reasoning: This paragraph describes the governance chain for cybersecurity oversight (Board of Directors → Audit Committee → Vice President of Strategic Initiatives/CFO → program), which is the defining characteristic of Board Governance. While officers are mentioned, the purpose is to explain the oversight structure and information flow, not to describe the officers' qualifications. The titles mentioned (CFO, VP of Strategic Initiatives) are generic corporate roles rather than cybersecurity-specific titles, and no dates, numbers, named frameworks, or other verifiable specifics are provided, making this generic boilerplate.


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the governance chain for cybersecurity oversight: a Co-President reports at least annually to the Audit Committee, which oversees the enterprise risk management program and may escalate to the full Board. While it mentions management responsibilities, the purpose is to explain the oversight structure and information flow upward to the Board, not to detail the individual's qualifications (Management Role) or specific technical processes (Risk Management Process). No specific facts are present—'Co-Presidents' and 'Audit Committee' are generic titles, and no dates, frameworks, or quantified details are provided.

provider: moonshotai

stage: benchmark


content_category: None/Other

reasoning: The paragraph contains generic IT-dependence language ('information systems are a vital aspect of our business operations') and a forward-looking risk disclaimer ('could potentially have a material impact') that constitutes boilerplate speculation rather than a substantive materiality assessment. It lacks any disclosure of the company's actual cybersecurity governance, processes, or specific incidents.


reasoning: Paragraph describes the governance chain and oversight structure (Board ← CFO/VP of Internal Audit ← IT resources/third-party provider), including briefing cadences and reporting protocols. While officers appear as grammatical subjects, the purpose is to explain the oversight structure, not individual qualifications. All cited elements—CFO (generic C-suite), VP of Internal Audit (standard corporate role), quarterly/periodic cadences, unnamed third-party provider, and generic 'cyber incident response plan'—appear on the exclusion list for specific facts, leaving no firm-specific details.


content_category: Strategy Integration

reasoning: The paragraph provides a formal materiality assessment stating that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which is the defining characteristic of Strategy Integration. It contains no specific dates, named roles, frameworks, or verifiable quantitative details, making it Generic Boilerplate.


reasoning: The paragraph provides a materiality assessment regarding past cybersecurity incidents and forward-looking risks, stating the company has not identified material effects from known threats and cross-referencing to Risk Factors for additional details. It contains no specific facts, dates, dollar amounts, named roles, or other verifiable details that would identify it as unique to this company.


content_category: Management Role

reasoning: The paragraph focuses on the COO's qualifications (over 30 years of experience) and reporting responsibilities. Per the three-step decision chain, the inclusion of specific years of experience triggers Management Role classification. The specificity is Firm-Specific due to the specific duration of experience cited, though this alone does not reach the Quantified-Verifiable threshold requiring two hard facts.


reasoning: While the paragraph opens with a materiality assessment, the substantive disclosure describes the governance structure: a specific 'cybersecurity committee' with named cybersecurity-specific roles (EVP of Technology, Director of IT) and its reporting cadence to the CFO. This fits Board Governance as it details the oversight structure and information flow. The specific committee composition and titles make it Firm-Specific.


content_category: Risk Management Process

reasoning: The paragraph describes the firm's internal governance structure for managing cybersecurity risk, including the establishment of an ERM committee and a dedicated cybersecurity committee with defined responsibilities (strategy, risk assessment, incident response). While it mentions the CTO and other senior officers, the focus is on the governance process and reporting cadence ('updates... on a quarterly and as-needed basis') rather than individual qualifications or board-level oversight. The mention of specific committees (ERM, Cybersecurity) and the cybersecurity-specific title (CTO) makes this Firm-Specific.


reasoning: Paragraph describes internal cybersecurity processes including system monitoring, vulnerability audits, and incident response protocols. While CISO and CIO are named actors, the content focuses on their functional responsibilities (implementing processes, overseeing monitoring) rather than individual qualifications, experience, or reporting structure. Per Step 3 tiebreaker—no years of experience, certifications, education, or team size are mentioned—this is Risk Management Process, not Management Role. Named cybersecurity-specific titles (CISO, CIO) elevate specificity from Generic to Firm-Specific.


reasoning: The paragraph describes the governance chain and oversight structure for cybersecurity risk, tracing information flow from the Board and its Risk Committee down through management committees to the Director of Information Security, and back up through reporting relationships. It identifies cybersecurity-specific governance roles (Director of Information Security) and named non-generic committees (Risk Committee, Operational Risk and IT Steering Committees).


reasoning: The paragraph describes the company's internal cybersecurity processes and controls (security technologies, internal controls, network resiliency, redundancy, disaster recovery processes, backup systems) implemented to mitigate risks. While it contains generic forward-looking risk warnings ('could have a material adverse effect'), the substantive content focuses on the company's own risk management activities rather than governance structures, specific incidents, or materiality assessments.


reasoning: The paragraph provides extensive qualification details about the CIO (10+ years experience, career history at two other public companies) and the supporting team (certified professionals, 13+ years average experience), triggering the Step 3 qualifications tiebreaker for Management Role. The specificity is Quantified-Verifiable due to multiple hard numerical facts: 'over 10 years,' 'two other public companies,' and 'average of over 13 years.'


reasoning: The paragraph describes the governance chain for cybersecurity oversight: IT providers inform the COO and CFO, who subsequently update the Board on significant matters. This describes the structure of board oversight and information flow (Board Governance), not the qualifications of management or specific risk processes. It contains no specific facts—only generic C-suite titles (COO, CFO), unnamed third parties ('information technology providers'), and vague timing ('regularly').


