reasoning: The paragraph describes a specific realized cybersecurity incident, including the unauthorized access vector, detection/containment actions, business disruption, and remediation status.


reasoning: The paragraph describes the status and effects of an actual cybersecurity incident (removal from IT systems, restoration of access, impacted systems/functions like billing/label making, data stolen/destroyed, and operational continuity), which fits incident disclosure.


reasoning: The paragraph describes a specific cyber incident (unauthorized access starting Feb 4, 2024; detection on Feb 5, 2024) and provides actions taken and data/system access/exfiltration details, which fits Incident Disclosure.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access and exfiltration beginning in late November 2023) and ongoing attacker behavior, including impact on employee email accounts and access attempts to source code repositories and internal systems.


reasoning: The paragraph discusses materiality and expected costs/impact of an incident on financial results and condition, without describing what happened in the incident or affected systems’ scope.


reasoning: The paragraph is a standard forward-looking statements and safe harbor disclaimer and does not describe any cybersecurity incident details, response actions, or company-specific cyber governance/processes.


reasoning: The paragraph describes an actual cybersecurity incident, including illegal access, temporary operational limitations, proactive halting of production, and data exfiltration, plus evaluation and notifications. It does not foreground a specific management role or a distinct governance/process program.


reasoning: The paragraph narrates a real cybersecurity incident, including the date, what the attacker did (defaced website at a specific domain), and the Company’s response actions (restoration attempts and taking the site down with a temporary page).


reasoning: The paragraph describes an ongoing cybersecurity investigation, including data exfiltration, evaluation of the exfiltrated files, the presence of personal information, and steps to notify clients and assess potential public release. No named roles, dates, tools, or other ✓-list facts are provided, so specificity remains generic.


reasoning: The paragraph describes a disclosed cybersecurity incident with a specific date and includes impact and response (network access, encryption, exfiltration, outage, and operational delays). Because it contains concrete incident details, it fits Incident Disclosure rather than risk/process or strategy.


reasoning: The paragraph describes an incident and its response (third-party investigation, scope limits, unauthorized access to customer personal information, customer notification, and lack of evidence of misuse), which is characteristic of incident disclosure. It does not provide any ✓-listed firm-specific facts (no dates, named vendors, named systems/tools, or quantified impacts), so it is treated as generic for specificity.


reasoning: The paragraph narrates a specific incident with a date, describes actions taken (containment, investigation, activating an incident response plan, shutting down systems), and explains impact (encryption, data theft including personal data, disruption to e-commerce order fulfillment).


reasoning: The paragraph focuses on financial/materiality impacts of the incident (expected earnings impact, material impact likelihood) without describing the incident itself or specific cybersecurity actions/scope. It therefore fits strategy/financial integration rather than incident disclosure or risk management.


reasoning: The paragraph describes the ongoing effects of a cyber incident (shutdown of systems, disrupted replenishment and delayed order fulfillment, customer order cancellations, delayed wholesale shipments) and the restoration progress (substantially restored IT systems and data, minor residual impacts). It is therefore an incident disclosure rather than a process or strategy statement.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access to file systems), the company’s response actions (incident response/business continuity protocols, containment/remediation), and operational impact (temporary interruption), all tied to a specific date.


reasoning: The paragraph discusses ongoing evaluation of unauthorized access tied to an existing security incident and describes incident impact (website offline and delayed communications) plus continued investigation and remediation actions.


reasoning: The paragraph focuses on materiality to financial condition/results and insurance coverage/cost treatment, without describing what the cybersecurity incident actually was.


reasoning: The paragraph discusses materiality/financial impact expectations and guidance ranges for future reporting periods, without describing any incident events or affected systems/data scope. It is therefore focused on financial implications rather than incident disclosure or cyber process details.


reasoning: The paragraph describes a real cybersecurity/IT disruption (what happened, key dates, and restoration actions) and the operational impact to the website and email communications, which fits Incident Disclosure.


reasoning: The paragraph describes the status/outcome of a real cybersecurity incident (contained/remediated) and its operational impacts, along with estimated costs tied to specific dates and an amount.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access and exfiltration), including notification timing, threat actor identification, response actions, and affected data scope. It therefore falls under Incident Disclosure rather than risk processes or governance.


reasoning: The paragraph describes the contents/scope of data under analysis (e.g., call/text records and related metadata), which is characteristic of incident data-scope disclosure, even though it does not narrate an event timeline.


