content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph contains generic risk acknowledgment language stating that breach attempts have been prevented, followed by forward-looking disclaimer language and a cross-reference to Risk Factors. It does not describe actual incidents (attempts were prevented), governance structure, specific processes, or materiality assessments.

provider: z-ai

stage: benchmark


content_category: Strategy Integration

reasoning: The paragraph contains a materiality assessment—a negative assertion that the company has not experienced a material cybersecurity incident—which is the defining characteristic of Strategy Integration. The language is entirely generic with no specific dates, named entities, or firm-specific details.


content_category: Board Governance

reasoning: This paragraph describes the governance oversight structure - how information flows from IT Management to the Risk Committee, including reporting cadence (annual and quarterly) and the topics covered in those reports. The Risk Committee is a named non-generic committee, which qualifies as a firm-specific fact.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk, identifying which board and management committees have oversight responsibility, which officers manage operational cybersecurity programs, and how information flows through regular updates to various committees.


reasoning: This paragraph contains generic IT-dependence language and common threat descriptions without any substantive disclosure about governance structures, management roles, risk management processes, or actual incidents. The materiality language is a generic forward-looking risk warning ('could materially adversely affect'), not a materiality assessment.


reasoning: This paragraph is a materiality assessment containing backward-looking ('have not materially affected'), forward-looking with SEC qualifier ('reasonably likely to materially affect'), and negative assertion ('have not experienced any cybersecurity incidents that have had a material adverse impact') statements, which are the defining characteristics of Strategy Integration.


reasoning: This paragraph contains only forward-looking risk disclaimers and generic warnings about potential cybersecurity threats without describing any actual governance structure, management roles, processes, or incidents. The materiality language ('could have a material adverse effect') is boilerplate speculation, not an assessment of actual events.


content_category: Risk Management Process

reasoning: The paragraph describes an internal team structure and its risk management functions—addressing cyber incidents, managing business continuity risks, and reviewing security programs—which constitutes a Risk Management Process disclosure. The named internal program (CSWAT) and specific team composition make it Firm-Specific, but there are no hard verifiable facts like dates, dollar amounts, or named third parties to reach Quantified-Verifiable.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk, including how the Board, Audit Committee, Governance and Compliance Committee, and Technology Committee exercise oversight, and how the CISO reports upward. This is a classic Board Governance disclosure focused on information flow and oversight chains rather than internal processes.


reasoning: The paragraph describes the company's cybersecurity program structure (three lines of defense model) and how the organization monitors, assesses, and responds to incidents. Management is mentioned as steering the program, but the substance is about process, not person qualifications.


reasoning: The paragraph contains a materiality assessment—a negative assertion that the company is not aware of any previous cybersecurity threats that have materially affected or are reasonably likely to materially affect the Company—which qualifies as Strategy Integration. The remainder is generic risk warning language and a cross-reference, with no specific facts such as named roles, dates, frameworks, or verifiable details.


reasoning: The paragraph describes the governance chain for cybersecurity oversight—how information flows from the CISO through management to the Audit Committee—making it a Board Governance disclosure focused on oversight structure rather than individual qualifications or processes.


reasoning: The paragraph contains a backward-looking materiality assessment stating the Company 'has not been materially affected by a cybersecurity breach,' which is a Strategy Integration content type. The remainder consists of generic risk warnings and cross-references to Risk Factors sections, with no firm-specific facts such as named roles, dates, frameworks, or verifiable details.


reasoning: This paragraph describes the governance structure for board oversight, specifically how the ITSC and CIO report to the Board on a quarterly basis to integrate cybersecurity risk management into enterprise risk management. The CIO is mentioned in the context of their reporting role in the oversight chain, not their qualifications, making this Board Governance rather than Management Role.


reasoning: The paragraph describes the company's internal cybersecurity organizational structure and processes—the Executive Cybersecurity Steering Committee's oversight role, quarterly meeting cadence, and the local Information Security Officer structure for monitoring and responding to cyber risks across business units.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically how the CISO reports to the IT/Cybersecurity Committee of the board. This is a governance-chain paragraph describing oversight structure rather than management qualifications or internal processes.


reasoning: The paragraph describes the company's internal processes for monitoring and managing cybersecurity risks through briefings, threat intelligence, and security tools. Applying the MR vs RMP test: while CISO and Sr. Director appear as subjects, removing person-specific details leaves a coherent process description with no qualifications or career history, so this is RMP not MR.


reasoning: The paragraph contains a backward-looking materiality assessment stating the company is not aware of cybersecurity risks that have materially affected business strategy, results of operations, or financial condition, which is a classic Strategy Integration disclosure. The cross-reference to risk factors is secondary to the primary materiality conclusion.


reasoning: The paragraph describes the Board's oversight structure for risk management, including the reporting chain from the Chief Risk Officer to the full Board, which is a governance structure disclosure. No cybersecurity-specific roles (CISO, CTO, CIO), named frameworks, specific dates, or other firm-specific facts are present, making this generic boilerplate that could apply to any company.


reasoning: The paragraph describes the governance structure for board oversight of cybersecurity, specifically how the CIO and General Counsel report to the Board and its committees on cybersecurity matters. This is a classic Board Governance disclosure about information flow and oversight cadence.


reasoning: This paragraph is a forward-looking risk disclaimer with a cross-reference to another section. The materiality language ('if realized, are reasonably likely to materially affect') is conditional and constitutes generic risk warning rather than an actual materiality assessment. There is no substantive disclosure about governance, processes, incidents, or strategy.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, detailing who reports to which committees (Audit Committee and QRC), the cadence of reporting, and escalation processes to the Board. This is a classic Board Governance disclosure focused on information flow and oversight mechanisms rather than individual qualifications or internal processes.


specificity_confidence: medium

reasoning: The paragraph describes the company's internal processes for embedding risk management into business operations and how teams collaborate to evaluate cybersecurity risks, which is a Risk Management Process disclosure. The CSO is a cybersecurity-specific title that qualifies as a firm-specific fact, but no named frameworks, dates, or other verifiable details are present to reach Quantified-Verifiable.


reasoning: The paragraph contains a materiality assessment stating the company is not aware of cybersecurity risks that have materially affected or are reasonably likely to materially affect the company, which is a backward-looking and forward-looking materiality conclusion under Strategy Integration. The first sentence is generic risk language and the third is a cross-reference, but the materiality assessment is the substantive disclosure.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including the board-approved IT/Cybersecurity Committee, its composition, meeting cadence, and reporting lines to both the Enterprise Risk Committee and the board's IT/Cybersecurity Committee. This is a classic Board Governance disclosure focused on oversight structure and information flow.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risks—reporting to leadership, integration into enterprise risk management, and internal audit activities. The Chief Security and Trust Officer is named as part of describing the reporting process, not to detail their qualifications, making this Risk Management Process under the person-removal test.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors, containing no substantive cybersecurity disclosure. The materiality language ('may materially affect') is part of the cross-reference itself, not a materiality assessment by the company.


reasoning: The paragraph contains a negative materiality assertion ('we have not experienced any recent material cybersecurity incidents'), which qualifies as a materiality assessment under Strategy Integration. The surrounding language is generic risk warning and cross-reference, but the explicit statement about absence of material incidents is a substantive conclusion.


reasoning: The paragraph describes the company's internal cybersecurity processes including monitoring tools, incident response procedures, and employee training. The VP Infrastructure is mentioned in the context of policy oversight rather than personal qualifications, so this is Risk Management Process not Management Role.


reasoning: The paragraph describes the company's internal cybersecurity risk management structure and processes, including the Information Security Office and Incident Response Plan. The CIO is mentioned incidentally as part of the organizational structure, not as the focus with qualifications, so this is RMP not Management Role.


reasoning: The paragraph describes the organizational structure and responsibilities for identifying, assessing, managing, and mitigating cybersecurity risks, which is a risk management process disclosure. Applying the MR vs RMP test, removing the named roles leaves a coherent process description about risk evaluation and mitigation, with no qualifications or credentials mentioned that would make it Management Role.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including how the InfoSec Leadership Team monitors incidents and operates the incident response plan. This is a description of internal processes rather than board governance, management qualifications, or an actual incident.


reasoning: The paragraph describes the governance chain for cybersecurity oversight, detailing how information flows from the Information Security Department through the CISO and Chief Risk Officer to the Risk Management Council and ultimately to the Board Risk Committee. This is a classic Board Governance disclosure focused on oversight structure and reporting lines.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including a named Compliance Committee's composition, meeting cadence, responsibilities, and escalation processes to ensure Board oversight.


