content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: Paragraph contains only generic forward-looking disclaimers and a cross-reference to Risk Factors, with no substantive cybersecurity disclosure or materiality assessment.

provider: xiaomi

stage: benchmark


reasoning: This paragraph consists of generic forward-looking risk warnings about cybersecurity threats and potential material adverse effects, with no specific incident, governance, process, or materiality assessment, making it boilerplate non-substantive content.


content_category: Strategy Integration

reasoning: The paragraph includes a materiality assessment stating that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company, which is the core of Strategy Integration. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph is generic cybersecurity risk acknowledgment with no substantive disclosure on governance, processes, incidents, or strategies, and contains no specific facts, making it boilerplate language.


reasoning: The paragraph contains a materiality assessment stating that the company has not been materially affected by cybersecurity breaches to date, which is a core element of Strategy Integration. It lacks any specific incident details, governance descriptions, or verifiable facts, making it generic boilerplate.


content_category: Board Governance

reasoning: The paragraph describes the governance structure where the Board oversees risk management and the Chief Risk Officer reports to the Board, focusing on oversight rather than specific processes or roles.


reasoning: The paragraph describes the oversight structure with specific cybersecurity roles reporting to named committees (Audit Committee and QRC), which is core to board governance.


content_category: Risk Management Process

reasoning: The paragraph describes internal cybersecurity processes and program implementation led by the Director and management, with no focus on board oversight or individual qualifications, fitting Risk Management Process. It includes a specific cybersecurity role title, making it Firm-Specific.


reasoning: The paragraph is a materiality assessment stating no previous material cybersecurity threats and a forward-looking qualifier, which is a conclusion about business impact, fitting Strategy Integration. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph includes a negative materiality assertion ('have not experienced a material cybersecurity incident'), which qualifies as a materiality assessment under Strategy Integration. It contains no verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the board-approved IT/Cybersecurity Committee's oversight structure, including its composition, meeting cadence, and reporting lines to the board, which is central to board governance of cybersecurity.


reasoning: The paragraph is a forward-looking disclaimer about material impact and a cross-reference to risk factors, with no substantive disclosure on cybersecurity governance, processes, or incidents, fitting 'None/Other'.


reasoning: The paragraph primarily consists of generic risk warnings and a cross-reference to another section for materiality information, with no substantive disclosure about governance, processes, or incidents.


reasoning: The paragraph describes the oversight structure for cybersecurity risk through specific committees and escalation processes, which is the core of Board Governance, focusing on how oversight is exercised rather than individual roles or incidents.


reasoning: The paragraph describes the oversight structure for cybersecurity, detailing how the CISO reports to the Cybersecurity Executive Steering Body and escalates matters to the Audit Committee, which is core to board governance.


reasoning: The paragraph describes the oversight structure where the ITSC and Chief Information Officer report to the Board quarterly, which is central to Board Governance, and includes specific roles and cadence that are firm-specific.


reasoning: The paragraph focuses on the oversight structure, detailing how the Audit Committee directs the CIO and SIRT, with reporting lines to the Board, which is characteristic of Board Governance. It includes specific roles (CIO) and named standards, making it Firm-Specific.


reasoning: The paragraph focuses on the oversight structure for cybersecurity risk, detailing how the Board, specific committees (Governance and Compliance Committee, Technology Committee), and the CISO interact, which aligns with Board Governance.


specificity_confidence: medium

reasoning: The paragraph focuses on the oversight structure where IT Management reports to the Risk Committee on cybersecurity matters, fitting Board Governance. The named Risk Committee is a specific, non-generic committee, making it Firm-Specific.


reasoning: The paragraph focuses on the process of reporting cybersecurity risks to executive leadership and integrating them into enterprise risk management through internal audit, which is a description of internal risk management procedures. The mention of the Chief Security and Trust Officer provides a firm-specific detail but does not shift the focus to the individual's qualifications or governance oversight.


reasoning: The paragraph describes the Cyber Security Watch Team's role in managing cybersecurity risks, implementing controls, and reviewing programs, which is centered on internal risk management processes rather than board oversight or individual management roles.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, with the Board and specific committees overseeing risk and management roles handling operational aspects, which is characteristic of Board Governance.