reasoning: The paragraph describes a real cybersecurity incident, including when unauthorized activity was detected and when the threat actor was believed ejected, plus concrete response actions (containment, investigation with experts, incident response plan activation, system shutdowns).


reasoning: The paragraph focuses on remediation-related evaluation, anticipated insurance reimbursements, and a statement about no material financial impact / not reasonably likely to materially impact results, without describing incident events or affected systems.


reasoning: The paragraph discusses forward-looking materiality and expected financial impacts (costs, revenue loss during recovery, insurance offset) without describing the incident itself or any specific cyber risk management/process details.


reasoning: The paragraph describes a specific cybersecurity incident at a third party (CDK), provides an incident date, and details the operational/system impact and restoration of access (including DMS and CRM, and July disruptions).


reasoning: The paragraph focuses on financial and revenue recognition impacts from an incident (timing of transactions, revenue delays, loss of revenue, and one-time expenses) rather than describing the incident mechanics or cybersecurity process.


reasoning: The paragraph describes a real cybersecurity incident with a specific detection date, investigation actions, and operational impact (network isolation causing disruption to business processes), which fits Incident Disclosure.


reasoning: The paragraph focuses on the estimated financial impact (remediation costs and customer reimbursements) and the ongoing assessment, without describing the incident itself (what happened, when, or affected systems).


reasoning: The paragraph describes a real cybersecurity event (ransomware incident), including how it originated, recovery/investigation activities, and the conclusion about whether further actions are needed. Because the incident itself is the focus, this falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized third-party access), containment/response actions (including activating an incident response plan and taking affected systems offline), and operational impact (temporarily halting and restarting production operations). No firm-specific details (names, dates, amounts, tools/firms) are provided beyond generic incident language.


reasoning: The paragraph describes a real cybersecurity-related disruption, including when it began, which systems were impacted (DMS/CRM and functions), and restoration/offline status as of the filing date.


reasoning: The paragraph narrates a real cybersecurity event (unauthorized activity), describes response actions (containment, investigation, activating an incident response plan, shutting down systems), explains the attacker impact (encrypting data files), and provides operational/data-scope consequences (manufacturing not operating, order fulfillment impacted, no belief of consumer personal info compromise).


reasoning: The paragraph describes a real cybersecurity incident (detection date, unauthorized access, containment/remediation actions) rather than only governance or a general risk program. It also references a prior disclosure timeline tied to the incident narrative.


reasoning: The paragraph describes an active cybersecurity incident’s scope (access and exfiltration), the affected data categories, and response actions (notifications and law enforcement), which is core incident disclosure. It includes incident-specific details, but no hard verifiable dates, dollar amounts, or named third-party firms/tools.


reasoning: The paragraph discusses the ongoing investigation of a disclosed cybersecurity incident, including what the threat actor did/did not access and whether it impacted operations or financial condition.


reasoning: The paragraph describes a specific cybersecurity incident with a stated discovery date, unauthorized access, third-party software deployment, notification/response actions, and operational disruptions with systems taken offline and being restored.


reasoning: This paragraph describes business disruption caused by a cybersecurity incident (operational halt/restoration timelines by geography) and remediation activities, including when operations were restored and the access status of the unauthorized third party.


reasoning: The paragraph focuses on liquidity/financing terms (waiver of interest/lease payments, additional capital amount) to fund remediation, without describing the underlying incident itself. This is therefore integrated strategy/financial impact rather than incident disclosure or risk process.


reasoning: The paragraph narrates a specific cybersecurity incident (unauthorized access), describes response actions (activating incident response, engaging external experts, notifying law enforcement), and specifies operational impact (disruptions/limited access to reporting systems). The presence of a concrete incident date makes it firm-specific, but it does not include enough hard, independently verifiable facts (e.g., vendor names, product names, quantities, or amounts) for Quantified-Verifiable.


reasoning: The paragraph describes an actual cybersecurity incident (detection, initiation of incident response/business continuity, isolation steps, and impact/delays for Canadian operations) with relevant timing and operational effects.


reasoning: The paragraph describes an ongoing cybersecurity incident (an unprecedented cyberattack), the restoration efforts, and investigation of impacted data, including which services were affected and the Company’s view of the scope.


reasoning: The paragraph is focused on board and audit committee oversight of cybersecurity risk management, with the board delegating responsibility and reporting back. However, it does not name any cybersecurity-specific leadership, committees beyond the generic Audit Committee, dates, or other firm-unique details.