category_confidence: medium

reasoning: The paragraph contains a backward-looking materiality assessment ('cybersecurity incidents have not materially affected our business to date'), which is a Strategy Integration element per the guidelines. The surrounding text consists of forward-looking disclaimers and a section header, but the materiality conclusion is substantive content that distinguishes this from None/Other. No specific facts are present—no named roles, dates, amounts, or firm-specific details—making this boilerplate language that could appear in any company's filing.


content_category: Management Role

reasoning: The paragraph describes the ISO's responsibilities, team composition, and reporting line to the Senior Risk Officer, which is fundamentally about management structure and roles rather than the risk management process itself. Applying the person-removal test confirms this is Management Role because the paragraph becomes incoherent without the role references.


reasoning: The paragraph describes the CDO's role in directing information security activities and developing cybersecurity risk management strategy, which focuses on what the program does rather than who the person is (no qualifications, credentials, or career history mentioned).


reasoning: The paragraph describes the company's internal cybersecurity risk management and incident response processes, including threat monitoring, vulnerability scanning, incident escalation procedures, and reporting chains. While governance bodies are mentioned, they are components of the process description rather than the primary focus.


reasoning: This paragraph is a cross-reference directing readers to risk factors in another section of the filing, not a substantive cybersecurity disclosure. The guidelines explicitly classify cross-references with materiality language as None/Other because they point elsewhere rather than making conclusions.


reasoning: The paragraph describes the company's internal cybersecurity organizational structure, oversight committees, and risk management processes. Although CIO and CISO are mentioned as grammatical subjects, applying the person-removal test shows the paragraph is fundamentally about the InfoSec program structure and processes, not individual qualifications.


reasoning: This paragraph consists primarily of forward-looking disclaimers about the limitations of cybersecurity defenses and a cross-reference to Item 1A Risk Factors, with no substantive disclosure about actual governance, processes, or incidents.


reasoning: The paragraph describes the company's internal management processes for evaluating and reviewing cybersecurity effectiveness, including a cross-functional program and an executive security council that routinely reviews strategy, policy, and program effectiveness. This fits Risk Management Process as it details how the company manages and oversees its cybersecurity program internally.


reasoning: This paragraph contains only generic IT-dependence language and boilerplate statements about the importance of cybersecurity, with no substantive disclosure about governance, processes, incidents, or materiality assessments.


reasoning: This paragraph describes the governance structure and information flow from the cybersecurity team to the Audit Committee, including reporting cadence and topics covered in updates, which constitutes board oversight disclosure.


reasoning: The paragraph focuses on the CISO's role, the organizational structure of the Cyber Security Office, and the team's professional certifications (CISSP, CISM, CRISC, CEH). Under the MR vs RMP decision chain, Step 3 applies: the paragraph includes specific qualifications (certifications) which is MR-specific content, indicating the paragraph is fundamentally about who these people are and their credentials.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, detailing who reports to the board/committee (CTO), the reporting cadence (quarterly), and what information flows upward for oversight. This is classic Board Governance content about information flow and oversight structure, not about the CTO's qualifications or internal processes.


reasoning: This is generic forward-looking risk warning language about potential data breaches that could appear in any company's filing. It does not describe governance structures, management roles, actual processes, real incidents, or materiality assessments.


reasoning: This paragraph describes the governance and oversight structure for cybersecurity risk, including the committee hierarchy (ORMC → ERMC → Board), escalation criteria, and information flow channels to board-level committees. The focus is on how oversight is exercised rather than on individual officer qualifications or specific risk management processes.


reasoning: The paragraph describes the company's internal processes for supervising and managing cybersecurity risks through various monitoring and intelligence-gathering means, which fits Risk Management Process. Applying the MR vs RMP test, removing the generic 'management team' reference leaves a coherent description of cybersecurity processes, so the paragraph is about the process, not about specific personnel.


reasoning: The paragraph describes Honda's internal organizational structure and process for conducting cybersecurity risk assessments and reporting through designated divisions, committees, and officers. While it mentions roles and committees, the primary purpose is describing how risk assessment and monitoring processes function, not detailing individual qualifications.


reasoning: This is a generic forward-looking risk warning using 'could' language without describing any actual incident, governance structure, risk management process, or materiality assessment. It represents boilerplate speculation that could appear in any company's filing.


reasoning: The paragraph describes the governance structure and information flow for cybersecurity oversight, specifically how management reports upward to the Information Technology Steering Committee quarterly and to the full Board annually.


reasoning: The paragraph describes management's responsibilities for cybersecurity risk management processes including hiring, budgeting, incident preparation, and reviewing assessments, which constitutes internal risk management process disclosure. No specific facts, roles, dates, or named entities are present.


reasoning: The paragraph primarily describes the company's cybersecurity risk management processes including protocols, policies, third-party assessments, incident response planning, and training. The CFO is mentioned as part of the oversight structure, but the paragraph is not about who the CFO is—the person-removal test confirms the process content stands alone. ISO 27001 is named as a framework the company aligns with, but no certification is claimed, placing this at Sector-Adapted.


reasoning: The paragraph describes the governance and oversight structure—how the Board exercises oversight through quarterly and annual briefings, the reporting chain from CTO through VP and Senior Director, and Board oversight of enterprise risk assessment. While management roles and qualifications are mentioned, they serve to explain the governance chain rather than being the primary focus.


reasoning: The paragraph describes the company's internal process for identifying, assessing, and managing cybersecurity risks through a third-party IT firm and internal IT lead, which constitutes a Risk Management Process disclosure rather than Third-Party Risk (which would require vendor oversight as the central topic) or Management Role (which would focus on credentials and qualifications).


reasoning: The paragraph describes the governance chain and oversight structure for cybersecurity, detailing how the CIO and SIRT report to the Audit Committee, which in turn reports to the Board, establishing the flow of cybersecurity information upward through the organization.


reasoning: The paragraph describes the company's internal cyber risk management process, including who manages it and what it covers. Applying the MR vs RMP test: removing the named roles leaves a coherent process description, and no qualifications are mentioned, so this is RMP not MR. For specificity, the titles mentioned (SVP Operations, VP Deputy General Counsel, CEO) are not cybersecurity-specific roles, no frameworks are named, and no hard verifiable facts appear.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including a named committee (Information Technology Steering Committee), its composition, meeting cadence, and the reporting flow from the Information Security Officer to the board.


reasoning: The paragraph contains a backward-looking materiality assessment stating that cybersecurity risks 'have not materially affected us, including our business strategy, results of operations or financial condition, to date,' which is the defining characteristic of Strategy Integration. The incidental mention of past breaches lacks any specific incident details and does not constitute an Incident Disclosure.


reasoning: This paragraph is a generic forward-looking risk disclaimer that could appear in any company's filing. It contains no substantive disclosure about governance structures, management roles, specific processes, actual incidents, or materiality assessments—only boilerplate risk warnings about potential cybersecurity threats and a vague statement that measures have been implemented.


reasoning: This paragraph contains a backward-looking materiality assessment stating that cybersecurity threats have not materially affected the company's business strategy, results of operations, or financial condition, which is a Strategy Integration element. The cross-reference to risk factors is secondary to the primary materiality conclusion.


reasoning: This paragraph contains only generic risk warnings about cybersecurity vulnerabilities and the company's lack of resources, with no substantive disclosure about governance structures, management roles, processes, or actual incidents. It is forward-looking disclaimer language that could appear in any small company's filing.


reasoning: This paragraph contains only generic threat landscape language describing types of cybersecurity threats (hackers, nation-state actors, social engineering) without any company-specific disclosure, governance structure, risk management processes, or materiality assessment. It is pure boilerplate risk warning that could appear in any company's filing.


reasoning: The paragraph describes an internal process for how cybersecurity information flows from IT leadership to senior management through periodic briefings. This is not Board Governance (not about the board), not Management Role (no qualifications or credentials described), but rather describes the company's internal communication and oversight process for cybersecurity matters.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, identifying the Audit Committee as the oversight body and the Senior Director - Information Security as the coordinator of cybersecurity initiatives, which constitutes a governance-chain description.


reasoning: The paragraph focuses on identifying the leaders overseeing cybersecurity (their team composition and qualifications), with specific details about their experience levels and departmental roles. The qualifications tiebreaker (20+ years of experience) confirms Management Role over Risk Management Process.


reasoning: The paragraph contains a materiality assessment (negative assertion that the company has not experienced material cybersecurity threats or incidents) and discusses cybersecurity insurance, both of which fall under Strategy Integration. The generic risk warnings and cross-reference do not override the primary materiality conclusion.