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically how the CEO briefs the Audit Committee on cyber risks and the cadence of such briefings. Although the CEO is the grammatical subject, the purpose is to explain the oversight flow and information structure to the board (Audit Committee), not to describe the CEO's qualifications or role as an individual. Both 'CEO' and 'Audit Committee' are standard, generic governance terms that appear at every company.


reasoning: The paragraph contains a negative materiality assertion ('have not experienced any material cybersecurity incidents'), which qualifies as a materiality assessment under Strategy Integration per the guidelines. The disclosure lacks specific dates, named roles, frameworks, or quantifiable details, consisting entirely of generic language that could apply to any company.


reasoning: The paragraph contains a backward-looking negative materiality assessment ('did not experience a material cybersecurity incident'), which the guidelines explicitly classify as Strategy Integration. It includes one specific date (December 31, 2024), meeting the threshold for Firm-Specific, but lacks a second hard verifiable fact needed for Quantified-Verifiable.


reasoning: The paragraph contains a negative materiality assertion ('have not resulted in a material cybersecurity incident'), which qualifies as a materiality assessment under Strategy Integration. The remainder consists of generic threat descriptions and forward-looking risk warnings without specific dates, named frameworks, or firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and management processes, including integration into overall risk management strategy and review of security assessments. While the COO and SVP for Operations are named, the focus is on process execution (hiring, integrating, reviewing) rather than individual qualifications or credentials, making it Risk Management Process rather than Management Role. The roles mentioned are generic C-suite/operations titles (not cybersecurity-specific), and no frameworks, dates, metrics, or tools are specified, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the governance structure and reporting chain for cybersecurity oversight: the CFO handles day-to-day risk oversight and reports breaches and mitigation efforts to the Board. This fits Board Governance as it explains how information flows upward to the Board. While the CFO is the grammatical subject, the purpose is to describe the oversight structure (officer → board), not the CFO's qualifications or credentials. The mention of the 'Coalition management platform' provides a firm-specific detail (named third-party tool), making the disclosure Firm-Specific rather than generic boilerplate.


category_confidence: medium

reasoning: The paragraph describes an oversight/governance function—ensuring senior leadership is informed of cybersecurity risks—but lacks any specific roles (e.g., CISO, Board committees), reporting cadences, or organizational details. It contains no named entities, dates, or quantifiable facts that would distinguish it from any other company's disclosure.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically that management reports cybersecurity incidents to the board of directors, which fits the Board Governance definition of describing 'who reports to the board' and 'how information flows upward.' It contains no specific facts—only generic references to 'Management,' 'board of directors,' and 'ERM approach' that could apply to any company.


reasoning: The paragraph contains generic risk disclosure language describing hypothetical cyber threats (malware, phishing) and their potential material adverse effects, but does not disclose specific governance structures, management roles, internal processes, or actual incidents. The materiality language ('could have a materially adverse effect') constitutes forward-looking speculation rather than a substantive assessment, and the content is interchangeable with standard risk factor language found in any financial institution's filing.


reasoning: The paragraph describes internal monitoring processes, system audits, vulnerability identification, and incident response planning. While the InfoSec Director is mentioned as the actor implementing these processes and their thought leadership activities are noted, the primary focus is on the company's cybersecurity risk management procedures (monitoring, prevention, detection, remediation) rather than the individual's qualifications or reporting structure. The presence of the specific title 'InfoSec Director,' the named program 'eRISC,' and specific conferences 'FS-ISAC' and 'CISO summits' makes this Firm-Specific.


reasoning: The paragraph contains a backward-looking materiality assessment ('have not experienced... that materially disrupted') and a forward-looking materiality conclusion using the SEC-qualified language 'reasonably likely to materially affect,' which constitutes a specific assessment of cybersecurity's impact on business outcomes rather than generic risk speculation.


reasoning: The paragraph describes the company's internal cybersecurity processes including risk assessments, safeguard implementation, and monitoring effectiveness. While it mentions an IT consultant and reporting lines to the IT Manager and COO, these roles are unnamed, lack qualifications or credentials, and serve only to describe the process structure rather than identifying specific personnel. No frameworks, dates, or verifiable specifics are provided.


reasoning: The paragraph details the operational responsibilities of the Information Security Management Committee regarding the company's Information Security Program, including setting program components, monitoring risk trends, ensuring resource allocation, conducting assessments, and maintaining incident response preparedness. These activities describe the company's internal risk management processes rather than board oversight structure alone. The disclosure also identifies specific firm organizational entities such as the 'Compliance and Information Security Committee of the Board of Directors', which distinguishes it from generic boilerplate.


reasoning: The paragraph contains a materiality assessment ('we believe the risk of significant cybersecurity incidents is minimal'), which is a conclusion about the business impact of cybersecurity risks, fitting Strategy Integration. It references only generic elements (CEO, standard commercial software, basic security features) without naming specific frameworks, tools, dates, or cyber-specific roles, making it generic boilerplate.


reasoning: The paragraph describes the company's Cybersecurity Plan and Incident Response Team (IRT) structure, detailing internal processes for monitoring, detecting, and responding to cybersecurity threats. While named officers are mentioned, they appear as components of the incident response process rather than as subjects of qualification or credential discussion, making this a process description rather than Management Role or Board Governance.


reasoning: The paragraph describes the governance/oversight structure of the cybersecurity program, detailing the composition, leadership, and monitoring responsibilities of the cybersecurity committee (a governance-chain description). It contains firm-specific details including the cybersecurity-specific title 'Vice President, IT,' the named non-generic 'cybersecurity committee,' and the specific departmental composition of the cross-functional team.


reasoning: The paragraph focuses on cybersecurity personnel qualifications and development, explicitly listing specific professional certifications held by staff (e.g., GIAC, CISSP, CompTIA Security+) and named industry groups. Per the Step 3 qualifications tiebreaker, the inclusion of specific certifications triggers Management Role. Specificity is Quantified-Verifiable due to multiple named third-party organizations (FS-ISAC, ABA) and specific named certifications, exceeding the two hard-fact threshold.


reasoning: This is a forward-looking hypothetical disclaimer ('If we were to experience...') and a cross-reference to Item 1A Risk Factors. It contains generic speculation about potential material adverse effects rather than a materiality assessment or conclusion, and does not describe actual governance structures, management roles, processes, or incidents.


reasoning: The paragraph describes the governance chain and oversight structure, detailing how information flows from the CISO through the information technology risk committee and management risk committee to the full Board. While management roles are mentioned, the primary purpose is explaining how the Board exercises oversight through this reporting structure, which falls under Board Governance per the governance-chain rule.


reasoning: The paragraph identifies specific management personnel (R. LaDuane Clifton) and details their qualifications (40 years of combined IT staff experience), focusing on who is responsible for cybersecurity rather than describing governance structure or internal processes. While it mentions board oversight briefly, the specific details about management credentials and experience make Management Role the primary category.


reasoning: The paragraph describes internal cybersecurity processes (risk assessment, security controls, and incident response) managed by the IT department. It contains no named frameworks, specific dates, dollar amounts, headcounts, or named individuals—only generic references to standard security functions that could apply to any company.