reasoning: This paragraph is a cross-reference to the Item 1A risk factors section and does not describe cybersecurity governance, management, processes, third-party risk, or an incident.


reasoning: The paragraph is a materiality-style statement about whether known cybersecurity threats have materially affected the company and directs readers to the risk factors section, without describing any specific incident or cybersecurity process/program.


reasoning: The paragraph describes company-run activities and process changes related to cybersecurity risk and compliance, without focusing on a specific management role, board oversight, third-party vendor oversight, or an actual incident.


reasoning: The paragraph is centered on specific cybersecurity management leaders (CIO and Information Security Director) and their credentials/experience, with the management roles serving as the grammatical subjects. It describes responsibilities and qualifications tied to those named roles rather than company-wide processes without a person foregrounded.


reasoning: The paragraph provides materiality/absence statements about cybersecurity incidents and related expenses/penalties, plus future intent to hire an investigation firm, but it does not describe any actual incident or cybersecurity governance/process details tied to named roles or programs.


reasoning: The paragraph primarily describes the company’s cybersecurity risk management program and how standards/controls are designed using industry frameworks, which fits the Risk Management Process category even though a management role is mentioned in the opening clause.


reasoning: The paragraph primarily describes how the company integrates cybersecurity into its enterprise risk management process (review cadence, mitigation plans). Board oversight is mentioned, but it is not the dominant subject of the paragraph’s processes compared to the ERM/risk management description.


reasoning: The paragraph is organized around a specific individual (Mr. Gharib) and describes his responsibilities for cybersecurity and risk/incident preparation, making management the grammatical subject throughout.


reasoning: The paragraph is centered on a named management role as the grammatical subject (the chief financial officer) and describes that person’s cybersecurity responsibilities and reporting. However, no cybersecurity-specific executive title, committee, or other firm-specific identifiers are provided, making the disclosure generic.


reasoning: The paragraph describes the company’s cybersecurity controls, procedures, and escalation/reporting process for identifying and managing threats and incidents, without foregrounding a specific cybersecurity leader or board committee.


reasoning: Most sentences are about Board/board-committee oversight, approvals, and reporting for cybersecurity risk and the cybersecurity program.


reasoning: The paragraph states that the board of directors is overseeing the company’s risk management program with respect to cybersecurity, indicating board-level governance as the primary focus. It also describes integration into ERM and cites recognized NIST/ISO standards, making it sector-adapted rather than firm-specific.


reasoning: The paragraph is centered on a named management role (Chief Technology Officer) and describes what that person is responsible for in cybersecurity risk management and reporting/meetings.


reasoning: The paragraph describes how the company integrates its cybersecurity program into enterprise risk management and other internal programs, focusing on processes rather than any specific cyber leader or board oversight.


reasoning: The paragraph is centered on named management cybersecurity/technology leaders (CISO and CTO) as the grammatical subject, describing qualifications, tenure, and experience. It also includes multiple hard verifiable facts (specific years, certification details, and program/education source).


reasoning: The paragraph describes the company’s cyber risk assessment and mitigation/incident response planning processes as the grammatical subject, with no specific cybersecurity leaders, committees, dates, tools, or uniquely identifying details.


reasoning: The paragraph centers on the Audit Committee’s (board-committee) responsibility and oversight of cybersecurity risks and describes reporting to it, making board governance the grammatical and substantive focus.


reasoning: The paragraph describes the company’s incident response/escalation procedures (i.e., how incidents are handled), focusing on the process rather than identifying a specific cybersecurity leader as the main subject.


reasoning: The paragraph describes how cybersecurity risk management is integrated into enterprise risk management processes and decision-making, with processes (ERM team) evaluating and addressing risks. Although a Chief Security Officer (CSO) is mentioned, the grammatical subject is the ERM team rather than the CSO.


reasoning: The paragraph is focused on the absence of materially affecting cybersecurity incidents and discusses resource spend (including cyber insurance costs) and potential materiality, without describing an actual incident or internal cybersecurity processes.


reasoning: The paragraph focuses on whether cybersecurity threats/incidents had a material impact and describes updates to an information security strategy in response to threat volume, without detailing an actual incident or naming specific cyber leaders, committees, frameworks, or tools.


reasoning: The paragraph focuses on materiality (no cybersecurity threats materially affecting strategy/results/financial condition) and general forward-looking risk limitation language, without describing an incident or naming specific management roles or processes.


