reasoning: This paragraph describes the governance and oversight structure for cybersecurity risk, including the board's risk oversight role, the Audit Committee's specific oversight responsibilities, and the establishment and role of the Cybersecurity Disclosure Committee in the oversight chain.


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the governance and oversight structure for cybersecurity, detailing how the Director of IT works with other officers to report to the audit committee and board, which is characteristic of Board Governance. The Director of Information Technology is a cybersecurity-specific role overseeing cybersecurity risk management, providing one firm-specific fact.

provider: z-ai

stage: benchmark


reasoning: The paragraph describes the governance structure and information flow between management and the Board, including management's oversight role, charter adoption for periodic Board reviews, and reporting obligations to the Board.


reasoning: The paragraph describes the company's cybersecurity governance structure, including how oversight flows from the Board and Audit Committee through the CEO, who consults with the CFO and third-party consultants. This is a governance-chain description focused on oversight structure.


content_category: Strategy Integration

reasoning: The paragraph contains a backward-looking materiality assessment—a negative assertion that the company has not identified any cybersecurity incidents with material impact—which is the defining characteristic of Strategy Integration. The subsequent risk warning language is generic boilerplate speculation and does not override the primary materiality conclusion.


content_category: Risk Management Process

category_confidence: medium

reasoning: The paragraph describes a management-level steering committee structure for cybersecurity oversight, including its composition and purpose. While it mentions the CISO as chair, the focus is on the committee's role in managing cybersecurity challenges rather than individual qualifications, making Risk Management Process more appropriate than Management Role.


reasoning: The paragraph primarily describes the governance and oversight structure for cybersecurity risk - how the Board and Audit Committee oversee risk management, and how the CTO reports upward to the Audit Committee. While the final sentence details CTO qualifications (Management Role content), the overall purpose is explaining the oversight chain and information flow from management to the Board.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks, including monitoring methods, tools, audits, and threat assessments. While roles are mentioned as grammatical subjects, the content focuses on what the processes do rather than on the qualifications or credentials of the individuals.


reasoning: The paragraph describes the composition and responsibilities of the Cybersecurity Team in maintaining and overseeing the company's cybersecurity program, monitoring technology trends, and managing training initiatives. This is a risk management process disclosure focused on how cybersecurity is managed, not on individual qualifications or credentials.


reasoning: The paragraph primarily describes the Board's oversight structure through committees and reporting lines, with management qualifications embedded within the governance narrative to explain who reports to the Board.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including who holds primary responsibility, the Rapid Response Team composition, and the reporting cadence to the audit committee and board. The primary purpose is explaining the oversight chain and how information flows upward, though incident response elements are present as supporting detail.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including how the Board receives updates from management and the Audit Committee, and the reporting lines between management, the CEO, and the Audit Committee. All named entities (Board of Directors, Audit Committee, CEO, management) are generic roles that appear in standard filings, with no cybersecurity-specific titles, frameworks, dates, or other firm-specific details.


reasoning: The paragraph primarily describes the governance and oversight structure for cybersecurity, including Board oversight, reporting lines from CISO/CIO to the Board, and management awareness processes. While it mentions monitoring and incident response processes, these are brief references that support the governance narrative rather than detailed process descriptions.


reasoning: The paragraph describes the company's internal cybersecurity processes (risk assessment, security controls, incident response) managed by a security team. Applying the MR vs RMP test: removing the person reference leaves a coherent process description, and no qualifications or credentials are provided, so this is Risk Management Process. No cybersecurity-specific titles (CISO, CTO, etc.), named frameworks, dates, or other firm-specific facts appear—'information technology manager' is a generic IT role, not a cybersecurity-specific title.


specificity_confidence: medium

reasoning: The paragraph describes the company's internal organizational structure for cybersecurity risk management, including team responsibilities, oversight relationships, and reporting lines. While certifications are mentioned, the primary focus is on the risk management process structure rather than individual officer qualifications.


