content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the governance structure for cybersecurity oversight, including the Executive Cybersecurity Steering Committee and local Information Security Officers, detailing how they monitor and coordinate responses to cyber risks.

provider: google

stage: benchmark


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal risk management processes, specifically the role and functions of the Cyber Security Watch Team (CSWAT) in managing cyber risks, business continuity, and reviewing various security programs.


content_category: Management Role

reasoning: The paragraph focuses on the management team, specifically identifying the CISO and Sr. Director of Information Security, and describes how they are informed about and monitor cybersecurity risks.


reasoning: The paragraph primarily describes the governance structure, detailing how the cybersecurity team is overseen by specific officers who then provide quarterly and annual updates to the Board of Directors, and how the Board oversees the enterprise risk assessment.


reasoning: The paragraph primarily describes the governance structure, detailing how the executive team, Audit Committee, and Board of Directors oversee cybersecurity risk, including reporting cadences from the Chief Information Officer.


reasoning: The paragraph primarily describes the board's oversight structure for cybersecurity risk, detailing how the Board, Audit Committee, Governance and Compliance Committee, and Technology Committee receive reports from management and the CISO.


content_category: Strategy Integration

reasoning: The paragraph contains a forward-looking materiality assessment using the SEC qualifier 'reasonably likely to materially affect', which classifies it as Strategy Integration.


reasoning: The paragraph describes the governance structure and reporting chain, detailing how cybersecurity information flows from the CISO to the Cybersecurity Executive Steering Body and ultimately to the Audit Committee of the Board of Directors.


reasoning: The paragraph explicitly states a negative materiality assessment ('not aware of any previous cybersecurity threats that have materially affected or are reasonably likely to materially affect the Company'), which falls under Strategy Integration.


reasoning: The paragraph consists entirely of backward-looking and forward-looking materiality assessments regarding cybersecurity risks and incidents, which falls under Strategy Integration.


reasoning: The paragraph explicitly describes the oversight structure for cybersecurity risk management, detailing that the entire Board of Directors holds responsibility and receives regular reports from the Chief Risk Officer.


content_category: None/Other

reasoning: The paragraph consists of generic risk warnings about thwarted attacks, forward-looking disclaimers, and a cross-reference to the Risk Factors section, lacking substantive disclosure about cybersecurity processes, governance, or actual material incidents.


reasoning: The paragraph makes a negative assertion regarding the occurrence of material cybersecurity incidents, which falls under Strategy Integration.


reasoning: The paragraph contains a backward-looking materiality assessment stating that cybersecurity incidents have not materially affected the business to date, which falls under Strategy Integration.


reasoning: The paragraph describes the governance and reporting structure for cybersecurity, detailing how information flows from the Information Security Department and CISO up to the Risk Management Council and ultimately the Board Risk Committee.


reasoning: The paragraph contains a negative materiality assessment stating the company has not experienced any recent material cybersecurity incidents, which falls under Strategy Integration.


reasoning: The paragraph describes the reporting structure and topics discussed between management (the CIO) and the Board of Directors, which is the core of board governance and oversight.


reasoning: The paragraph describes the governance structure for cybersecurity risk, detailing the oversight roles of the Board Risk Committee, Executive Committee, and specific officers, as well as the reporting cadence to the board.


reasoning: The paragraph describes the governance structure and reporting chain, detailing how management receives briefings from internal teams and committees and subsequently reports upward to the Board of Directors and Audit Committee.


reasoning: The paragraph describes the reporting cadence and information flow from IT Management to the Risk Committee, detailing how the board exercises oversight over the Information Security Program.


reasoning: The paragraph provides a backward-looking materiality assessment concluding that cybersecurity threats have not materially affected the company's business strategy, results of operations, or financial condition.


reasoning: The paragraph describes the company's internal approach to managing cybersecurity risk, specifically mentioning a 'three lines of defense' model and incident response procedures, without detailing specific management roles or qualifications.


reasoning: The paragraph describes the internal processes for monitoring, detecting, and responding to cybersecurity incidents, including the operation of the incident response plan and disclosure controls.


reasoning: The paragraph describes the internal process and cross-functional collaboration (legal, compliance, and IT) used to identify, assess, and mitigate cybersecurity risks, without detailing specific management qualifications or board oversight.


reasoning: The paragraph explicitly details the qualifications and certifications (CISSP, GIAC) of the cybersecurity team overseen by management, which triggers the Management Role category under the qualifications tiebreaker rule.


reasoning: The paragraph describes the company's internal processes for evaluating and addressing cybersecurity risks, specifically highlighting the integration of the ERM team with the IT risk management team and CSO.


reasoning: The paragraph primarily describes the governance chain and reporting structure, detailing how the CIO and SIRT report to the Audit Committee, which in turn reports to the Board of Directors.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including system monitoring, the adoption and structure of an Incident Response Policy, and employee security training.


reasoning: The paragraph describes the reporting cadence and structure from management (ITSC and CIO) to the Board of Directors, which falls under Board Governance.


reasoning: The paragraph primarily describes the governance and oversight structure, detailing how the CTO reports cybersecurity information upward to the Audit and Finance Committee and executive leadership teams.


reasoning: The paragraph describes the implementation of the company's cybersecurity program, incident response, and risk management processes. Although it names the Director of Information Systems, it focuses on the processes they execute rather than their personal qualifications.


reasoning: The paragraph consists entirely of generic risk warnings and boilerplate statements about the importance of cybersecurity, without detailing any specific processes, governance, or actual materiality assessments.


reasoning: The paragraph details the governance structure for cybersecurity, describing the formation of management and board-level IT/Cybersecurity Committees, their composition, and the upward reporting chain to the board.


reasoning: The paragraph focuses on identifying the Information Security Officer (ISO), detailing the composition of the Information Security team, and outlining the ISO's reporting line to the Senior Risk Officer.


reasoning: The paragraph contains a backward-looking materiality assessment stating that the company has not been materially affected by a cybersecurity breach to date, which falls under Strategy Integration.


reasoning: The paragraph explicitly states a materiality assessment, concluding that the company is not aware of any cybersecurity risks or incidents that have materially affected or are reasonably likely to materially affect its business strategy, results of operations, or financial condition.


reasoning: The paragraph consists entirely of generic, forward-looking risk warnings and boilerplate language about potential cyber threats, without describing any substantive cybersecurity processes, governance, or actual incidents.


reasoning: The paragraph primarily describes the company's internal incident response workflow, detailing how threats are identified, assessed, managed, and escalated through the organization.


reasoning: The paragraph primarily describes the management-level personnel responsible for cybersecurity, specifically detailing the Risk Management Officer and the cybersecurity supervisory divisions, including their headcount, organizational placement, and experience.


reasoning: The paragraph explicitly identifies the CDO and describes their specific responsibilities in directing and organizing the company's information security activities and risk management strategy.


reasoning: The paragraph consists entirely of generic risk disclaimers and a cross-reference to the Risk Factors section, containing no substantive cybersecurity program details or materiality assessments.


reasoning: The paragraph primarily describes the internal cybersecurity team, identifying the CISO and information security directors, and detailing their specific professional certifications.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risks, detailing the delegation of authority from the Enterprise Risk and Return Council to the Information Security Council and outlining its oversight responsibilities.


reasoning: The paragraph primarily describes the management personnel responsible for overseeing cybersecurity processes, specifically detailing their team composition and their average years of relevant work experience.


reasoning: The paragraph explicitly details the CISO's certifications and the information security team's combined years of experience, which are key indicators of the Management Role category, alongside their reporting lines to specific board committees.


reasoning: The paragraph describes internal reporting processes to executive leadership and the integration of cybersecurity risks into the broader enterprise risk management program.


reasoning: The paragraph describes the governance chain and oversight structure, detailing how the management-level Compliance Committee assesses risks and escalates information upward to ensure the Board maintains comprehensive oversight.


reasoning: The paragraph describes the reporting structure and information flow from management (CIO, CISO, VP of Product Security) to board committees (Audit Committee, QRC) and the Board of Directors, which is the core definition of Board Governance.