reasoning: The paragraph describes the oversight structure through a named cybersecurity committee and designated local officers responsible for monitoring risks, which aligns with Board Governance.


reasoning: The paragraph is a materiality assessment concluding that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company, which is the defining characteristic of Strategy Integration.


reasoning: The paragraph contains a backward-looking materiality assessment concluding that no cybersecurity threats have materially affected the company, which is a core element of Strategy Integration. It lacks any verifiable facts, named entities, or specific details, making it generic boilerplate common in SEC filings.


reasoning: The paragraph describes the governance chain from the Information Security Department to the Board Risk Committee, focusing on oversight structure and reporting lines, which aligns with Board Governance. It includes specific roles and committees like CISO and Risk Management Council, making it Firm-Specific.


reasoning: The paragraph describes the integration of cybersecurity risk management into business processes through collaboration between enterprise risk management and IT teams, which is core to Risk Management Process. It does not focus on board oversight, individual qualifications, or incidents.


reasoning: The paragraph describes the governance structure where management (CIO and General Counsel) regularly reports to the Board on cybersecurity oversight topics, which is core to Board Governance. It includes the cybersecurity-specific title 'Chief Information Officer,' making it Firm-Specific.


reasoning: The paragraph primarily presents materiality assessments, stating that cybersecurity incidents have not materially affected the business to date and includes forward-looking disclaimers, which aligns with Strategy Integration. It lacks any specific details, making it generic boilerplate.


reasoning: The paragraph primarily describes the risk management program and cybersecurity as a component, with the CISO and committee mentioned as part of the process structure, not as the main focus on governance oversight.


reasoning: The paragraph includes a materiality assessment (negative assertion about past incidents) and generic risk warnings about future material effects, which aligns with Strategy Integration. It contains no specific details, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes management's monitoring activities for cybersecurity risks through processes like briefings and threat intelligence, with specific roles mentioned but no individual qualifications, making it process-focused rather than about the individuals themselves.


category_confidence: medium

reasoning: The paragraph describes management's involvement in steering the cybersecurity program using a multi-disciplinary approach and a 'three lines of defense' model, which focuses on internal processes rather than individual management qualifications or board oversight.


reasoning: The paragraph describes the company's internal processes for cybersecurity threat monitoring, incident response, and reporting, which aligns with Risk Management Process. It includes firm-specific details like the Sr Director of Tech role and a defined cross-functional team composition.


reasoning: The paragraph focuses on describing the company's cybersecurity risk management program and processes, including oversight roles, which aligns with Risk Management Process. It contains specific cybersecurity titles and experience details, making it Firm-Specific.


reasoning: The paragraph describes the oversight structure of cybersecurity risk through the ERC committee, including its delegated authority from the BRC and specific officer roles, which fits Board Governance, and contains firm-specific committee names and titles.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management process, including the structure led by the CIO and implementation of a specific plan, with no focus on individual qualifications or board oversight.


reasoning: The paragraph describes the oversight structure where management supervises cybersecurity efforts and reports to the board, aligning with Board Governance. It contains no specific dates, named entities, or verifiable facts, making it Generic Boilerplate.


reasoning: This paragraph is a cross-reference to risk factors and does not contain substantive cybersecurity disclosure, making it None/Other with Generic Boilerplate specificity.


reasoning: The paragraph describes the InfoSec Leadership Team's involvement in monitoring and managing cybersecurity incidents through internal processes like incident response plans, which aligns with Risk Management Process. It lacks specific dates, amounts, or named entities beyond a generic team reference, making it Generic Boilerplate.


reasoning: The paragraph describes the delegation of cybersecurity risk management to a specific council (ISC) and its functions, such as monitoring and escalating risks, which aligns with internal risk management processes rather than board governance or individual management roles.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including specific committees and reporting lines, which aligns with Board Governance. It contains firm-specific details like named roles and committees, making it Firm-Specific.


reasoning: The paragraph describes internal cybersecurity processes like monitoring, incident response policy, and training, with management roles mentioned incidentally, fitting Risk Management Process. It is Firm-Specific due to the cybersecurity-specific title and specific departmental composition.