reasoning: The paragraph primarily describes the company's cybersecurity committee structure, composition, meeting cadence, and reporting lines as part of its risk management response to past incidents. While a materiality assessment appears at the beginning, the substantive disclosure focuses on the governance and control processes implemented to mitigate future risks.


content_category: None/Other

reasoning: This paragraph contains only generic risk warnings and boilerplate language about cybersecurity threats without any substantive disclosure about governance structures, management roles, risk management processes, specific incidents, or materiality assessments. The materiality language ('could have a material adverse effect') is forward-looking speculation, not a materiality assessment.


reasoning: The paragraph describes the company's processes for identifying, assessing, and managing cybersecurity threats (monitoring, automated tools, escalation protocols). Applying the MR vs RMP decision chain: while the CFO is the grammatical subject, removing the person reference leaves a coherent process description with no qualifications or person-specific details, so it classifies as Risk Management Process. No specific facts remain after filtering—CFO is generic C-suite, vendors are unnamed, and practices like 'automated tools' and 'real-time monitoring' are generic.


reasoning: The paragraph describes the company's internal cybersecurity risk management structure, including ERM integration and the Information Security Team's composition and reporting. While roles are mentioned, the focus is on the process and organizational structure for managing cyber risks, not on individual qualifications or credentials.


reasoning: The paragraph describes the Board's oversight responsibility for cyber risk and the Risk Committee's governance role in identifying, assessing, and managing enterprise risks including cybersecurity, as well as making materiality determinations for incidents.


reasoning: The paragraph describes the oversight structure and information flow from management (CISO, senior management) to the Audit Committee and Board of Directors, which is the governance chain for cybersecurity oversight.


reasoning: The paragraph describes the governance structure of how management reports to the audit committee on cybersecurity matters, including briefing cadence and topics covered. This is oversight structure describing information flow upward, not management qualifications or internal processes.


reasoning: The paragraph describes the company's internal processes for monitoring cybersecurity threats and the escalation procedures from the cybersecurity organization through the CISO to senior leadership, which is a Risk Management Process disclosure.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, detailing multiple committees (Compliance Committee, Information Governance and Privacy Committee), their compositions, and their responsibilities for cybersecurity risk oversight. This is governance structure rather than individual management qualifications or specific risk management processes.


reasoning: The paragraph contains materiality assessments—a backward-looking negative assertion ('Risks from cybersecurity threats have not materially affected us') and a forward-looking statement with SEC qualifier ('reasonably likely to materially affect us')—which are the defining features of Strategy Integration.


reasoning: The paragraph describes the governance structure for IT and cybersecurity oversight, including the IT Steering Committee's composition and functions, and the reporting line from the IT manager to the Risk Management committee. This is about oversight structure (committees, reporting lines) rather than specific risk management processes or individual qualifications.


reasoning: This paragraph describes the governance structure for cybersecurity oversight—the flow of information from management-level committees through escalation to the Non-Financial Risk Committee, and ultimately to the Board. The focus is on oversight structure and reporting lines, not on individual officer qualifications or internal processes.


reasoning: The paragraph describes the governance structure for board oversight - specifically how a management officer reports to the board on cybersecurity matters, including the reporting cadence and topics covered. This is classic board governance disclosure about information flow and oversight structure.


content_category: Management Role

reasoning: The paragraph focuses on the cybersecurity sub-committee's qualifications and expertise (45 years combined experience, wealth of expertise, in-depth knowledge), meeting the Management Role criteria for describing who the responsible party is and their credentials. The person-removal test confirms this—the paragraph becomes incoherent without the role and qualifications, indicating it is fundamentally about who these people are rather than what a process does.


reasoning: The paragraph describes the company's cybersecurity program structure, policies, technical safeguards, and risk management processes. While it names management roles (CTO, Head of Technology Infrastructure), the content focuses on what the program does rather than who the people are, and the person-removal test yields a coherent cybersecurity disclosure about processes and controls.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk management, including the ISMS Governance Committee composition, its alignment with the Data Protection Governance Committee, and reporting lines to the audit committee. This is a governance-chain description focused on how oversight is exercised, not on individual qualifications.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, identifying committees and management positions responsible for risk assessment and management. The Enterprise Risk Management Committee is a named non-generic committee that qualifies as a firm-specific fact.