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section (Item 1A) and contains no substantive cybersecurity disclosure or materiality assessment.


reasoning: The paragraph primarily describes the internal structure and processes of the company's cybersecurity program, including the roles of the CIO and CISO, internal management committees, alignment with the NIST framework, and specific security practices like employee training and technical tools.


reasoning: The paragraph describes the general responsibilities of the management team in integrating cybersecurity into the overall risk management strategy and overseeing security processes, without detailing specific personnel qualifications.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including protocols, third-party assessments, incident response planning, and employee training. While the CFO is mentioned as overseeing the program, the bulk of the text details the risk management framework itself.


reasoning: The paragraph focuses on identifying a specific management role (Senior Principal Security and Infrastructure Architect) and detailing their qualifications (over 20 years of experience), which aligns with the Management Role category.


reasoning: The paragraph primarily focuses on the management-level roles and committees responsible for cybersecurity, specifically detailing the titles and exact years of experience (30 and 22 years) of the key security officers.


reasoning: The paragraph primarily describes the company's internal cybersecurity programs, training, and incident response plans. Although it includes management qualifications, applying the person-removal test leaves a comprehensive description of the risk management processes.


reasoning: The paragraph consists entirely of generic, forward-looking risk warnings and boilerplate speculation about potential cybersecurity threats, without describing any substantive processes, governance, or actual incidents.


reasoning: The paragraph describes the governance chain and oversight structure, detailing how the interim CISO reports to the executive-level ERC, which in turn enacts delegated oversight from the Board Risk Committee (BRC).


reasoning: The paragraph provides a backward-looking materiality assessment, concluding that cybersecurity risks have not materially affected the company's business strategy or financial condition to date.


reasoning: The paragraph describes the internal management processes and structures (a cross-functional management program and an executive security council) used to evaluate and review the company's cybersecurity program effectiveness.


reasoning: The paragraph primarily details the management-level personnel responsible for cybersecurity, specifically highlighting the Senior Director of Cybersecurity's title and years of experience, as well as the composition of the security steering committee.


reasoning: The paragraph primarily describes the oversight structure, detailing how the SVP, Head of Legal and Compliance reports to the Audit Committee, which in turn reports to the full Board of Directors.


reasoning: The paragraph describes the complete governance chain, detailing how the CISO and CIDO manage the program and report upward to the Audit Committee and ultimately the Board of Directors, making Board Governance the most appropriate category for this structural overview.


reasoning: The paragraph describes the governance structure for cybersecurity, detailing the Information Technology Steering Committee, its officer composition, and the reporting chain from the Information Security Officer up to the board of directors.


reasoning: The paragraph contains a backward-looking materiality assessment ('we have not experienced material adverse effects from cybersecurity threats to date'), which classifies it as Strategy Integration.


reasoning: The paragraph describes the internal processes and methods used to prevent, detect, and mitigate cybersecurity risks, such as threat intelligence and security tool alerts, making it a Risk Management Process disclosure.


reasoning: The paragraph primarily describes the company's internal cyber risk management processes, including strategy, policy, training, and resource investments, managed by specific executives.


reasoning: The paragraph primarily describes the company's internal incident response process, detailing how threats are detected, assessed by a cross-functional team, and escalated through the organization.


reasoning: The paragraph provides a backward-looking materiality assessment, explicitly stating that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition to date.


reasoning: The paragraph describes the internal management-level governance structure for cybersecurity risk, specifically the role, composition, and escalation processes of the TRCC and ERC, which integrates into the broader ERM process.


reasoning: The paragraph focuses on the roles, qualifications, and reporting lines of the individuals managing cybersecurity (third-party consultant and Security Operations Center Manager), fitting the Management Role category.


reasoning: The paragraph explicitly details the qualifications of the Director of IT, specifically noting their 40 years of experience, which triggers the Management Role category based on the qualifications tiebreaker.


reasoning: The paragraph primarily details the individuals and teams responsible for the cybersecurity program, including specific management titles (CTO, CISO), their years of experience, and the cross-functional team composition, which aligns with the Management Role category.


content_category: Third-Party Risk

reasoning: The paragraph focuses entirely on how the Fund identifies and oversees cybersecurity risks associated with its use of third-party service providers.


reasoning: The paragraph primarily describes the governance structure and reporting chain for cybersecurity, detailing the oversight roles of the Board, Audit Committee, and the Principal Accounting Officer.


reasoning: The paragraph describes the governance reporting structure, detailing how management monitors cybersecurity and reports upward to the Information Technology Steering Committee and the full Board of Directors.


reasoning: The paragraph primarily describes the company's internal process for identifying and assessing cybersecurity risks, which involves utilizing a third-party IT firm working in conjunction with internal staff.


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


reasoning: Although the paragraph begins by mentioning risk assessment processes, the primary focus and substantive detail describe the Vice President of Informatics, including their years of experience and departmental oversight, which aligns with the Management Role category.


reasoning: The paragraph describes the governance and oversight structure, specifically detailing the reporting chain from the Chief Technology Officer to the Committee and subsequently to the full Board.


reasoning: The paragraph describes the oversight structure for cybersecurity, detailing how the management team administers the program, informs senior stakeholders, and how the Audit Committee provides ultimate oversight.


reasoning: The paragraph describes the reporting structure and cadence to the board of directors regarding cybersecurity risks, controls, and procedures, which is the definition of Board Governance.


reasoning: Applying the person-removal test, the paragraph fundamentally describes the company's cybersecurity risk management program and its integration into ERM. The mentions of the CTO, CISO, and their qualifications are components of this broader process description.


reasoning: The paragraph primarily describes the governance structure, detailing how the Audit Committee and Board oversee cybersecurity risk and the reporting cadence of the Chief Information Officer to the committee.


reasoning: The paragraph describes the full governance chain, starting with the Audit and Risk Committee's oversight, detailing the management roles (CIO, Senior Director) and committees responsible for the program, and concluding with how risks are reported back to the board committee.


reasoning: The paragraph primarily describes the company's internal cybersecurity program, controls, assessments, and threat intelligence processes. While it mentions the CISO, CTO, and CIO, removing these roles leaves a coherent description of the risk management process, making RMP the primary category.


specificity_confidence: medium

reasoning: The paragraph primarily describes the governance and oversight structure, detailing how the Board and Audit Committee oversee cybersecurity risk and how management (specifically the Principal Accounting Officer) reports upward to them.


reasoning: The paragraph consists of generic introductory language regarding the company's dependence on IT systems and the general importance of cybersecurity, without detailing any substantive processes, governance structures, or materiality assessments.


reasoning: The paragraph consists of generic risk warnings and boilerplate language about the potential consequences of cyberattacks, without describing any specific cybersecurity processes, governance structures, or materiality conclusions.


reasoning: The paragraph describes the responsibilities and reporting lines of a specific management role (SVP of IT) to the senior management team regarding cybersecurity matters.


