reasoning: The paragraph primarily describes the oversight structure for cybersecurity: a management committee oversees strategy and processes, receives reports, evaluates incidents, and escalates matters to the Audit Committee or Board. Although specific officers are named, the focus is governance flow and oversight responsibilities rather than their qualifications or the underlying risk processes themselves.


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is only a cross-reference to risk factor disclosures in Item 1A and does not provide substantive cybersecurity governance, process, incident, or materiality disclosure itself. Although it contains materiality language, it merely points elsewhere rather than stating a company conclusion in this paragraph.

provider: openai

stage: benchmark


content_category: Risk Management Process

category_confidence: medium

reasoning: The paragraph primarily describes the company's internal management structure for assessing and managing cybersecurity and related operational risks, which makes it a risk management process disclosure rather than a management-biography paragraph. It is firm-specific because it identifies a named committee and its specific cross-functional composition.


content_category: Strategy Integration

reasoning: The paragraph's main substance is a materiality assessment stating that no cybersecurity incident has been identified as having a material impact on the business or financial statements. The remaining language is generic forward-looking risk cautionary language without incident-specific or company-specific details.


reasoning: The paragraph is primarily about the company's internal risk management process: how the ERMC receives risk assessments and information security action plans and incorporates cybersecurity into enterprise risk decision-making. Although specific roles are mentioned, the focus is not on qualifications or identity of personnel, but on the process itself.


content_category: Board Governance

reasoning: The paragraph primarily describes the oversight structure and reporting flow for cybersecurity matters—from the ISO to management and the BRCC, with escalation to the full Board—so it is Board Governance. It includes firm-specific governance details such as a cybersecurity-specific role and a named committee, but no two hard verifiable facts needed for Quantified-Verifiable.


specificity_confidence: medium

reasoning: Although the paragraph names the SVPF and Director of IT, its main substance is the company's process for identifying, assessing, and managing cybersecurity risk through monitoring, tools, scans, audits, and threat assessments. Removing the titles still leaves a coherent description of internal risk management activities, so this is Risk Management Process rather than Management Role.


reasoning: This paragraph is a generic statement about being subject to cybersecurity-related regulations and possible consequences of non-compliance, without describing governance, management roles, processes, third-party oversight, incidents, or a materiality assessment. It is non-substantive boilerplate rather than a specific cybersecurity disclosure.


reasoning: The paragraph primarily describes the company’s cybersecurity assessment and management processes and the responsibilities involved in running them, rather than focusing on the qualifications or identity of specific individuals. The listed titles do not provide qualifying firm-specific cybersecurity facts under the extraction rules.


reasoning: The paragraph primarily describes the company's internal cybersecurity oversight and response process—how a management committee and multidisciplinary teams monitor and address cyber threats and incidents. Although it identifies a named committee and role, it does not focus on board-level oversight or on the qualifications of a particular officer.


reasoning: The paragraph is primarily about how the company runs its cybersecurity risk management program—who leads it and how internal personnel and consultants are supervised—rather than describing board oversight or the qualifications of a specific officer. The cross-functional team composition makes it firm-specific.


reasoning: The paragraph primarily describes the escalation and oversight structure for significant cybersecurity threats, including when matters move from management to the Risk Committee or Board, which makes it a governance-chain disclosure. Although management roles are named, the focus is on how oversight and escalation operate rather than on individual biographies.


reasoning: The paragraph is primarily about oversight structure and upward reporting on cybersecurity matters to senior leadership and the Board, which fits Board Governance. It contains only generic actors and cadences, with no qualifying firm-specific cybersecurity roles, named committees, frameworks, dates, or other specific facts.


reasoning: The paragraph primarily describes the company’s internal process for identifying, assessing, and managing cybersecurity threats through monitoring, evaluation, and escalation procedures. Although the CFO is mentioned, the substance is about the risk management process rather than the CFO’s qualifications or role profile.


