reasoning: The paragraph details an actual cybersecurity incident, including unauthorized access, data exfiltration (images of video meetings and screens), extortion threat, response actions (closing access, bolstering defenses), and operational/financial impacts, matching Incident Disclosure criteria. It describes the event's scope and response rather than focusing solely on financial or materiality aspects.


content_category: Incident Disclosure

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes a specific cybersecurity incident including dates, the nature of the attack (website defacement), and response actions (restoration from backups, taking site down, review), making it a clear Incident Disclosure. It contains two hard verifiable facts: a specific date and a named system (wytecintl.com).

provider: x-ai


content_category: None/Other

reasoning: This paragraph consists entirely of forward-looking statement disclaimers, cross-references to Risk Factors, and vague mentions of 'the Incident' without any substantive cybersecurity disclosure, fitting None/Other.


reasoning: This paragraph provides a narrative of a specific cybersecurity incident, including response actions by the third-party provider (investigation, engaging experts, notifying law enforcement), scope (limited to provider's environment, access to customer personal information like names, DOB, SSN/TIN), and no evidence of misuse, directly matching Incident Disclosure criteria over Strategy Integration since it describes the event details rather than focusing solely on financial/materiality impacts.


reasoning: The paragraph details the incident narrative including exfiltration of files, engagement of experts, confirmation of personal information scope, ongoing analysis, client notifications, and no public release, making it a clear Incident Disclosure. No qualifying specific facts (e.g., dates, named firms, quantified metrics) are present after filtering per guidelines, resulting in Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including unauthorized access by a threat actor, temporary operational disruptions, data exfiltration, and ongoing review/notifications, directly matching Incident Disclosure criteria with narrative of what happened, scope, and response. No qualifying specific facts (e.g., dates, named entities, quantities) from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


content_category: Strategy Integration

reasoning: The paragraph focuses on the materiality assessment, financial impact, and expected costs of the Incident without describing the event itself, narrative, scope, or response actions, fitting Strategy Integration per tiebreakers for financial/materiality discussions absent incident details. No specific facts like dates, amounts, named firms, or roles are present, confirming Generic Boilerplate specificity.


reasoning: Paragraph describes a specific cybersecurity incident including the date (February 3, 2025), attack details (unauthorized access, encryption of critical applications, exfiltration of files), response actions (containment, remediation, working with vendors), and operational impacts (system outage, product limitations, delayed back-office functions). This matches Incident Disclosure criteria with a real event narrative.


reasoning: The paragraph focuses on financial impacts, cost estimates, and ongoing assessment of an incident without describing the event itself, aligning with Strategy Integration per tiebreakers for financial costs without incident narrative. It contains one quantifiable dollar range as a firm-specific fact but lacks a second hard verifiable fact for Quantified-Verifiable.


reasoning: The paragraph details the scope and content of compromised data (call/text records, phone numbers, interaction counts, durations, cell site IDs) for AT&T's wireless customers and MVNOs, directly describing affected data/systems in a disclosed incident. No qualifying specific facts (e.g., dates, named roles, quantified metrics, named firms/tools) from the ✓ IS list are present after filtering.


reasoning: The paragraph describes a real cybersecurity incident with specific date, unauthorized access, system encryption, data theft (personal data), response actions (investigation, incident response plan activation, system shutdowns), and operational impacts (e-commerce fulfillment disruptions), making it a clear Incident Disclosure. It contains one hard verifiable fact (specific date), qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second verifiable fact like a named firm or tool.


reasoning: The paragraph describes the scope and operational impact of a specific cybersecurity incident (website offline, delayed IT communications, no material impact on IP or customer data) and ongoing response actions, fitting Incident Disclosure. No verifiable facts like dates, names, or quantities qualify it beyond Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident including the date, unauthorized access to file systems, response actions (incident response activation, containment, external assistance), and operational impact (temporary interruption), directly matching Incident Disclosure criteria. It includes one verifiable specific date, qualifying as Firm-Specific with no additional hard facts for Quantified-Verifiable.


reasoning: The paragraph details a specific cybersecurity incident including dates of notification and data access, threat actor names, access method, scope of affected mailboxes, and response actions, matching Incident Disclosure criteria. Two specific dates qualify it as Quantified-Verifiable.


reasoning: The paragraph focuses on the financial and operational impacts of the Incident, including materiality assessment for Q2 ended June 30, 2024, and effects on vehicle sales due to Affected Systems, without describing the incident event itself, aligning with Strategy Integration per tiebreakers.


reasoning: Paragraph describes a specific cybersecurity incident including detection date, response actions (investigation, incident response plan activation, system shutdown), and containment date, directly matching Incident Disclosure criteria with a real event narrative. Two specific dates provide verifiable facts for Quantified-Verifiable specificity.


reasoning: Paragraph describes operational impacts (disrupted inventory replenishment, order fulfillment delays, cancellations, reduced e-commerce demand, delayed shipments) and recovery actions (system shutdown, restoration of IT systems and data) from a real cyber incident, making Incident Disclosure the clear fit over Strategy Integration which lacks incident narrative details. No qualifying specific facts from the ✓ IS list (no dates, roles, named entities, quantifiers), resulting in Generic Boilerplate.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including dates, cause (former executive action), affected systems (website, email, IT), and response actions (restoration, investigation, expert involvement), matching Incident Disclosure criteria. Two specific dates qualify it as Quantified-Verifiable.


reasoning: The paragraph focuses on the materiality assessment of the cybersecurity incident's impact on business operations and financial condition, cyber insurance coverage, and future reporting of losses, without describing the incident itself. This matches Strategy Integration for financial impact and materiality conclusions lacking incident narrative.


reasoning: The paragraph details the incident's response actions (restored, contained, remediated), operational scope (communications, shipping, manufacturing), and impacts, fitting Incident Disclosure as it describes a real event's narrative and effects rather than just financial materiality. It contains multiple hard verifiable facts including specific dates and a dollar amount, exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses on remediation activities, insurance recoveries for costs, and a materiality assessment of the cybersecurity incident without narrating the incident details, aligning with Strategy Integration per tiebreakers for financial/insurance discussions without event description. No specific facts from the ✓ IS list (e.g., dates, named roles, quantified amounts, named tools) are present, confirming Generic Boilerplate.


reasoning: The paragraph describes a specific ransomware incident including dates, origin (third-party vulnerability), scope (internal IT systems), investigation, and response actions, fitting Incident Disclosure. It references a real event with narrative details rather than just financial or materiality impacts.


reasoning: The paragraph focuses on the expected financial impact and materiality assessment of 'this incident' without any narrative description of the event itself, aligning with Strategy Integration per tiebreakers. Multiple specific dates qualify as hard verifiable facts, exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph discusses financial costs, insurance, business impact, and materiality conclusions related to 'the incident' without any narrative description of the event itself, aligning with Strategy Integration per tiebreakers. It contains no verifiable facts, named entities, standards, or firm-specific details from the ✓ IS list, making it Generic Boilerplate.


reasoning: This paragraph details the operational impacts, response actions (halting operations, remediation, deploying new infrastructure, engaging experts), and restoration timeline of a specific cybersecurity incident, matching Incident Disclosure criteria. It includes one firm-specific date ('mid-June') but lacks a second hard verifiable fact for Quantified-Verifiable, and no named frameworks or third-parties.


reasoning: The paragraph describes a specific cybersecurity incident including the date it occurred (June 19, 2024), affected systems (DMS, CRM), scope of disruptions, restoration status, and ongoing operational impacts, fitting Incident Disclosure. It contains multiple hard verifiable facts like a precise date, named third-party firm (CDK), and named systems (DMS, CRM).


reasoning: This paragraph describes a specific cybersecurity incident including dates, scope of affected systems (DMS, CRM), third-party provider (CDK), and response status, fitting Incident Disclosure. It contains multiple verifiable facts like dates, named firm, and named systems, exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph details the detection of a specific cybersecurity incident on February 6, 2024, including response actions like initiating protocols, network isolation, business disruption, investigation, and notifications to regulators, directly matching Incident Disclosure criteria with a real event narrative.


reasoning: The paragraph describes a real cybersecurity incident, including unauthorized access, detection, response actions (activating incident response plan, taking systems offline, containment, notifying law enforcement), and operational impacts (halting production at various locations), matching Incident Disclosure criteria. No specific dates, named firms, products, roles, or other firm-unique facts are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph details financial impacts (delayed revenue recognition, lost revenue, one-time expenses) from 'the incident' without narrating the event itself (no dates, access, scope, or response details), matching Strategy Integration per tiebreakers for financial effects absent incident description.


reasoning: This paragraph describes a specific cybersecurity incident including the date it was detected, unauthorized occurrences on IT systems, encryption of data files, response actions like activating the incident response plan and shutting down systems, and operational impacts such as manufacturing facilities offline and order fulfillment affected. It fits Incident Disclosure as it provides a narrative of what happened, when, scope, and response for a real event.