reasoning: The paragraph describes an internal management program and executive security council that oversee cybersecurity strategy and effectiveness, which is a risk management process. The named 'executive security council' is a specific, non-generic committee, making the disclosure firm-specific.


content_category: Management Role

reasoning: The paragraph identifies the CDO and describes their responsibilities in directing cybersecurity activities, which is focused on a management role rather than a process or governance structure.


reasoning: The paragraph focuses on identifying the ISO, team composition, and reporting lines, which are about who is responsible for cybersecurity, aligning with Management Role. It includes firm-specific details such as the cybersecurity-specific ISO title and specific departmental composition.


reasoning: The paragraph describes the oversight structure through a cross-functional Compliance Committee that assesses cybersecurity risks and escalates to senior management and the Board, fitting the Board Governance category.


reasoning: The paragraph focuses on the qualifications of the Senior Director of Cybersecurity and the structure of the security steering committee, which aligns with Management Role content. It includes specific facts like the role title, years of experience, and committee details, making it Firm-Specific.


reasoning: The paragraph is a generic forward-looking risk warning about data breaches with no substantive disclosure about the company's cybersecurity governance, processes, or incidents, fitting None/Other and Generic Boilerplate.


reasoning: The paragraph focuses on the company's internal cybersecurity incident response processes, including threat monitoring, severity assessment, and reporting procedures, which is characteristic of Risk Management Process. It includes firm-specific details such as the VP of Tech role and a defined cross-functional team composition.


reasoning: The paragraph is generic IT-dependence language with no substantive cybersecurity disclosure, such as governance, processes, incidents, or materiality assessments, fitting None/Other.


reasoning: The paragraph details Honda's internal cybersecurity risk management structure, focusing on designated divisions, headcount, and reporting lines, which aligns with Risk Management Process, and includes firm-specific facts like the number of members and named organizational divisions.


reasoning: The paragraph describes the cybersecurity governance structure, detailing reporting lines from the CISO to the Board via the Audit Committee, which is central to Board Governance.


reasoning: This paragraph is a cross-reference to risk factors in Item 1A, which is standard boilerplate language without substantive cybersecurity disclosure, fitting the None/Other category.


reasoning: The paragraph describes management's general responsibilities in cybersecurity risk management, such as integrating risk into business processes and approving budgets, which aligns with internal processes rather than identifying specific roles or qualifications, and it contains no specific details like names, dates, or frameworks.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including policies, tools, third-party assessments, and incident response planning, with the CFO mentioned in an oversight role but not the primary focus. It names the ISO 27001 standard, which is a recognized framework, but contains no unique firm-specific details.


reasoning: This paragraph is a generic forward-looking risk warning about potential operational disruptions from cybersecurity incidents, with no specific details or substantive disclosure, fitting the None/Other category.


reasoning: The paragraph is a generic risk warning about potential cybersecurity incidents with no specific details on governance, processes, or actual events, fitting None/Other, and it lacks any verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph focuses on the oversight structure, detailing how the Audit Committee and Board are briefed on cybersecurity risks and the reporting role of the Chief Information Officer, which is central to Board Governance.


reasoning: The paragraph describes general cybersecurity risk management processes supervised by management, with no specific details, verifiable facts, or named standards, making it applicable to any company.


reasoning: The paragraph describes the oversight structure with the cybersecurity team reporting to the Audit Committee on cybersecurity risks and programs, which is central to Board Governance. It lacks any firm-specific details, using generic terms like 'Audit Committee' and 'quarterly' without verifiable facts.


reasoning: The paragraph primarily focuses on the qualifications and reporting lines of the CISO and COO, with detailed experience years, making management roles the central topic. It contains two hard verifiable facts (specific durations of experience), meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph focuses on identifying specific management roles (General Counsel and Assistant General Counsel – Compliance) responsible for driving the cybersecurity program and risk management, which aligns with the Management Role category. It is Firm-Specific because it names unique roles involved in cybersecurity governance at this company, though no hard verifiable facts like dates or numbers are present.


reasoning: The paragraph describes the board-approved committee structure and reporting lines for cybersecurity oversight, which is central to Board Governance, with specific roles and a named committee indicating firm-specific details.


reasoning: The paragraph describes the governance structure for cybersecurity oversight through the TRCC committee, including its composition and responsibilities, which aligns with Board Governance. It contains firm-specific details like named committees and roles.