reasoning: This is a generic forward-looking risk warning that a cyber incident affecting the company, customers, or suppliers could harm operations. It does not describe an actual incident, a management or board role, or any concrete risk management or third-party oversight process.


reasoning: The paragraph primarily describes the oversight structure and reporting flow between management and the Board regarding cybersecurity risk, which is a governance-chain disclosure. It does not identify any cybersecurity-specific roles, named committees, frameworks, dates, or other firm-specific facts.


reasoning: The paragraph primarily describes the oversight structure for cybersecurity risk: the board is responsible for oversight and executive officers report material incidents upward to the board. Although it mentions the CEO's experience, that detail is incidental and does not change the paragraph's main focus from governance to management qualifications.


reasoning: This paragraph is generic IT-systems importance language describing business dependence on data integrity, privacy, availability, and security, without discussing governance, management roles, risk processes, third-party oversight, incidents, or materiality assessments. It contains no cybersecurity-specific facts or firm-unique details.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management structure and process, including how cyber risk is handled within ERM and by the Information Security Team. Although roles are named, the focus is on the operation of the risk management process rather than qualifications or biographies of specific officers.


reasoning: The paragraph primarily describes the company’s internal cybersecurity management functions—risk assessment, security controls, and incident response—so it is best classified as Risk Management Process. Although an information technology manager is mentioned, the focus is on what the team does rather than the manager’s identity or qualifications.


reasoning: The paragraph primarily describes the company's internal cybersecurity program and how the Cybersecurity Team maintains it, monitors technology developments, and oversees training. Although specific officers are identified, they are presented as part of the operating process rather than for their qualifications or biographies.


reasoning: The paragraph primarily describes the company's internal process for reviewing cybersecurity risks and determining material or reasonably likely material cyber risks at the management level. Although specific roles are named, the focus is on how risk review and assessment are carried out rather than on board oversight or the qualifications of those individuals.


reasoning: The paragraph primarily describes the company's cybersecurity oversight structure—management acting under the CEO with oversight from the Board and Audit Committee—rather than detailing a specific internal risk process or the qualifications of a cybersecurity officer. It contains no qualifying firm-specific facts because the roles and entities mentioned are generic and the outside consultants are unnamed.


reasoning: The paragraph primarily describes the oversight structure and reporting flow for cybersecurity risks from management up to board-level bodies, which is board governance. Its only qualifying specific fact is the named Enterprise Risk and Compliance Committee; the Audit Committee is too generic to count.


reasoning: The paragraph primarily describes the oversight structure and information flow for cybersecurity risk, with the Board and Audit Committee receiving updates from management. Although management responsibilities are mentioned, the main purpose is governance oversight rather than detailing a distinct risk process or management qualifications.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management and incident response process, including monitoring, response, remediation, and materiality evaluation. Although management roles are mentioned, the focus is not on who they are or their qualifications, but on how the process operates.


content_category: Management Role

reasoning: The paragraph is primarily about the personnel responsible for cybersecurity execution and their qualifications, especially the identified roles and the team's accumulated experience. Although it mentions implementation of the cybersecurity program, the emphasis is on who the people are and their expertise rather than the process itself.


reasoning: The paragraph’s main point is a backward-looking assessment that the company has not experienced cybersecurity incidents resulting in business interruption or system breaches, which fits Strategy Integration rather than describing a governance structure or risk process. It includes one qualifying specific fact—a precise date reference—making it Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph primarily describes the company's internal cybersecurity management activities and processes—setting objectives, allocating resources, overseeing risk assessments, incident response, and compliance—rather than identifying specific individuals or board oversight structure. It contains no qualifying firm-specific facts, named frameworks, dates, tools, committees, or other verifiable details.


reasoning: The paragraph is centered on the internal group responsible for cybersecurity and emphasizes that group's qualifications and expertise, especially its combined years of experience. Although it mentions activities like remediation and training, the main thrust is who holds responsibility and why they are qualified, which fits Management Role best.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk management structure within its ERM process, including how cyber risk is identified and managed. Although specific roles are named, the focus is on the process and organizational arrangement rather than the qualifications of particular individuals.