reasoning: The paragraph focuses on financial arrangements (waivers of interest and lease payments) to fund cybersecurity incident remediation, emphasizing business/financial impact without describing the incident itself. Multiple verifiable facts including dates, dollar amount, and named third-party firms confirm Quantified-Verifiable specificity.


reasoning: This paragraph describes a specific cybersecurity incident including the detection date (June 30, 2024), unauthorized access to systems, and response actions like initiating protocols and investigation, directly matching Incident Disclosure criteria with a real event narrative.


reasoning: This paragraph describes a real cybersecurity incident with specifics on the date of discovery, unauthorized access method (encryption and monitoring software), affected systems (internal corporate IT systems, business applications), response actions (incident response activation, law enforcement notification, external experts), and operational disruptions, directly matching Incident Disclosure criteria.


reasoning: This paragraph describes the details of a specific cybersecurity incident, including unauthorized access by a cybercrime organization, data exfiltration scope (limited customer and employee PII from retail business environment), and response actions (investigation with experts, notifications to parties, regulators, and law enforcement). It fits Incident Disclosure as it provides a narrative of what happened, scope, and response without focusing on financial impacts or processes.


reasoning: The paragraph describes a specific cybersecurity incident with date of detection, unauthorized access details, response actions (incident response procedure activation, external experts, law enforcement notification), and operational disruptions/scope, directly matching Incident Disclosure criteria. It includes one verifiable specific date, qualifying as Firm-Specific with no additional hard facts for Quantified-Verifiable.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including detection date, scope (Canadian operations), response actions (isolation, engagement of professionals), and operational impacts (service delays in Canada), matching Incident Disclosure criteria. It does not focus on board/management roles, processes, or strategy.


content_category: Board Governance

reasoning: The paragraph focuses on the board of directors and audit committee's oversight of cybersecurity risks, with the board and committee as the grammatical subjects of most sentences. No firm-specific facts or named standards are present, making it generic boilerplate.


reasoning: The paragraph describes response actions to a real cybersecurity incident (ongoing investigation, reporting to law enforcement and regulators), scope (no evidence of customer data access), and lack of material operational or financial impact, aligning with Incident Disclosure criteria. No qualifying specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference to risk factors in another section of the filing, providing no substantive cybersecurity disclosure itself.


reasoning: This paragraph provides a standalone materiality assessment, stating no prior incidents have materially impacted the company and acknowledging potential future risks, with a cross-reference to Risk Factors, fitting Strategy Integration per guidelines. No specific facts, roles, dates, or frameworks are mentioned, confirming Generic Boilerplate specificity.


content_category: Risk Management Process

reasoning: The paragraph outlines company activities for monitoring emerging data protection laws and implementing process changes for compliance, which aligns with risk management processes as the company's processes are the grammatical subject. No specific management roles, board, incidents, or third parties are foregrounded.


reasoning: The paragraph focuses on the company's risk management processes, including integration of cybersecurity risks, biannual reviews, mitigation plans, and ERM reviews with the Board, with processes as the primary grammatical subjects. CISO and CIO are mentioned as participants but not foregrounded as the main subjects, aligning with Risk Management Process over Management Role or Board Governance.


reasoning: Paragraph provides narrative of a specific cyberattack on Change Healthcare services, detailing targeted areas (pharmacy, claims, payments), response actions (mitigation, restoration, investigation with law enforcement), and scope (isolated to Change Healthcare, other systems operational), matching Incident Disclosure criteria over Strategy Integration due to event description.


reasoning: Paragraph discusses immaterial expenses, no penalties/settlements, and materiality conclusions for past cybersecurity incidents without describing any specific events, aligning with Strategy Integration per tiebreakers for financial impact and materiality without incident narrative.


content_category: Management Role

reasoning: The paragraph centers on named cybersecurity-specific roles (CIO, Information Security Director) and their team, qualifications, and experience as the grammatical subjects, fitting Management Role. It includes two quantified experience years and named roles/team, meeting Quantified-Verifiable threshold.


reasoning: The paragraph centers on the Chief Technology Officer (CTO), detailing their qualifications, responsibilities for cybersecurity processes, and reporting to the General Counsel, with the person as the grammatical subject, fitting Management Role over Risk Management Process.


reasoning: The paragraph centers on the Audit Committee's primary responsibility for overseeing cybersecurity risks and how it receives regular updates from senior IT leadership, with the board/committee as the grammatical subject of most sentences, fitting Board Governance. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate.


reasoning: The paragraph focuses on the Adviser's cybersecurity program, controls, and procedures for assessing threats, identifying, classifying, and escalating incidents, with processes as the grammatical subject and no specific management roles foregrounded. It contains no named standards, roles, dates, or other firm-specific facts, making it generic boilerplate.


reasoning: The paragraph describes the Board of Directors' and Enterprise Risk Management Committee's oversight, training, approvals, and reporting on cybersecurity programs, with the board/committee as the primary grammatical subjects. It fits Board Governance clearly, as no management roles or internal processes are foregrounded.


reasoning: The paragraph describes the company's cybersecurity program, standards, policies, processes, and controls for risk identification, assessment, management, and mitigation, with processes/programs as the grammatical subject. Brief mention of the Global CISO leadership does not foreground a specific management role as the primary focus.


reasoning: The paragraph focuses on the company's processes for managing cybersecurity risks, including employee training, awareness updates, testing, penetration testing, and assessments, with processes as the grammatical subject and no specific management roles foregrounded. It contains no specific facts, named standards, roles, dates, or quantifiable details, making it generic boilerplate.


reasoning: The paragraph assesses the immaterial impact of cybersecurity risks and past incidents on business strategy, operations, and financial condition, with a mention of updating the information security strategy, fitting Strategy Integration for materiality conclusions without incident narratives. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes the company's cybersecurity program integration into various risk management processes and systems, with processes as the grammatical subject, fitting Risk Management Process. No specific management roles, board oversight, incidents, or vendor focus as central topic.


reasoning: The paragraph details the company's processes for threat assessments, risk prioritization, and mitigation strategies, including incident response plans, making processes the primary subject. No specific management roles, board, vendors, or incidents are foregrounded.


reasoning: The paragraph describes the company's incident response policies and escalation procedures to specific teams, making processes the grammatical subject without foregrounding named management roles. Named committees like Incident Management Team and Privacy and Security Subcommittee qualify as firm-specific facts, but no hard verifiable facts (dates, dollars, etc.) reach Quantified-Verifiable.


reasoning: The paragraph centers on the AGM board of directors' involvement in overseeing the risk management program, including cybersecurity, as the primary grammatical subject, aligning with Board Governance. Processes are mentioned secondarily in the context of board oversight and ERM integration.


reasoning: The paragraph centers on Mr. Gharib, a specific individual, and his cybersecurity responsibilities (hiring personnel, risk integration, budgeting, incident prep, process approval, report review), making a named management figure the grammatical subject per the Management Role test. Mr. Gharib is a unique, firm-specific identifier qualifying as Firm-Specific with no hard verifiable facts reaching Quantified-Verifiable and no named standards.


reasoning: The paragraph describes the company's processes for assessing, monitoring, managing cybersecurity risks via the CFO, consultants, and committee updates, with no specific cybersecurity leadership role (e.g., CISO) foregrounded. No qualifying specific facts from the ✓ IS list are present, as CFO is generic C-suite and the committee is standard governance.


reasoning: The paragraph describes how cybersecurity risks are managed through embedded business processes and collaboration between the enterprise risk management team, CSO, and IT risk management team, making processes the grammatical subject without foregrounding a specific management role. No board, incident, or third-party focus.


reasoning: The paragraph addresses the potential materiality of cybersecurity risks, resource expenditures including cyber insurance, and lack of material incidents, aligning with Strategy Integration as it focuses on business/financial impacts and materiality assessments without incident narratives. No qualifying specific facts, named standards, or verifiable details are present, resulting in Generic Boilerplate.


reasoning: The paragraph describes the company's processes for engaging external experts in audits, threat assessments, penetration testing, and security enhancements as part of its risk management, with the company's processes as the grammatical subject. Third-party engagement is a component of internal risk management, not central oversight of vendor security.


reasoning: The paragraph centers on the CISO and CTO as the grammatical subjects, detailing their roles, tenure, experience, and certifications, which fits 'Management Role'. It contains multiple hard verifiable facts including specific dates (2013, 2020), quantified years of experience, named certifications, and Carnegie Mellon, exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's established processes for assessing, identifying, and managing cybersecurity risks, with the processes as the grammatical subject and no specific management roles foregrounded. It contains no firm-specific facts, named standards, or verifiable details, making it generic boilerplate.