reasoning: The paragraph centers on the Board/Audit Committee’s oversight and continuing education on cybersecurity, with the Board as the grammatical subject of the oversight activities.


reasoning: The paragraph provides materiality/impact conclusions (no material cybersecurity incidents; immaterial expenses; no penalties/settlements) without describing any incident details or cybersecurity management/process specifics. It also directs readers to Item 1A Risk Factors rather than disclosing an event.


reasoning: The paragraph describes general processes for assessing and managing cybersecurity risks, but it does not foreground any specific cybersecurity management role or board oversight. It contains no firm-unique operational details, named frameworks, dates, or tools, so it is generic boilerplate.


reasoning: The paragraph describes general use of external experts (assessors/consultants/auditors) as part of evaluating/testing cybersecurity risk management systems, without vendor security oversight being the central focus. No incident, named roles/tools/firms, or specific dates are provided.


reasoning: The paragraph describes the company’s internal processes for managing breach-related risk (training, awareness updates, employee testing, penetration testing, and assessments). No specific management cybersecurity leader is identified as the grammatical subject, so it fits Risk Management Process rather than Management Role.


reasoning: The paragraph is centered on a named cybersecurity-specific individual (Jack Wang) and describes his responsibilities and reporting role for cybersecurity risk and incidents, making it primarily a Management Role disclosure.


reasoning: The paragraph is structured around specific cybersecurity management roles (CISO and CTO) and describes their reporting and oversight responsibilities, making the management roles the grammatical subject of the content.


reasoning: The paragraph describes governance and oversight for timely public disclosure decisions made by management and the Board, but it does not name any specific cybersecurity leaders, committees, frameworks, dates, or tools.


reasoning: The paragraph centers on named management roles (Vice President of Information Systems and Chief Financial Officer) as the grammatical subject describing their qualifications and responsibilities related to cyber risk management.


reasoning: The paragraph is centered on who directs and performs cybersecurity risk assessment/monitoring (IT department under the CFO) and includes reporting to the Audit Committee, making management-role content the primary subject. It also provides a hard quantified fact (over 70 years of combined experience).


reasoning: The paragraph makes a materiality determination about whether identified cybersecurity risks have materially affected the company and states that additional risks are discussed elsewhere, without describing an incident or outlining cyber risk-management processes or specific cyber leadership roles.


reasoning: The paragraph’s grammatical subject is the Board and its standing Cybersecurity Committee, describing how the committee supports oversight of cybersecurity risk. It also provides firm-specific details about the committee and the chair’s specific CERT certification.


reasoning: The paragraph describes the company’s cybersecurity testing and program review processes using independent third parties, but it does not center on vendor requirements/oversight as the primary topic. No specific management roles, frameworks, named tools, dates, or firm-unique details are provided.


reasoning: The paragraph centers on board-level oversight by a committee responsible for reviewing cybersecurity risk management and receiving incident/environment reviews. Other references (IRP elevation) are subordinate to the board/committee governance focus and contain no firm-specific or verifiable details.


reasoning: The paragraph describes internal cybersecurity preparedness and capability enhancement activities (crisis simulation, augmenting monitoring/IR/detection/forensics) but does not foreground a specific cybersecurity management role or an actual incident. Because all vendors are unnamed and there are no verifiable firm-specific details, it remains generic boilerplate.


reasoning: This paragraph is a cross-reference to another section and contains no substantive description of cybersecurity governance, management roles, risk processes, or incidents.


reasoning: The paragraph describes a company process (internal audit business risk assessment that evaluates cybersecurity risks and produces a cybersecurity posture report for business leaders). No specific cybersecurity management role or board committee is identified, and the focus is on risk assessment activities rather than an incident or third-party oversight.


reasoning: The paragraph focuses on potential material adverse effects and limitations of cybersecurity insurance without describing any actual incident or internal risk processes; it is primarily financial/materiality framing.


reasoning: The paragraph contains generalized statements about cybersecurity importance and potential business impact, without describing processes, governance, specific roles, incidents, third-party requirements, frameworks, or any firm-specific details.


reasoning: The paragraph focuses on assessing and mitigating cybersecurity risks arising from vendors/suppliers/business partners and third-party service providers, which is central to third-party risk management. It does not name any specific roles, tools, dates, frameworks, or unique identifiers.


reasoning: The paragraph focuses on the Board and its audit committee overseeing cybersecurity risk, delegation, and reporting cadence. It does not name a specific cybersecurity leader, team composition, dated event, or internal program identifier beyond generic governance boilerplate.