reasoning: The paragraph describes the reporting structure and information flow from the cybersecurity team to the Audit Committee, detailing how the board exercises oversight over cyber risks.


reasoning: The paragraph is a generic, forward-looking risk warning about potential operational disruptions, containing no substantive disclosure about the company's actual cybersecurity program or a materiality assessment.


reasoning: The paragraph explicitly states backward-looking and forward-looking materiality assessments regarding cybersecurity threats, which falls squarely under Strategy Integration.


reasoning: The paragraph explicitly describes the governance and oversight structure for cybersecurity risk, detailing the roles of the Board and the CFO.


reasoning: The paragraph provides a backward-looking materiality assessment stating that cybersecurity threats have not materially affected the company, which falls under Strategy Integration.


reasoning: The paragraph contains a negative materiality assertion stating the company has not experienced any prior material cybersecurity incidents, which classifies it as Strategy Integration.


reasoning: The paragraph is a generic, forward-looking risk warning about potential data breaches and does not contain substantive cybersecurity program disclosure or materiality assessments.


reasoning: The paragraph provides a backward-looking materiality assessment, concluding that cybersecurity risks have not materially affected the company's business strategy or financial condition to date.


reasoning: The paragraph describes the reporting structure and flow of cybersecurity information to the Board of Directors via the CFO, DIT, and DIS, which falls under board oversight and governance.


reasoning: The paragraph explicitly states the company lacks the resources and expertise to manage cybersecurity risks, effectively describing the absence of a functional cybersecurity program, which falls under None/Other.


reasoning: The paragraph contains a negative materiality assessment stating the company has not experienced material cybersecurity incidents, and discusses the maintenance of cybersecurity insurance, both of which fall under Strategy Integration.


reasoning: The paragraph describes the governance and reporting chain, detailing how the incident response team reports to executive officers and the Board, as well as the composition and oversight responsibilities of the internal information security advisory board.


reasoning: The paragraph consists of a section header and generic descriptions of the cybersecurity threat landscape without providing any substantive disclosure about the company's actual processes, governance, or materiality assessments.


reasoning: The paragraph primarily details the CISO's reporting lines, career history, and qualifications, as well as the composition of the Cybersecurity Governance Council (Deputy CISOs) that supports the CISO.


reasoning: The paragraph describes the governance chain for cybersecurity, starting with the Audit Committee's oversight and detailing how the Senior Director - Information Security directs initiatives throughout the company.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risks, detailing the involvement of the Board, a specific committee, and executive management.


reasoning: The paragraph primarily describes the company's internal processes for monitoring information systems and responding to incidents using a runbook, overseen by the CICSO and cybersecurity team.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, their integration into the overall risk management program, and the adoption of recognized frameworks like NIST and ISO.


reasoning: The paragraph primarily describes the internal processes and management-level working group responsible for implementing the cybersecurity program, monitoring threats, and managing incident response.


reasoning: The paragraph describes the composition of a management-led Risk Committee and details the governance chain by explaining how this committee reports cybersecurity risks and mitigation processes upward to a higher-level committee.


reasoning: The paragraph primarily describes the company's cybersecurity policies, processes, and framework adoption (ISO and NIST), despite a brief introductory mention of the Board's general oversight.


reasoning: The paragraph describes the reporting structure and cadence for how management and the COO inform the board of directors and Audit Committee about cybersecurity risks and incidents.


reasoning: The paragraph is entirely dedicated to identifying the specific management roles and personnel (including the CISO, CTO, and Chief Risk Officer) that comprise the ISO Committee, including their specific qualifications and experience.


reasoning: The paragraph details the governance structure, specifically the Information Technology Steering Committee's oversight role and the reporting chain from the Information Security Officer to the board of directors.


reasoning: The paragraph describes the governance and oversight structure, detailing the reporting cadence of the CISO, CTO, and Enterprise Risk Management Committee to the Board of Directors and Audit Committee.


reasoning: The paragraph describes the reporting structure and oversight mechanisms, detailing how the CIO briefs executive teams and the Audit Committee, and how incidents are escalated to the Board.


reasoning: The paragraph describes the management team's efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents, including the use of threat intelligence, external consultants, and security tools. This focuses on the internal processes for managing cyber risk.


reasoning: The paragraph primarily describes the governance structure for cybersecurity, detailing the Information Security Governance Committee's role, its reporting cadence to the Board of Directors, and the Board's cybersecurity educational sessions.


reasoning: The paragraph provides a negative materiality assessment, stating the company has not experienced any cybersecurity incidents that materially affected its business strategy or financial condition, which falls under Strategy Integration.


reasoning: The paragraph describes the reporting structure and briefing cadence from management (CISO and CIO) to the Board of Directors and Audit Committee, which falls under Board Governance.


reasoning: The paragraph describes the governance chain and oversight structure, detailing how the Board and Audit Committee oversee cybersecurity, and how the IT Director reports to the CFO who in turn updates the Board.


reasoning: The paragraph describes the operational structure of the company's cybersecurity risk management, specifically detailing how the outsourced Information Security Team functions and reports to the Principal Financial Officer.


reasoning: The paragraph primarily describes the company's risk management program and how cybersecurity is integrated into it, making it a Risk Management Process disclosure.


reasoning: The paragraph describes the internal processes for managing cybersecurity risks, detailing how the CISO and specific internal teams collaborate to implement the program, monitor threats, and execute incident response.


reasoning: The paragraph describes management's internal process for monitoring and being informed about cybersecurity incidents, including reliance on service providers and specific personnel.


reasoning: The paragraph primarily describes the internal risk management process, detailing how vulnerabilities are identified, assigned, and remediated by specific management roles.


reasoning: The paragraph consists entirely of generic, forward-looking risk warnings and potential consequences of cyberattacks, without describing any actual processes, governance structures, or materiality assessments.


reasoning: The paragraph contains a negative materiality assessment, stating that the company has not experienced any significant compromise or material financial losses related to cybersecurity attacks to date.


reasoning: The paragraph is a cross-reference pointing to the Risk Factors section for discussions on materiality, rather than providing a substantive cybersecurity disclosure or materiality conclusion itself.


reasoning: The paragraph explicitly states the company has not adopted a cybersecurity program or formal processes, which triggers the rule that SPACs/shell companies stating an absence of a program are classified as None/Other.


reasoning: The paragraph primarily details the company's internal Information Security Program, the Information Security Incident Response Team, and the steps of the incident response plan. While it mentions board oversight and the CISO's qualifications, the core focus remains on the internal risk management and incident response processes.


reasoning: While the paragraph begins with board oversight structure, the primary focus and majority of the text details the specific educational backgrounds, certifications (CISSP), and professional memberships of the CIO and CISO.


reasoning: The paragraph primarily focuses on the roles, reporting structure, and specific qualifications (over 50 years of combined experience) of the Information Security Manager and Chief Information Officer, making it a Management Role disclosure.


reasoning: The paragraph describes the governance chain and oversight structure for cybersecurity, detailing how responsibility flows from the Board to the Audit Committee, down to the CTO and VP of Cyber Security.


reasoning: The paragraph provides a backward-looking materiality assessment, concluding that previous cybersecurity incidents and threats have not materially affected the company's business strategy, results of operations, or financial condition.


reasoning: The paragraph describes internal management committees (Engineering Risk Steering Group, Firmwide Technology Risk Committee) and their roles in overseeing engineering and technology risk, which falls under the company's internal risk management processes.