reasoning: This paragraph describes risk factors and exposure landscape (why the company faces cybersecurity risks) rather than governance structures, management roles, internal processes, third-party oversight, incident details, or materiality assessments. It is essentially risk factor language that does not fit the defined content categories.


reasoning: The paragraph describes the company's cybersecurity governance structure from the Board down through committees and teams, with the primary purpose being to explain oversight structure and information flow. The CISO section, while containing Management Role content (qualifications), is embedded within a broader governance chain description.


reasoning: This paragraph describes the governance-chain structure (Board → Sustainability & Safety Committee → CIO → program), including oversight transition, reporting cadences, and information flow. While it opens with CIO qualifications and closes with RMP content, the primary purpose is explaining how board oversight operates.


reasoning: The paragraph primarily describes the governance chain for cybersecurity oversight: CFO direction of cybersecurity programs, incident reporting flow to the board, and Audit Committee receiving periodic updates. While a materiality statement (negative assertion about no incidents) appears, the governance structure content is more substantial and represents the primary focus of the disclosure.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including the Board's delegation to the Audit Committee, the establishment of a Risk Committee chaired by the CISO, and the reporting chain from the CISO to the Audit Committee.


reasoning: The paragraph describes management's responsibilities in overseeing cybersecurity processes including setting objectives, resource allocation, policy development, risk management, incident response, and compliance. Applying the MR vs RMP test: removing 'management team' leaves a coherent description of cybersecurity processes (objectives, policies, risk assessments, incident response planning), with no qualifications or person-specific details, so this is Risk Management Process.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically how management reports to the Board on a monthly basis and how program evaluations flow upward to senior management and the Board. This is classic Board Governance content focused on oversight mechanisms and information flow.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, detailing the DPIRC's oversight responsibilities and the Enterprise Risk Committee's receipt of quarterly CISO updates, which constitutes board/committee oversight of cyber risk.


reasoning: The paragraph contains a negative materiality assertion ('we have not yet experienced any material impacts from a cyber-attack') which qualifies as a materiality assessment under Strategy Integration, followed by forward-looking risk warnings. No specific facts, named entities, dates, or frameworks are present—only standard boilerplate risk language.


reasoning: The paragraph primarily describes the governance structure for cybersecurity oversight, centered on the DPIRC committee, its composition, and leadership. The CIO qualifications are mentioned in the context of who co-chairs the oversight committee, supporting the governance description rather than being the main focus.


reasoning: The paragraph describes the company's internal governance structure for managing cybersecurity risks through a Cybersecurity Steering Committee, including its composition, leadership, and responsibilities. This is management-level oversight of cybersecurity processes, not board-level governance.


reasoning: The paragraph describes the company's internal cybersecurity organizational structure and incident response processes, including team composition, responsibilities, and reporting flows. The person-removal test confirms this is RMP because the process description remains coherent without the named roles.


reasoning: The paragraph describes how cybersecurity risk is managed through management responsibility and a third-party IT provider, including incident response procedures. While management roles are mentioned, the primary focus is on the process structure rather than individual qualifications (no specific years, certifications, or career history are provided), and the person-removal test leaves a coherent process description intact.


reasoning: The paragraph describes the company's internal cybersecurity processes including ongoing education, monitoring, penetration testing, and incident response planning. Applying the MR vs RMP test, the CIO is mentioned as leading these efforts, but removing the person reference leaves a coherent process description, so this is Risk Management Process.


reasoning: The paragraph describes the company's internal risk assessment and continuous evaluation processes for cybersecurity risks. Applying the MR vs RMP test, removing the named roles (head of IT department, CFO) leaves a coherent process description about evaluating and addressing cybersecurity risks, so this is RMP not Management Role.