reasoning: Paragraph contains only generic threat descriptions applicable to any large IT company ('advanced and persistent threat actors,' 'suppliers and other third-party service providers'), vague forward-looking disclaimers ('could be adversely affected'), and non-specific resource commitments ('expend considerable resources') without dollar amounts, percentages, dates, named roles, frameworks, or firm-specific programs. No verifiable facts specific to Dell's cybersecurity program, governance structure, or incidents are present.


reasoning: The paragraph describes the ERMC's quarterly meetings and its role in receiving cybersecurity action plans and integrating them into company-wide risk management processes, which constitutes a description of internal risk management processes. While it mentions the CISO and CDO as report providers, the focus is on the committee's functioning and process integration rather than individual qualifications or board-level governance.


reasoning: The paragraph describes the company's internal risk management structure and processes, including the responsibilities of the IT and C&RM teams, oversight relationships between teams, and the Internal Audit function's validation role. While team certifications are mentioned, the focus is on the process and governance chain rather than individual management qualifications or board oversight structure. The specificity is Quantified-Verifiable because it lists four distinct, named professional certifications (CISSP, CISM, CRMA, CRISC) held by team members, which are hard facts that could be independently verified.


reasoning: The paragraph describes an internal management governance structure (a steering committee) and its operational composition to strategize on cybersecurity challenges, which is a Risk Management Process. It is Firm-Specific due to the named internal committee, the cybersecurity-specific CISO role, and the detailed departmental composition of the membership.


reasoning: The paragraph contains a backward-looking materiality assessment stating that no material cybersecurity incidents have been identified to date, which triggers Strategy Integration. However, it lacks any specific facts (no dates, roles, numbers, or named entities) and consists entirely of generic language that could apply to any company, making it Generic Boilerplate.


reasoning: The paragraph describes the company's cybersecurity program, ERM integration, and use of frameworks, with named officers (CTO/CIO and CISO) mentioned as part of the process description rather than for their personal qualifications. Removing the titles leaves a coherent description of the risk management process. Specific cybersecurity titles make this Firm-Specific, but there are no quantifiable metrics (dates, dollars, headcounts) to reach Quantified-Verifiable.


reasoning: The paragraph focuses primarily on the CIO's qualifications, including specific years of experience (30) and career history prior to joining in 2018, triggering the Step 3 qualifications tiebreaker for Management Role. It contains firm-specific details including the cybersecurity-specific title, specific tenure, and the named ISMS Committee, but only one hard quantified fact (30 years), making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph contains only vague references to past cyber-attacks without specific details (dates, scope, systems affected, or response actions) and generic forward-looking risk warnings about potential future harm. It lacks substantive disclosure about governance, management, processes, or specific incidents, constituting standard boilerplate risk language rather than a materiality assessment or incident description.


reasoning: The paragraph identifies the specific cybersecurity leadership role (Director of IT) and describes the individual's qualifications ('extensive experience'), which aligns with the Management Role category focused on who holds the position. While it mentions team activities, the primary focus is on the role and its experience.


reasoning: The paragraph describes the company's internal cybersecurity processes including periodic control reviews, internal and external audits, and annual risk assessments using a specific framework. While it mentions Board approval and reporting, the primary focus is on the operational risk management activities and assessment methodology rather than governance structure.


reasoning: The paragraph describes the company's internal governance structure for cybersecurity risk management through a specifically named management committee (ISSC) with defined departmental composition, rather than focusing on board-level oversight or individual officer qualifications. It references a specific third-party services agreement with LMC and details the specific functional departments represented on the committee.


reasoning: The paragraph contains generic statements about cybersecurity importance and threats without disclosing specific governance structures, management roles, internal processes, or materiality assessments. It serves as introductory risk context rather than substantive disclosure of the company's cybersecurity program.


reasoning: The paragraph contains a backward-looking materiality assessment ('have not experienced any material cyber breaches'), which explicitly qualifies as Strategy Integration per the negative assertion rule. The remainder consists of generic, non-specific process language ('periodically reviewing,' 'policies and procedures') without named frameworks, dates, roles, or quantifiable details, making the disclosure generic boilerplate.


reasoning: The paragraph describes the company's internal risk management process for identifying, prioritizing, and monitoring cybersecurity risks as part of its overall ERM program. While it mentions Board oversight responsibility, the primary focus is on the process design rather than governance structure, and it contains no specific frameworks, titles, dates, or quantifiable details—only generic language applicable to any company.


reasoning: This paragraph constitutes a backward-looking materiality assessment (negative assertion) stating that no cybersecurity incidents have materially affected operations, which aligns with Strategy Integration. The inclusion of the specific fiscal year-end date December 31, 2024 provides one firm-specific fact, meeting the Firm-Specific threshold.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, detailing how the Chief Security Officer reports upward to the Management Board and to the Supervisory Board's Committee responsible for technology, data and innovation, including specific reporting cadences (quarterly, ad hoc, regular updates).


reasoning: The paragraph describes the company's internal hierarchical escalation process for cybersecurity threats, detailing how threats are escalated through management to specific executives and ultimately to the Risk Committee or Board. While it mentions specific roles and their qualifications, the primary focus is the operational escalation workflow, and the text remains coherent when person-specific details are removed, indicating Risk Management Process rather than Management Role. It qualifies as Firm-Specific due to the identification of cybersecurity-specific titles (CISO, CIO), the named Risk Committee, and the specific duration of experience cited.


reasoning: The paragraph contains generic forward-looking speculation about potential cyber-attack consequences using 'could' language, without describing actual governance structures, management roles, internal risk processes, or materiality assessments. It lacks any specific facts, dates, or entity-specific details that would constitute substantive disclosure.


specificity_confidence: medium

reasoning: The paragraph describes the governance chain from Committee to Board to management team, detailing oversight structure, reporting lines, and board continuing education. While it names specific management titles (Senior Director of IT, SVP Quality Assurance) and mentions their experience, the primary purpose is to map the oversight structure (committee → board → officer → program), making it Board Governance rather than Management Role.


reasoning: Paragraph describes the governance structure and oversight chain (Board → Audit Committee → CIO/HIS), including reporting cadences and information flow, rather than focusing on individual qualifications or internal risk processes.