reasoning: The paragraph describes internal cybersecurity risk management processes and how third-party risk is assessed and incorporated, rather than focusing primarily on third-party oversight as the central topic.


reasoning: The paragraph describes the company’s internal cybersecurity tools and recurring security processes (training, phishing testing, tabletop exercises, penetration testing) as ongoing risk/security management, with no specific cybersecurity leader or board oversight in the grammatical subject.


reasoning: The paragraph’s grammatical focus is on the Board and, primarily, the Audit Committee overseeing cybersecurity risk, including reviews and delegated responsibility.


reasoning: The paragraph centers on a named cybersecurity leadership role (Director of Cybersecurity) and describes that person’s responsibilities and experience, making it Management Role.


reasoning: The paragraph is dominated by Board and Audit Committee oversight and update/briefing responsibilities for cybersecurity risk.


reasoning: The paragraph is primarily framed around board and an Audit Committee oversight of cybersecurity risk management, with only generic references to management and risk strategy. No specific cybersecurity roles, unique programs, frameworks, dates, or other firm-specific details are provided.


reasoning: The paragraph describes the company’s cybersecurity risk management program activities (meetings, employee training, and security policies) rather than providing oversight details as the primary focus. Although a Security Committee and an information security leader are mentioned, the grammatical and substantive emphasis is on program/process content.


reasoning: The paragraph centers on a named management role (Vice President of Finance and Treasurer) and their responsibility for cyber insurance coverage, even though it also describes incident-related continuity and tabletop testing.


reasoning: The paragraph describes the company’s incident response plan processes (triage, severity assessment, investigation, escalation, containment, remediation) as part of its cybersecurity risk management activities. No specific management role, board committee, named framework, or incident event is identified.


reasoning: The paragraph describes the company’s cybersecurity measures and processes (incident response, continuity, risk assessments, encryption, monitoring, training) as the subject, but it does not foreground any specific cybersecurity leadership role or board governance. It also contains no firm-specific identifiers, named frameworks, dates, tools, or quantified details.


reasoning: The paragraph describes the company’s vulnerability assessment program and how it is used within enterprise cybersecurity risk management (process/framework, prioritizing vulnerability management, continuous evaluation). No specific cybersecurity leader, board/committee, named program identifier, dates, tools, or third parties are provided.


reasoning: The paragraph describes internal processes to oversee and identify cybersecurity risks, but it does not name any specific management roles, board/committee, tools, dates, standards, or incidents.


reasoning: The paragraph describes how cybersecurity is integrated into the company’s Enterprise Risk Management process and references a cybersecurity risk management program, but it does not identify any specific cyber leader, committee, framework, tool, third party, dates, or other firm-unique details.


reasoning: The paragraph describes a real cybersecurity incident, including when it was discovered, what the threat actor did (unauthorized access and encryption), and key response actions taken (containment, investigation, engaging external specialists, restricting access).


reasoning: The paragraph describes the company’s incident prevention/detection/mitigation workflow (monitoring, severity assessment, escalation procedures) as part of its cybersecurity process. While it references a specific management role, the grammatical subject is the information security team and the focus is on process steps.


reasoning: The paragraph does not describe what occurred in the incident; instead it provides materiality and business operations impact timing statements and uncertainty about financial/material effects, which is strategy/materiality integration.


reasoning: This paragraph discusses materiality/regulatory impact conclusions and investigation-driven notification timing without describing incident mechanics or cybersecurity process details.


reasoning: The paragraph primarily describes the company’s cybersecurity risk management and monitoring/mitigation processes (risk identification, monitoring, mitigation, and program direction), rather than focusing on the qualifications or reporting lines of a specific cybersecurity executive. Board/audit-committee reporting is mentioned, but the main substance is the organization’s risk management approach.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity detected on May 1, 2024) and the company’s response actions (investigation, activating its incident response plan, shutting down IT portions, and notifying law enforcement).


reasoning: The paragraph describes a real incident (unauthorized activity), includes response actions, and gives an incident-relevant date and technical containment step (isolating systems from the Internet), which fits Incident Disclosure.


reasoning: The paragraph describes the ongoing investigation into a cybersecurity incident (e.g., whether malware/ransomware/data destruction occurred and whether the threat actor has access), which is incident-related disclosure even though it provides no concrete dates, systems, or scope.