reasoning: The paragraph assesses the materiality of past cybersecurity incidents, stating none were material with immaterial expenses and no penalties, without any incident narrative or description of events. This aligns with Strategy Integration for materiality conclusions lacking incident details, per tiebreakers.


reasoning: The paragraph focuses on the Audit Committee, full Board, and Board members as the grammatical subjects receiving reports, briefings, and presentations on cybersecurity, aligning with Board Governance. Named cybersecurity-specific roles (CIO, CISO, CIRO) are mentioned as providing information but are not the primary subjects.


reasoning: The paragraph describes the Board's assignment of cybersecurity oversight to the Audit Committee, including annual reviews of risks and incidents, with the board/committee as the primary grammatical subjects. No qualifying specific facts from the ✓ IS list (e.g., cybersecurity-specific roles, non-generic committees beyond standard Audit Committee, dates, or named programs) are present, confirming Generic Boilerplate.


reasoning: The paragraph centers on the Company's cybersecurity risk management program and its components (committee meetings, training, policies), with the program as the grammatical subject, fitting Risk Management Process. Vendor management is a minor example, not central, and no board or specific role is foregrounded.


reasoning: This paragraph provides a standalone materiality conclusion (no material cybersecurity threats identified in 2023) with forward-looking disclaimers on risk management limitations, matching Strategy Integration per guidelines and tiebreakers for materiality assessments without incident narrative.


reasoning: The paragraph focuses on the Board establishing a Cybersecurity Committee for oversight and the chair's specific cybersecurity expertise, with the board/committee as the primary grammatical subjects, fitting Board Governance. It contains firm-specific facts like the named committee, establishment date, and chair's unique certification, but only one hard verifiable fact (date), making it Firm-Specific.


reasoning: The paragraph details the company's incident response plan, including processes for triage, assessment, investigation, and remediation, making the risk management processes the grammatical subject without foregrounding specific management roles. Vendors are mentioned only as a component of internal processes, not as the central topic.


reasoning: The paragraph describes the company's processes for vulnerability testing (ethical hacks, penetration tests) and program reviews using third parties, with the company's actions and program as the grammatical subject, fitting Risk Management Process; third-party engagement is a component of internal processes, not the central topic.


reasoning: The paragraph describes the company's processes for identifying risks, cross-functional strategies for threat mitigation and incident response, and escalation procedures, with processes as the grammatical subject and no specific management roles foregrounded. No firm-specific facts, named standards, roles, or quantifiable details are present, making it generic boilerplate.


reasoning: The paragraph centers on the CISO and CTO as the primary subjects, detailing their reporting lines, oversight responsibilities, and leadership in cybersecurity, which aligns with the Management Role category per the test for named management roles being foregrounded.


reasoning: The paragraph provides a standalone materiality conclusion stating no material impacts from past cybersecurity threats or incidents during a specific fiscal year, with forward-looking risks, fitting Strategy Integration per tiebreakers for materiality assessments without incident narratives.


reasoning: The paragraph details the company's internal audit program, including annual risk assessments that evaluate cybersecurity risks and reporting to business leaders, fitting Risk Management Process as the processes are the grammatical subject. No specific management roles, board, incidents, or third-parties are foregrounded.


reasoning: This paragraph is a cross-reference to the Risk Factors section with no substantive cybersecurity disclosure, fitting the 'None/Other' category for section headers and cross-references.


reasoning: This paragraph consists of forward-looking disclaimers about potential cybersecurity risks, insurance limitations, and a cross-reference to Risk Factors, offering no substantive disclosure on governance, processes, roles, or incidents.


reasoning: This paragraph discusses general cybersecurity threats, risks to the company and third parties, and the need to expend resources, which is boilerplate risk language with no substantive disclosure on governance, processes, incidents, or strategies.


reasoning: The paragraph describes the company's engagement of third-party services to support cybersecurity processes like crisis simulations, monitoring, incident response, detection, forensics, and threat intelligence, with processes as the grammatical subject and no specific management roles foregrounded. Third-party engagements are components of internal risk management processes, not central vendor oversight.


content_category: Third-Party Risk

reasoning: The paragraph centers on assessing, selecting, overseeing, and managing risks from third-party vendors, suppliers, and service providers, making third-party risk the primary topic rather than a mere component of broader internal processes.


reasoning: The paragraph centers on the qualifications, tenure, certifications, and cybersecurity-related experience of named executives (VP of Information Systems and CFO), making named management roles the grammatical subjects. Multiple quantifiable durations (19 years, 6 years, 25 years) and named entities (GIAC Board, GIAC certifications) exceed the threshold for Quantified-Verifiable.


reasoning: The paragraph identifies the Vice President of Operations as directing and monitoring cybersecurity programs, making a named management role the key subject despite board oversight mentions; per tests and tiebreakers, this foregrounds Management Role over Board Governance or Risk Management Process.


reasoning: The paragraph centers on named individual Jack Wang's role, qualifications, experience, and reporting lines for cybersecurity, making a named management figure the primary subject per the Management Role test. It includes a cybersecurity-specific role/responsibility and quantified experience, qualifying as Firm-Specific with no hard verifiable facts reaching Quantified-Verifiable threshold.


reasoning: The paragraph centers on cybersecurity risk assessment, selection, oversight, and due diligence for third-party service providers, making vendor oversight the primary topic rather than a mere component of broader internal processes.


reasoning: The paragraph focuses on the Board's and audit committee's oversight responsibilities for cybersecurity risks, including delegation, reviews, and reporting cadence, making Board Governance the primary category as board/committee are the grammatical subjects of most sentences. No firm-specific facts qualify under the ✓ IS list (e.g., no cybersecurity-specific roles, named non-generic committees beyond standard Audit Committee, dates, or quantifiables), resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the Board of Directors and Audit Committee's oversight responsibilities and update cadences for cybersecurity risks, with the board/committee as the grammatical subject of most sentences, fitting Board Governance. It contains no firm-specific facts, named frameworks, or verifiable details beyond generic governance language.


reasoning: The paragraph focuses on the Board's responsibility for risk oversight, delegation to the Audit Committee for cybersecurity matters, the committee's review of policies, and members' experience, with the board/committee as the grammatical subject of most sentences. No qualifying specific facts from the ✓ IS list are present, as Audit Committee is standard/generic and no other unique details like named roles, dates, or programs appear.


reasoning: The paragraph describes the company's Enterprise Risk Management process and cybersecurity risk management program as the subjects, focusing on integration, identification, and protection without foregrounding specific management roles. No specific facts, named standards, or unique details qualify it beyond generic boilerplate.


reasoning: The paragraph primarily describes the company's adoption of cybersecurity risk management processes using a risk-based approach to assessing, identifying, and managing risks, integrated into overall risk management strategy, with board oversight mentioned only briefly at the start. This aligns with Risk Management Process as the processes/programs are the grammatical subject, per category tests and tiebreakers.


reasoning: The paragraph details the company's operational cybersecurity processes, including security tools, tabletop exercises, penetration testing, and employee training, with processes and 'the Company' as the grammatical subjects and no specific management roles foregrounded.


reasoning: The paragraph details the company's implemented measures, processes, and policies (e.g., incident response plan, risk assessments, encryption) to manage cybersecurity risks, with processes as the grammatical subject and no management roles foregrounded. It contains no named standards, specific roles, dates, or other firm-unique facts, making it generic boilerplate.


reasoning: The paragraph focuses on the company's processes for implementing the NIST Cybersecurity Framework and adopting internal policies aligned with regulatory requirements, with processes as the grammatical subject and no specific management roles foregrounded.


reasoning: The paragraph focuses on the company's vulnerability assessment program and enterprise-wide cybersecurity risk management processes, with processes/programs as the grammatical subject, fitting Risk Management Process. No specific management roles, board, incidents, or third-party risks are foregrounded.


reasoning: The paragraph centers on the Director of Cybersecurity as the grammatical subject, detailing their leadership role, experience, and reporting lines to the Head of IT and executive committee, fitting Management Role. It includes cybersecurity-specific roles and a quantified experience metric, qualifying as Firm-Specific but lacking a second hard verifiable fact for Quantified-Verifiable.


reasoning: The paragraph centers on the Senior Vice President, IT Operations, as the director of the information security team responsible for monitoring, assessing incidents, and escalation, fitting the Management Role category where a specific cybersecurity-related management role is the grammatical subject and foregrounded. No other category like Risk Management Process applies as the named role takes precedence per guidelines.


reasoning: The paragraph describes the company's Security Operations Center processes for incident detection, severity assessment, triage, notification, and escalation, making processes the grammatical subject with no specific management roles foregrounded. No named standards, roles, dates, or unique firm facts qualify for higher specificity; all elements are generic cybersecurity practices.