reasoning: The paragraph describes the company's internal cybersecurity processes (risk identification, monitoring technology trends, overseeing training) maintained by an identified team. While it names officers, it describes what the program and team DO rather than officer qualifications, making it Risk Management Process under the three-step test. It is Firm-Specific because it identifies the CTO (a cybersecurity-specific title) and details the specific cross-functional composition of the Cybersecurity Team.


reasoning: The paragraph identifies a specific cybersecurity leadership role (SVP and CTO) and provides specific qualifications including years of experience, which per the MR vs RMP decision chain (Step 3 qualifications tiebreaker) classifies this as Management Role. The specificity is Firm-Specific due to the cybersecurity-specific title and specific experience duration cited.


reasoning: This paragraph contains generic regulatory risk disclosure language applicable to any regulated entity, describing potential consequences of non-compliance without detailing specific internal processes, governance structures, materiality assessments, or identifiable compliance frameworks.


reasoning: The paragraph describes the company's internal cybersecurity risk management framework, including ERM Committee integration, internal audit control assessments, and specific governance mechanisms like the ARB and PMO, rather than focusing primarily on Board oversight structures or individual management qualifications.


reasoning: The paragraph describes internal processes for identifying, assessing, and managing cybersecurity risks, including monitoring threat environments, conducting scans, and completing audits. While the SVPF and Director of IT are mentioned as actors, the content focuses on the risk management processes and methods used rather than the individuals' qualifications or backgrounds. The disclosure contains no specific dates, dollar amounts, named third-party firms, cybersecurity-specific titles (e.g., CISO), or named tools—only generic references to 'manual and automated tools,' 'third-party threat assessments,' and standard IT roles.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, detailing the composition and function of the Cybersecurity Council and executive management's role in risk assessment. While it references material risk assessment, it focuses on the organizational structure and oversight chain rather than stating a materiality conclusion, fitting Board Governance. It includes firm-specific details like the named Cybersecurity Council, specific cybersecurity titles (CIO, VP of Information Security), and the cross-functional team composition.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for risk factor disclosures rather than providing a substantive disclosure about the company's cybersecurity program, governance, or materiality assessments. It contains no specific facts, dates, or named entities.


reasoning: The paragraph contains a forward-looking materiality assessment using SEC-qualified language ('reasonably likely to materially affect') regarding the potential impact of cybersecurity threats on business outcomes, which qualifies as Strategy Integration. It lacks any specific details about governance structures, processes, or management roles, and contains no verifiable facts, dates, or named entities, making it generic boilerplate.


reasoning: Paragraph contains generic IT-dependence language describing the importance of data integrity and security to business operations without disclosing specific governance structures, management roles, risk management processes, or incidents. This is boilerplate that could apply to any company with no substantive cybersecurity program disclosure.


reasoning: The paragraph describes the governance/oversight structure, detailing a cross-functional committee's role in overseeing cybersecurity execution, receiving reports on strategy and risks, and escalating to the Audit Committee or Board of Directors. This represents a governance-chain description (board → committee → officer → program) focused on how oversight is exercised, rather than describing specific risk management processes or individual management qualifications.


reasoning: The paragraph contains a negative materiality assessment ('no such incident has had any such impact to date') and references the SEC-required materiality framework ('materially affected or are reasonably likely to materially affect'), which qualifies as Strategy Integration. It lacks specific frameworks, roles, dates, or quantifiable data, consisting only of generic protocol descriptions and cross-references that could apply to any company.


reasoning: Paragraph contains generic forward-looking speculation ('could materially adversely affect') about potential impacts from customer/supplier incidents without describing actual vendor oversight, contractual standards, or specific materiality assessments. This is boilerplate risk language excluded from Strategy Integration per guidance.


reasoning: The paragraph describes the company's internal cybersecurity processes including risk assessment, mitigation, continuous monitoring, and routine meetings for threat updates. While management and a third-party partner are mentioned as actors, the focus is on the operational processes rather than individual qualifications (except for the incidental mention of the partner's 21 years of experience). The specific number of years provides one firm-specific detail, but without a named firm, date, or second hard fact, it does not reach Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity processes, including team responsibilities, associate training, program reviews/tests, and engagement of third-party consultants. While it mentions a chief information security officer, the focus is on the team's implementation and maintenance of practices rather than the individual's qualifications or background.


reasoning: The paragraph describes the governance chain and oversight structure: the Board receives updates from management and the Audit Committee, management reports to the Audit Committee on cybersecurity programs, and the CEO directs the programs. This focuses on how oversight is exercised and information flows upward. It contains no specific facts beyond generic governance terms (Board of Directors, Audit Committee, CEO, management) and vague cadences ('periodic', 'regularly').


reasoning: The paragraph describes management's functional responsibilities in leading cybersecurity processes (hiring, budgets, strategy integration, incident preparation) rather than personal qualifications or credentials. After removing named roles, the text remains a coherent description of the company's risk management structure, indicating the focus is on the process, not the individuals themselves.


reasoning: The paragraph traces a governance chain (Board → Audit Committee → CTO → program teams) describing oversight structure, briefing cadence, and information flow. While it includes Management Role elements (CTO qualifications), the primary purpose is establishing the governance hierarchy. Specificity is Firm-Specific due to the named cybersecurity-specific role, specific years of experience, and named external industry committees/consortiums.


reasoning: The paragraph identifies specific management positions (CIO, CFO, Director of Internal Audit, Director of IT) that comprise the Cybersecurity Committee and describes their qualifications, experience, and IT expertise, which aligns with Management Role. It contains firm-specific details including the named committee, specific headcount, and cybersecurity-specific titles (CIO), but only one hard verifiable fact (headcount), making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes the governance structure and oversight chain, specifically how the CEO and management oversee cybersecurity risks and report to the Board of Directors periodically (at least annually). This fits the Board Governance definition of describing 'how the board exercises oversight, who reports to the board, how information flows upward.' It contains no specific facts—only generic references to the CEO, Board of Directors, and standard reporting cadences without dates, named committees, or specific program details.


reasoning: The paragraph describes the governance chain and oversight structure (Board → Audit Committee → CEO → CFO/third-party consultants) rather than specific risk processes or management qualifications. It contains only generic references to standard C-suite roles (CEO, CFO) and the Audit Committee without naming specific individuals, firms, frameworks, or dates.