reasoning: The paragraph describes the information security program's design and objectives, with the CISO mentioned as the program leader. Applying the MR vs RMP test: the program is the grammatical subject, removing person details leaves a coherent disclosure about the program, and no specific qualifications (years of experience, certifications) are provided, so this is Risk Management Process rather than Management Role.


reasoning: The paragraph describes the Enterprise Risk Council's structure and function for managing enterprise-wide risks including cybersecurity, which is an internal risk management process. The CISO's membership is incidental to describing the council's role in ERM integration, not a focus on the individual's qualifications.


reasoning: The paragraph primarily describes the Board's cybersecurity oversight structure, establishing the governance chain from Board to Audit Committee to management (CIO and CISO). While the second half contains detailed qualifications for the CIO and CISO, these support the governance disclosure by establishing the credibility of officers in the oversight chain, making this a governance-chain paragraph under the Board Governance category.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including escalation procedures, notification thresholds to management and the Board, and disclosure review processes with the Audit Committee. The final sentence references Board member IT experience, reinforcing the governance focus.


reasoning: The paragraph describes management's responsibilities in leading cybersecurity processes (hiring, budgeting, risk integration, oversight, incident preparation) without detailing individual qualifications or credentials. Applying the MR vs RMP test: roles are subjects but the content describes what the management structure does, and removing person references leaves coherent process disclosure with no qualifications mentioned, so RMP applies. Specificity is Generic Boilerplate because 'President of P&T' contains 'President' (generic C-suite on the NOT list), 'CDO' is not a cybersecurity-specific title, and 'senior-most employee responsible for cybersecurity management' is a description rather than a specific title like CISO.


reasoning: The paragraph primarily describes the company's internal information security program, organizational structure, and security tools employed. While governance reporting channels are mentioned at the end, the main focus is on the security processes and methods rather than board oversight structure.


reasoning: The paragraph describes how the Risk Management Steering Committee monitors cybersecurity threats and incidents in real time and reports to the Audit Committee. While governance elements are present (reporting to Audit Committee), the primary focus is on the management-level monitoring process for prevention, detection, mitigation, and remediation of cybersecurity threats.


reasoning: The paragraph describes management's responsibilities for the cybersecurity program, including risk identification, incident response coordination, policy assessment, and reporting—these are internal process activities. The Executive Vice President, Administration is mentioned as part of the process structure, but the paragraph contains no qualifications or person-specific details, so it remains RMP under the person-removal test.


reasoning: The paragraph contains a materiality assessment in the form of a negative assertion ('no such incident has had any such impact to date'), which is a backward-looking conclusion about whether cybersecurity incidents have materially affected the company. The cross-reference to Item 1A for additional materiality information does not negate the fact that the company made a materiality statement in this paragraph.


reasoning: The paragraph describes the company's internal cybersecurity program structure and the CIRT's responsibilities for managing cybersecurity risks, including policy management, detection, assessment, classification, and reporting. The mention of leadership roles and their experience is incidental to the primary focus on process description.


reasoning: The paragraph primarily describes the Board's oversight structure - reviewing the security program annually and receiving incident reports from management. While the COO's qualifications (30+ years experience) appear, they serve as supporting detail for the governance chain rather than the paragraph's main focus.


reasoning: The paragraph describes the company's cybersecurity risk management structure and processes, including monitoring activities, governance councils (Enterprise Security Council, Enterprise Risk Council), and controls evaluation. While CISO and CEO qualifications are mentioned, they are embedded within a broader description of the risk management framework rather than being the primary focus—the process stands alone when person details are removed.


reasoning: The paragraph describes the governance chain from board to audit committee to cybersecurity leaders, including oversight structure, reporting cadence ('at least semi-annually'), and escalation protocols. While management roles and qualifications are detailed, they are presented in the context of who reports to the audit committee, making the primary purpose describing oversight structure.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, with the Audit Committee receiving reports from the CIO and management on threat detection, training, and program effectiveness. The CIO qualifications at the end support the governance narrative by demonstrating the person in the oversight chain is qualified, but naming an officer as part of a governance description does not make it Management Role.