reasoning: The paragraph describes the oversight structure and responsibility chain for cybersecurity risk management, with the Board and Nominating and Corporate Governance Committee providing oversight while the IT management team and specified officers are responsible for assessment and management.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including reporting lines from the incident response team to executive officers and the Board, and details the composition and responsibilities of a named information security advisory board.


reasoning: The paragraph describes the Board and Audit Committee oversight structure for cybersecurity, including reporting cadences, information flow from CISO to the Board, and the Audit Committee's oversight responsibilities.


reasoning: The paragraph primarily describes the governance structure for cybersecurity oversight, including how the Board and Audit Committee receive briefings and the CIO's role in reporting upward. The CIO's qualifications are mentioned at the end but are secondary to the governance-chain focus.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including named committees (Information Security Council, Executive Information Security Committee), reporting lines from CISO to CEO, and oversight mechanisms involving quarterly reviews by management, executive committees, and the board.


reasoning: The paragraph describes the company's internal cybersecurity risk management structure, specifically how the Information Security Team is outsourced to service providers and how oversight flows through the Principal Financial Officer for prevention, detection, mitigation, and remediation efforts. No specific facts qualify for Firm-Specific status because Principal Financial Officer is a generic financial role (not a cybersecurity-specific title like CISO or CTO), the service providers are unnamed, and no frameworks, dates, or quantified details are provided.


reasoning: The paragraph describes the company's internal risk management process for identifying, assessing, and remediating cybersecurity risks and vulnerabilities, including how risks flow through the organization to stakeholders. Named officers appear as part of explaining how the process works, not as the primary focus with qualifications or credentials.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including reporting lines from the CIO to the Executive Leadership Team and Audit Committee, Board member engagement mechanisms, and the escalation protocol for material incidents to the Executive Response Team and Board. Contains CIO (cybersecurity-specific title) and CSIRP (named internal program with unique identifier), making it Firm-Specific.


reasoning: The paragraph contains a backward-looking materiality assessment ('we have not experienced material adverse effects from cybersecurity threats to date'), which qualifies as a Strategy Integration disclosure. However, the paragraph lacks any specific facts from the IS list—no named roles, dates, frameworks, or quantified details—making it generic boilerplate that could appear in any company's filing.


reasoning: The paragraph describes an internal working group and cybersecurity program for threat prevention, detection, mitigation, and response. Applying the person-removal test, the process description stands alone without the named officers, making this Risk Management Process rather than Management Role or Board Governance.


reasoning: This paragraph describes the governance chain and oversight structure—Board oversight, management responsibilities, reporting lines through the Principal Accounting Officer to the Audit Committee, and annual briefing cadence. The focus is on how oversight flows from board to committee to management, which is the hallmark of Board Governance.


reasoning: The paragraph describes the company's internal cybersecurity processes—ongoing education, system monitoring, and incident response procedures—rather than focusing on the qualifications or identity of the CICISO. Applying the MR vs RMP decision chain, the person-removal test confirms the process content stands alone.


reasoning: This paragraph describes the governance structure and information flow for cybersecurity oversight, tracing the chain from the internal Information Security team through management to the Board and Audit Committee with quarterly reporting on an alternating basis. The focus is on oversight structure rather than individual qualifications or specific risk management processes.


reasoning: This paragraph describes the governance oversight structure and information flow from the CTO to a committee and then to the full Board, which is the hallmark of Board Governance. The CTO is mentioned as part of the reporting chain, not to describe their qualifications or identity.


reasoning: The paragraph primarily describes the governance and oversight structure, detailing the reporting chain from CISO to CIDO to Audit Committee and Board, what information flows upward, and how oversight is exercised. While it contains Management Role content (CISO/CIDO qualifications) and Risk Management Process elements, the governance chain is the primary thread connecting the paragraph's components.


reasoning: The paragraph describes the company's internal cybersecurity program implementation and risk management process, including incident response and risk treatment activities (mitigation, transference, acceptance). Although a person is the grammatical subject, the person-removal test shows the process content stands alone without person-specific qualifications, making it Risk Management Process rather than Management Role.


reasoning: The paragraph describes the internal management structure for cybersecurity risk oversight, including delegation of authority between councils and the ISC's monitoring and policy oversight functions. While governance-related, this is management-level risk management structure rather than board-level oversight, fitting RMP's 'ERM integration' scope.


reasoning: This paragraph primarily describes the governance and oversight structure for cybersecurity risk - the flow of responsibility from Board to Audit Committee to management to consultants. The reporting chain and oversight structure are the main focus, with the materiality assertion about no incidents being one component sentence.


reasoning: The paragraph contains a backward-looking materiality assessment stating that cybersecurity risks 'have not materially affected us, including our business strategy, results of operations or financial condition, to date,' which is the defining characteristic of Strategy Integration. The brief mention of experiencing threats and breaches is generic and does not constitute a specific incident disclosure.


reasoning: The paragraph is primarily about identifying a specific officer (VP of Informatics), their qualifications (20+ years experience), and the scope of their oversight, which fits the Management Role category. The VP of Informatics overseeing cybersecurity is a named cybersecurity-specific role, and the specific years of experience provides a second verifiable fact, reaching Quantified-Verifiable specificity.


reasoning: The paragraph primarily describes the company's cybersecurity risk management approach, including policies, standards, and framework adoption (NIST, ISO), with only a brief mention of board oversight that does not dominate the content.


reasoning: The paragraph describes AGM's internal cybersecurity risk management program—how teams are deployed, how threats are monitored, and how response activities are coordinated. The CISO appears as part of the process description, not as the focus of a credentials/qualifications disclosure. Applying the person-removal test, the remaining text coherently describes the program's activities, confirming RMP over Management Role.


reasoning: This paragraph describes the governance structure for cybersecurity oversight—a management-level Risk Committee that reviews cybersecurity risks and reports to a board committee. This is a governance-chain paragraph describing how oversight flows from management to the board.


reasoning: The paragraph describes the company's cyber risk management program structure—who administers it, what activities it encompasses (prevention, detection, mitigation, remediation), and information sources used. Management is mentioned as the actor administering the process, not profiled with specific credentials or qualifications, and the Audit Committee reference is a brief appendage rather than the primary focus.


reasoning: The paragraph describes the organizational structure for cybersecurity risk management, with management responsible for the program and supervising external consultants. Applying the MR vs RMP test: after removing the COO reference (a generic C-suite role with no qualifications provided), the remaining text describes a coherent risk management process structure, making this RMP rather than MR.


reasoning: This is a cross-reference to the Risk Factors section, pointing readers elsewhere for materiality information rather than making an actual disclosure or assessment. Under the guidelines, cross-references with materiality language are classified as None/Other because the company is directing readers to another section rather than concluding or disclosing substantive content.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including who evaluates risks (management and BDT & MSD), who reports to the board (the CTO), and what information flows upward to the board. This is a classic Board Governance disclosure about oversight structure and reporting lines.


reasoning: The paragraph primarily describes the governance and oversight structure for cybersecurity risk, including the ITRGC committee and the reporting chain from the Director of Enterprise Information Security through the Information Security Officer and Chief Risk Officer to the Board. While qualifications (years of experience) are included, they support the governance description rather than being the main focus.


reasoning: The paragraph describes a governance chain (Board oversight → CFO direction → security governance structure), which fits Board Governance as it explains how oversight flows rather than detailing internal processes. However, CFO is a generic C-suite role and no cybersecurity-specific titles, frameworks, or verifiable facts are present, making this generic boilerplate.


reasoning: The paragraph primarily describes the governance and oversight structure for cybersecurity risk, including how the Audit Committee and Board engage with management and receive briefings. The CIO's qualifications are mentioned briefly at the end, but the main focus is on the oversight structure and information flow from management to the Board.


reasoning: This paragraph contains both backward-looking and forward-looking materiality assessments ('have not materially affected' and 'reasonably likely to materially affect'), which constitute conclusions about cybersecurity's impact on business outcomes.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk, detailing the TRCC committee's composition, reporting relationships, and escalation pathways within the firm's risk management hierarchy.


reasoning: The paragraph identifies a specific cybersecurity role and provides detailed qualifications (20+ years of experience), which triggers Management Role under Step 3 of the MR/RMP tiebreaker since qualifications are MR-specific content. The cybersecurity-specific title makes it Firm-Specific, but the approximate 'over 20 years' does not qualify as a hard verifiable fact for Quantified-Verifiable.


reasoning: The paragraph contains a backward-looking materiality assessment stating the company has not experienced a cybersecurity incident that materially affected its business, which is a Strategy Integration disclosure. The cross-reference to risk factors and forward-looking disclaimer are secondary to the materiality conclusion.


reasoning: The paragraph describes the governance structure for information flow to the Board, with the CFO providing updates based on information from the DIT and DIS. This is a classic Board Governance disclosure about oversight and reporting channels.


reasoning: This paragraph describes the governance and oversight structure for cybersecurity—the chain from Board to Audit Committee to the SVP of Legal and Compliance—with the purpose of explaining how oversight flows through the organization. The SVP is mentioned only as part of the reporting structure, not with qualifications or credentials, making this Board Governance rather than Management Role.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including the Information Security Governance Committee's composition, its reporting cadence to the Board, and what information flows upward (risk summaries, updates on oversight activities, material changes). This is a classic governance-chain paragraph focused on oversight structure rather than internal processes or individual qualifications.


reasoning: The paragraph describes the company's internal process for how management monitors and stays informed about cybersecurity incident prevention, detection, mitigation, and remediation. No specific roles, frameworks, dates, or named entities are included—only generic references to 'management,' 'service providers,' and 'ISP personnel.'