reasoning: The paragraph describes the governance oversight structure, specifically how the Risk Management Steering Committee (comprising the CFO, GC, and business unit representatives) monitors cybersecurity threats in real time and reports to the Audit Committee. This establishes a governance chain (committee → board) focused on oversight mechanisms rather than individual management qualifications or specific risk management processes.


reasoning: The paragraph describes internal cybersecurity processes—setting objectives, resource allocation, policy development, risk assessments, incident response planning, and compliance—framed as management responsibilities. However, it contains no named frameworks (e.g., NIST, ISO), specific roles (e.g., CISO), dates, headcounts, or other verifiable facts unique to the firm.


reasoning: The paragraph describes the governance structure and oversight chain, specifically how the Chief Operating Officer briefs the Audit Committee on cybersecurity matters, including the frequency (annual) and scope of these briefings. Despite mentioning a management role, the purpose is to explain the board committee's oversight mechanisms and information flow, which is Board Governance. The content contains only generic elements (COO, Audit Committee, annual reviews, standard briefing topics) that could apply to any company, with no cybersecurity-specific titles, named standards, or firm-unique details.


reasoning: The paragraph describes the governance oversight structure: the Manager of Information Technology reports to the Audit Committee, and the Committee receives briefings on the cyber risk management program and incidents. This is a classic governance-chain description (committee ← officer ← program). It contains no specific facts—'Audit Committee' is standard governance, 'Manager of Information Technology' is not a cybersecurity-specific title (unlike CISO/CIO), and 'periodically' is a vague cadence without specific dates.


reasoning: The paragraph contains backward-looking materiality assessments ('have not materially affected') and forward-looking assessments using the SEC qualifier 'reasonably likely to materially affect,' which are definitive Strategy Integration content. It lacks specific dates, dollar amounts, named entities, or frameworks, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, detailing the cadence of briefings to management (monthly) and the Board (quarterly) as part of the Board's oversight functions. While management roles are mentioned, they are described as recipients within the governance information flow rather than as individuals with specific qualifications or credentials.


reasoning: The paragraph describes the governance and oversight structure, detailing the reporting chain from the ISO to management and the BRCC, and escalation procedures to the full Board. This aligns with Board Governance, which covers oversight structures and information flow to the board. It contains the cybersecurity-specific title 'ISO' and the named committee 'BRCC', making it Firm-Specific.


reasoning: The paragraph describes the governance structure and information flow whereby Management reports cybersecurity risks to the Board under a formal charter, which fits Board Governance. It contains no specific dates, named officers, frameworks, or quantifiable details, rendering it Generic Boilerplate.


reasoning: The paragraph describes the company's internal information security processes (policy management, employee training, access reviews, monitoring) and organizational structure for executing the Information Security and BC/DR Programs. While the CISO is the grammatical subject and reporting lines are mentioned, the person-removal test demonstrates the content remains a coherent process description focused on program execution rather than individual qualifications, making it Risk Management Process. The identification of the CISO role—a cybersecurity-specific title—makes the disclosure Firm-Specific.


reasoning: The paragraph describes internal cybersecurity processes including regulatory monitoring, system audits, and incident response planning. Applying the person-removal test, the text remains a coherent description of risk management processes even without the named role, confirming Risk Management Process over Management Role. The specific functional title 'Director of Infrastructure' (who oversees these cybersecurity activities) qualifies as a firm-specific fact, distinguishing this from generic boilerplate.


reasoning: The paragraph describes the design and objectives of the information security program (risk oversight, confidentiality/integrity/availability controls). While it identifies the CISO and reporting line to the GCSO, applying the person-removal test leaves a coherent description of the program's processes, and the paragraph lacks specific qualifications (years, certifications) that would trigger Management Role under Step 3 of the decision chain.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically the reporting lines and information flow from the CISO to the Audit Committee and Board of Directors regarding threats and incidents.


reasoning: The paragraph describes governance structure by identifying specific committees and management positions responsible for cybersecurity risk oversight. The naming of the 'Enterprise Risk Management Committee' constitutes a firm-specific governance fact, distinguishing it from generic boilerplate.


reasoning: The paragraph describes the governance structure for cyber risk oversight, establishing that the Board delegates responsibility to a specific Risk Committee (a named non-generic committee) which handles enterprise risk management including materiality determinations for cybersecurity incidents.


reasoning: The paragraph primarily describes the governance structure for cybersecurity oversight, specifying that the full board retains responsibility rather than delegating to a committee, and details the reporting lines from management (CEO and Interim CFO) to the board. While it includes a backward-looking materiality assessment, the substantive content focuses on the oversight chain and governance framework.


reasoning: The paragraph describes the company's internal cybersecurity processes (threat detection, incident classification, documentation, reporting) managed by the CIRT. While it mentions the leaders' experience, the focus is on the team's operational responsibilities. It contains firm-specific details including the named CIRT program, specific IT leadership roles, and quantified experience, but lacks two hard verifiable facts (dates, dollars, headcounts, percentages, named third parties/tools) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk management processes, including integration with the Enterprise Risk Management Program and how risks are assessed and managed by the Information Security Team. While specific roles (CIO and Director of Information Security) are mentioned, they serve to describe the operational structure and reporting lines rather than individual qualifications, making this Risk Management Process under the three-step test. The inclusion of cybersecurity-specific titles and detailed team composition makes the disclosure Firm-Specific.


reasoning: Paragraph describes the company's Enterprise Risk Council, its composition, meeting cadence, and risk management functions (identification, assessment, monitoring). Under the MR vs RMP test, removing the named roles (CISO, VP, Internal Audit) leaves a coherent description of an internal risk management process. Contains firm-specific details including the cybersecurity-specific title CISO and the non-generic committee 'Enterprise Risk Council'.


reasoning: The paragraph contains a forward-looking materiality assessment using the SEC qualifier 'reasonably likely to materially affect,' which explicitly qualifies as Strategy Integration per the category definition. It contains no specific dates, dollar amounts, named entities, or frameworks, making it Generic Boilerplate.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically the reporting cadence and information flow from a corporate officer to the board of directors. It contains no specific dates, named frameworks, cybersecurity-specific roles (VP of Corporate Development & Administration is a generic corporate title), or quantifiable details that would distinguish it from standard boilerplate disclosure language.