reasoning: The paragraph describes the board's cybersecurity oversight structure, including policy adoption, the CTO's reporting lines to the CEO and board/audit committee, and the audit committee's ERM oversight role. While the CTO's qualifications are mentioned, the primary purpose is describing the governance chain, making this Board Governance rather than Management Role.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, identifying the CFO as the officer responsible for day-to-day oversight and their reporting relationship to the Board. While the CFO is the grammatical subject, the purpose is describing the oversight chain and information flow upward to the Board, not the CFO's qualifications or credentials.


reasoning: The paragraph primarily describes the governance structure for cybersecurity oversight—board responsibility, executive officers' roles in safeguarding data, and reporting lines to the board. While CEO qualifications are detailed (15+ years IT experience), they support the governance narrative rather than constituting the main focus, and the paragraph opens and closes with board oversight matters.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including team structure, Incident Response Team composition, monitoring activities, and incident reporting workflows. While governance chain elements appear, the primary focus is on operational processes rather than board oversight structure.


reasoning: The paragraph describes a hierarchical escalation process for cybersecurity threats flowing from management through executives to the Risk Committee and Board, which constitutes a governance-chain paragraph describing oversight structure under the BG tiebreaker.


reasoning: The paragraph describes the CISO's qualifications, prior roles, and career history, which triggers Management Role per the MR vs RMP test Step 2 (remaining text after person-removal is not coherent due to broken sentences).


reasoning: The paragraph describes the internal governance structure for managing cybersecurity risks, including management-level committees (IT Operating Committee, IT Steering Committee), their compositions, meeting cadences, and review processes. This is Risk Management Process rather than Board Governance because the committees are management-level, not board-level, and the board (Audit Committee) is only mentioned briefly for ERM coordination.


reasoning: The paragraph describes the oversight structure for Morgan Stanley's Cybersecurity Program, detailing how assessments flow from Internal Audit to multiple committees (BAC, BOTC) and the board of trustees, plus third-party and regulatory review channels. This is governance-chain disclosure focused on who oversees and receives reports rather than the internal processes themselves.


reasoning: The paragraph includes detailed qualifications for the CTO (30 years IT experience, 20 years cybersecurity focus), which is MR-specific content per the Step 3 tiebreaker. While the paragraph also describes the broader risk management structure and third-party engagement, the presence of years-of-experience qualifications tips a borderline case toward Management Role.


reasoning: This is a governance-chain paragraph describing how oversight flows from the Board through the CISO to the IS Program and Incident Response Team. The paragraph establishes the Board's approval and oversight role, identifies the CISO as the program coordinator with specific qualifications, and traces the structure down to operational response elements—fitting the Board Governance category per the guidance that governance-chain paragraphs are BG even when officers and programs appear as subjects.


reasoning: The paragraph describes the company's cybersecurity governance structure and oversight processes, including a management committee composition, the InfoSec Roadmap program, and how cybersecurity strategy is implemented across the enterprise. While governance elements are present, the focus is on how cybersecurity risk management is organized and executed rather than board-level oversight or individual qualifications.


reasoning: The paragraph includes detailed qualifications (over 25 years and over 20 years of experience with specific areas of expertise) for named officers (CTO and Head of Technology Infrastructure), which is MR-specific content per Step 3 of the MR vs RMP decision chain.


reasoning: Applying the three-step MR vs RMP test: Step 1 identifies a person/role as subject; Step 2 shows the remaining text after removing roles and qualifications is not fully coherent (first two sentences become fragmented); Step 3 confirms qualifications are present ('over a decade of experience'), which tips the classification to Management Role.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically the ERC's role as a cross-functional executive forum that receives updates from the CISO and has delegated authority from the BRC. This is a governance-chain paragraph explaining how oversight flows from board to committee to officers.


reasoning: The paragraph primarily describes board committee oversight structure (Technology Committee and ERM Committee receiving regular updates on the information security program), with CISO and team qualifications serving to establish the governance chain being overseen.