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including a named committee (Information Technology Steering Committee), its composition with cybersecurity-specific roles, meeting cadence, and how information flows upward to the board. This is Board Governance because it describes the oversight STRUCTURE rather than individual qualifications or internal processes.


reasoning: The paragraph primarily describes the cybersecurity team's ongoing monitoring activities, vulnerability assessments, threat intelligence, tools and methodologies, and incident escalation protocols. While team certifications are mentioned, the person-removal test shows the remaining text is coherent process disclosure, and the bulk of the paragraph describes what the program does rather than who the individuals are.


reasoning: The paragraph contains a backward-looking materiality assessment stating the company has not identified any cybersecurity risks that have materially affected the Company, its business strategy, results of operations, or financial condition. This negative assertion about material impact is a Strategy Integration disclosure. The cross-reference to Item 1A is secondary to the primary materiality conclusion.


reasoning: The paragraph describes the governance chain from Board to Audit Committee to CTO to VPCS, explaining how cybersecurity oversight flows through the organization. This is a classic governance-structure disclosure where the purpose is describing oversight, not individual qualifications.


reasoning: The paragraph contains a negative assertion about material cybersecurity incidents ('we are not aware of having experienced any prior material data breaches, regulatory non-compliance incidents, or cyber security incidents'), which constitutes a materiality assessment that triggers Strategy Integration. The remainder is generic forward-looking risk language.


reasoning: The paragraph describes the company's internal processes for preventing, detecting, mitigating, and remediating cybersecurity risks, including briefings, threat intelligence gathering, and security tool monitoring. Applying the MR vs RMP decision chain: while 'management team' is the grammatical subject, removing the person reference leaves a coherent process description with no qualifications or person-specific details, confirming RMP.


reasoning: The paragraph primarily describes the company's cybersecurity program, controls, assessments, and threat intelligence processes. Named officers (CISO, CTO, CIO) are mentioned only in their oversight capacity without qualifications or career history, so the person-removal test confirms this is RMP, not Management Role.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, specifically how the CISO reports upward to management committees and the Board. This is a classic Board Governance disclosure about information flow and oversight chains.


reasoning: The paragraph describes the governance structure and information flow from the CISO through senior management to the Compliance Committee and Board, focusing on how oversight is exercised rather than the CISO's qualifications.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity incidents, specifically the escalation and reporting chain from management to the Audit Committee and Board. It focuses on how information flows upward in the event of an incident, which is the core definition of Board Governance.


reasoning: The paragraph's primary content is a backward-looking materiality assessment stating that cybersecurity threats and incidents have not materially impacted the company's business strategy, results of operations, or financial condition, which is a Strategy Integration matter. The forward-looking disclaimer and cross-reference are secondary elements.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including Board and Audit Committee oversight roles and the reporting chain from IT Director through CFO to the Board. This is a governance-chain paragraph focused on how oversight flows through the organization.


reasoning: The paragraph describes the governance/oversight structure, specifically how management reports to the Board on cybersecurity matters and the cadence of those updates, which constitutes the information flow upward for Board oversight.


reasoning: The paragraph describes the company's internal cybersecurity risk management structure—how processes are implemented, who executes them, and how cyber risk integrates into overall risk management. Applying the MR vs RMP decision chain: although executives are grammatical subjects, removing role titles leaves a coherent process description about hiring, budget approval, incident preparation, and assessment review, with no qualifications or credentials mentioned.


reasoning: This paragraph lists oversight topics (personnel capabilities, strategy, resources) that a governance body reviews, describing the scope of board/committee oversight responsibilities. However, it appears to be a fragment (items g and h of a larger list) with no specific details about the governance structure, personnel, or processes.


reasoning: The paragraph describes the governance structure for board oversight of cybersecurity, specifically how management (COO and others) reports to the full board and Audit Committee on cybersecurity programs, risks, and incidents. This is a classic governance-chain disclosure focused on information flow and oversight structure rather than internal processes or individual qualifications.


reasoning: This paragraph describes the governance structure for board oversight of cybersecurity, specifically the reporting chain from management (Executive Officer and VP of Technology) to the Board and the topics covered in briefings. The Vice President of Technology is a technology-specific leadership role providing cybersecurity briefings, which qualifies as a firm-specific fact.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk, specifically how information flows from management (CISO and CRO) to the Board and risk committee through regular reporting and escalation processes.


reasoning: The paragraph primarily identifies the SVP of Information Technology and describes their qualifications (over 20 years of experience) and the team's credentials (relevant education, industry experience, positions at large technology companies), which triggers the Management Role category under the qualifications tiebreaker in Step 3 of the MR vs RMP decision chain.


reasoning: This paragraph contains only generic risk warning language about cybersecurity threats that could apply to any company, with no substantive disclosure about actual governance structures, risk management processes, or specific incidents. The statement that AFG 'recognizes the importance of assessing, identifying and managing material risks' is boilerplate acknowledgment rather than description of actual processes.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes - specifically how risks are identified, assessed, and monitored through various methods (threat intelligence, scans, testing). While the Director of Information Technology is mentioned as leading these processes, the paragraph does not describe the person's qualifications or credentials; it focuses on what the process does rather than who the person is.


reasoning: The paragraph primarily describes the company's cybersecurity program, systems, training, and incident response processes, with the CISO and COO mentioned as part of the governance structure overseeing these processes. While the CISO and COO qualifications are detailed, they support the program description rather than being the main focus, and applying the person-removal test leaves a coherent cybersecurity process disclosure.


reasoning: The paragraph describes governance structure—an oversight committee's role, its chair (CISO), and reporting relationship to another committee. This is governance-chain content explaining how oversight flows, not a description of the CISO's qualifications or credentials.


reasoning: The paragraph describes the board-level oversight structure for cybersecurity, detailing the Audit and Examination Committee's responsibilities and the Information Security Officer's reporting cadence to the committee.


reasoning: The paragraph describes the governance structure for board oversight—specifically how CISO and CIO inform the Board and Audit Committee about cybersecurity risks. This is about information flow upward to the board (oversight structure), not about officer qualifications.


reasoning: This paragraph describes the governance and oversight structure for cybersecurity - how the Board retains oversight rights while the General Partner manages operations, with delegation to the Investment Manager and reliance on Blackstone's cybersecurity program. The focus is on the organizational chain of oversight rather than specific processes or individual qualifications.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including a named committee (ERC), its composition and reporting lines, how cybersecurity risk is integrated into ERM, and a director's cybersecurity qualifications. The CISO is mentioned only incidentally as one of many senior leaders, not as the focus of the paragraph.


reasoning: This paragraph contains a negative materiality assertion ('we have not experienced any material cybersecurity threats or incidents in recent years'), which is a backward-looking materiality assessment that falls under Strategy Integration. The forward-looking disclaimer in the second sentence does not change the primary purpose.


reasoning: The paragraph primarily identifies the CTO and CISO with their specific qualifications (25 years of experience) and details the cross-functional team composition responsible for the Information Security program, making it about management roles rather than describing what the processes actually do.


reasoning: The paragraph describes the Information Security team's internal processes for reviewing and updating governance documents and maintaining a strategic cybersecurity plan, which constitutes risk management process disclosure rather than board governance structure.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, detailing how information flows from management (CFO and IT consultant) to the audit committee and then to the Board. This is a classic governance-chain paragraph focused on oversight reporting lines rather than individual qualifications or internal processes.


reasoning: The paragraph describes the board-level oversight structure, specifically the Audit Committee's responsibility for cybersecurity oversight and the reporting relationship from the CIO/CISO to the committee, which is a classic governance-chain disclosure.