reasoning: The paragraph primarily describes the Board's oversight structure and governance chain, including the Board's receipt of semiannual updates from the CISO and CIO, oversight of risk management programs, and integration with external experts and executive management. While internal processes (monitoring, audits, incident response) are mentioned, they are framed within the context of Board governance and oversight rather than serving as the primary topic.


reasoning: The paragraph describes the company's internal cybersecurity processes, including ongoing education, system monitoring, penetration testing, and incident response planning. While the CIO is mentioned as the leader implementing these efforts, the content focuses on the processes themselves rather than the officer's qualifications, credentials, or career history, making this Risk Management Process under the three-step test. The specific title 'CIO' qualifies as a cybersecurity-specific role, making the disclosure Firm-Specific.


reasoning: The paragraph describes the company's internal organizational structure for managing cybersecurity risks, specifically the establishment of a cross-functional team and its responsibility for day-to-day program implementation. While specific titles (CIO, Director of Cybersecurity) and collective experience (85 years) are mentioned, the focus is on the process and organizational structure rather than individual qualifications or reporting lines. Applying the person-removal test, the text remains a coherent description of the company's risk management process.


reasoning: The paragraph describes the governance chain and oversight structure (Board → Audit Committee → Risk Committee → CISO), including the Risk Committee's charter and the CISO's quarterly reporting cadence. While the CISO is mentioned, the purpose is to explain the oversight structure and information flow, not to describe management qualifications or internal operational processes.


reasoning: The paragraph describes the management team's composition from standard departments and their supervisory role over cybersecurity personnel and consultants, but contains no named individuals, specific certifications, years of experience, headcounts, dollar amounts, dates, or named third-party firms. The reference to 'prior work experience' is vague and unquantified, and 'information security personnel' is a generic category rather than a specific titled role (e.g., CISO).


reasoning: The paragraph describes the company's ERM program and how cybersecurity risk is integrated into it, including the organizational structure and specific roles (CISO, CDIO, VP Internal Audit) involved in managing the process. It focuses on the internal risk management framework rather than board oversight, individual qualifications, or materiality assessments.


reasoning: The paragraph describes the company's internal cybersecurity processes (risk assessment, security controls, and incident response) managed by a security team. While it mentions an 'information technology manager,' the focus is on the processes and program structure rather than the individual's qualifications or credentials, making this Risk Management Process under the person-removal test. The content lacks specific dates, dollar amounts, named frameworks, or unique organizational details, rendering it Generic Boilerplate.


reasoning: The paragraph lists generic cybersecurity risk factors (system complexity, geographic scope, attractiveness to threat actors, third-party dependencies) without describing specific governance structures, management roles, internal risk management processes, or vendor oversight programs. It constitutes generic risk disclosure that could apply to any company with distributed IT systems.


reasoning: The paragraph describes the governance chain and oversight structure for cybersecurity risk, detailing how risks flow from management-level committees to Morgan Stanley's Non-Financial Risk Committee, and ultimately to various board-level committees (Firm Risk Committee, BOTC, MS Board) and the Company's Board. While it mentions the CIO and Head of Operational Risk, they appear as part of the reporting structure description rather than as a focus on their qualifications or identity. Specific named committees (Non-Financial Risk Committee, Firm Risk Committee, BOTC) and cybersecurity-specific roles (CIO) make this Firm-Specific.


reasoning: The paragraph describes the company's internal processes for identifying and assessing cybersecurity risks (monitoring threat environments, using automated tools, real-time monitoring, escalation protocols). While the CFO is identified as responsible, the content focuses on the risk management activities rather than the officer's qualifications or background. No specific dates, named tools, vendors, frameworks, or quantifiable details are provided, making the disclosure generic boilerplate applicable to any company.


reasoning: The paragraph describes the governance chain for cybersecurity oversight—management reports to the Enterprise Risk and Compliance Committee and the Board's Audit Committee to facilitate board assessment of program effectiveness and threat awareness. This describes oversight structure and information flow to the board, not internal risk processes or management qualifications. The specificity is Firm-Specific because it names the non-standard 'Enterprise Risk and Compliance Committee' (distinct from the generic Audit Committee), but it lacks two hard verifiable facts (dates, dollar amounts, headcounts, percentages, or named third-party firms/products) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity processes, including threat monitoring, the structure of the Global Information Security team, the Enterprise Security Council's role in risk discussions, and escalation procedures to the Enterprise Risk Council. While it mentions the CISO and CEO, removing these roles leaves a coherent description of the cybersecurity program and governance processes, indicating the focus is on risk management operations rather than individual qualifications. Specific details include named councils, departmental compositions, and the CISO's experience level, making it Firm-Specific.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including the Board of Directors, Audit Committee, and the specific Cybersecurity Disclosure Committee (CDC) with its departmental composition, fitting the Board Governance category. It contains firm-specific details including the named CDC and specific participating departments (IT, Legal, Internal Audit, Accounting and Reporting).


reasoning: The paragraph describes the company's internal reporting process and the topics covered in quarterly cybersecurity briefings to the audit committee (policies, threat landscape, incidents, investments, compliance). It does not identify specific personnel, their qualifications, or reporting lines beyond generic 'members of management,' and lacks any named frameworks, dates, metrics, or other firm-specific details that would distinguish it from standard disclosure language.


reasoning: The paragraph describes the governance oversight structure and briefing cadence, explaining how management reports cybersecurity updates to the Board of Directors on a monthly basis and how evaluation results flow upward to senior management and the Board. It contains no specific facts—only generic references to management, the Board, unnamed internal/external experts, and standard reporting frequencies (monthly) without specific dates, frameworks, or named roles.


reasoning: The paragraph describes the company's internal risk assessment and mitigation processes (re-examining systems, implementing safeguards, continuous evaluation) rather than focusing on the qualifications or credentials of specific personnel. Despite mentioning the head of IT and CFO, the content passes the person-removal test as the process description remains coherent without these roles. The disclosure contains no specific dates, frameworks, named tools, or quantifiable details that would distinguish it from a generic template.


reasoning: The paragraph centers on the qualifications and expertise of the cybersecurity sub-committee, specifically citing their combined 45 years of experience, which triggers the Step 3 tiebreaker for Management Role. While the text describes processes the committee performs, the emphasis on credentials and experience makes it about who the responsible party is rather than purely the processes themselves.