reasoning: The paragraph describes STARZ’s cybersecurity measures and processes (e.g., detection/response, vulnerability management, encryption, continuity, monitoring, and risk assessments) as part of how it manages risks. No specific named cybersecurity leader, committee, incident event, third-party security oversight requirement, or verifiable firm-specific detail is provided.


reasoning: This paragraph describes a specific cybersecurity incident outcome (unauthorized access and exfiltration of limited data including PII) and related response actions (notifications to affected parties and regulators). It is not primarily about governance, management roles, or general risk processes.


reasoning: The paragraph describes company efforts to implement and align with the NIST Cybersecurity Framework and related internal policies/standards, which are process/program driven rather than board or specific management-role driven.


reasoning: The paragraph describes incident response actions and provides incident scope/impact (no compromise of IT systems, no unauthorized transactions or transfers, and continued member transaction execution), which is substantive incident disclosure even though it lacks hard dates/tools/vendors.


reasoning: The paragraph discusses expected material financial/operational impact and associated business risks (management attention, litigation, customer/investor behavior, regulatory scrutiny) rather than describing incident events or cybersecurity processes.


reasoning: The paragraph describes a specific cybersecurity incident (detection date) and the company’s incident response, investigation, regulator/law enforcement notification, and containment of impact.


reasoning: The paragraph is a standard forward-looking statements disclaimer with no substantive cybersecurity governance, process, incident, or risk details.


reasoning: The paragraph does not describe what occurred in the incident; instead it provides materiality/financial impact conclusions while the investigation is ongoing.


reasoning: The paragraph describes a real cybersecurity incident with when it was discovered, what the threat actor did (access and encryption), and key response actions (containment, internal investigation, engaging specialists, restricting access), which fits incident disclosure.


reasoning: The paragraph describes the effects of a cybersecurity incident on business operations (shipping/receiving/manufacturing), states that files were taken, and describes ongoing investigation and response actions including potential notifications.


reasoning: The paragraph describes the company’s understanding of an ongoing cybersecurity incident, including the threat actor’s earlier activity, the timing (May 2023 and June 2023), and investigative/containment/remediation actions, along with material impact assessment.


reasoning: The paragraph describes a cybersecurity event (unauthorized activity) and the company’s response actions, including a specific incident containment step taken on December 20, 2023.


reasoning: The paragraph discusses an ongoing cybersecurity investigation and provides an estimated scope of stolen personal data (including what types of data were not acquired), which is characteristic incident-disclosure content.


reasoning: The paragraph provides only a materiality/impact conclusion about the cybersecurity incident on business operations and financial condition, without describing the incident or cybersecurity program/process details.


reasoning: The paragraph describes an actual cybersecurity event (additional data exfiltration) and provides the scope of what was affected (PII and PHI, mostly maintained by a subsidiary providing patient support services). No hard verifiable identifiers (dates, dollar amounts, named tools/firms, or unique internal program names) are included, so it cannot be treated as firm-specific under the specificity rules.


reasoning: The paragraph references an exfiltration event and describes the general type of data involved, but it contains no incident-specific verifiable details (no dates beyond relative phrasing, no systems, and no clear incident narrative scope).


reasoning: The paragraph focuses on the Incident’s material financial impact (GAAP diluted EPS effects) rather than describing what happened in the incident or governance/process details.


reasoning: The paragraph describes operational impact from a cybersecurity incident (delays/limited distribution and online operations) and includes incident recovery status and scope. It also provides verifiable incident-related business impact details (a specific cutoff date and revenue percentage affected).


reasoning: The paragraph describes a specific ransomware incident with a dated discovery date, affected internal IT systems, and concrete response actions (containment, taking platforms offline, engaging experts, and plans to notify individuals/regulators). It is therefore an incident narrative rather than a general process or materiality discussion.


reasoning: The paragraph describes actions taken after becoming aware of an incident (launching an investigation, mitigation, working with law enforcement, notifying regulators and users), which is characteristic of cybersecurity incident disclosure even without technical scope details.


reasoning: The paragraph discusses materiality to business operations/financial condition and ongoing remediation risk without describing the incident itself beyond a limited scope statement. It is focused on financial/business impact (materiality conclusions), not incident narrative details.


reasoning: The paragraph focuses on materiality/financial impact (non-recurring expenses) and mentions cyber insurance and notification to authorities, without describing the incident’s technical details or system/data scope.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access, deletion of email messages) and its response details (misdirected wire payment and unrecovered funds), including a specific dollar amount.