reasoning: The paragraph contains a backward-looking materiality assessment stating that cybersecurity threats have not materially affected the company to date, which aligns with Strategy Integration. It includes no specific facts, frameworks, or verifiable details, making it generic boilerplate.


reasoning: The paragraph focuses on the company's internal process for identifying and assessing cybersecurity risks with the help of a third-party firm and an internal IT lead, fitting Risk Management Process. It lacks any named entities, dates, or verifiable details, making it generic boilerplate applicable to many companies.


reasoning: The paragraph describes the cybersecurity team's ongoing processes for monitoring, evaluating, and managing risk, which aligns with Risk Management Process, and it lacks any unique company-specific details or verifiable facts such as dates, amounts, or named entities.


reasoning: The paragraph describes the management team's responsibilities in overseeing the cyber risk management program and the Audit Committee's oversight, focusing on internal processes without specific details or qualifications.


reasoning: The paragraph is a generic description of cybersecurity threats without any reference to specific incidents, governance, processes, or materiality assessments, making it non-substantive boilerplate.


reasoning: The paragraph describes the management team's responsibilities in assessing and managing cybersecurity risks as part of the internal risk management process, with no focus on individual qualifications or specific details.


reasoning: The paragraph centers on who implements cybersecurity processes, detailing a specific role and qualifications, which aligns with Management Role. It includes firm-specific facts like a cybersecurity-related title and quantified experience duration.


reasoning: The paragraph is a generic risk warning about cybersecurity vulnerabilities and the company's lack of resources, with no substantive disclosure of processes, governance, or incidents. It contains no specific facts, named standards, or verifiable details, making it boilerplate language.


reasoning: The paragraph primarily contains a backward-looking materiality assessment ('risks have not materially affected us'), which is a core element of Strategy Integration, while the mention of past incidents is vague and not the main focus.


reasoning: The paragraph describes the governance oversight structure, detailing how management reports cybersecurity matters to the Information Technology Steering Committee quarterly and to the Board annually, which aligns with Board Governance.


reasoning: The paragraph describes the internal cybersecurity team's structure, responsibilities, and qualifications as part of the company's risk management processes, with specific roles and certifications indicating firm-specific details.


reasoning: The paragraph describes the governance structure where an internal working group with senior management implements cybersecurity programs and reports to the Board, fitting Board Governance; it includes a cybersecurity-specific title (CISO), making it Firm-Specific.


reasoning: The paragraph focuses on the CSIRT's activities in risk assessment, incident response, and compliance, which are core risk management processes, with the Director mentioned as leading but not the primary subject. It includes a cybersecurity-specific title and a specific number of years of experience, making it Firm-Specific.


reasoning: The paragraph describes the governance structure for cybersecurity risk oversight, detailing a management-led Risk Committee that reports to a board committee, which fits the Board Governance category.


reasoning: The paragraph describes the governance/oversight structure with reporting lines to the board, and includes specific cybersecurity roles and a named committee, making it firm-specific.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including specific committees, reporting lines to the CEO and board, and review processes, which aligns with Board Governance.


reasoning: The paragraph describes the cybersecurity governance structure, including reporting lines from the CIO to the Executive Leadership Team and Audit Committee, and escalation protocols to the Board, which aligns with Board Governance.


reasoning: The paragraph focuses on the cybersecurity oversight structure, detailing reporting lines from the CISO to the Board and Audit Committee, which aligns with Board Governance. It includes firm-specific elements like the CISO role and the Enterprise Risk Management Committee, making it Firm-Specific.


reasoning: The paragraph describes the governance structure with the CTO reporting to a committee and the committee reporting to the board, focusing on oversight processes. The mention of the Chief Technology Officer, a cybersecurity-specific role, makes it Firm-Specific.


reasoning: The paragraph provides a materiality assessment by stating no material cybersecurity incidents have occurred and discusses potential financial impacts and insurance limitations, which is characteristic of Strategy Integration.


reasoning: The paragraph contains a materiality assessment stating that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition, which is a conclusion about business outcomes. It lacks any specific dates, names, or verifiable details, using standard boilerplate language.