reasoning: The paragraph provides a backward-looking materiality assessment, stating that the company has not been materially impacted by prior cybersecurity incidents.


reasoning: The paragraph describes the company's internal processes for cybersecurity risk assessment and management, including the roles of management and the executive team in implementing these processes, integrating them into overall risk management, and preparing for incidents.


reasoning: The paragraph primarily details the CIO's reporting lines, years of experience, and supporting team (Director of IT Security and vCISO), which aligns with the Management Role category.


reasoning: Although the paragraph begins by describing risk assessment processes, it concludes by detailing the specific roles (Manager of Information Technology, COO) and their exact years of experience (25 and 15 years, respectively), triggering the Management Role classification based on the qualifications tiebreaker.


reasoning: The paragraph primarily describes the internal processes of the Information Security team, specifically focusing on the lifecycle and maintenance of its internal governance documents and its three-year strategic plan.


reasoning: The paragraph primarily describes the governance and oversight structure for cybersecurity, detailing reporting lines to the Audit Committee, Board of Directors, GLT, ERM Committee, ARB, and PMO.


reasoning: The paragraph describes the reporting structure and information flow from the CISO to management committees and the Board of Directors, which is the core of Board Governance.


reasoning: The paragraph describes the reporting chain and oversight structure, detailing how the CISO reports to executive management and how significant matters are escalated to the Compliance Committee and the Board of Directors.


reasoning: The paragraph outlines the governance and oversight structure for cybersecurity risk, detailing the involvement of the Board, Audit Committee, and a specific management-level Security Steering Group.


reasoning: The paragraph primarily describes the company's internal cybersecurity organization, the specific security controls it employs, and its processes for managing risks, including a component on third-party risk management.


reasoning: The paragraph consists entirely of generic, forward-looking risk warnings ('could have a material adverse effect') and contains no substantive disclosure about cybersecurity processes, governance, or actual materiality assessments.


reasoning: The paragraph describes the governance and oversight structure, specifically detailing the composition and functions of the IT Steering Committee and the reporting chain from the IT manager to the Risk Management committee.


reasoning: The paragraph describes the escalation and reporting structure to the Audit Committee and the Board in the event of a cybersecurity incident, which falls under board governance.


category_confidence: low

reasoning: The paragraph is a fragment listing components of the company's cybersecurity program, specifically personnel capabilities and strategy/resource allocation, which falls under general risk management and program administration.


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section in Item 1A and does not contain substantive cybersecurity disclosure or a standalone materiality conclusion.


reasoning: The paragraph describes the internal oversight and strategy approval process conducted by a management-level Information Security committee, detailing how internal cybersecurity initiatives are reviewed and approved.


reasoning: The paragraph primarily describes the governance structure, detailing how the CFO directs the cybersecurity program and reports incidents to the Board of Directors and Audit Committee.


reasoning: The paragraph primarily describes the governance and oversight structure for enterprise risk (including cybersecurity), detailing the composition of the Enterprise Risk Committee, reporting lines to the Co-CEOs, and the specific cybersecurity credentials of a board director.


reasoning: The paragraph describes the reporting structure and cadence between management and the Board regarding cybersecurity matters, which is the core of board governance.


reasoning: The paragraph describes the methods and tools used to identify and assess cybersecurity risks, such as threat intelligence analysis and environment scanning. Although a specific role is named as the subject, applying the person-removal test reveals the core focus is on the company's internal risk management processes rather than the individual's qualifications.


reasoning: The paragraph describes the board's oversight structure, specifically detailing the responsibilities of the Audit and Examination Committee and the reporting cadence of the Information Security Officer to this committee.


reasoning: The paragraph describes the board's oversight structure, specifically the delegation of cybersecurity oversight to a subsidiary's Information Security Committee and the reporting cadence to the board.


reasoning: The paragraph describes the company's internal processes for monitoring cybersecurity incidents, including system audits, vulnerability identification, and incident response planning. Although it mentions the InfoSec Director frequently, the primary focus is on the processes they oversee rather than their personal qualifications.


reasoning: The paragraph describes the internal governance structure for cybersecurity, detailing specific management committees, reporting lines from the CISO to the CEO, and the ultimate oversight cadence by the board of directors.


reasoning: The paragraph describes the governance structure by detailing how the Vice President of Technology and Executive Officer brief the Board of Directors on cybersecurity risks and activities.


reasoning: The paragraph contains a negative materiality assessment stating the company has not experienced a material cybersecurity incident, which falls under Strategy Integration.


reasoning: The paragraph primarily details the qualifications and experience of the IT Lead and the assisting external agency, fitting the Management Role category.


reasoning: The paragraph describes the internal processes for managing cybersecurity incidents, including the formation of a crisis management team and a disclosure committee to evaluate materiality. While it mentions the CIO and CISO, the primary focus is on the incident response and evaluation process.


reasoning: The paragraph describes the reporting structure and information flow regarding cybersecurity risks, specifically how the CFO and IT consultant brief the audit committee, which then updates the Board.


reasoning: The paragraph explicitly describes the board-level oversight structure, detailing the Audit Committee's responsibilities and the reporting cadence from the CIO and CISO to the committee.


reasoning: The paragraph describes the governance structure, specifically detailing how the CISO and CRO report to and escalate cybersecurity issues to the Board's risk committee.


reasoning: The paragraph describes management's responsibility for the cybersecurity risk management program and supervision of external consultants, without detailing specific qualifications or career histories.


reasoning: The paragraph explicitly states a materiality assessment regarding cybersecurity threats and prior incidents ('have not identified risks... that have materially affected us or are reasonably likely to materially affect us'), which falls under Strategy Integration.


reasoning: The paragraph provides generic background information on the company's reliance on IT systems and the types of data it processes, without detailing any substantive cybersecurity processes, governance, or materiality assessments.


reasoning: The paragraph describes the cross-functional departmental composition responsible for overseeing the company's cybersecurity risk management processes.


reasoning: The paragraph focuses heavily on the individuals responsible for cybersecurity, specifically detailing the Chief Technology Officer's years of experience and listing the specific management roles involved in the program.


reasoning: The paragraph primarily describes the oversight structure and reporting chain for cybersecurity matters, detailing how the CFO, VP of Internal Audit, and IT resources share responsibility and communicate upward to the Board.


reasoning: The paragraph describes the governance structure, specifically the reporting chain where management notifies the board of directors in the event of a cybersecurity incident.


reasoning: The paragraph describes the reporting structure and cadence between the CISO and the Risk Committee, detailing how cybersecurity information flows upward for oversight.


reasoning: The paragraph contains a negative assertion materiality assessment, stating the company has not experienced any material cybersecurity events, which falls under Strategy Integration.


reasoning: The paragraph explicitly states the company is a SPAC with no operations and has not adopted a cybersecurity program, which falls under the None/Other category per the tiebreaker rules.


reasoning: The paragraph contains a negative assertion regarding the occurrence of material cybersecurity incidents, which is classified as a materiality assessment under Strategy Integration.


reasoning: The paragraph details the internal management committees (IT Steering Committee and IT Subcommittee) and their specific responsibilities in monitoring, detecting, and mitigating cybersecurity risks, which constitutes the company's internal risk management process.


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section and contains only boilerplate risk warnings without any substantive cybersecurity disclosure.