reasoning: The paragraph focuses on expenses and whether the incident is reasonably likely to materially impact financial condition/results, without describing what happened. That fits materiality/financial impact disclosure rather than incident or process details.


reasoning: The paragraph describes an ongoing cybersecurity-related disruption (network interruption), restoration efforts, and operational scope (Change Healthcare systems affected while others are operational). It does not name specific tools/roles/dates, so it is not firm-unique beyond the incident scope, yielding generic specificity.


reasoning: The paragraph discusses an incident’s disclosure timing and current status (law enforcement actions/apprehension and whether data is publicly available), which are incident-related disclosures rather than process or strategy.


reasoning: The paragraph describes internal cybersecurity processes (how incidents are detected, severity is determined via a severity matrix, and notification/escalation and triage are initiated). No specific cybersecurity leader or board committee is the grammatical subject, so it fits Risk Management Process rather than Management Role or Board Governance.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation, including potential data exfiltration and assessment of sensitive/personal information and potential legal/regulatory notifications tied to the incident.


reasoning: The paragraph describes a specific cybersecurity event (unauthorized access by a threat actor), response actions (activating a response plan, containing/assessing/remediating), and operational impact (restoration within days/hours and no material impact).


reasoning: The paragraph discusses uncertainty about materiality and provides financial impact expectations for a specified reporting period, without describing what occurred in the cybersecurity incident.


reasoning: The paragraph ties cyber impact only to financial results (additional expenses and lost/undelivered revenue) without describing the incident itself or operational details. It is therefore best categorized as strategy/financial integration rather than incident disclosure.


reasoning: The paragraph discusses response-related expenses and whether the disclosed incident will have a material impact on operations/financial condition, without describing the incident or any cyber processes.


reasoning: The paragraph narrates an actual cybersecurity incident (unauthorized activity), describes response actions, and includes a specific date (December 20, 2023) and operational impact (resumed business operations).


reasoning: The paragraph describes a real cybersecurity incident, including detection date, unauthorized access, containment/remediation actions, investigation activities, and a belief that the threat actor was ejected on the same date.


reasoning: The paragraph describes a real cybersecurity incident, including when it was identified, unauthorized access to information systems, and activation of the incident response plan.


reasoning: The paragraph is a standard forward-looking statements disclaimer with no substantive cybersecurity governance, risk process, incidents, or management-role details.


reasoning: The paragraph describes a specific cybersecurity incident, including the learning date, investigation/response actions, unauthorized access, exfiltration timeframe, and the scope of affected customer call/text records.


reasoning: The paragraph provides an update tied to a specific previously disclosed cybersecurity incident (the Change Healthcare cyberattack) and describes ongoing restoration/progress and support activities, anchored to a specific date.


reasoning: The paragraph describes an unauthorized access event, including the nature of the accessed data and the approximate affected user population, which is substantive incident disclosure.


reasoning: The paragraph narrates a real cybersecurity incident (date of awareness, unauthorized access, detection/response/investigation, and claims about containment and integrity of systems), which is the hallmark of Incident Disclosure.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized activity and data exfiltration) and the immediate response actions (containment and investigation). It includes a specific incident date, supporting firm-specific specificity.


reasoning: The paragraph describes actions taken after discovering a cybersecurity incident (activation of response protocols, containment by taking the network offline, investigation with third-party cybersecurity professionals, and notifications). It also discusses incident response objectives (containment, restoring systems, enhancing monitoring) and notification of affected parties.


reasoning: The paragraph provides a materiality/impact conclusion about the incident on financial systems, operations, and financial condition, without describing what occurred. It focuses on likelihood of material financial impact rather than cyber processes or response actions.


reasoning: The paragraph discusses costs, production losses, and expected material financial impact (profit margins, fourth quarter results) from a cybersecurity incident, without describing the incident’s events or technical scope. Therefore it is best categorized as Strategy Integration rather than Incident Disclosure.


reasoning: The paragraph describes the detection of suspicious activity in IT systems and the ensuing actions to assess, contain, and remediate the unauthorized activity, anchored to a specific date.


reasoning: The paragraph describes how the Company is managing ongoing operations and working to identify incident effects using an internal process (Halliburton Management System), without providing an incident narrative or scope. No specific cybersecurity management role or board oversight is the grammatical focus.


reasoning: The paragraph describes response actions to an actual cybersecurity incident (contain the threat, enhance security posture, monitoring/access control reviews, notifying authorities, cooperating). It contains no firm-specific details that would raise specificity.