reasoning: The paragraph describes the cybersecurity oversight structure involving the Board, Audit Committee, and a specific management role, which aligns with Board Governance as it focuses on governance chain and information flow.


reasoning: The paragraph states a backward-looking materiality assessment that no cybersecurity threats have materially affected the company, which is a core element of Strategy Integration. It contains no specific facts about the company's cybersecurity program, consisting only of boilerplate materiality language and a cross-reference.


reasoning: The paragraph primarily describes the qualifications and experience of the leaders overseeing cybersecurity processes, focusing on who they are rather than the processes themselves.


reasoning: The paragraph focuses on the oversight structure, detailing specific roles, a named internal team, and reporting cadence to the board and audit committee, which aligns with Board Governance.


reasoning: The paragraph describes the CISO's ongoing education and the cybersecurity team's processes for monitoring and incident response, which are internal risk management activities, with no focus on governance, incidents, or materiality.


reasoning: The paragraph describes the board-approved committee's oversight structure, reporting lines to the board, and committee composition, which is central to governance rather than individual roles or processes.


content_category: Third-Party Risk

reasoning: The paragraph centers on overseeing cybersecurity risks from third-party service providers, with vendor oversight as the primary focus, and includes a specific team composition from the Investment Adviser.


reasoning: The paragraph describes the governance structure for cybersecurity risk oversight, with the Board and a named committee overseeing the IT management team and specific C-suite roles, fitting Board Governance. It includes a named non-generic committee, making it Firm-Specific.


reasoning: The paragraph focuses on the qualifications and composition of the management team responsible for cybersecurity, including specific roles (CTO, CISO) and years of experience, rather than describing the risk management processes in detail.


reasoning: The paragraph describes the cybersecurity risk management processes led by the Director of Information Technology, focusing on methods for identifying and assessing risks, which aligns with Risk Management Process. It contains no verifiable facts, named standards, or unique details, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the cybersecurity oversight structure with the CISO coordinating teams and reporting to the audit committee or board, which is a governance chain. It includes the cybersecurity-specific title 'CISO', making it firm-specific.


reasoning: The paragraph primarily describes the governance oversight structure, including Board and Audit Committee engagement, briefing cadence, and CIO reporting lines, which aligns with Board Governance. The CIO's experience is mentioned but is secondary to the oversight framework.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, including incident response, monitoring, testing, insurance, and reporting, with board oversight and management roles integrated as part of the overall program structure.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including management evaluation and reporting by the BDT & MSD CTO to the board, which aligns with Board Governance rather than focusing on individual roles or processes alone.


reasoning: The paragraph describes the oversight structure with Board oversight and CFO direction, which is characteristic of Board Governance disclosures focusing on governance hierarchy.


reasoning: The paragraph is a materiality assessment concluding that cybersecurity threats have not materially affected the company and are not reasonably likely to do so, which is a defining feature of Strategy Integration. The language is entirely generic with no specific dates, names, or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph primarily describes internal cybersecurity processes, including incident response procedures and coordination of initiatives, which are core elements of risk management, with board oversight mentioned as contextual governance.


reasoning: The paragraph describes the company's internal cyber risk management process, including management roles and resource investments, without focusing on qualifications, incidents, or materiality. It lacks hard verifiable facts, named standards, or cybersecurity-specific titles as defined, making it generic.


reasoning: The paragraph describes the board's oversight responsibility and the governance chain from management to the board, fitting Board Governance. It includes multiple specific fiscal years as hard verifiable facts, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the cybersecurity governance structure involving the Board, Audit Committee, management, and a Security Steering Group with specific officer roles, which aligns with Board Governance. It contains firm-specific details like the named SSG committee and cybersecurity-specific titles, making it Firm-Specific.


reasoning: The paragraph describes the composition of the ISO Committee, listing specific executives and their roles, which is focused on governance oversight structure rather than individual qualifications or processes.


reasoning: The paragraph describes the oversight structure with the SVP of IT briefing senior management on cybersecurity, fitting governance/oversight description. It includes a specific cybersecurity-related title (SVP of IT), making it Firm-Specific.


reasoning: The paragraph describes the oversight structure and reporting cadence from the CTO to the Audit and Finance Committee and executive teams, which is central to Board Governance. It includes a named internal program (Digital QBR), making it Firm-Specific.