reasoning: The paragraph describes the company's internal cybersecurity governance process and committee structure, focusing on the responsibilities of the Cybersecurity Steering Committee co-chaired by the CSO and interim Chief Legal Officer. It details internal oversight mechanisms rather than board-level governance or individual officer qualifications.


reasoning: The paragraph contains only generic forward-looking risk warnings ('could have a material adverse effect') and boilerplate speculation without describing any specific cybersecurity governance structures, management roles, risk processes, or actual incidents. While it mentions having 'experienced' cyber incidents, it provides no details (dates, scope, systems affected) that would constitute incident disclosure. As generic risk language with no substantive disclosure of the company's cybersecurity program, it falls under None/Other.


reasoning: The paragraph primarily identifies the company's CIO and CISO and provides extensive details about their qualifications, experience, and certifications (25 years experience, 18 years at Matson, 7 years at Charles Schwab, CISSP, CISA, and AWS certifications), which falls squarely within Management Role. While it mentions governance structures and reporting cadences to the Board and Audit Committee, the detailed biographical and credential information about the specific individuals is the dominant content.


reasoning: The paragraph describes the governance structure and oversight responsibilities of specific committees (DPIRC and Enterprise Risk Committee), including their roles in implementing policies, monitoring cybersecurity risk programs, and receiving updates from the CISO. This focuses on how oversight is exercised rather than describing internal risk management processes or the CISO's qualifications.


reasoning: The paragraph describes the governance chain for cybersecurity oversight, tracing delegation from the Board to the Audit Committee, CFO, and internal IT resources, ultimately identifying the Director of IT as the manager of the security team. While management roles appear, the primary purpose is to explain the oversight structure and reporting hierarchy (Board → Committee/Officers → Director → Team), which is the defining characteristic of Board Governance disclosures.


reasoning: The paragraph focuses on identifying specific cybersecurity leadership roles (CTO and Head of Technology Infrastructure) and detailing their qualifications, years of experience, and areas of expertise, satisfying the Management Role category. It meets the Quantified-Verifiable threshold by containing two specific numerical facts (25 years and 20 years of experience) that are independently verifiable.


reasoning: The paragraph focuses on identifying specific cybersecurity personnel (the ISO), detailing the cross-functional composition of the Information Security team, and establishing reporting lines to the Senior Risk Officer, which aligns with the Management Role category's focus on role identification and reporting structure.


reasoning: The paragraph describes the governance structure of a specific Cybersecurity Steering Committee (CSC), including its composition of named senior executive roles and its oversight responsibilities for integrating cyber risk management with business processes. While specific management titles are listed, the content focuses on the committee's structure and function rather than individual qualifications or career histories, placing it in Board Governance rather than Management Role.


reasoning: The paragraph describes the company's internal cybersecurity processes, controls, and governance framework (monitoring, vulnerability management, encryption, NIST), making it Risk Management Process. It identifies specific cybersecurity leadership roles (CTO, Head of Technology Infrastructure) and a named internal policy ('ISG Policy'), making it Firm-Specific rather than generic or sector-adapted alone.


reasoning: The paragraph describes the company's internal risk management governance structure, including the establishment and responsibilities of management-level committees (IT Operating Committee and IT Steering Committee) and their review cadences. While it mentions the Director of IT and CISO, it focuses on the processes and oversight structure rather than the individuals' qualifications. It contains firm-specific details including cybersecurity-specific titles and named internal committees, but lacks quantifiable metrics or third-party names needed for Quantified-Verifiable.


reasoning: This paragraph maps the governance chain from the Board to the Audit Committee to the CISO and operational teams, which constitutes a description of oversight structure under Board Governance. It includes multiple firm-specific facts such as the CISO's name (Casey O'Malley), specific career dates (since 2001, since 2015), educational background, and uniquely named internal teams.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes (training programs, tabletop exercises, role-based training) and program implementation. While the Information Security Officer is mentioned, the content focuses on what the program does rather than who the officer is. The specific title 'Information Security Officer' and the experience detail 'over a decade' provide firm-specific identifiers.


reasoning: The paragraph focuses primarily on the identification and qualifications of the Vista CIO (appointment date, years of experience) and describes the DPIRC committee composition, fitting the Management Role category. While governance structures are mentioned, the detailed biographical information about the CIO represents the substantive content.


reasoning: The paragraph describes the governance chain from the Board to the Sustainability & Safety Committee to the CIO, including specific reporting cadences and the 2025 transition of oversight authority, fitting the Board Governance definition for governance-chain disclosures. It meets the Quantified-Verifiable threshold with multiple hard facts: specific certifications (CISSP, CISM, ISA 62443), a specific duration (over three decades), and a specific year (2025).


reasoning: The paragraph focuses primarily on the qualifications and experience of the CEO (15 years in IT with software development focus) and notes the limited cybersecurity experience of other executive officers. While it references board oversight and reporting lines, the substantive content describes who the officers are and their credentials, triggering the qualifications tiebreaker for Management Role.


reasoning: The paragraph describes the company's internal escalation workflow for cybersecurity incidents (evaluation by the cybersecurity organization, severity-based escalation to CISO, then to senior leadership), which constitutes a risk management process. It mentions the CISO—a cybersecurity-specific role title that distinguishes this from generic C-suite references—making it Firm-Specific rather than Generic Boilerplate, though no additional quantifiable facts (dates, dollars, headcounts) are present.


reasoning: The paragraph describes management's responsibilities for core cybersecurity processes including risk identification, incident response coordination, and policy maturity assessment. While reporting lines to the Board are mentioned, the primary focus is on operational program activities rather than governance oversight structure. The disclosure is firm-specific due to the naming of the non-standard 'Cybersecurity Committee'.


reasoning: Paragraph describes the governance oversight structure (board → audit committee → CTO → program), including reporting lines, briefing cadences, and board expertise. While the CTO's qualifications are mentioned, they support the governance description rather than constituting a standalone management profile.


reasoning: The paragraph describes the company's internal processes for assessing and monitoring its cybersecurity program, including internal audit assessments, annual third-party reviews, and regulatory examinations. While it mentions reporting lines to board committees, the focus is on the assessment mechanisms rather than governance structure. It contains firm-specific organizational details (the Internal Audit Department 'IAD' and the committee 'BOTC') that are unique to this disclosure.