reasoning: This paragraph is a materiality/impact statement about a cybersecurity incident on financial condition and results of operations, without describing what happened or any incident scope or response details.


reasoning: The paragraph describes an actual cybersecurity event (data exfiltration) including when it was learned and the Company’s immediate response steps and investigation activities, which squarely fits incident disclosure.


reasoning: The paragraph describes what the company did after discovering an unauthorized activity (activating a response plan, investigating, taking systems offline, notifying law enforcement, restoring systems, and assessing impacted data), which is incident-response narrative tied to an actual incident.


reasoning: The paragraph narrates a real incident with specific dates, ransomware/encryption, and unauthorized disclosure, including management’s materiality conclusion tied to escalation.


reasoning: The paragraph describes post-incident remediation outcomes (third party removed, access restored, completeness/integrity confirmed) tied to impacted information, which is characteristic of an incident disclosure update. It does not provide firm-unique details like dates, named systems, or third-party firms.


reasoning: The paragraph describes the incident’s impact and scope (what was and was not compromised, whether customer funds were accessible, and types of affected data). Because it is an actual incident narrative with data-type scope, it fits Incident Disclosure.


reasoning: The paragraph provides materiality/financial impact conclusions about a cyber incident but does not describe what happened, affected systems/data scope, or response actions—so it is treated as financial/strategy integration rather than incident disclosure or risk/process description.


reasoning: The paragraph describes integration of cybersecurity operating procedures into the company’s enterprise risk management program and mentions shared methodologies/reporting channels, but it does not identify a specific cybersecurity leader, board/committee, or any named frameworks or verifiable details.


reasoning: This paragraph is a standard legal disclaimer about filing status and incorporation by reference, with no cybersecurity governance, processes, roles, incidents, or strategy content.


reasoning: The paragraph describes ongoing remediation and system strengthening activities as part of the company’s response processes, but it does not provide incident-specific scope/details or name any cybersecurity leader, committee, tools, dates, or parties. The only actionable content is generic remediation/process language, so it fits best under risk management process.


reasoning: The paragraph discusses the financial materiality/likelihood of financial impact from a cybersecurity incident, without describing what happened or any cybersecurity process details.


reasoning: This is a forward-looking disclaimer with a cross-reference to another section and provides no incident description, management roles, or company-specific cybersecurity process details.


reasoning: The paragraph describes general dependence on internal and third-party technology but does not describe incident details, board/management roles, or specific cyber risk-management programs or requirements imposed on vendors.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation (files exfiltrated, assessing sensitive/personal information, evaluating required regulatory/legal notifications), which is characteristic of incident disclosure.


reasoning: The paragraph provides a materiality/financial-impact conclusion about an ongoing incident (no expected material impact on financial condition or results) and describes operational disruption at a high level, without incident specifics. It does not foreground a particular cybersecurity management role or describe risk/process mechanics, so it fits Strategy Integration.


reasoning: The paragraph’s grammatical subject is a specific cybersecurity management role (“Group Head, Cybersecurity/Information Security Officer”) and describes her experience and tenure, which is characteristic of management qualifications.


reasoning: The paragraph describes ongoing cybersecurity and resiliency/internal controls processes using generic company-wide language, without naming specific management roles or a board/committee subject or any incident details.


reasoning: The paragraph describes the company’s cyber risk management program and how it is integrated with enterprise risk management to manage cybersecurity threats, without foregrounding a specific cybersecurity leader or board oversight.


reasoning: The paragraph centers on how the company evaluates third-party vendors as part of its cybersecurity risk approach, which is the core subject rather than board or a specific management role.


reasoning: The paragraph is centered on the board of directors and its committee’s oversight of cybersecurity risk. It does not provide any firm-specific, named, or uniquely identifying details beyond generic references to board/audit committee oversight.


reasoning: The paragraph describes an enterprise risk management-related cybersecurity program and its purpose (assess/identify/manage cybersecurity risks). It does not foreground any specific cybersecurity management role or board committee, and contains no firm-unique details or named frameworks.


reasoning: The paragraph focuses on a board committee (“The Committee”) receiving and reporting cybersecurity-related updates and briefing the full Board, indicating board/committee oversight. It does not name a specific committee, role, cadence, or incident details beyond generic statements.


reasoning: The paragraph centers on a named individual (Mr. Tao) and describes his qualifications/experience, making it Management Role. It includes a verifiable quantified detail ('more than 20 years'), but does not mention a cybersecurity-specific role.