reasoning: The paragraph contains a backward-looking materiality assessment stating that cybersecurity risks 'have not materially affected us, including our business strategy, results of operations or financial condition, to date,' which constitutes a materiality conclusion under Strategy Integration. The brief mention of past threats and breaches is generic without describing any specific incident.


reasoning: This paragraph is a cross-reference directing readers to the Risk Factors section (Item 1A) for cybersecurity risk information. It contains no substantive disclosure about governance, management, processes, incidents, or strategy—merely pointing elsewhere in the filing.


reasoning: This is a SPAC explicitly stating it has not adopted any cybersecurity risk management program or formal processes, which triggers the None/Other category per the SPAC-specific guidance, regardless of incidental mentions of board oversight or materiality conclusions.


reasoning: The paragraph describes the organizational structure for cybersecurity risk management oversight, identifying which internal teams are responsible for overseeing these processes, which constitutes internal process governance rather than board-level oversight or individual management qualifications.


reasoning: The paragraph describes the oversight structure for cybersecurity risk, with the Board providing oversight and the CFO having ultimate direction over the security governance structure.


reasoning: The paragraph contains a negative materiality assertion ('There have been no material cybersecurity threats and incidents incurred to-date'), which qualifies as a materiality assessment under Strategy Integration. The remainder consists of forward-looking disclaimers and generic risk warnings.


reasoning: The paragraph primarily describes the company's cybersecurity policies, standards, processes, and framework adoption (ISO, NIST), with brief Board oversight framing that does not detail governance structure, reporting lines, or information flow.


reasoning: The paragraph contains a materiality assessment in the form of a negative assertion ('we have not experienced a cybersecurity incident that we deemed to be material'), which qualifies as Strategy Integration. The generic IT-dependence language and cross-reference to risk factors are secondary elements.


reasoning: This paragraph contains only generic risk acknowledgment language stating that cybersecurity threats exist and could have a material adverse effect, without describing any governance structure, management roles, processes, incidents, or materiality assessments. The 'could have a material adverse effect' language is boilerplate speculation, not a materiality assessment.


reasoning: This paragraph contains generic IT-dependence language describing the importance of IT systems and types of data handled, without substantive cybersecurity disclosure content such as governance structure, risk management processes, incident details, or materiality assessments.


reasoning: The paragraph primarily describes the CSIRT's role in executing cybersecurity risk assessment and management processes, including reviewing initiatives, incident response planning, compliance, and training. Although the Director of IT's qualifications are mentioned, applying the person-removal test shows the process description stands alone—the Director is incidental to the main focus on team activities and processes.


reasoning: The paragraph primarily identifies the IT Lead and describes their qualifications (11 years of experience) and the external agency's expertise (8 years), which constitutes disclosure about personnel credentials and experience characteristic of Management Role.


reasoning: This paragraph is a SPAC disclosure explicitly stating the company has no business operations and has not adopted any cybersecurity risk management program or formal processes. Per the guidelines, SPACs and shell companies stating they have no operations or no formal processes are classified as None/Other, as the absence of a program is not a description of a program.


reasoning: The paragraph contains a negative materiality assertion ('has not experienced any material cybersecurity events'), which is a materiality assessment that triggers Strategy Integration. The generic risk warning and cross-reference are secondary to this conclusion.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, explaining how the board has delegated oversight to a subsidiary's Information Security Committee and how information flows back to the board through occasional updates.


reasoning: The paragraph describes the company's comprehensive approach to managing cybersecurity risks, including established policies, processes, and the Security Steering Group as a key component. While Board and Audit Committee oversight is mentioned briefly, the primary focus is on the internal risk management process and organizational structure rather than detailed governance mechanics.


reasoning: This paragraph contains generic forward-looking risk warnings describing what 'could' happen in hypothetical scenarios (data breaches, service disruption, IP theft, response costs). It provides no substantive disclosure about the company's actual governance, processes, incidents, or materiality assessments—only speculative risk language that could appear in any company's filing.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically the information flow from management to the board regarding incident notification and response decisions. While management is the grammatical subject, the purpose is describing the oversight chain and escalation process to the board.


reasoning: The paragraph describes management receiving briefings from a cybersecurity advisory firm to prepare them to assess and manage cybersecurity risks, which is an internal risk management process. The mention of third-party service providers having credentials is incidental, not the central topic of vendor oversight.


reasoning: This is a cross-reference paragraph directing readers to specific risk factor headings in Item 1A, not a substantive disclosure about governance, processes, or incidents. The materiality language describes what the referenced sections contain rather than stating a company conclusion.


reasoning: The paragraph contains a materiality assessment in the form of a negative assertion ('the Company has not detected a significant compromise, significant data loss or any material financial losses related to cybersecurity attacks'), which qualifies as Strategy Integration. However, this statement is embedded within predominantly generic risk warning language about threat landscapes and future risks, creating some ambiguity about the paragraph's primary purpose.


reasoning: This paragraph describes the oversight structure and information flow from the CISO to the Risk Committee, including briefing cadence and report contents, which is characteristic of Board Governance disclosure.


reasoning: The paragraph describes the company's internal cybersecurity organizational structure, security controls, and processes for managing cyber risks. While CISO and CIO are mentioned, they appear as part of describing the cybersecurity program structure, not as profiles of individuals' qualifications.


reasoning: This paragraph describes the governance structure for cybersecurity oversight—specifically how the Director of Compliance reports to the Board and what information flows upward. The focus is on the oversight/reporting mechanism rather than the officer's qualifications or internal processes.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity - reporting lines from IT leadership to the Audit Committee and Board, the role of the ERM Committee, and oversight mechanisms including internal audit, ARB, and PMO. The focus is on how oversight flows through the organization rather than on specific management qualifications or operational processes.


reasoning: The paragraph describes the oversight structure for cybersecurity, including how responsibility is shared among the Board, CFO, VP of Internal Audit, and IT resources, and how information flows from IT through the CFO to the Board. This is governance-chain content describing how oversight is exercised.


reasoning: The paragraph describes the composition of the Technology and Operations Committee, which is a governance structure for cybersecurity oversight. The focus is on the committee's membership structure rather than individual management qualifications.


reasoning: The paragraph describes a management-level governance committee (Bank Technology Governance Committee), its composition, responsibilities for approving cybersecurity policies, and reporting structure—this is oversight structure describing how information flows through the governance chain.


reasoning: The paragraph describes the governance structure for cybersecurity oversight - specifically how the Sponsor's Board of Directors receives periodic reports from BlackRock on cybersecurity matters, establishing the information flow and oversight chain despite the Trust having no direct employees.


reasoning: The paragraph describes the company's internal cybersecurity risk management process, including threat monitoring, incident assessment, response procedures, and the reporting chain. Applying the MR vs RMP decision chain: the VP of Tech appears as grammatical subject but the person-removal test confirms the process stands alone without person-specific details (no qualifications, certifications, or career history). The governance chain is a component of the process description, not the primary focus.


reasoning: The paragraph describes the governance structure through two named committees (IT Steering Committee and IT Subcommittee), their compositions, meeting cadence, and oversight responsibilities for cybersecurity risks, with board representation on the IT Steering Committee.


reasoning: The paragraph contains materiality assessments: a backward-looking negative assertion that risks have not materially affected the company, and forward-looking assessments using the SEC qualifier 'reasonably likely to materially affect.' This is a materiality conclusion rather than a description of governance, processes, or an actual incident.


reasoning: The paragraph contains explicit materiality assessments: a negative assertion that the company has not experienced material cybersecurity incidents, and a forward-looking statement that no cybersecurity threats are reasonably likely to materially affect the business. These are classic Strategy Integration disclosures per the guidelines.


reasoning: The paragraph describes the company's internal incident response and disclosure processes, including the structure of the crisis management team and the materiality evaluation process. This is a clear Risk Management Process describing how incidents are managed and evaluated rather than board oversight or individual qualifications.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, identifying the CISO and Cybersecurity Committee as the bodies responsible for overseeing policies and staying informed about cybersecurity processes. This is oversight structure, not a description of the CISO's qualifications or the risk management process itself.


reasoning: The paragraph describes the cybersecurity team structure, responsibilities, and committee governance. Applying the person-removal test: deleting the Senior Director's qualifications leaves a coherent disclosure about team responsibilities and the security steering committee's composition and activities, confirming RMP. The qualifications are incidental to the primary purpose of describing the organizational structure and processes.


reasoning: The paragraph primarily describes the cybersecurity program activities—defining work plans, setting improvement objectives, incorporating third-party assessments, and implementing system investments. While the Director of IT and their qualifications are mentioned, the person-removal test confirms the process content stands alone coherently, making this RMP rather than Management Role.