reasoning: The paragraph describes a specific cybersecurity incident including the date it was detected, unauthorized access by a threat actor, data encryption, and immediate response actions like containment and engaging specialists, matching the Incident Disclosure category. No other category fits as it provides a narrative of the event rather than processes, roles, or strategy.


reasoning: The paragraph details a specific cybersecurity incident including the detection date (May 1, 2024), unauthorized access to portions of IT systems, and response actions like activating the incident response plan and engaging external experts, clearly fitting Incident Disclosure. It includes one verifiable specific date, qualifying as Firm-Specific with no other hard facts or named entities reaching Quantified-Verifiable.


reasoning: The paragraph focuses on the IT department's responsibilities for assessing and managing cybersecurity risks, their collective experience, monitoring processes, and participation in the risk management process, with the Audit Committee mention being brief; no cybersecurity-specific leadership role (e.g., CISO, VP of IT) is foregrounded as the subject.


reasoning: The paragraph describes the company's internal processes and measures for managing cybersecurity risks, such as incident detection, vulnerability management, and vendor risk processes, with 'we' and processes as the grammatical subjects and no specific management roles foregrounded. Vendor risks are mentioned as one component in a list of internal processes, not the central topic.


reasoning: The paragraph focuses on the materiality assessment of an ongoing cybersecurity incident's impact on business operations and financial condition without describing the event itself, aligning with Strategy Integration per tiebreakers. No specific facts, dates, roles, or standards are mentioned, making it generic boilerplate.


reasoning: The paragraph details the detection of unauthorized activity, containment and remediation steps, a specific date of action, and involvement of experts/law enforcement for a real incident, clearly fitting Incident Disclosure. It includes one verifiable specific date, qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard fact.


reasoning: The paragraph focuses on the company's processes for purchasing cyber insurance, maintaining business continuity/disaster recovery plans, and testing incident response readiness via tabletop exercises, with company processes as the primary grammatical subjects. A finance role is mentioned briefly but is not a cybersecurity-specific leader, so it does not shift to Management Role; insurance and planning fit Risk Management Process over Strategy Integration.


reasoning: The paragraph assesses the materiality of 'the incident' on operations and financial condition without describing the event, incident response details, or scope, matching the tiebreaker for Strategy Integration. Response actions like notifying law enforcement are mentioned but secondary to the materiality conclusion.


reasoning: The paragraph centers on processes to oversee and identify cybersecurity risks specifically in connection with third-party service providers, making vendor/supplier oversight the central topic rather than general internal processes. No specific facts qualify under the IS list, resulting in generic boilerplate language.


reasoning: The paragraph describes investigation findings (no evidence of malware, ransomware, etc.) and ongoing assessment of the incident's extent and impact, directly referencing response actions for a real event, which matches Incident Disclosure. No specific dates, names, numbers, roles, or other firm-unique facts are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the details of a cybersecurity incident, including unauthorized access, data exfiltration of PII, and ongoing response actions like notifications, fitting Incident Disclosure. No specific facts from the ✓ IS list or hard verifiable elements are present, making it Generic Boilerplate.


reasoning: The paragraph narrates a specific cybersecurity incident including detection date, response actions (incident response protocols, investigation, engaging a firm, notifications), and containment, directly matching Incident Disclosure criteria. It includes one verifiable specific date, meeting Firm-Specific threshold without reaching Quantified-Verifiable (only one hard fact).


reasoning: The paragraph details response actions (contain and remediate), scope of unaffected systems/networks, absence of unauthorized transactions or fund transfers, and minimal operational impact on members, directly matching Incident Disclosure criteria for incident response and scope. No verifiable facts, named entities, dates, or specifics are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph details the operational scope and impact of a specific cybersecurity incident, including affected areas like distribution and billing, delays, current status, and revenue percentage affected, fitting Incident Disclosure. It contains two hard verifiable facts (specific date and percentage), qualifying as Quantified-Verifiable.


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


reasoning: Paragraph assesses materiality and business impacts (operational disruption in Q4 2024, no full-year impact, risks like litigation) of a referenced incident without describing the event itself, fitting Strategy Integration per tiebreakers. Two specific date periods qualify as hard verifiable facts for Quantified-Verifiable.


reasoning: Paragraph provides a narrative of a real cybersecurity incident, including the specific date of awareness, unauthorized access, data encryption, and response actions like containment and engaging specialists, directly matching Incident Disclosure criteria. It includes one verifiable specific date, making it Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: The paragraph describes a specific cybersecurity incident, including timelines (May and June 2023), unauthorized access and exfiltration of SharePoint files, investigation, and response actions, fitting Incident Disclosure. It provides multiple verifiable facts like dates and a named system, exceeding the threshold for Quantified-Verifiable.


reasoning: Paragraph focuses on the materiality conclusion and specific financial impacts (EPS figures) of the Incident on Q2 results without any incident narrative or event description, aligning with Strategy Integration per tiebreakers. Contains a specific date and multiple quantified dollar amounts, meeting Quantified-Verifiable criteria with multiple hard verifiable facts.


reasoning: Paragraph discusses the ongoing investigation and materiality assessment of an incident without any narrative of the event, operations impact, or financial details, aligning with Strategy Integration per tiebreakers for materiality conclusions lacking incident description. No specific facts, named entities, dates, or frameworks present, confirming Generic Boilerplate.


reasoning: This paragraph details the detection of unauthorized activity on IT systems, containment and remediation steps, and a specific action on December 20, 2023, directly describing an actual cybersecurity incident with response actions. It matches Incident Disclosure as it provides event narrative including a date and scope details, without emphasizing financial impact or internal processes.


reasoning: The paragraph details the operational impacts (shipping, receiving, manufacturing, support functions), evidence of data exfiltration (files taken), and response actions (interim measures, file review, notifications), directly describing a real cybersecurity incident. No qualifying specific facts from the ✓ IS list (no roles, dates, named programs, firms, numbers, etc.), resulting in Generic Boilerplate.


reasoning: This paragraph describes the scope and details of data affected in a real cybersecurity incident, including the number of consumers impacted and specifics on data not stolen, fitting Incident Disclosure. It contains one quantified fact (35.5 million consumers), making it Firm-Specific but not Quantified-Verifiable due to lacking a second hard verifiable fact.


reasoning: The paragraph discusses financial impacts (material expenses in the first quarter), cyber insurance, and materiality of an incident without describing the event itself, matching Strategy Integration per tiebreakers. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph solely addresses the materiality assessment of a cybersecurity incident on business operations and financial condition without any incident narrative, dates, scope, or response details, fitting Strategy Integration per tiebreakers for materiality conclusions without event description. No specific facts, named standards, roles, or verifiable details present, confirming Generic Boilerplate.


reasoning: The paragraph discusses financial expenses, materiality assessment of the incident's impact on financial condition and operations, and ongoing business risks without describing the incident itself, fitting Strategy Integration per tiebreakers. No specific facts, named standards, roles, dates, or quantifiable details are present, making it Generic Boilerplate.


reasoning: This paragraph describes the details of a cybersecurity incident, including additional data exfiltration, review process, and confirmation of PII and PHI affected in a subsidiary's systems, fitting Incident Disclosure as it provides incident narrative and scope without focusing on response actions, financial impact, or processes. No qualifying specific facts (e.g., dates, named entities, roles, or quantifiable metrics) are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes a specific cybersecurity incident, including unauthorized access, misdirection of a $250,000 wire payment, deletion of email messages, and non-recovery of the payment, matching the Incident Disclosure category. It contains one verifiable quantified fact ($250,000), making it Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact like a date or named firm.


reasoning: The paragraph details financial impacts including additional expenses and lost revenue due to 'the cybersecurity incident' without any narrative description of the event itself, aligning with Strategy Integration per tiebreakers for financial costs without incident details. Multiple quantifiable facts (dollar amounts and fiscal periods) confirm Quantified-Verifiable specificity.


reasoning: The paragraph provides a narrative of a real cybersecurity incident, including the specific date, ransomware nature, affected systems, and response actions like containment and engaging experts, clearly fitting Incident Disclosure. It includes one verifiable specific date, making it Firm-Specific with no other qualifying facts or named standards.


reasoning: This paragraph details the company's response actions to a specific cybersecurity incident, including launching an investigation, notifying law enforcement, regulatory authorities, and affected users, which aligns with Incident Disclosure criteria for incident narratives and response actions.


reasoning: This paragraph details a real cybersecurity incident, including the date of occurrence, unauthorized access by a threat actor, response actions (activating response plan with external experts, containment, remediation, restoration), scope (limited portion), and operational impact (no material disruption, restored within days/hours), directly matching Incident Disclosure criteria.


reasoning: The paragraph details regulatory delays in disclosure, collaboration with law enforcement, apprehension of an individual involved, and the status of affected data availability, which qualifies as descriptions of incident response actions for a referenced cybersecurity incident.