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


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including system monitoring, audits, vulnerability identification, and incident response planning, despite naming the CISO and CIO as the individuals overseeing these processes.


reasoning: The paragraph describes the high-level governance structure for evaluating cyber risk, including Board oversight and CFO direction.


reasoning: The paragraph focuses entirely on the qualifications, training, and specific professional certifications held by the company's cybersecurity personnel, which falls under the Management Role category.


reasoning: The paragraph focuses on the training, experience, and certifications of management and third-party service providers responsible for managing cybersecurity risks.


reasoning: The paragraph explicitly details the qualifications of the Chief Technology Officer, including their specific years of experience, which triggers the Management Role category based on the qualifications tiebreaker.


reasoning: The paragraph describes the composition of an internal management committee (Technology and Operations Committee), detailing the specific roles and departments involved in the internal risk management and oversight structure.


reasoning: The paragraph identifies the specific management role (Senior Director, Head of IT and Informatics) responsible for assessing and managing cybersecurity risks, and describes their reporting line to the CFO.


reasoning: The paragraph primarily describes the internal processes and management-level committees (crisis management team, disclosure committee) established to handle cybersecurity incidents and evaluate their materiality.


reasoning: The paragraph describes the governance structure and reporting chain for cybersecurity, detailing the board's oversight, management's responsibilities, the specific officer directing the program, and the reporting flow back to the audit committee and board.


reasoning: The paragraph describes the governance structure for overseeing cybersecurity risk, detailing specific committees (OROC, IT Steering Committee) and the roles/departments involved in oversight.


reasoning: The paragraph explicitly states the company lacks significant investments and resources for data security protection, triggering the SPAC/shell company rule where the absence of a formal program is classified as None/Other.


reasoning: The paragraph describes the internal management structure and committees (ERM and cybersecurity committees) responsible for overseeing the firm's risk management process and cybersecurity program.


reasoning: The paragraph primarily describes the company's internal risk management framework, including lines of defense, control testing, and vulnerability assessments. Applying the person-removal test, the core content remains focused on the risk management processes rather than the qualifications of the VP, ISS.


reasoning: The paragraph consists entirely of negative assertions regarding the materiality of past or potential cybersecurity incidents, which constitutes a materiality assessment.


reasoning: The paragraph describes the oversight structure and responsibilities of the CISO and the Cybersecurity Committee, detailing how they monitor and oversee cybersecurity policies and processes.


reasoning: The paragraph details the governance structure, describing specific management committees, the roles that chair them, and how the CISO reports upward to the board's Innovation and Technology Committee.


reasoning: The paragraph contains a negative materiality assessment stating the company has not experienced a material cybersecurity incident, which falls under Strategy Integration.


reasoning: The paragraph describes the governance structure for overseeing and reporting cybersecurity threats, specifically detailing the roles of the MAT, CIO, CISO, and Risk Committee in the escalation and reporting process.


reasoning: The paragraph describes the governance structure, specifically management's oversight of cybersecurity risk and their reporting responsibilities to the board of directors.


reasoning: The paragraph consists entirely of generic threat landscape descriptions and boilerplate forward-looking risk warnings ('could have a material adverse effect'), which do not constitute a substantive materiality assessment or process description.


reasoning: The paragraph primarily details the qualifications, career history, and reporting structure of the Chief Information Officer (CIO) and the internal ISMS Committee, fitting the Management Role category.


reasoning: The paragraph consists entirely of generic IT-dependence language and boilerplate risk warnings ('could potentially have a material impact'), lacking any substantive disclosure about processes, governance, or actual materiality assessments.


reasoning: The paragraph describes the reporting structure and cadence between management (VP of IT) and the board committee (Audit and Reserves Committee), which is the core definition of Board Governance.


reasoning: The paragraph provides a negative assertion regarding the existence of material weaknesses or malware, which constitutes a materiality assessment.


reasoning: The paragraph describes the reporting cadence and topics covered by the CEO when briefing the Audit Committee on cybersecurity risks, which falls under board oversight and governance.


reasoning: The paragraph describes the governance chain and oversight structure, detailing how the Committee reports to the Board, how the Board receives briefings, and how management (including the CFO) is delegated responsibility for the program.


reasoning: The paragraph contains a negative materiality assertion stating that the company has not experienced a material cybersecurity incident to date, which classifies it as Strategy Integration.


reasoning: The paragraph describes the upward flow of information regarding cybersecurity posture to top management, which is a component of the governance and oversight structure.


reasoning: The paragraph contains a negative assertion regarding material cybersecurity incidents, which constitutes a materiality assessment and falls under Strategy Integration.


reasoning: The paragraph describes the reporting chain and how the Board is updated on cybersecurity matters, which falls under Board Governance.


reasoning: The paragraph consists entirely of generic, forward-looking risk warnings about the potential consequences of an IT compromise, which falls under None/Other.


reasoning: The paragraph details the responsibilities of a specific management committee and its role in reporting cybersecurity matters upward to a specific Board committee, which is a clear description of governance structure and oversight.


reasoning: Although the paragraph mentions the Director of Information Technology and their years of experience, the primary focus and majority of the text describe the technology team's processes for maintaining cybersecurity maturity, setting control objectives, and upgrading systems.


reasoning: The paragraph contains a negative assertion materiality assessment stating that the company has not incurred any material cybersecurity threats or incidents to date, which falls under Strategy Integration.


reasoning: The paragraph primarily describes the specific teams responsible for cybersecurity and details their professional certifications (CISSP, CISM, CRMA, CRISC), which aligns with the Management Role category.


reasoning: The paragraph describes the reporting structure and information flow to the Board of Directors regarding cybersecurity risks, which falls under Board Governance.


reasoning: The paragraph primarily describes the company's internal processes for cybersecurity risk assessment, mitigation, and continuous monitoring, led by management and supported by a third-party partner.


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


reasoning: The paragraph describes the internal risk management and governance process, specifically detailing how a management-level technology committee approves policies and monitors cybersecurity threats.


reasoning: The paragraph consists of a negative assertion regarding material cybersecurity incidents, which qualifies as a materiality assessment under Strategy Integration.


reasoning: The paragraph describes management's responsibilities in implementing the cybersecurity risk management process and integrating it into overall risk management. Following the MR vs RMP tiebreaker, it lacks specific qualifications or career history, making it a process description rather than a Management Role disclosure.


reasoning: The paragraph consists entirely of generic, forward-looking risk warnings about potential cybersecurity threats and their hypothetical impacts, without describing any actual processes, governance structures, or materiality assessments.


reasoning: The paragraph describes the governance and oversight structure, specifically how the CISO informs and assists the Enterprise Risk Management Committee (ERMC) in monitoring cybersecurity risks.


reasoning: The paragraph details the governance structure for cybersecurity, specifically how the Board and Audit Committee exercise oversight and receive updates from management.


reasoning: The paragraph describes the governance structure for cybersecurity risk, detailing the oversight roles of the Board, Audit Committee, and executive management.


reasoning: The paragraph contains a backward-looking materiality assessment stating that no cybersecurity incident has had a material adverse impact to date, which falls under Strategy Integration.


reasoning: The paragraph primarily describes the reporting structure and cadence of cybersecurity information flowing from the Chief Security Office to the Management Board and the Supervisory Board's technology committee, which is characteristic of Board Governance.


reasoning: The paragraph primarily consists of materiality assessments, including a negative assertion of past material incidents and a forward-looking conclusion about potential material impacts, which falls under Strategy Integration.


reasoning: The paragraph primarily describes the governance structure, detailing how the Board delegates oversight responsibility for information security to the Audit Committee, CFO, and IT resources, and how the Director of IT manages the team.