reasoning: The paragraph is a backward-looking materiality assessment stating no cybersecurity incidents have materially affected the company, which is the core of Strategy Integration. It contains no verifiable facts, named standards, or company-specific details, making it Generic Boilerplate.


reasoning: The paragraph describes the incident response team reporting structure and an advisory board with specific responsibilities, which are internal processes for managing cybersecurity risks, not focused on individual qualifications or board oversight details.


reasoning: The paragraph describes the company's outsourced information security team and reporting channels as part of its cyber risk management process, with no focus on board oversight, incident details, or materiality assessments. It contains no named entities, dates, or verifiable facts, using generic roles and unnamed service providers.


reasoning: The paragraph is centered on a materiality assessment, stating that cybersecurity threats have not materially affected the company and referencing forward-looking risks, which is characteristic of Strategy Integration.


reasoning: The paragraph focuses on materiality assessments of cybersecurity risks and incidents, which is a core element of Strategy Integration. It contains no specific dates, names, or verifiable facts, making it generic boilerplate language applicable to any company.


reasoning: The paragraph is a generic acknowledgment of cybersecurity risks without describing any specific processes, governance structures, incidents, or materiality assessments, fitting 'None/Other' for lack of substantive disclosure.


reasoning: The paragraph describes management's monitoring of cybersecurity prevention, detection, mitigation, and remediation processes, which is a core internal risk management procedure without focusing on individuals, incidents, or materiality.


reasoning: The paragraph focuses on identifying who is responsible for cybersecurity management—executive officers and a third-party consultant with qualifications—aligning with Management Role. It contains no specific dates, names, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph focuses on the oversight structure, detailing how a named committee with senior management including the CIO reports to the Board, which aligns with Board Governance. It includes firm-specific elements like the CIO title and the named Information Security Governance Committee.


reasoning: The paragraph describes the oversight structure where the CFO reports cybersecurity updates to the Board based on inputs from specific IT and security roles (DIT and DIS), fitting Board Governance. It includes firm-specific internal roles, making it Firm-Specific.


reasoning: The paragraph focuses on the governance structure by detailing how the CISO reports cybersecurity updates to committees and management, which aligns with board oversight processes.


reasoning: The paragraph contains a backward-looking materiality assessment stating no prior material incidents, which is a core element of Strategy Integration, and it lacks any specific details such as dates, names, or figures, making it Generic Boilerplate.


reasoning: The paragraph describes the cybersecurity oversight structure involving the Board, Audit Committee, CFO, and IT Director, which is characteristic of Board Governance, and includes firm-specific organizational details like reporting lines and roles.


reasoning: The paragraph focuses on the Vice President of Informatics's qualifications, experience, and responsibilities in leading cybersecurity processes, which is characteristic of Management Role.


reasoning: The paragraph describes management's responsibility for cybersecurity implementation and reporting to the Board, focusing on the oversight structure rather than specific processes or individuals.


reasoning: The paragraph is a materiality assessment stating no material impact from cybersecurity incidents, which aligns with Strategy Integration. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the cybersecurity oversight structure, including board responsibility, management roles, and reporting lines to the Audit Committee, which aligns with Board Governance. It contains one firm-specific fact (100% independent directors on the Audit Committee), making it Firm-Specific.


reasoning: The paragraph primarily describes the company's cybersecurity program, risk assessments, and controls, with management roles mentioned as part of the process implementation, fitting Risk Management Process. The specific roles (CISO, CTO, CIO) make it Firm-Specific.


reasoning: The paragraph focuses on management's role in supervising cybersecurity processes, which aligns with Risk Management Process, and it contains no specific verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph contains a backward-looking materiality assessment stating that cybersecurity risks have not materially affected the company, which is a core element of Strategy Integration, and it lacks any specific details about incidents, processes, or governance, making it Generic Boilerplate.


reasoning: The paragraph describes the governance chain from the Board to the Audit Committee to specific officers, focusing on oversight structure, which aligns with Board Governance. It includes cybersecurity-specific titles (CTO and VPCS), making it Firm-Specific.