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


reasoning: The paragraph focuses on the materiality assessment of an incident's impact on business operations and financial condition, without narrating the event details, aligning with Strategy Integration per tiebreakers for financial/materiality discussions. It references the incident's scope limited to a specific product, but lacks incident description.


reasoning: Paragraph details the scope of data exfiltrated in a cybersecurity incident (IT and financial information for specific 10-K filing), fitting Incident Disclosure as it describes affected data without financial impact or materiality focus.


reasoning: Paragraph details response actions to an ongoing cybersecurity incident (system restoration, retaining experts, law enforcement collaboration, notifications) and specifies the scope as limited to Change Healthcare systems, fitting Incident Disclosure as it describes what is happening in a real event without focusing on processes, roles, or strategy.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including detection of unauthorized activity, containment actions, a precise date of system isolation, expert retention, law enforcement involvement, and resumption of operations, matching Incident Disclosure criteria. It contains one verifiable specific date, qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: This paragraph describes a specific cybersecurity incident including discovery date, access method, exfiltration timeframe, and scope of affected customer data, with initial response actions, clearly fitting Incident Disclosure. Multiple specific dates provide more than two hard verifiable facts, confirming Quantified-Verifiable specificity.


reasoning: The paragraph describes aspects of a specific cybersecurity incident, including exfiltration of files, investigation into sensitive/personal information scope, and evaluation of required notifications, fitting Incident Disclosure as it details response actions and event scope without foregrounding processes, roles, or board oversight.


reasoning: This paragraph provides a narrative of a real cybersecurity incident, including the specific date of identification, method of discovery via employee communications from a threat actor, and activation of the incident response plan, directly matching Incident Disclosure criteria.


reasoning: This is a standard forward-looking statement disclaimer, which falls under None/Other as it contains no substantive cybersecurity disclosure.


reasoning: The paragraph provides a narrative of a real cybersecurity incident, including the date of awareness, unauthorized access to data/systems, and specific response actions like investigation and law enforcement notification, directly matching Incident Disclosure criteria. It contains one verifiable specific date, qualifying as Firm-Specific with no additional hard facts for Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident including the detection date, suspicious activity on IT systems, and response actions like isolation and investigation, directly matching Incident Disclosure criteria.


reasoning: The paragraph assesses the materiality and financial impact of a cybersecurity incident without describing the event itself, focusing on current non-material status and future expectations, which aligns with Strategy Integration per tiebreakers for materiality conclusions lacking incident narrative.


reasoning: The paragraph describes a specific cybersecurity incident including the date it was learned, the nature of the event (data exfiltration possibly containing personal information), and initial response actions (containment and investigation), matching Incident Disclosure criteria. No other category fits as it provides a narrative of the actual event rather than processes, roles, or strategy.


reasoning: This paragraph describes the detection of unauthorized access on a specific date (July 10, 2024), immediate response actions including investigation, incident response plan activation, and system shutdowns, and the ejection of the threat actor, clearly fitting Incident Disclosure as it narrates a real event. It includes specific dates as verifiable facts but lacks a second distinct hard fact like named firms or amounts, making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph discusses the immaterial financial and operational impact of 'the incident' and provides a materiality conclusion without any description of the event itself, aligning with Strategy Integration per tiebreakers. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph details response actions taken to an actual cybersecurity incident, including containment measures, enhanced monitoring, expert engagement, and notifications, fitting the Incident Disclosure category which encompasses incident response actions for a real event. No specific management roles, board oversight, or vendor focus is present.


reasoning: This paragraph discusses the materiality assessment of an incident on the company's financial condition without any incident narrative or description of the event, aligning with Strategy Integration per tiebreakers. It contains no specific facts from the ✓ IS list, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses on financial expenses ($600,000), operational impacts (lost production), and materiality conclusions for the cybersecurity incident without describing the event itself, aligning with Strategy Integration per tiebreakers. It contains two hard verifiable facts (dollar amount and specific date), qualifying as Quantified-Verifiable.


reasoning: The paragraph details an actual cybersecurity incident, including the scope of unauthorized access, types of compromised personal information (names, phone numbers, car registration numbers, addresses, emails), and what was not affected, directly matching Incident Disclosure criteria with a real event narrative.


reasoning: The paragraph details the subsidiary's response actions to a specific cybersecurity incident, including activation of protocols, containment measures, investigation with third-party assistance, law enforcement notification, and ongoing restoration and notification efforts, which matches Incident Disclosure criteria. No qualifying specific facts (e.g., dates, named firms, roles, or standards) are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes a real cybersecurity incident with specific dates, ransomware encryption of files, escalation to data disclosure, and management's response and materiality determination, directly matching Incident Disclosure criteria over Strategy Integration due to the detailed event narrative.


reasoning: This paragraph is a standard legal disclaimer about non-filed information and incorporation by reference, with no cybersecurity content or substantive disclosure.


reasoning: The paragraph describes response actions to a specific cybersecurity incident, including activating the response plan, internal/external investigation, taking systems offline, notifying law enforcement, and ongoing restoration/assessment, which matches Incident Disclosure criteria for incident response actions referencing a real event. No qualifying specific facts (e.g., dates, named firms, unique programs, or numbers) are present after filtering per guidelines, resulting in Generic Boilerplate.


reasoning: This paragraph details a specific cybersecurity incident including the date it was learned (February 21, 2024), the nature of the event (data exfiltration from information systems, potentially including personal information), and initial response actions (containment and investigation), directly matching Incident Disclosure criteria.


reasoning: Paragraph details the incident's data exfiltration, accessed systems, investigation of sensitive/personal information scope, and evaluation of notifications, directly describing aspects of a real cybersecurity event per Incident Disclosure criteria. No qualifying specific facts (no dates, names, numbers, or unique identifiers), resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses on assessing the materiality of the cyber incident's impacts on business operations and financial condition, referencing prior disclosures without narrating the incident itself, fitting Strategy Integration per tiebreakers for materiality conclusions without event description.


reasoning: The paragraph describes response actions to a specific cybersecurity incident, including containment, ongoing remediation efforts, and collaboration with experts to reinforce systems, fitting Incident Disclosure. No firm-specific facts, named standards, dates, roles, or quantifiable details are present, making it Generic Boilerplate.


reasoning: The paragraph details remediation actions and outcomes post-incident, such as removing the third party from IT systems, restoring access, and confirming data integrity, which qualifies as incident response actions under Incident Disclosure. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes how cybersecurity risk management procedures are incorporated into overall enterprise risk management programs, sharing methodologies, reporting, and governance, making processes the grammatical subject, which fits Risk Management Process. No specific facts, named standards, roles, or details qualify it beyond Generic Boilerplate.


category_confidence: medium

reasoning: Paragraph describes ongoing response actions (communication with stakeholders, following internal standards, assessing effects, maintaining operations) to a referenced cybersecurity incident, fitting Incident Disclosure despite lacking event details or scope. No firm-specific or verifiable facts present after filtering.


reasoning: This paragraph consists of a forward-looking disclaimer about potential cybersecurity incidents and a cross-reference to Item 1A Risk Factors, with no substantive disclosure on governance, processes, incidents, or other categories.


reasoning: The paragraph describes the board of directors' oversight of cybersecurity risks and its receipt of updates from the audit committee and executive team on an annual basis, with the board as the grammatical subject of most sentences, fitting Board Governance. No specific management roles or processes are foregrounded.


reasoning: The paragraph describes the company's internal cybersecurity risk management process, including a risk-based approach to evaluating third-party vendors as a component thereof, fitting 'Risk Management Process' per guidelines. Vendor oversight is not the central topic but embedded within the broader process description.


reasoning: The paragraph focuses on the Committee's oversight role in receiving periodic reports and updates from management on cybersecurity risks and incidents, and reporting to the full Board, with the committee as the grammatical subject of most sentences.


reasoning: The paragraph discusses the financial and operational materiality of a cybersecurity incident without any narrative description of the event, aligning with Strategy Integration per tiebreakers for materiality conclusions. It lacks any specific facts, named entities, dates, or quantifiable details, making it generic boilerplate.


reasoning: Paragraph discusses financial and operational materiality of the incident (no material impact on financials, disruption limited to Targus subsidiary, not significant to EBITDA) without describing the event itself, matching Strategy Integration tiebreaker for materiality conclusions without incident narrative.


reasoning: This paragraph describes the scope of affected data and what was not compromised in a specific cybersecurity incident, directly matching Incident Disclosure criteria including affected data details. No qualifying specific facts from the ✓ IS list (no roles, dates, named entities, programs, products, firms, or hard numbers), resulting in Generic Boilerplate.


reasoning: The paragraph updates on a specific cybersecurity incident (Change Healthcare cyberattack), describing ongoing response actions like data assessment, notifications to impacted individuals, and service restoration progress, which aligns with Incident Disclosure criteria including incident response actions and operational impact. There is some ambiguity as it primarily references an attached press release, but the summary of response efforts constitutes substantive incident-related disclosure.