reasoning: The paragraph describes the full governance and oversight structure, detailing how cybersecurity risk escalates from management roles (CISO, CRO) and the Enterprise Risk Committee up to the Board's Risk and Technology Committee.


reasoning: The paragraph primarily describes the composition, specific roles, and qualifications of the management-level Cybersecurity Committee.


reasoning: The paragraph contains a backward-looking materiality assessment stating that past threats or incidents have not materially affected the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration.


reasoning: The paragraph primarily describes the internal processes for reviewing, auditing, and assessing the company's Information Security Program, including the use of a specific assessment tool.


reasoning: Although the paragraph uses the CISO and CTO as grammatical subjects, it primarily describes the company's internal cybersecurity processes, such as maintaining and testing the Incident Response Plan, logging incidents, and conducting training, rather than detailing the officers' personal qualifications.


reasoning: The paragraph describes the governance chain and oversight structure, detailing how the Board delegates risk oversight to committees and relies on management, specifically outlining the reporting lines from the Director of Information Security up to the Risk Committee.


reasoning: The paragraph primarily describes the governance structure, detailing the Board's annual review of the security program and the upward reporting flow from the COO to the Board.


reasoning: The paragraph primarily describes the company's internal processes for risk assessment, implementing safeguards, and monitoring effectiveness, while identifying the specific roles responsible for executing these processes.


reasoning: The paragraph describes the governance and reporting structure, detailing how the CFO oversees day-to-day cybersecurity risks and keeps the Board apprised of mitigation efforts and breaches.


reasoning: The paragraph focuses on the roles, team composition, and specific qualifications (over 85 years of combined experience) of the individuals responsible for implementing the cybersecurity program.


reasoning: The paragraph primarily details the management-level structure responsible for cybersecurity oversight, specifically identifying the cybersecurity committee, its leader (VP, IT), and its cross-functional departmental composition.


reasoning: The paragraph describes the governance and oversight structure, detailing how the Committee and management report to the full Board, board education, and the specific composition of the management team responsible for supervising the cybersecurity program.


reasoning: The paragraph outlines the responsibilities of the information technology department regarding risk assessment, security controls, and incident response, which describes the company's internal risk management processes.


category_confidence: medium

reasoning: The paragraph describes the company's basic internal approach to managing cybersecurity risk, noting CEO oversight and reliance on standard commercial software with basic security features.


reasoning: The paragraph primarily describes the governance structure, specifically detailing the Board's oversight responsibility and the reporting relationship between the Director of Information Technology and the Board.


reasoning: The paragraph describes the governance structure and briefing cadence for both executive management and the Board of Directors regarding cybersecurity risks, detailing how oversight is exercised.


reasoning: The paragraph consists entirely of a generic forward-looking risk warning and a cross-reference to the Risk Factors section, containing no substantive cybersecurity program disclosure or actual materiality assessment.


reasoning: The paragraph contains a forward-looking materiality assessment using the SEC qualifier 'reasonably likely to materially affect', which falls under Strategy Integration.


reasoning: The paragraph concludes with a negative assertion regarding the occurrence of cybersecurity incidents during the fiscal year, which aligns with the Strategy Integration category.


reasoning: The paragraph primarily identifies the management role (Director of IT) responsible for cybersecurity, detailing their experience and the team's general monitoring responsibilities.


reasoning: The paragraph describes the company's internal risk management framework and the establishment of a management-level committee to oversee risk, which falls under internal processes rather than board oversight or individual qualifications.


reasoning: The paragraph consists entirely of generic risk warnings and high-level introductory statements about facing cybersecurity threats, without detailing any specific processes, governance structures, or materiality assessments.


reasoning: The paragraph describes the reporting structure and information flow to the board, specifically detailing how the Manager of Information Technology and IT team report to the Audit Committee regarding cybersecurity risks.


reasoning: The paragraph describes an internal management committee (Corporate Cybersecurity Steering Committee), its composition, and its function in strategizing and managing cybersecurity challenges, which falls under internal risk management processes.


reasoning: The paragraph describes the operational responsibilities of the CISO and the Information Security Department, including managing policies, conducting access reviews, and supervising training. Because it focuses on what the program does rather than the personal qualifications or background of the CISO, it is classified as Risk Management Process.


reasoning: The paragraph contains a negative materiality assertion stating the company has not experienced cyber-attacks that materially disrupted its business, which falls under Strategy Integration.


reasoning: The paragraph describes the company's internal risk management processes, specifically how the management-level Enterprise Risk Management Committee integrates cybersecurity into broader risk management through self-assessments and action plans.


reasoning: The paragraph describes the governance structure for cybersecurity risk, detailing the reporting chain from the Co-President to the Audit Committee and ultimately to the Board of Trustees.


reasoning: The paragraph describes the internal reporting structure and incident response communication process within management. Applying the MR vs RMP tiebreaker, the absence of specific qualifications or career history for the IT Team Director points to Risk Management Process.


reasoning: The paragraph consists of introductory boilerplate language and generic risk warnings about potential cybersecurity threats and their possible impacts, without providing substantive details on processes, governance, or actual incidents.


reasoning: The paragraph describes the internal management-level processes for assessing cybersecurity risks, specifically detailing the role of the cross-functional Cybersecurity Council and the executive management team.


reasoning: The paragraph describes the governance structure for cybersecurity risk management, detailing the oversight role of the Board and Audit Committee, and the reporting cadence of the CIO and Head of Information Security to the committee.


reasoning: The paragraph consists entirely of generic risk warnings, forward-looking disclaimers, and boilerplate language about potential consequences of cyber incidents, lacking substantive disclosure of actual processes or materiality assessments.


reasoning: The paragraph explicitly describes the company's cybersecurity governance structure, detailing the roles of the Board, Audit Committee, CISO, and various internal teams in overseeing and managing cyber risks.


reasoning: The paragraph begins with a definitive backward-looking materiality assessment regarding past cyber-attack incidents, which classifies it as Strategy Integration according to the tiebreaker rules.


reasoning: The paragraph describes the governance and reporting structure for cybersecurity risks, detailing how the CISO and IT risk committee report up to the management risk committee and ultimately to the full Board.


reasoning: The paragraph details the reporting structure between management (COO) and the board (Audit Committee), including briefing cadences and the committee's oversight responsibilities.


reasoning: The paragraph contains a negative materiality assertion stating that the company has not experienced any material cybersecurity incidents to date, which falls under Strategy Integration.


reasoning: The paragraph describes the composition of the management-level Cybersecurity Team and its responsibilities in maintaining the cybersecurity program, monitoring trends, and overseeing training, which details the company's internal risk management processes.


reasoning: The paragraph describes the governance and oversight structure, detailing how the Director of Information Technology and other executives report on cybersecurity risks to the audit committee and the full board of directors.


reasoning: The paragraph primarily introduces the company's risk management process, describing its integration into overall risk management and its purpose to identify, prioritize, and monitor risks.


reasoning: The paragraph contains a negative materiality assertion ('we have not experienced any material cyber breaches'), which classifies it as Strategy Integration according to the tiebreaker rules.


reasoning: Although a specific role is the grammatical subject, the paragraph primarily describes the company's internal cybersecurity processes, including monitoring, system audits, and incident response planning, without detailing the individual's credentials or career history.


reasoning: The paragraph describes the composition and responsibilities of a management-level committee (the ISSC) tasked with overseeing cybersecurity risk, fitting the Management Role category.