reasoning: This paragraph is a cross-reference directing readers to risk factors in Item 1A, not substantive cybersecurity disclosure. Under the guidelines, cross-references pointing elsewhere without concluding materiality assessments are classified as None/Other.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk, detailing how the Board, Audit Committee, and officers (VP of Strategic Initiatives and CFO) interact in the oversight chain. This is a classic Board Governance disclosure focused on reporting lines and oversight responsibilities rather than individual qualifications or internal processes.


reasoning: This paragraph describes the governance and oversight structure for cybersecurity risk, outlining how oversight flows from the board to management to the VP of Operations, and how incidents are reported upward to the audit committee and board.


reasoning: The paragraph contains a negative materiality assessment stating the company is not aware of any cybersecurity threats or incidents that have materially affected business operations, which is a backward-looking conclusion about business/financial impact. The forward-looking disclaimer and cross-reference are secondary to this materiality assertion.


reasoning: The paragraph's primary content is a materiality assessment stating the company's conclusion that no cybersecurity threats have materially affected or are reasonably likely to materially affect them—this backward-looking and forward-looking assessment with SEC qualifier is the definition of Strategy Integration. The remainder is generic risk disclaimer and a cross-reference to Item 1A.


reasoning: The paragraph describes the company's internal processes for monitoring cybersecurity threats and incident response, with the InfoSec Director serving as the implementer rather than the primary subject of the disclosure. Applying the MR vs RMP decision chain: person-removal test yields a coherent process description (monitoring, audits, incident response plan), and no specific qualifications like certifications or years of experience are mentioned.


reasoning: This is a governance-chain paragraph describing the oversight structure from Board through Risk Committee and Cybersecurity Committee to CISO, with CISO qualifications provided to explain who leads the Cybersecurity Committee. The specific years of experience (20) plus multiple named certifications (CISSP, CISM, GLAW, GSEC) constitute two or more hard verifiable facts per the calibration examples.


reasoning: The paragraph describes the governance structure for cybersecurity incident oversight, including a crisis management team that reports to the Board and a disclosure committee that evaluates materiality. While it touches on incident response processes, the primary purpose is explaining how oversight and disclosure decisions flow through organizational structures to the Board.


reasoning: This is a governance-chain paragraph describing how cybersecurity oversight flows from the Board through the CIO, including reporting cadence and support structure. Per the guidelines, governance-chain paragraphs are classified as Board Governance even when officers appear as grammatical subjects, because the purpose is describing oversight structure. The CIO's qualifications are mentioned to establish the credibility of the oversight structure, not as the primary focus.


reasoning: The paragraph describes the governance structure and oversight responsibilities of a named management-level committee, including its role in the reporting chain to the Board's Compliance and Information Security Committee. This is a governance-chain paragraph explaining how oversight flows through the organization.


reasoning: The paragraph primarily describes the governance structure for incident response, stating that the Management Team will report to the Board of Directors during cybersecurity incidents. While it includes a negative assertion about incidents and acknowledges limited resources, the core disclosure is about oversight and reporting structure. No cybersecurity-specific roles, named committees, frameworks, or other qualifying facts are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph contains a materiality assessment in the form of a negative assertion ('To date, these threats and attacks have not resulted in a material cybersecurity incident'), which qualifies as Strategy Integration per the guidelines. The remainder of the paragraph consists of generic risk warnings and a cross-reference, with no substantive disclosure about governance, processes, or specific incidents.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including two named non-generic committees (ERM committee and cybersecurity committee) and the CTO's role within that structure. This is a governance-chain paragraph focused on oversight structure rather than management qualifications.


reasoning: This paragraph contains generic risk factor language about cybersecurity threats, boilerplate speculation about potential material adverse effects, and a cross-reference to Item 1A. It lacks substantive disclosure about the company's specific governance structure, risk management processes, or actual incidents.


reasoning: The paragraph focuses on CIO identification, qualifications (30 years experience, previous roles at large public companies), and reporting lines to the ISMS Committee. The ISMS Committee is a management-level committee, not a board committee, and the detailed qualifications content triggers the MR tiebreaker.


reasoning: This paragraph is a materiality assessment—a negative assertion that the company is not aware of any system weaknesses or malware that would materially affect operations. This fits the Strategy Integration category for materiality conclusions.


reasoning: The paragraph describes a management-level committee structure that oversees the cybersecurity program, including its composition and oversight activities (quarterly reviews, strategy approval). This is governance structure at the management level, not board-level oversight, and not about individual qualifications, making Risk Management Process the best fit among available categories.


reasoning: The paragraph describes the company's internal cybersecurity processes including monitoring, security measures, audits, and incident response planning. Applying the MR vs RMP test, removing the named roles leaves a coherent process description, so this is RMP not Management Role. CISO and CIO are cybersecurity-specific titles that establish Firm-Specific, but there are no dates, dollar amounts, headcounts, named firms, or named tools to reach Quantified-Verifiable.


reasoning: The paragraph primarily describes the company's cybersecurity program structure, including the incident response team composition, governance roles, GRC platform, and third-party support. While it mentions personnel qualifications (over 50 years combined experience), the focus is on how the program operates rather than detailed individual credentials, making Risk Management Process the appropriate category.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including the three lines of defense model, testing, assessments, monitoring activities, and third-party risk management. The VP, ISS is mentioned as leading the function but without qualifications or career history, so the focus is on what the program does rather than who the person is.


reasoning: The paragraph describes the governance chain from the Audit and Risk Committee through management (CIO, Senior Director of Information Security) to processes and back up via reporting, making Board Governance the primary category despite mixed content including management qualifications, risk management processes, and a materiality assessment.


reasoning: The paragraph describes the governance structure for cybersecurity oversight - how the Committee reports to the Board, how management briefs the Board on cyber risk, and the management team's role in the oversight chain. While management roles are named, they are mentioned in the context of their place in the governance structure rather than their individual qualifications or credentials.


reasoning: This paragraph contains generic risk warning language about potential cyber threats and their possible consequences, without describing actual governance structures, processes, incidents, or materiality assessments.


reasoning: The paragraph describes the company's internal cybersecurity processes—risk assessments, implementing safeguards, monitoring effectiveness—and the delegation structure for managing these processes. Applying the MR vs RMP decision chain, removing the named roles leaves a coherent process description, and no qualifications (certifications, years of experience, career history) are mentioned, so this is RMP not MR.


reasoning: The paragraph identifies the Director of IT as the individual responsible for cybersecurity and describes their experience and focus areas, which is primarily about WHO manages cybersecurity rather than describing the risk management process itself.


reasoning: This paragraph contains only generic forward-looking risk language about potential consequences of IT system compromise, with no substantive disclosure about governance structure, management roles, processes, or actual incidents.


reasoning: The paragraph contains a materiality assessment in the form of a negative assertion ('We have not experienced a cybersecurity incident that resulted in a material adverse impact'), which is a backward-looking conclusion about cybersecurity's effect on the business. The subsequent forward-looking risk language is generic boilerplate speculation, not an assessment.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically how the CEO informs the Audit Committee about cybersecurity risks through regular briefings. This is Board Governance as it describes the oversight chain and information flow to the board committee, even though the CEO (a generic C-suite role) is the grammatical subject.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach, including ERM integration and management's oversight and reporting processes. While it mentions reporting to the board, the primary focus is on the internal risk management structure rather than board-level governance.


reasoning: The paragraph describes the IT Department and security team's responsibilities for managing cybersecurity risk, including prevention, detection, mitigation, and remediation of incidents. While a VP of IT Services is mentioned with a reporting line to the CSO, the paragraph's primary focus is on what the organizational unit does rather than the person's qualifications, so it falls under Risk Management Process per the person-removal test.


reasoning: This paragraph describes the oversight structure and information flow from management to the board committee, including reporting cadence (semi-annual and annual) and topics covered. The VP IT appears as the grammatical subject, but the purpose is describing governance/reporting structure, not the individual's qualifications.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including Board responsibility for oversight and the reporting chain where the Director of Information Technology reports to the Board on cybersecurity threats, defensibility measures, and control effectiveness. While it includes RMP elements (risk assessments, audits), the primary focus is on how oversight flows from the Board through management.


reasoning: The paragraph describes the Company's cybersecurity program structure and its key focus areas, with governance and collaborative approach as components of that program. While the governance section describes oversight structure, the primary subject is the cybersecurity program itself and how it operates across multiple dimensions.


reasoning: The paragraph is primarily about the qualifications and credentials of cybersecurity personnel, listing specific professional certifications held by information security staff and industry group affiliations. This fits Management Role because the focus is on who the personnel are in terms of their credentials and training rather than describing a risk management process or governance structure.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk, including the reporting chain from a Co-President to the Audit Committee to the Board of Trustees. This is a classic Board Governance disclosure focused on oversight structure and information flow, not on the qualifications of the individual or internal risk management processes.