reasoning: The paragraph focuses on the company's investments in enhancing internal controls and processes to protect systems and infrastructure, with processes as the grammatical subject, aligning with Risk Management Process. No board, management roles, incidents, or third-parties are foregrounded.


reasoning: The paragraph focuses on the board of directors and its audit committee as the subjects overseeing cybersecurity risk management and related matters, directly matching the Board Governance category. No specific management roles, processes, or incidents are described.


reasoning: The paragraph focuses on the company's cyber risk management program and its integration with enterprise risk management processes, with the processes themselves as the grammatical subject, aligning with Risk Management Process. No specific management roles, board oversight, incidents, or third-party risks are foregrounded.


reasoning: The paragraph describes the company's cybersecurity program integrated into enterprise risk management for assessing and managing risks, with processes as the grammatical subject and no specific management roles foregrounded. No specific facts, named standards, roles, or verifiable details are present, making it generic boilerplate.


reasoning: The paragraph describes oversight responsibilities for data privacy and cybersecurity policies, compliance, and evaluation of the Cybersecurity Committee's composition and performance, with the board or committee as the implied grammatical subject. This aligns with Board Governance as it focuses on committee oversight rather than management roles or internal processes.


reasoning: This paragraph provides a general statement about dependencies on IT systems and third-party providers without substantive details on cybersecurity processes, roles, governance, or incidents, qualifying as non-substantive disclosure.


reasoning: The paragraph describes the design and purpose of the company's cybersecurity program, with the program as the grammatical subject, aligning with Risk Management Process. It contains no specific details, roles, or named elements.


reasoning: The paragraph describes the general professional experience of Mr. Tao in business consultation, operations, and management in the marketing industry, with no reference to cybersecurity, roles, processes, or any cyber-related content, making it non-substantive for cybersecurity disclosure.


reasoning: The paragraph focuses on the company's incident response and recovery frameworks and their testing through simulations and tabletop exercises, with processes as the grammatical subject, fitting Risk Management Process. No specific management roles, incidents, or other categories are foregrounded.


reasoning: The Board of Directors is the grammatical subject of both sentences, describing its oversight through receiving quarterly reports from the CISO and CIO on cybersecurity threats, risks, and mitigation processes. This clearly fits Board Governance over Management Role, as the board's role is foregrounded.


reasoning: The paragraph describes company processes for protecting information via a policy and employee training/testing programs, with processes as the grammatical subject and no specific management roles foregrounded. No specific facts, named standards, or unique details qualify it beyond generic boilerplate.


reasoning: The paragraph describes cybersecurity risk management as integral to the company's enterprise risk management program, with processes/programs as the grammatical subject and no specific management roles foregrounded. No firm-specific facts or named standards are present, making it generic boilerplate.


reasoning: The paragraph focuses on the qualifications, experience, and joining date of a specific cybersecurity leader (Group Head, Cybersecurity/Information Security Officer), making the named role the grammatical subject. This fits 'Management Role' per the test for named management roles in cybersecurity.


reasoning: The paragraph focuses on the audit committee reporting to the board and the board receiving briefings from management on cybersecurity, with the board and committee as the grammatical subjects, aligning with Board Governance. No specific management roles or processes are foregrounded.


reasoning: This paragraph describes general oversight of strategic and material risks by the board and executive officers with no mention of cybersecurity, qualifying as non-cybersecurity content with no substantive disclosure.


reasoning: The paragraph identifies specific management roles (head of the ITS Department and executive management) as the grammatical subjects responsible for assessing and managing cybersecurity risks, fitting the Management Role category per the test. No board or processes are foregrounded.


reasoning: This paragraph consists of generic boilerplate language describing common cybersecurity vulnerabilities and threats like malware, ransomware, and phishing, with no substantive disclosure on governance, processes, roles, incidents, or strategy.


reasoning: This is a standalone materiality conclusion with no incident reference or narrative, directly matching the tiebreaker for Strategy Integration. It contains no specific facts, frameworks, or details beyond boilerplate language.


reasoning: The paragraph describes the company's cybersecurity program as a critical element of its overall risk management approach, with the program as the grammatical subject, fitting Risk Management Process. No specific management roles, board oversight, incidents, or third-party focus is present.


reasoning: The paragraph provides vague, non-substantive praise of the generic 'information technology team' qualifications without referencing specific roles, processes, incidents, or other core categories. No qualifying specific facts present, confirming generic boilerplate.


reasoning: The paragraph centrally describes the company's process for reviewing and monitoring key third-party IT service providers' cybersecurity measures, including specific use of Security Scorecard, which fits Third-Party Risk as vendor oversight is the primary focus rather than general internal processes.


reasoning: This paragraph outlines a generic step in the incident response eradication process, aligning with Risk Management Process as it describes IR planning without foregrounding specific management roles, board oversight, or actual incidents.


reasoning: This paragraph fragment generically describes the use of third-party e-mail and cloud storage services from reputable providers with built-in protections, lacking any substantive cybersecurity disclosure, specific processes, oversight, or incidents, thus fitting None/Other.


reasoning: The paragraph centers on the Board receiving regular updates on cybersecurity risks from the Audit Committee and Cybersecurity team, with the Board as the grammatical subject, aligning with Board Governance. No specific management roles or processes are foregrounded.


reasoning: The paragraph foregrounds specific cybersecurity management roles (CSO and CISO) as the grammatical subjects describing their activities and reporting lines, with brief mention of board oversight; per tiebreakers, management roles as main focus assigns Management Role over Board Governance.


reasoning: The paragraph centers on the 'internal cybersecurity coordinator' as the grammatical subject, detailing their responsibilities for risk assessment and management, collaboration with the IT team, and reporting to the CEO, which fits Management Role. No board or processes are foregrounded.


reasoning: The paragraph identifies specific cybersecurity leaders (CIO, Director of IT Security, Risk and Compliance) and their qualifications/experience, with these roles as the grammatical subjects, fitting Management Role. No board oversight or processes are foregrounded.


reasoning: The paragraph states no significant cybersecurity breach or associated financial impacts (expenses, penalties, settlements) occurred in specific periods, which aligns with Strategy Integration as a materiality assessment without describing any incident. It contains two specific dates (December 31, 2023 and 2022), qualifying as Quantified-Verifiable.


reasoning: The paragraph focuses on the Board and Audit Committee receiving regular reports from management on cybersecurity risks and incidents, with the board/committee as the grammatical subjects, fitting Board Governance. No specific facts qualify under the ✓ IS list, resulting in Generic Boilerplate.


reasoning: The paragraph describes components of the company's cybersecurity programs, including investment in threat intelligence, engagement in forums, and use of external experts for program maturity challenges, control assessments, and capability testing, with processes as the grammatical subject. No specific management roles, board oversight, incidents, or third-party vendor focus is present.


reasoning: The paragraph identifies a specific cybersecurity leader (CFO serving as CISO) and describes their role in managing processes, making a named management role the grammatical subject. No board or processes are foregrounded over the person.


reasoning: The paragraph centers on specific cybersecurity leaders (CIO and VP of Information Security) as the grammatical subjects with primary responsibility for the cybersecurity program, directly matching the Management Role category definition. No board or processes are foregrounded.


reasoning: The paragraph focuses on the company's incident response plan, its ongoing review, refinement, and updates based on lessons learned, making processes the grammatical subject, which aligns with Risk Management Process; no specific management roles are foregrounded. No specific facts from the ✓ IS list or named standards are present, confirming Generic Boilerplate.


reasoning: This paragraph provides a standalone materiality conclusion stating no cybersecurity incidents have materially impacted or are likely to impact the company as of specific dates, fitting Strategy Integration per tiebreakers. No incident narrative is described.


reasoning: The paragraph describes management's monitoring of cybersecurity processes like prevention, detection, mitigation, and remediation, with vendors mentioned as a component of notifications, fitting Risk Management Process as the company's processes are the focus rather than specific roles or central third-party oversight.


reasoning: The paragraph provides a standalone materiality conclusion regarding the absence of material cybersecurity incidents and immaterial expenses over the last three fiscal years, without any incident narrative or description of events, fitting Strategy Integration. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes the company's internal processes for conducting phishing simulations and cybersecurity training, with processes as the grammatical subject and no specific management roles foregrounded. It contains no named standards, roles, dates, or other firm-specific facts, making it generic boilerplate.


reasoning: The paragraph discusses cyber insurance coverage to mitigate financial losses from cyber incidents, which aligns with Strategy Integration's focus on cyber insurance and financial impact strategies. No specific details, roles, or incidents are mentioned, making it a clear fit without ambiguity.