reasoning: The paragraph is primarily about the company's internal cybersecurity risk management structure and responsibilities—day-to-day monitoring, management, and integration of cyber risk practices into business processes—rather than board oversight or an individual's qualifications. It includes firm-specific facts through the named Cybersecurity Steering Committee and the cybersecurity-specific CISO role.


reasoning: The paragraph is primarily about oversight structure and reporting flows: the Board oversees cybersecurity and receives updates from management roles and external experts. Although it mentions operational practices, the central focus is governance and how cybersecurity information is escalated to the Board.


reasoning: The paragraph primarily describes the company's cybersecurity processes—ongoing monitoring, system audits, penetration testing, and incident response planning. Although the CIO is mentioned, the text is about how the program operates rather than the CIO's qualifications or identity.


reasoning: The paragraph primarily describes the company’s internal cybersecurity response and monitoring process, including how the IRT and IT leadership implement and oversee prevention, detection, mitigation, remediation, and incident response activities. Although it mentions reporting to the Board, that is incidental to the broader operational process rather than a description of governance structure.


reasoning: This paragraph is a generic statement of exposure to cybersecurity threats and dependencies, not a description of governance, management roles, risk processes, third-party oversight practices, or an actual incident. It contains no substantive company-specific cybersecurity disclosure or materiality assessment.


reasoning: The paragraph’s main purpose is a materiality assessment: it states that cybersecurity threats have not materially affected the company to date and that a material incident would be reasonably likely to do so. The cross-reference to risk factors does not change the primary focus from materiality/business impact to another category.


reasoning: The paragraph primarily describes the governance and oversight structure for cybersecurity risk, including how information flows from management to the audit committee and board. Although several officers are mentioned, the focus is not on their qualifications or identities but on the board-level oversight process.


reasoning: The paragraph primarily describes the governance and oversight structure for cybersecurity risk, including how the board, Audit Committee, and CDC oversee incidents and disclosures. Although it discusses materiality assessments and review activities, the main purpose is to explain the oversight chain rather than the company's operational risk processes.


reasoning: Although the paragraph mentions the CISO and reporting line, its main purpose is to describe the Adviser's information security program and what it is designed to do. Removing the role references still leaves a coherent description of the company's cybersecurity risk management process.


reasoning: The paragraph primarily describes how cybersecurity information flows from management to the Board and how the Board receives oversight updates, which is governance structure. It does not provide qualifying firm-specific facts under the extraction rules; the Board, unnamed experts, and regular/monthly reporting do not count.


reasoning: The paragraph primarily describes the governance structure for cybersecurity oversight: the Board oversees cyber risk and a named Risk Committee handles enterprise-level risk review and materiality determinations. Although management is mentioned, the focus is on oversight and information-governance structure rather than management qualifications or operational processes.


reasoning: The paragraph primarily describes the governance chain and information flow to the board—management reporting cybersecurity matters upward for board oversight. It does not focus on the officer's qualifications or describe the company's risk management process in substantive detail.


reasoning: The paragraph primarily describes the company’s ongoing cybersecurity risk assessment and mitigation process, with the IT leader mentioned only as part of carrying out that process. It does not focus on the individual’s qualifications or identity, so this is best classified as Risk Management Process rather than Management Role.


reasoning: The paragraph primarily describes the board oversight structure for cybersecurity, including how the Board, Audit Committee, senior leaders, and the Corporate Compliance Committee interact and receive reporting. Although it includes management qualifications, those details are embedded within a broader governance-chain description rather than serving as the main focus.


reasoning: The paragraph primarily describes the company's internal incident evaluation and escalation process, not board oversight or the qualifications of a particular officer. It includes a firm-specific cybersecurity role fact—the CISO—as part of that process description.