reasoning: The paragraph describes the CISO's and CTO's responsibilities for cybersecurity processes (Incident Response Plan, training, logging incidents, threat information sharing) rather than their qualifications or career history. Applying the MR vs RMP decision chain: persons are subjects (Step 1 signal), but removing role names leaves coherent process descriptions (Step 2), and no qualifications are present (Step 3), so RMP applies. The CISO and CTO are named as part of process descriptions, not as the primary focus of who they are.


reasoning: The paragraph contains a negative assertion about cybersecurity incidents (stating no incidents occurred during 2024), which qualifies as a materiality-type conclusion under Strategy Integration. The year reference provides one specific fact.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk through two named management-level committees (OROC and IT Steering Committee), including their leadership, composition, and meeting cadence. This is oversight structure rather than individual qualifications or risk management processes.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes—implementation, integration with overall risk strategy, and review of security assessments. While officers are named, they are mentioned as part of a process description, not to establish credentials or qualifications, and the titles (COO, Senior VP for Operations) are not cybersecurity-specific roles.


reasoning: The paragraph describes the company's internal risk management framework and committee structure for administering risk exposures, which is a Risk Management Process disclosure. The Executive Director of Information Technology is a cybersecurity-relevant IT leadership role that qualifies as a firm-specific fact, but without a second hard verifiable fact, the specificity remains Firm-Specific.


reasoning: The paragraph contains materiality assessments—a negative assertion that no material cybersecurity incidents were identified and statements that threats have not materially affected and are not reasonably likely to materially affect the business—which are explicitly Strategy Integration content per the guidelines.


reasoning: The paragraph describes the governance structure and information flow from IT providers through COO/CFO to the Board, which is a classic Board Governance disclosure about oversight structure and reporting lines.


reasoning: This paragraph is a cross-reference to Item 1A Risk Factors, quoting risk factor language about cybersecurity risks without providing any substantive disclosure about governance, processes, or incidents. It directs readers elsewhere rather than presenting original content.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk, including how the Board and Audit Committee exercise oversight and how management (CEO/CFO) implements the program. All named roles (CEO, CFO, Audit Committee) are generic entities that appear on the NOT list, and no frameworks, specific dates, or verifiable facts are present.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and mitigation processes, including who leads them and how monitoring and reporting work. The third-party partner's experience is mentioned incidentally as part of describing the process structure, not as the primary focus of the disclosure.


reasoning: The paragraph describes the governance chain and oversight structure for cybersecurity, including how the Committee reports to the Board, how management briefs the Board, and management's role in supervising the cybersecurity program. While management and IT staff are mentioned, they appear as part of describing the oversight structure rather than as standalone personnel qualifications.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically the Materiality Assessment Team (MAT) and its role in the oversight chain from officers (CIO, CISO) to the Risk Committee. This is governance structure describing how information flows upward for materiality determination.


reasoning: This is a generic statement about management being informed of cybersecurity risks without describing any specific governance structure, management role, risk management process, or materiality assessment. It contains no substantive disclosure unique to the company.


reasoning: This paragraph contains only generic IT-dependence language and a boilerplate risk warning ('could potentially have a material impact'), which is speculative language that appears in virtually every 10-K and does not constitute substantive cybersecurity disclosure or an actual materiality assessment.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including management committees established by the board, their composition, meeting cadences, and how information flows upward from the CISO through committees to the board's Innovation and Technology Committee.


reasoning: The paragraph primarily describes the company's cybersecurity risk management process, including its integration with ERM and program components. The CTO and CISO are named as part of the governance structure overseeing the process, not as the primary focus, and the person-removal test yields coherent process content. The qualifications mention at the end is incidental supporting detail rather than the paragraph's main purpose.


reasoning: This paragraph contains only generic forward-looking risk warnings about potential cybersecurity incidents and their consequences, without describing any actual governance structure, management roles, specific processes, or materiality assessments. The language is speculative ('could potentially result,' 'may not effectively prohibit') and could apply to any company.


reasoning: The paragraph describes the third-party consultant and their SOC Manager who oversee the company's cybersecurity, including their qualifications (technical certifications, extensive background in IT infrastructure, risk mitigation, and incident response planning). This is about WHO manages cybersecurity rather than the processes themselves, fitting Management Role.


reasoning: The paragraph describes the governance/oversight structure for cybersecurity risk, including how the Board exercises oversight through its Risk Committee and the reporting chain from Director of Information Security to CIO to the Board's Risk Committee.


reasoning: The paragraph contains a materiality assessment in the form of a negative assertion ('we have not experienced any material cybersecurity incidents'), which the guidelines explicitly classify as Strategy Integration. The language is entirely generic with no named roles, frameworks, dates, or other firm-specific details.


reasoning: This paragraph describes the company's internal cybersecurity processes - risk assessment, security controls, and incident response - which is the core subject matter of Risk Management Process. No specific personnel, frameworks, or unique identifiers are mentioned.


reasoning: The paragraph describes a governance structure—a named Cybersecurity Committee including its composition, oversight role, and how it works with the Board and Executive Leadership Team. This is governance-chain disclosure about how oversight is exercised, not individual officer qualifications.


reasoning: The paragraph describes the company's internal processes for cybersecurity risk communication and incident reporting structure, including regular meetings and escalation protocols. This fits Risk Management Process as it describes how the company manages and responds to cybersecurity risks operationally.


reasoning: The paragraph describes the governance structure for how the ERMC (a named committee) receives cybersecurity information through the CISO's supervision, which is oversight structure rather than a description of the CISO's qualifications or internal processes.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, detailing how security metrics and reports flow upward from the Chief Security Office to the Management Board and Supervisory Board's Committee, including reporting cadence (quarterly, ad hoc, regular updates).


reasoning: This paragraph contains only generic threat landscape language and a high-level statement about expending resources on cybersecurity, without describing any specific governance structure, management role, risk management process, or materiality assessment. It is standard IT-dependence language that could appear in any company's filing.


reasoning: The paragraph describes the governance structure for cybersecurity risk management through a management-level committee, including its composition and oversight activities. Applying the MR vs RMP decision chain, removing person details leaves a coherent description of the committee's oversight role, and no qualifications or credentials are provided, so this is RMP not Management Role.


reasoning: Paragraph describes the governance structure and information flow for cybersecurity oversight: IT risk committee reports to management risk committee, which reports to the Board. The focus is on oversight structure and reporting lines rather than individual qualifications or specific risk management processes.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including program reviews, audit procedures, and annual risk assessments using a recognized framework.


reasoning: This paragraph contains only a generic acknowledgment of past cyber-attacks without any incident details and a forward-looking risk warning about potential future harm. It lacks substantive disclosure about governance, processes, specific incidents, or materiality assessments—only boilerplate risk language that could appear in any company's filing.


reasoning: This paragraph contains only a forward-looking generic risk disclaimer ('may have an adverse effect') and a cross-reference to the Risk Factors section. Per guidelines, generic risk warnings are boilerplate speculation, not materiality assessments, and cross-references pointing elsewhere are classified as None/Other.


reasoning: The paragraph describes the company's internal cybersecurity processes including risk assessments, safeguard implementation, and monitoring. The mention of an IT consultant and reporting structure describes who manages the process, not qualifications or credentials of a specific person.


reasoning: The paragraph identifies two named roles managing the risk assessment process and includes specific years of experience (25 years and 15 years), which triggers Management Role under the qualifications tiebreaker. The two quantified experience durations constitute hard verifiable facts for Quantified-Verifiable specificity.


reasoning: The paragraph primarily describes the company's cybersecurity program structure, ERM integration for cyber risk management, and the organizational framework for identifying and assessing risks. While officer roles are mentioned, they serve to explain how the program operates rather than focusing on individual qualifications.


reasoning: The paragraph describes the Cyber Incident Management Team (CIMT), its composition, leadership structure, and incident response responsibilities, which constitutes the company's internal process for managing cybersecurity incidents. The focus is on the team's operational role in incident response rather than individual qualifications or board oversight structure.


reasoning: The paragraph primarily describes the governance structure for cybersecurity oversight, including reporting lines (CISO and CRO reporting to Board and Risk and Technology Committee quarterly), risk escalation through the ERM framework, and committee composition. While it includes CISO qualifications, these are embedded within the broader governance description rather than being the primary focus.


reasoning: The paragraph describes the company's internal risk assessment process, including the Cybersecurity Council's quarterly reviews and executive management's role in assessing material cybersecurity risks. This is a governance-chain description focused on how risk assessment processes work, not on individual qualifications.