reasoning: The paragraph discusses the company's approach to developing, implementing, and maintaining cybersecurity measures to protect systems and data, with the company's processes as the grammatical subject and no specific management roles foregrounded. It contains no specific facts, frameworks, roles, or details unique to the firm, making it generic boilerplate.


reasoning: The paragraph describes the company's processes for identifying, assessing, and managing cybersecurity risks to its systems and data, with processes as the grammatical subject and no specific management roles foregrounded. Third-party services are mentioned only as part of protected assets, not as the central topic of vendor oversight.


reasoning: The paragraph describes the company's general strategies for assessing, identifying, and managing cybersecurity risks, including traffic monitoring tools and user training, with the company's processes as the grammatical subject. No specific management roles, incidents, or other categories are foregrounded.


reasoning: The paragraph describes the activities of cybersecurity professionals in analyzing threats, defining policies, implementing protections, and monitoring/responding to incidents, which aligns with risk management processes rather than specific roles, board oversight, or other categories. No specific management roles are named or foregrounded, confirming Risk Management Process per guidelines.


reasoning: The paragraph describes the Board of Directors' oversight of the cybersecurity program through periodic quarterly updates and annual discussions in enterprise risk management, with the board as the grammatical subject. No specific facts qualify under the ✓ IS list, confirming generic boilerplate.


reasoning: The paragraph describes the company's cybersecurity risk management system as a framework for identifying, assessing, and mitigating risks, with the process itself as the grammatical subject, fitting Risk Management Process. No specific management roles, board oversight, incidents, or other categories are foregrounded.


reasoning: The paragraph describes company processes including employee training and a risk management process for third-party providers with due diligence and monitoring, making processes the grammatical subject without foregrounding specific management roles. Vendors are mentioned as a component of internal risk management, not the central topic.


reasoning: The paragraph describes a company process of providing regular mandatory cybersecurity training to employees and contractors, aligning with Risk Management Process as the processes are the grammatical subject without specific management roles foregrounded. It contains no specific facts, named standards, or verifiable details, qualifying as Generic Boilerplate.


reasoning: The paragraph describes the current handlers of day-to-day cybersecurity management (IT staff) and their qualifications (lack of specialized training), fitting the Management Role category as it focuses on personnel responsible for cybersecurity without foregrounding processes or board oversight.


reasoning: The paragraph provides only generic, boilerplate statements about high-level goals for cyber incidents without any substantive details on processes, roles, incidents, or strategies, fitting None/Other.


reasoning: The paragraph focuses on the company's Incident Response Plan (IRP) and its testing via annual tabletop exercises, which are core components of cybersecurity risk management processes. No management roles, board oversight, or other category elements are foregrounded, and it lacks firm-specific details beyond generic practices.


reasoning: The paragraph describes the establishment of a company-specific cybersecurity team and its responsibilities for awareness and training, making processes/programs the grammatical subject, which fits Risk Management Process. No specific management roles or board oversight is foregrounded.


reasoning: The paragraph focuses on the company's multi-layered cybersecurity program, processes, and incident response plan as the grammatical subjects, describing risk management practices without foregrounding specific management roles. No qualifying specific facts or named standards are present, making it generic boilerplate.


reasoning: The paragraph describes the company's information technology and cybersecurity programs, including policies, procedures, assessments, monitoring, response plans, and testing, with the programs as the grammatical subject, fitting Risk Management Process. No specific management roles, board oversight, incidents, or third-party focus is present.


reasoning: The paragraph discusses seeking reimbursement from cybersecurity insurance for costs related to a cyber incident, focusing on financial/insurance aspects without any incident narrative or description of the event itself. This fits Strategy Integration per tiebreakers for insurance and financial impact without event details.


reasoning: The paragraph identifies specific named management roles (CFO, COO, CEO) as the grammatical subjects responsible for managing cybersecurity risks, implementing policies, and strategic decisions, directly matching the Management Role category definition and test.


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


reasoning: The paragraph describes ongoing incident response actions (forensic analysis and investigation) for a specific cybersecurity incident referenced as 'the incident,' fitting Incident Disclosure criteria which includes response actions to a real event. No firm-specific facts, dates, names, or standards are present, making it generic boilerplate.


reasoning: This paragraph states a materiality conclusion for 'the Incident' without any description of the event, financial costs, or other details, aligning with Strategy Integration per tiebreakers for standalone materiality assessments. No specific facts, named standards, or verifiable details are present, making it Generic Boilerplate.


reasoning: The paragraph discusses plans to implement processes for identifying, assessing, and managing cybersecurity risks as part of broader risk management, making the company's processes the grammatical subject with no specific management roles foregrounded. No named standards, roles, dates, or other firm-specific facts are present, rendering it generic boilerplate.


reasoning: This paragraph provides a standalone materiality conclusion stating no material cybersecurity impacts in 2024, with a cross-reference to Risk Factors, fitting Strategy Integration per tiebreakers. It contains one specific date (2024), qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard fact.


reasoning: This paragraph describes ongoing incident response actions (system restoration, retaining experts, law enforcement coordination, regulatory notifications) for a cybersecurity disruption, fitting Incident Disclosure as it references response to a real event without financial or materiality details. No specific facts qualify under the ✓ IS list, resulting in Generic Boilerplate specificity.


reasoning: The paragraph discusses the potential material impact on financial condition and ongoing forensic assessment without describing the incident itself, fitting Strategy Integration per tiebreakers for materiality conclusions without event narrative. No specific facts or named standards are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph identifies specific management roles (Senior Director of IT and CFO) responsible for implementing and maintaining cybersecurity processes, making named roles the focus per category tests. Senior Director of IT qualifies as a cybersecurity-specific title, elevating to Firm-Specific; no hard verifiable facts for higher levels.


reasoning: The paragraph states a materiality conclusion for 'the incident' without any description of the event, financial costs, or other details, aligning with Strategy Integration per tiebreakers for standalone materiality assessments. It consists entirely of boilerplate language with no specific facts, named standards, or unique details.


reasoning: The paragraph addresses the lack of material operational disruption and potential financial risks (revenue loss, expenses, penalties, litigation) from 'the Incident' without any incident narrative or event description, aligning with Strategy Integration per tiebreakers for financial/materiality discussions. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph assesses the materiality of a cybersecurity incident on operations and financial condition without any narrative description of the event, aligning with Strategy Integration per tiebreakers for materiality conclusions. It uses standard boilerplate language with no specific facts, dates, roles, or quantifiable details.


reasoning: The paragraph describes cybersecurity insurance coverage for various costs and forward-looking updates on assessment, aligning with Strategy Integration's focus on financial impacts and cyber insurance without any incident narrative or event description. No verifiable facts, named standards, roles, or unique company details are present, confirming Generic Boilerplate specificity.


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


reasoning: The paragraph describes the details of a specific cybersecurity incident, including unauthorized access, data exfiltration of limited data including some PII, and ongoing response actions like notifications, matching Incident Disclosure criteria. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


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


reasoning: The paragraph provides a materiality assessment of a cybersecurity incident, stating no material impact on operations or likely future financial effects, without describing the incident itself. This fits Strategy Integration per tiebreakers for materiality conclusions without incident narrative.


reasoning: This paragraph describes incident response actions, specifically notifications to law enforcement and regulatory bodies about 'the matter,' which fits Incident Disclosure as it references actions taken for a real cybersecurity event without narrating the incident itself. No other category applies, as it lacks board/management focus, processes, or strategy elements.


reasoning: This paragraph assesses the materiality of a cybersecurity incident on operations and financials without any incident narrative, scope, or response details, aligning with Strategy Integration per tiebreakers for materiality conclusions. It contains no verifiable facts, named standards, or firm-specific details, making it Generic Boilerplate.


reasoning: This paragraph discusses legal waivers under credit and lease agreements with no reference to cybersecurity, board, management, processes, incidents, or strategy, making it non-substantive cyber disclosure.


reasoning: The paragraph focuses on specific cybersecurity leaders (CTO and senior director of cybersecurity and compliance), their qualifications (certifications), and reporting lines to the Audit Committee, fitting Management Role as the roles are the grammatical subjects. Brief program mention does not override the management focus.


reasoning: This paragraph provides a cross-reference to an external status page for incident updates with no substantive description of the incident, its scope, response, or other cybersecurity details, fitting None/Other. No specific facts from the ✓ IS list are present after filtering self-references and generic terms.


reasoning: The paragraph states a materiality conclusion regarding 'the incident' without any description of the event, scope, or response, aligning with Strategy Integration per tiebreakers for financial/materiality discussions absent incident narrative.


reasoning: This paragraph describes incident response actions (notifying law enforcement and regulators), which falls under Incident Disclosure as it references actions taken for a real cybersecurity event without narrating the incident itself. No specific details like dates, scopes, or named entities are present, making it generic boilerplate.


reasoning: The paragraph discusses the materiality assessment of a cybersecurity incident on operations and financial condition without describing the event itself, fitting Strategy Integration per tiebreakers. No specific facts, dates, amounts, or named entities are present, making it generic boilerplate.


reasoning: The paragraph describes an executive resignation and interim appointment at a subsidiary with no reference to cybersecurity risks, incidents, processes, or governance, making it non-cybersecurity content.


reasoning: This paragraph addresses financial impacts (direct costs) and cyber insurance recoveries related to a cybersecurity incident without any narrative description of the event, aligning with Strategy Integration per tiebreakers for financial/insurance discussions lacking incident details.