reasoning: The paragraph primarily describes how cybersecurity information flows from management to the audit committee through quarterly briefings and formal updates, which is an oversight/governance structure topic. It does not identify specific cybersecurity officers, qualifications, named frameworks, or other firm-specific facts.


reasoning: The paragraph primarily describes the governance and escalation structure for cybersecurity matters—how incidents are reported to management, the Audit Committee, and the full Board, and how the Board is involved in oversight and disclosure review. Although it mentions a board member's IT-related experience, the main purpose is explaining board-level oversight rather than management qualifications or internal risk processes.


reasoning: The paragraph is primarily about governance and oversight structure through named committees and how cybersecurity oversight is organized, rather than describing a specific security process or the qualifications of individual managers. It contains firm-specific committee names and team composition details, which makes it more than generic boilerplate.


reasoning: The paragraph includes a backward-looking materiality assessment stating the company has not yet experienced any material impacts from a cyber-attack. The rest of the paragraph is generic forward-looking risk language about possible adverse effects and added costs, not a description of governance or risk-management processes.


reasoning: This paragraph is a generic risk warning about potential cybersecurity threats and possible adverse effects, not a description of governance, management roles, risk processes, third-party oversight, strategy integration, or a specific incident. Its materiality language is speculative ('could have a material adverse effect'), which does not qualify as a materiality assessment.


reasoning: The paragraph primarily describes the company's internal cybersecurity monitoring, escalation, and risk discussion processes, with management roles included as part of how the process operates. It does not focus on board oversight structure or on qualifications alone, so Risk Management Process is the best fit.


reasoning: The paragraph primarily describes the oversight and escalation structure for cybersecurity matters—how threats and incidents are reported to the Audit Committee and Board—so it is Board Governance rather than Management Role. It includes one firm-specific fact, the presence of a CISO, but otherwise relies on generic governance language.


reasoning: The paragraph primarily describes the company's internal cybersecurity program activities, including exercises, external advisor use, and employee training, which makes it chiefly about risk management processes. Although it includes qualifications for the Information Security Officer, those details are secondary to the broader description of how the company manages cybersecurity.


reasoning: The paragraph is primarily about the oversight structure for cybersecurity, describing how the Board and management focus on cyber risk through the DPIRC and related information flow. Although it includes some CIO qualifications, those details are secondary to the governance framework being described.


reasoning: The paragraph primarily describes the company's cybersecurity oversight structure—named committees, their responsibilities, reporting/review flow, and coordination with internal audit and the Audit Committee—so Board Governance is the best fit. It includes firm-specific governance details such as named committees and the CISO, but lacks two or more hard verifiable facts required for Quantified-Verifiable.


reasoning: The paragraph primarily describes the oversight and escalation structure for cybersecurity risk, including how management-level committees and officers report up to senior committees and the board. Although officers are mentioned, the focus is on governance flow rather than their qualifications or identities.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk governance and mitigation process, including a risk-based approach and the functions of the Steering Committee. Although specific officers are mentioned, removing them leaves a coherent description of the company’s cybersecurity risk management process rather than a description of those individuals’ qualifications or roles.


reasoning: The paragraph primarily describes the oversight structure and escalation path for cybersecurity matters, with the Risk Management Steering Committee monitoring threats and reporting them to the Audit Committee. Although management roles are mentioned, the main focus is how cybersecurity information flows through the governance chain.


reasoning: The paragraph is primarily about the company's cybersecurity oversight structure: the audit committee's role, reporting up to the board, and escalation protocols under the Cyber Incident Response Plan. Although it also includes management qualifications, those details are secondary to the governance chain and oversight framework.


reasoning: The paragraph primarily identifies the governance structure responsible for cybersecurity risk oversight by referencing committees and management positions rather than describing a concrete risk management process. The named Enterprise Risk Management Committee makes the disclosure firm-specific.


reasoning: The paragraph primarily describes the company's cybersecurity oversight structure: named governance committees, their responsibilities, and the reporting flow from management roles up to the audit committee. Although management roles are mentioned, they are part of the governance chain rather than the main focus of the disclosure.