reasoning: The paragraph describes the composition of the ISO Committee, identifying multiple executives by title and providing specific qualification details for the Chief Risk Officer (25+ years of experience). While it describes a governance structure, the ISO Committee is a management-level committee rather than a board committee, and the paragraph includes person-specific qualification content, placing it in Management Role rather than Board Governance.


reasoning: This paragraph contains generic IT-dependence language and forward-looking risk warnings without substantive disclosure of governance structures, management roles, risk management processes, or materiality assessments. It could appear in any company's filing unchanged, with no named frameworks, roles, dates, or firm-specific details.


reasoning: The paragraph describes the company's internal risk management framework, specifically how the ERMC integrates cybersecurity considerations into enterprise-wide risk assessment and monitoring processes through quarterly reviews and action plans from the CISO.


reasoning: The paragraph describes the company's internal cybersecurity processes including monitoring, prevention, detection, vulnerability identification through audits, and incident response planning. Although the Director of Infrastructure is the grammatical subject, applying the Person-Removal Test shows the process content stands alone coherently, making this a Risk Management Process rather than Management Role.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including how the Board and Audit Committee receive information from management (CIO and HIS) through quarterly meetings. This is a classic governance-chain disclosure showing information flow upward to the board.


reasoning: This paragraph contains only generic forward-looking risk language describing what 'could' happen in a hypothetical cyber-attack scenario, with no substantive disclosure about the company's actual governance, processes, incidents, or materiality conclusions.


reasoning: The paragraph contains a negative materiality assertion ('we have not experienced any material cyber breaches'), which is explicitly classified as Strategy Integration per the guidelines. The remainder describes generic ongoing policy review without specific details.


reasoning: The paragraph describes the internal management structure for overseeing cybersecurity risks through the Information Security Steering Committee (ISSC), including its composition and oversight responsibilities. This is an internal process description rather than board governance, specific individual qualifications, or third-party risk management.


reasoning: The paragraph primarily describes management's role in cybersecurity risk management processes including continuous monitoring, threat analysis, policy implementation, and training. While the CTO and their qualifications are mentioned, they are incidental to the process description—the paragraph is not fundamentally about who the person is, but rather what the process does.


reasoning: The paragraph describes the Fund's internal process for identifying and overseeing cybersecurity risks from third parties, with the CCO and Investment Adviser personnel mentioned as part of this oversight structure rather than as the primary focus. While third-party dependencies are mentioned, the disclosure centers on the internal oversight process rather than vendor requirements or contractual standards.


reasoning: The paragraph describes the oversight structure and information flow from IT management to the Audit Committee, which is the governance chain for board-level cybersecurity oversight. No specific facts qualify under the IS list—'Manager of Information Technology' is a generic IT title rather than a cybersecurity-specific role like CISO, and 'Audit Committee' is a standard committee that does not count as firm-specific.


reasoning: The paragraph describes the CISO's role in executing the company's cybersecurity program (policies, procedures, training, access reviews, monitoring) rather than focusing on credentials or career history. Under the MR vs RMP test, removing the person/role titles leaves process descriptions that are the paragraph's primary substance, making this Risk Management Process.


reasoning: The paragraph contains a backward-looking negative materiality assertion ('we did not experience a material cybersecurity incident during the year ended December 31, 2024'), which is explicitly classified as Strategy Integration. The cross-reference to risk factors is secondary to the primary materiality conclusion.


reasoning: The paragraph opens with a materiality assessment ('we believe the risk of significant cybersecurity incidents is minimal'), which is a conclusion about cybersecurity risk exposure. The CEO oversight mention and basic software description support this risk assessment but contain no specific facts—CEO is generic C-suite, and 'standard commercial software' with 'password protection and data encryption' are generic terms applicable to any small company.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, focusing on how the Audit Committee receives briefings from the Chief Operating Officer, participates in strategic decisions, and conducts annual reviews of the cybersecurity program. All named entities (COO, Audit Committee) and cadences (once per year, annual) fall on the exclusion list, yielding no qualifying specific facts.


reasoning: The paragraph opens with a negative materiality assertion ('We have not experienced cyber-attacks or other malicious activities that materially disrupted our business'), which qualifies as a materiality assessment under Strategy Integration. The remaining content is generic forward-looking risk language and a cross-reference to Item 1A, but the opening statement is a clear materiality conclusion.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, detailing how management receives monthly briefings and the Board receives quarterly briefings as part of its oversight functions. CIO is a cybersecurity-specific title that qualifies as a firm-specific fact.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including team structure, training, testing, audits, and third-party engagement. The CISO title qualifies as a firm-specific fact, but no named frameworks or multiple hard verifiable facts are present.


reasoning: This is a generic forward-looking risk disclaimer stating what 'could' happen, not a substantive disclosure about governance structures, management roles, internal processes, or actual incidents. It falls under the None/Other category as boilerplate speculation.


reasoning: The paragraph primarily describes the governance and oversight structure for cybersecurity - identifying that the CEO and Interim CFO handle incidents while the full board retains oversight responsibility without delegation, and establishing the reporting chain from management to the board. The materiality assessment in the final sentence is secondary to the governance structure description.


reasoning: This paragraph is a forward-looking disclaimer with generic risk warning language ('reasonably likely to materially affect us') and a cross-reference to Item 1A Risk Factors, containing no substantive disclosure about the company's actual cybersecurity program, governance, or incidents.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, beginning with Board responsibility and delegating through Audit Committee, CFO, and IT resources to the Director of IT. This is a governance-chain paragraph where the purpose is explaining how oversight flows, making it Board Governance even though officers and personnel are mentioned.


reasoning: This is a forward-looking generic risk warning with conditional language ('if realized'), which falls under boilerplate speculation rather than a materiality assessment. The paragraph contains no substantive disclosure about governance, processes, incidents, or actual business impact.


reasoning: The paragraph describes the Cybersecurity Steering Committee's composition and its day-to-day responsibility for monitoring and managing cybersecurity risks, as well as integrating cybersecurity risk management practices with business processes. This is an internal risk management structure rather than board-level governance or individual officer qualifications.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically how management reports upward to two committees to enable board-level assessment of cybersecurity program effectiveness. The Enterprise Risk and Compliance Committee is a named non-generic committee that distinguishes this disclosure from standard boilerplate.


reasoning: This is a negative assertion about cybersecurity incidents - the company states it has not experienced any incidents that resulted in operational interruptions or system breaches, which constitutes a materiality assessment under Strategy Integration.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for cybersecurity risk disclosures, rather than making substantive disclosures about governance, processes, incidents, or materiality conclusions itself.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, specifically the reporting chain from the ISO to management and the BRCC, with escalation procedures to the full Board. This is classic Board Governance content focused on how information flows upward through the oversight structure.


reasoning: The paragraph describes the oversight structure for cybersecurity, specifically how management oversees cyber risks and the flow of information to the CEO and Board through periodic updates. This is governance-chain content focused on how oversight is exercised.


reasoning: This paragraph contains only generic IT-dependence language describing the importance of data security and IT systems to business operations, with no substantive cybersecurity disclosure content such as governance, processes, incidents, or materiality assessments.


reasoning: The paragraph describes the organizational structure for leading and supervising the cybersecurity risk management program, focusing on how the program operates rather than on specific individuals' qualifications. Applying the person-removal test, the remaining text coherently describes program leadership and supervision, indicating Risk Management Process.


reasoning: The paragraph describes the company's internal ERM program structure and how cybersecurity risk is managed through that process, with named roles mentioned incidentally as part of the process description rather than as the primary focus with qualifications or credentials.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including the Cyber Incident Response Team structure, the Cybersecurity Plan's protocols for incident prevention and response, and monitoring/reporting mechanisms. This is core RMP content about how the company manages cyber risks internally.


reasoning: The paragraph is primarily about WHO comprises the cybersecurity team and their qualifications, including a named cybersecurity-specific role (Director of Cybersecurity) and quantified combined experience (over 85 years), which is MR-specific content per the qualifications tiebreaker in Step 3.


reasoning: This paragraph contains generic regulatory compliance language with forward-looking risk warnings ('could result in financial penalties') but no substantive disclosure about the company's actual cybersecurity program, governance structure, processes, or materiality assessments. It is boilerplate speculation that could appear in any company's filing.


reasoning: The paragraph describes the company's risk management process designed to identify, prioritize, monitor, and mitigate risks, which is the primary substantive content. However, the disclosure is entirely generic with no specific frameworks, named roles, or unique details that would distinguish it from any other company's filing.