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


reasoning: The paragraph describes specific response actions taken to an actual cybersecurity incident, including closing the point of access and notifying impacted customers, which fits Incident Disclosure as it includes incident response actions referencing a real event. No firm-specific or verifiable facts are present, making it generic boilerplate.


reasoning: The paragraph describes a real cybersecurity incident with specific dates of notification and confirmation of customer data exposure by a third-party provider, fitting Incident Disclosure as it provides a narrative of what happened and when.


reasoning: The paragraph describes response actions to a specific cybersecurity incident (containment, restoration of IT environment and operations), fitting Incident Disclosure as it references a real event and operational impact without financial or materiality details. No specific facts like dates, names, or quantifiers are present, making it generic boilerplate.


reasoning: The paragraph focuses on the materiality of financial impact from 'the incident' without any narrative description of the event, aligning with Strategy Integration per tiebreakers. No verifiable facts, dates, names, or specifics are present, confirming Generic Boilerplate.


reasoning: The paragraph describes response actions to a specific cybersecurity incident (containment, system restoration, resuming operations), fitting Incident Disclosure as it references a real event and includes incident response details without focusing on financial impacts or processes.


reasoning: The paragraph focuses on a materiality assessment of 'the incident' without describing the event itself, ongoing generic response actions, or financial details, fitting Strategy Integration per tiebreakers for materiality conclusions without incident narrative. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph details ongoing elements of a specific cybersecurity incident, including undetermined data scope, ongoing investigation, and remediation efforts with an insurance provider, aligning with Incident Disclosure criteria for incident narrative and response actions. No qualifying specific facts such as dates, named firms, roles, or quantifiable metrics are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph discusses the immaterial impact of a past cybersecurity incident on operations and financial condition without describing the event itself, fitting Strategy Integration per tiebreakers for materiality conclusions. No specific facts or named standards are present, confirming Generic Boilerplate.


reasoning: The paragraph describes aspects of a specific cybersecurity incident, including the ongoing investigation, scope assessment of exfiltrated personal information, and planned notifications to affected parties and regulators, fitting Incident Disclosure as it references response actions for a real event without financial or materiality details.


reasoning: The paragraph addresses the materiality of a cybersecurity incident's financial impact without any incident narrative or event description, aligning with Strategy Integration per tiebreakers. It contains no specific facts, named standards, or unique details, making it Generic Boilerplate.


reasoning: This paragraph details ongoing investigation and forensic analysis into a cybersecurity incident, specifically assessing whether personally identifiable information was compromised by threat actors, which qualifies as Incident Disclosure due to its focus on response actions and scope related to a real event.


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


reasoning: This paragraph describes what happened during a cybersecurity incident, including unauthorized access to systems, data exfiltration, and encryption of non-production systems, directly matching the Incident Disclosure category as it provides a narrative of the event without focusing on financial impacts or processes.


reasoning: This paragraph details the operational scope and impacts of a cybersecurity incident (shops open globally, disruptions to online ordering in parts of the US, uninterrupted deliveries), fitting Incident Disclosure criteria for descriptions of affected systems/services and operational impact without narrative of the event itself.


reasoning: Paragraph assesses potential material financial impact of an incident without describing the event, matching Strategy Integration tiebreaker for materiality discussions lacking incident narrative.


reasoning: This paragraph describes a post-incident response action (mailing notification letters based on investigation findings), which qualifies as Incident Disclosure as it references actions taken for a real cybersecurity event without detailing the incident itself.


reasoning: The paragraph describes post-incident response actions (restoration of IT systems and data), ongoing operational impacts, and investigation outcomes for a specific cyber incident, fitting Incident Disclosure. No firm-specific facts like dates, names, or quantifiers are present, making it Generic Boilerplate.


reasoning: The paragraph describes a real cybersecurity incident with a specific date, system outage details, and initial response actions (activating incident response team), making it Incident Disclosure. No other categories fit as there is no focus on board/management roles, processes, or financial impacts.


reasoning: This paragraph describes a real cybersecurity incident with a specific date, the event (systems outage caused by attack), and response actions (activated incident response team), directly matching Incident Disclosure criteria.


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


reasoning: The paragraph describes the nature of a cybersecurity incident (threat actor access to IT systems with sensitive personal information) and response actions (planned notifications), fitting Incident Disclosure as it references a real event with scope and response details. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


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


reasoning: This paragraph details the operational impacts (shipping, receiving, manufacturing, back office functions) and response actions (temporary measures, restoration) of a specific cybersecurity incident, directly matching Incident Disclosure criteria for incident scope and response without focusing on financial materiality or processes.


reasoning: Paragraph discusses materiality assessment and financial impact of an incident without any narrative of the event itself, aligning with Strategy Integration per tiebreakers. No qualifying specific facts present, resulting in Generic Boilerplate.


reasoning: The paragraph describes response actions taken and the cause of a specific cybersecurity incident (fourth-party vendor compromise), fitting Incident Disclosure as it provides a narrative of what happened without focusing on financial impacts or processes. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph assesses the materiality and financial impact of a cybersecurity incident on specific quarterly results without describing the incident itself, aligning with Strategy Integration per tiebreakers for financial/materiality discussions lacking event narrative.


reasoning: The paragraph provides a materiality assessment of a cybersecurity incident's impact on operations and financial condition without any incident narrative or description, aligning with Strategy Integration per tiebreakers. No specific facts, frameworks, or verifiable details are present, making it Generic Boilerplate.


reasoning: The paragraph discusses the ongoing assessment of material financial impact from 'the incident' without any incident narrative, dates, scope, or response details, fitting Strategy Integration per tiebreakers for materiality conclusions. No specific facts, standards, or unique details present, confirming Generic Boilerplate.


reasoning: The paragraph describes the operational impact on the primary website and a specific response action (creating a special communications website), referencing a real ongoing incident, which fits Incident Disclosure per the criteria for affected systems scope and response actions. It contains one firm-specific verifiable fact (the named special website URL), qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: The paragraph describes a specific cybersecurity incident, including the date it was detected and the nature of the event (attempt by unknown persons to fraudulently obtain funds), matching the Incident Disclosure category. No other category fits as it provides a narrative of what happened in a real event.


reasoning: Paragraph describes the scope and operational impact (inaccessibility of business applications including financial and operating reporting systems for approximately six weeks) of a specific cybersecurity incident, directly matching Incident Disclosure criteria. No qualifying specific facts (no dates, named entities, roles, exact quantifiables, or standards named), resulting in Generic Boilerplate specificity.


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


reasoning: The paragraph describes temporary response measures and operational workarounds implemented during system restoration following a cybersecurity incident, fitting Incident Disclosure as it details incident response actions without focusing on processes, roles, or financial impacts.


reasoning: The paragraph primarily describes the company's processes for evaluating cybersecurity incidents, escalation procedures, Incident Response Program, and Business Continuity Plan, with processes as the grammatical subject. The CSO is mentioned in the context of evaluation but not as the foregrounded subject, fitting Risk Management Process over Management Role.


reasoning: This paragraph solely cross-references a press release attached as Exhibit 99.1, providing no substantive cybersecurity disclosure, which fits None/Other.


reasoning: The paragraph describes the company's general processes for monitoring and developing IT networks to prevent, detect, and mitigate cyber risks, with 'we' as the grammatical subject and no specific management roles foregrounded. It contains no named frameworks, roles, dates, or other specific facts, making it generic boilerplate.


reasoning: The paragraph primarily describes the company's cybersecurity risk management strategy and its key components (CIS framework, risk assessments, infrastructure, personnel, training), with processes/programs as the grammatical subject. Board committee is mentioned briefly in one context, but does not make governance the focus.


reasoning: The paragraph centers on the specific management roles and team composition (Risk Management Team including Sr. Director of IT) that monitor cybersecurity risks, meet quarterly, and report to the Audit Committee, foregrounding named management personnel per the Management Role criteria. Audit Committee oversight is referenced but is secondary to the management team's actions and structure.


reasoning: The paragraph describes incident response actions (notifying regulators and working with law enforcement) tied to a specific unauthorized access event, fitting Incident Disclosure. It includes one firm-specific named entity (Targus), qualifying as Firm-Specific but not reaching Quantified-Verifiable with only one hard fact.