reasoning: The paragraph primarily describes the organizational structure of the company's cybersecurity risk management program and the implementation of an incident response plan. Applying the MR vs RMP test, removing the CIO title leaves a coherent description of the risk management process.


reasoning: The paragraph primarily describes the governance chain and oversight structure, detailing how the Board, Audit Committee, Corporate Compliance Committee, and specific management officers (CIO, CISO) interact and report to one another.


reasoning: The paragraph describes the governance structure, specifically how management oversees cybersecurity risk, discusses policies with the Board, and reports to the Board.


reasoning: The paragraph primarily describes the company's governance and oversight structure, detailing the roles of the CEO, CFO, and the full board of directors in managing and reporting cybersecurity risks, despite the lack of a formal program. The materiality assessment at the end does not override the primary governance focus.


reasoning: The paragraph focuses on the qualifications (45 years of combined experience) and responsibilities of the cybersecurity sub-committee, fitting the Management Role category based on the qualifications tiebreaker.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, specifically the composition and responsibilities of the Cyber Incident Response Team (IRT) and the execution of the Cybersecurity Plan.


reasoning: The paragraph primarily describes the governance and oversight structure of the cybersecurity program, detailing the delegation of board oversight to a specific committee and the reporting chain involving the CIO.


reasoning: The paragraph consists entirely of generic, forward-looking risk warnings about the potential impacts of a cyber-attack, without describing any actual processes, governance, or specific materiality assessments.


reasoning: The paragraph consists entirely of generic IT-dependence language, stating that data security and IT systems are important to the company's operations, without describing any substantive cybersecurity processes, governance, or materiality assessments.


reasoning: The paragraph primarily describes the internal escalation process for cybersecurity threats, detailing how incidents are routed to management and potentially the Board, which falls under incident response planning within the Risk Management Process.


reasoning: The paragraph describes the overarching governance and management structure for cybersecurity, detailing how operations are managed by the General Partner and Investment Manager subject to Board oversight.


reasoning: The paragraph primarily describes the management-level structure and specific roles (CCO, Compliance Committee, Information Governance and Privacy Committee) responsible for day-to-day cybersecurity oversight.


reasoning: The paragraph primarily details the composition and responsibilities of a management-level committee (the Cybersecurity Steering Committee), specifically identifying the CISO and other executive roles responsible for day-to-day cybersecurity risk management.


reasoning: The paragraph primarily describes the composition of the management team and their role in supervising internal security personnel and external consultants, fitting the Management Role category.


reasoning: The paragraph describes the methods and processes used to identify, assess, and manage cybersecurity risks, such as automated tools, scans, and audits. Although named officers are the grammatical subjects, the primary focus is on the risk management activities they perform, with no details about their personal qualifications or credentials.


reasoning: The paragraph describes the reporting structure and information flow regarding cybersecurity risks from the Information Security Officer (ISO) to the BRCC and the full Board, which is the core of Board Governance.


reasoning: The paragraph provides a high-level overview of the company's cybersecurity risk management program, including its integration into the broader ERM framework and the specific executive roles responsible for its execution.


reasoning: The paragraph details the composition, leadership, and reporting lines of the management-level Cyber Incident Management Team (CIMT), focusing on management's role and structure for handling cybersecurity incidents.


reasoning: The paragraph primarily describes the governance structure, detailing the board's collective oversight responsibility and the reporting chain from executive officers to the board, while also noting the CEO's relevant experience.


reasoning: The paragraph outlines the general components of the company's cybersecurity risk management program, such as policy development, risk assessments, and incident response planning, framed around management's responsibilities.


reasoning: The paragraph primarily describes the company's internal risk management processes, including threat monitoring, the day-to-day responsibilities of the GIS team, and the management-level committee structure (Enterprise Security Council and Enterprise Risk Council) used to assess and escalate cyber risks.


reasoning: The paragraph primarily describes the governance structure, detailing how the Board of Directors and Audit Committee receive updates from management regarding cybersecurity risks and programs.


reasoning: The paragraph primarily describes management's role and organizational structure for cybersecurity, detailing the composition of a management committee (including the CISO and CTO), its responsibilities, and the CISO's supervision of the InfoSec team.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, policies, technical safeguards, and framework alignment. While management roles are mentioned, the core focus remains on the implementation and components of the risk management program.


reasoning: Although the paragraph begins with board and committee oversight, the majority of the text is dedicated to detailing the specific titles, degrees, and years of experience of the Chief Digital and Technology Officer, Chief Information Officer, and a CISO consultant.


reasoning: The paragraph primarily focuses on identifying the members of the management team responsible for cybersecurity, explicitly detailing their lack of specialized cybersecurity backgrounds and their general risk management experience.


reasoning: The paragraph primarily describes the reporting cadence and flow of cybersecurity information from management to the Board of Directors, which is the core of board governance and oversight.


reasoning: The paragraph describes the governance and reporting structure, specifically how the Risk Management Steering Committee monitors threats and reports them upward to the Audit Committee.


reasoning: The paragraph primarily details the composition of the management-level DPIRC and explicitly lists the career history and years of experience of the Vista CIO, which aligns perfectly with the Management Role category.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including system monitoring, audits, penetration testing, and incident response planning, which are overseen by the CIO.


reasoning: The paragraph explicitly identifies the Information Security Officer and details their qualifications, including over a decade of experience, which triggers the Management Role classification based on the qualifications tiebreaker.


reasoning: The paragraph describes the governance structure by detailing how and what the Vice President of Corporate Development & Administration reports to the board of directors regarding cybersecurity matters.


reasoning: The paragraph consists entirely of a generic, forward-looking risk warning about potential material adverse effects, which does not constitute a substantive cybersecurity disclosure or a definitive materiality assessment.


reasoning: The paragraph introduces the Trust's cybersecurity risk management approach, specifically noting its reliance on the Sponsor's (BlackRock's) Enterprise Risk Management (ERM) framework, which it proceeds to summarize.


reasoning: The paragraph primarily describes the governance structure for cyber risk oversight, detailing the Board's responsibility and the establishment of a management-level Risk Committee.


reasoning: The paragraph primarily describes the company's internal risk management processes, specifically detailing the functions and responsibilities of the management-level Cybersecurity Steering Committee.


reasoning: The paragraph primarily details the governance structure, focusing on the board of directors' and audit committee's oversight responsibilities, board expertise, and the reporting chain from the Chief Technology Officer.


reasoning: The paragraph describes the composition and function of a management-level risk committee (Enterprise Risk Council) responsible for identifying and managing risks, including cybersecurity.


reasoning: The paragraph identifies the 'information technology manager' as the leader of the security team and describes their responsibilities, fitting the Management Role category.


reasoning: The paragraph contains a negative assertion regarding the occurrence of past cybersecurity incidents affecting business operations, which falls under Strategy Integration.


reasoning: The paragraph describes the internal process for evaluating and escalating cybersecurity incidents through the organization to the CISO and senior leadership.


reasoning: The paragraph is a generic risk warning acknowledging the company's exposure to cybersecurity threats, without detailing any substantive oversight, processes, incidents, or materiality assessments.


reasoning: The paragraph primarily describes the company's Enterprise Risk Management (ERM) program and how cybersecurity risk is integrated and managed within that internal process, including the roles of specific management teams.


reasoning: The paragraph describes the governance structure by detailing how management reports cybersecurity risks upward to specific committees (Enterprise Risk and Compliance Committee and the Audit Committee) for oversight.