reasoning: The paragraph primarily describes how the company's cybersecurity program is managed and implemented, including monitoring, alert response, vulnerability management, and system-change safeguards. Although it includes leadership roles and experience, those details are secondary to the description of the program's operation and governance within management.


reasoning: The paragraph primarily describes the company’s internal risk management structure and processes for identifying, assessing, managing, and monitoring cybersecurity risk, rather than board oversight or the CISO’s qualifications. The named CISO role and Enterprise Risk Council make it firm-specific.


reasoning: The paragraph primarily describes the oversight structure for cybersecurity risk: the Board authorizes committee oversight, a Risk Committee manages escalation and materiality, and the CISO reports upward to the Audit Committee. Although the CISO is mentioned, the focus is governance and reporting lines rather than the individual's qualifications or the company's operational cyber processes.


reasoning: The paragraph primarily describes the company's cybersecurity oversight structure from the board down through committees, the CISO, and specialized teams, which makes Board Governance the best fit. Although it includes some CISO qualifications, those details are embedded within a broader governance-chain description rather than serving as the paragraph's main purpose.


reasoning: The paragraph primarily describes the oversight structure for cybersecurity, moving from the Board to delegated oversight roles and IT personnel, which makes it a governance-chain disclosure. Although it includes some detail about IT personnel qualifications, those details are secondary to the explanation of how oversight is assigned.


reasoning: The paragraph primarily describes the company’s internal cybersecurity operating process—who manages it, what the CIRT does, and how incidents are detected, classified, escalated, and reported. Although individual roles and experience are mentioned, the core disclosure is about the functioning of the cybersecurity program rather than personnel qualifications.


reasoning: The paragraph primarily describes the board and audit committee oversight structure for cybersecurity, including how the Chief Technology Officer reports upward and briefs governance bodies. Although it includes some information about the CTO's experience, the main purpose is explaining governance and oversight rather than management qualifications.


reasoning: The paragraph is primarily about oversight structure and reporting flows: internal assessment results go to board-level bodies and third-party review results are reviewed with the BOTC. Although it mentions assessment activities, the main purpose is describing how cybersecurity oversight is exercised and escalated to governance bodies.


reasoning: The paragraph primarily describes the company's cybersecurity program, controls, and risk management processes, with management roles mentioned only as part of how the program is run. It includes firm-specific facts such as the named ISG Policy and cybersecurity-specific leadership roles, but lacks two or more hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph primarily describes management's operational responsibilities within the company's cybersecurity program, including risk identification, incident response, and assessment activities. Although it mentions reporting to the Cybersecurity Committee and the Board, the main focus is the company's internal cybersecurity processes rather than the board's oversight structure.


reasoning: The paragraph primarily describes the company's internal cybersecurity and incident response process: who participates, how incidents are monitored, and how response and reporting are carried out. Although it mentions escalation to the Board and committees, that upward reporting appears as one component of the broader operational process rather than the main focus on governance structure.


reasoning: The paragraph is primarily about the company's internal cybersecurity program and protective controls, with management and board-reporting references serving as supporting context. Although it mentions channels to the Board, the central focus is the implementation and maintenance of Atleos' security processes and technologies.


reasoning: The paragraph is primarily about cybersecurity oversight and reporting structure, describing committee-level responsibilities and the flow of information from the CISO to the Enterprise Risk Committee. Although it includes process details, the main focus is governance rather than the mechanics of the risk management program itself.


reasoning: The paragraph primarily describes the board’s cybersecurity oversight structure, including the shift of oversight to the Sustainability & Safety Committee and reporting flows from the CIO to the committee and full board. Although it includes management qualifications and process details, those are secondary to the governance-chain description.


reasoning: The paragraph primarily describes the company's internal cybersecurity and incident response structure, including team responsibilities, coordination, and escalation procedures. Although it mentions reporting to governance bodies, the main focus is how management-level teams monitor, respond to, and escalate cybersecurity incidents.