reasoning: The paragraph contains a backward-looking materiality assessment ('have not yet experienced any material impacts') and discusses potential financial costs and business impact, which fits Strategy Integration. It lacks specific dates, dollar amounts, named roles, frameworks, or other identifying details, making it generic boilerplate language that could apply to any company.


reasoning: The paragraph describes the governance chain for cybersecurity oversight: the Board oversees risk, the Audit Committee receives briefings from management, and CEO/CFO implement the program. This is a classic governance-structure disclosure where officers appear as grammatical subjects but the purpose is describing oversight flow, not individual qualifications. No specific frameworks, dates, dollar amounts, or cybersecurity-specific roles (e.g., CISO) are named.


reasoning: The paragraph primarily describes the company's Cybersecurity Program, including notification/escalation procedures, severity thresholds, and incident review protocols with the Audit Committee. Applying Step 2 (Person-Removal Test): removing the sentence about the independent Board member's IT experience leaves a coherent standalone description of internal risk management processes. The remaining content centers on program operations, not governance structure or individual roles. Specificity is Firm-Specific due to named entities (Angel Oak Capital, Manager), the capitalized internal program name, and unique Board expertise descriptors tied to the mortgage sector.


reasoning: The paragraph describes the governance oversight structure, specifically the ISMS and Data Protection Governance Committees, and the reporting line from the interim CSO/DPO to the audit committee. While it mentions management roles, the purpose is to explain the oversight chain (board committee ← officers ← management committees), which falls under Board Governance per the tiebreaker rules. It names specific cybersecurity roles (interim CSO, DPO) and specific committee names, making it Firm-Specific.


reasoning: The paragraph describes internal processes for risk communication and incident reporting (management meetings and escalation protocols), not board oversight or individual qualifications. While named officers appear, removing them leaves a coherent process description (reporting structure and risk discussions), and no certifications or experience are provided, making this Risk Management Process under the three-step test. The specificity is Firm-Specific because it identifies the 'IT Team Director' as a specific organizational role responsible for cybersecurity, which is more specific than generic 'management' references.


reasoning: While the paragraph opens with board oversight mechanisms, the substantive disclosure focuses on the identification and detailed qualifications of specific cybersecurity leaders (CDTO, CIO, and CISO consultant), including years of experience, educational degrees, and industry backgrounds. Per the tiebreaker rule, when management roles and qualifications are the main focus with specific biographical details, the category is Management Role. The specificity is Quantified-Verifiable due to multiple hard facts: 'over 25 years' and 'approximately 15 years' of experience (specific durations), along with named credentials (MIS degree, MBA) and specific cybersecurity titles.


reasoning: Paragraph focuses on management's responsibility for cybersecurity and explicitly describes their qualifications (lack of specialized cybersecurity backgrounds, general experience in other areas), triggering Step 3 of the MR vs RMP test. Audit Committee appears only briefly as a recipient of material incident reports, confirming management as the primary focus. No specific facts from the ✓ IS list are present (CEO, COO, CAO are generic C-suite; Audit Committee is standard governance; no dates, numbers, named firms, or certifications listed).


reasoning: The paragraph describes a governance chain (cybersecurity team → Disclosure Committee → Strategy Board → Audit Committee → Board) explaining how information flows upward to the Board, which fits the Board Governance definition. It identifies firm-specific elements including the CISO, CIO, Incident Response Team, Disclosure Committee, Strategy Board, and specific departmental composition of the response team.


reasoning: The paragraph primarily describes the company's internal monitoring and detection processes (briefings, threat intelligence, security tools) rather than focusing on governance structure or board oversight mechanics. Although the CISO and ERMC are mentioned, they serve as actors within the process description rather than being the primary subject of the disclosure.


reasoning: The paragraph describes the company's internal cybersecurity operations, incident response team structure, and monitoring processes. While it mentions reporting lines to the Board, the primary focus is on the program's operational implementation and internal coordination (RMP), not board oversight mechanics (BG). Applying the person-removal test, the text remains a coherent description of the cybersecurity program without the named roles. Specific organizational details (CISO, Incident Response Team composition, Disclosure Committee, Strategy Board) make this Firm-Specific, but no quantifiable data (dates, dollars, headcounts, external firms) reach the Quantified-Verifiable threshold.


reasoning: The paragraph primarily describes the governance chain and oversight structure, detailing how the Board, Audit Committee, CIDO, and CISO interact regarding cybersecurity oversight, reporting lines, and information flow. While it mentions management qualifications (Management Role) and third-party risk activities (Risk Management Process), the central purpose is depicting the governance framework and oversight cadence.


reasoning: Paragraph describes Tripadvisor's internal governance structure for cybersecurity risk management, including specific management committees (Compliance Committee, Information Governance and Privacy Committee) and their departmental compositions. While officers are mentioned, the focus is on the oversight process and committee functions, not individual qualifications, placing it in Risk Management Process rather than Management Role.


reasoning: The paragraph describes the governance chain from the Board to the Audit Committee to the CIO and SIRT, including reporting cadences and oversight mechanisms, which constitutes Board Governance. It contains firm-specific elements including cybersecurity-specific titles (CIO, SIRT) and named security standards (NIST, ISO, COBIT, ITIL).


reasoning: The paragraph primarily describes the company's internal information security program and the specific technical controls and methods employed (firewalls, intrusion prevention systems, SIEM, endpoint detection, etc.), which falls under Risk Management Process. While it mentions Board reporting channels for the Chief Compliance Officer, this governance aspect is secondary to the detailed description of the security program itself. The specificity is Firm-Specific due to the unique cybersecurity-related title 'Chief Security & Cash Operations Officer' (a combined role specific to this ATM/payments company); other mentioned roles (Chief Risk Officer, Chief Compliance Officer) are generic C-suite positions, and the security technologies listed are generic categories rather than specific product names.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk, detailing the reporting chain from the Director of Information Technology through the Chief People Officer to the audit committee, with participation from the CFO, CLO, and board of directors. This focuses on how the board exercises oversight and how information flows upward (Board Governance), rather than individual qualifications (Management Role) or technical processes (Risk Management Process). It is Firm-Specific because it identifies the specific roles constituting the governance chain—particularly the Director of Information Technology as the cybersecurity lead rather than a CISO or CIO, and the involvement of the Chief People Officer and Chief Legal Officer in oversight—though it lacks quantifiable data or dates that would make it Quantified-Verifiable.