reasoning: The paragraph introduces the management-level structure and specific committees (Enterprise Risk Management Committee) responsible for cybersecurity risk management.


reasoning: The paragraph describes the full governance chain, detailing how the Board and Audit Committee oversee cybersecurity risk, how the CTO reports to the committee, and concluding with the CTO's specific qualifications.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including the IT security team's responsibilities, cross-functional approach, training, and internal audits. While the CISO is mentioned, the focus is on the program and processes rather than the individual's qualifications.


reasoning: The paragraph consists entirely of a forward-looking disclaimer, a generic risk warning about potential material impacts, and a cross-reference to the Risk Factors section, lacking any substantive disclosure about the company's actual cybersecurity program.


reasoning: The paragraph describes the internal processes for identifying, assessing, and managing cybersecurity threats, including monitoring, evaluating risk profiles, and using automated tools. Although the CFO is mentioned, the primary focus is on the risk management process itself.


reasoning: The paragraph primarily describes the company's internal processes for re-examining systems and evaluating risks following risk assessments, naming the head of IT as the executor of these processes.


reasoning: The paragraph consists entirely of generic risk warnings regarding regulatory compliance and potential consequences of non-compliance, lacking substantive cybersecurity program details or materiality assessments.


reasoning: The paragraph is a cross-reference pointing the reader to Item 1A for risk factor disclosures, containing no substantive cybersecurity program details or standalone materiality conclusions.


reasoning: The paragraph describes the oversight structure and reporting cadence to the CEO and Board of Directors regarding cybersecurity risks and the overall cybersecurity program.


reasoning: The paragraph describes the overarching security governance structure, detailing the oversight roles of the Board, Audit Committee, and executive management.


reasoning: The paragraph contains explicit backward-looking and forward-looking materiality assessments regarding cybersecurity risks, which directly aligns with the Strategy Integration category.


reasoning: The paragraph describes the internal management-level processes and committee structures (IT Operating Committee, IT Steering Committee) used to oversee and execute cybersecurity risk management and integrate it into the broader enterprise risk management strategy.


reasoning: The paragraph describes the organizational structure of the security program and explicitly details how various officers (Chief Risk Officer, Chief Compliance Officer) maintain reporting channels to the Board to provide a clear picture of the risk landscape, which aligns with Board Governance.


reasoning: The paragraph describes the reporting structure and cadence for cybersecurity threats and incidents, specifically how the CISO and senior management report to the Audit Committee and the Board of Directors. This is a clear description of board governance and oversight structure.


reasoning: The paragraph primarily describes the governance and oversight structure, detailing how the Board and executive management receive updates from the CISO and CIO regarding cybersecurity risks and programs.


reasoning: The paragraph primarily describes the governance structure for cybersecurity risk oversight, detailing the roles of the board, the Audit Committee, and a specialized Cybersecurity Disclosure Committee.


reasoning: The paragraph consists entirely of generic risk warnings and boilerplate language about potential material adverse effects, without describing any actual processes, governance, or specific incidents.


reasoning: The paragraph consists of a generic acknowledgment of past cyber-attacks and boilerplate forward-looking risk warnings without detailing any specific incidents, processes, or formal materiality assessments.


reasoning: The paragraph explicitly identifies the CISO, their reporting line to the GCSO, and their experience, which aligns with the Management Role category.


reasoning: The paragraph contains a negative materiality assessment stating the company has not experienced material impacts from cyber-attacks, which falls under Strategy Integration.


reasoning: The paragraph primarily describes the oversight structure and upward reporting flow of cybersecurity assessments to specific board committees (BAC, BOTC, and the board of trustees).


reasoning: The paragraph explicitly details the specific roles (Chief Technology Officer and Head of Technology Infrastructure) and their respective years of experience (25 and 20 years) leading the cybersecurity program, which strongly aligns with the Management Role category.


reasoning: The paragraph details the governance structure and reporting chain for cybersecurity risks, describing how information flows from management-level committees up to the CIO, Head of Operational Risk, various risk committees, and ultimately the Board.


reasoning: The paragraph primarily describes the escalation and notification structure to the Audit Committee and Board of Directors, and details the specific IT experience of an independent board member.


reasoning: The paragraph describes the reporting cadence and the specific topics covered in briefings provided by management to the audit committee, which details the board/committee oversight structure and information flow.


reasoning: The paragraph describes the governance structure for cybersecurity risk oversight, detailing the roles of the Audit Committee, the Risk Committee, and the CISO's reporting cadence to the Audit Committee.


reasoning: The paragraph describes the oversight structure, strategic direction, and reporting cadences involving the DPIRC, the Enterprise Risk Committee, and the CISO, outlining the governance chain for cybersecurity.


reasoning: The paragraph primarily describes the operational responsibilities of the Cyber Incident Response Team (CIRT) in detecting, assessing, classifying, and escalating cybersecurity threats, which falls under Risk Management Process. While it mentions the titles and experience of the team leaders, the core focus remains on the internal processes executed by the team.


reasoning: The paragraph describes the governance chain and reporting structure, detailing management's responsibilities and their obligation to report to the Cybersecurity Committee and the Board of Directors.


reasoning: The paragraph provides a clear materiality assessment, stating that the company is not aware of any cybersecurity threats that have materially affected or are reasonably likely to materially affect its business strategy or financial condition.


reasoning: The paragraph primarily describes the responsibilities and functions of the IT Department's security team in managing cybersecurity risk, rather than focusing on the specific credentials or career history of an individual officer.


reasoning: The paragraph primarily describes the governance structure, detailing how the Audit Committee oversees cybersecurity risk and the specific reporting cadence from management and the CIO to the committee.


reasoning: The paragraph primarily describes the governance and oversight structure, detailing management-level committees (ISMS and Data Protection Governance Committees) and how the interim CSO and DPO report upward to the audit committee.


reasoning: While the paragraph begins by mentioning the board's Risk Committee, the primary focus and most detailed portion of the text describes the CISO's responsibilities, reporting lines, years of experience, and specific professional certifications, which firmly places it in the Management Role category.


reasoning: The paragraph primarily describes the internal processes and organizational structure for incident response, detailing how specific management teams execute the incident response plan and escalate issues. Following the MR vs RMP test, the absence of specific credentials or career history points to Risk Management Process rather than Management Role.


reasoning: The paragraph primarily details the management structure responsible for cybersecurity, specifically identifying the Information Security Team, its composition (Director of Information Security, managers, analysts), and its reporting line to the CIO.


reasoning: The paragraph details the governance structure and escalation paths for cybersecurity risk, including specific management committees (ORMC, ERMC) and their reporting lines to the Board and Risk Committee.


reasoning: The paragraph primarily describes the cybersecurity oversight structure, detailing the shift of responsibility to the Sustainability & Safety Committee and the reporting cadence from the CIO to the committee, board, and executive management, while also including management qualifications.


reasoning: The paragraph primarily focuses on identifying the management role (Senior Vice President of Information Technology) and detailing their qualifications, years of experience, and the expertise of their supporting team.


reasoning: The paragraph primarily describes the company's internal processes for managing cybersecurity operations and incident response, including the composition and responsibilities of the Incident Response Team and its escalation pathways.


reasoning: The paragraph describes management's responsibilities in leading cybersecurity assessment and management processes. Following the decision chain, removing the specific titles leaves a coherent description of internal processes, and there are no individual qualifications or credentials listed, making it Risk Management Process rather than Management Role.