reasoning: The paragraph describes internal cybersecurity management processes, such as personnel capabilities and strategy, without focusing on specific individuals or governance structures, fitting Risk Management Process. It contains no specific facts, named entities, or verifiable details, making it generic boilerplate.


reasoning: The paragraph focuses on the Board's active oversight of cybersecurity within the risk management program, fitting Board Governance. It references recognized frameworks (ISO, NIST) but contains no unique company-specific details, making it Sector-Adapted.


reasoning: The paragraph describes management's reporting obligations to the Audit Committee and Board in the event of a cybersecurity incident, which is focused on governance oversight structure rather than incident details, management roles, or risk processes.


reasoning: The paragraph focuses on the company's internal risk assessment and mitigation process, which stands alone without the mentioned managers, making it Risk Management Process. It includes specific roles and experience durations, qualifying as Firm-Specific.


reasoning: The paragraph lists generic, forward-looking cybersecurity risks (e.g., data breaches, service disruption) without describing any actual incident, governance structure, or management processes, fitting the 'None/Other' category for non-substantive risk warnings.


reasoning: The paragraph describes the oversight structure with the Audit Committee receiving updates from the CIO/CISO, which is core to Board Governance. It includes cybersecurity-specific titles, making it Firm-Specific.


reasoning: The paragraph describes the oversight structure by detailing how executive officers provide periodic briefings to the Board on cybersecurity risks and activities, which is a core governance function.


reasoning: The paragraph describes the governance structure with management reporting to the board and audit committee on cybersecurity, which is core to Board Governance. It includes a specific date (2024) for audit committee updates, making it Firm-Specific.


reasoning: The paragraph is a cross-reference to risk factors in Item 1A, containing no substantive cybersecurity disclosure and only generic materiality language, fitting None/Other.


reasoning: The paragraph explicitly states the company has no cybersecurity program or formal processes, which aligns with the SPAC/shell company tiebreaker for 'None/Other' classification.


reasoning: The paragraph primarily describes the company's risk management process and integration of cybersecurity practices, with Board oversight mentioned briefly; it names recognized frameworks (NIST and ISO) but contains no unique company-specific details.


reasoning: The paragraph describes the oversight structure where management briefs the audit committee on cybersecurity, and the committee updates the board, focusing on governance flow rather than specific processes or roles.


reasoning: The paragraph focuses on the board's oversight structure and the CIO's reporting cadence to the board, which defines the governance chain. It includes firm-specific details such as cybersecurity-specific titles and the CIO's years of experience.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management program and the team's responsibilities, with the person-removal test showing coherent process disclosure, making it Risk Management Process. It includes firm-specific details like the SVP's title and experience, justifying Firm-Specific specificity.


reasoning: The paragraph describes the governance oversight structure, detailing how cybersecurity information flows from the CISO to management and escalates to the Compliance Committee and Board, which aligns with Board Governance.


reasoning: The paragraph primarily identifies the executive team, including the CEO and CFO, and details their responsibilities in cybersecurity risk management, which aligns with the Management Role category.


reasoning: The paragraph describes the oversight structure with the board committee responsible for cybersecurity risk and reporting from the Information Security Officer, which is core to Board Governance. The specific title 'Information Security Officer' makes it Firm-Specific, though no other verifiable facts are present.


reasoning: The paragraph describes the oversight structure of the cybersecurity program through an Information Security committee that reviews threats and approves strategy, which aligns with Board Governance. It includes specific roles like CISO and a named committee, making it Firm-Specific.


reasoning: The paragraph explicitly states the company was a SPAC with no operations and has not adopted any cybersecurity risk management program, which aligns with the None/Other category for SPACs/shell companies. As per instructions, None/Other paragraphs are always classified as Generic Boilerplate.


reasoning: The paragraph describes the oversight structure of the Engineering Risk Steering Group, including its chair (CISO) and reporting line to the Firmwide Technology Risk Committee, which aligns with board governance of cyber risk.


reasoning: The paragraph includes a negative materiality assessment ('have not experienced a cybersecurity incident that we deemed to be material'), which is a core element of Strategy Integration, but the content is generic with no specific dates, names, or verifiable facts, making it boilerplate.


reasoning: The paragraph describes the oversight structure where the CISO and CRO support the Board and risk committee, focusing on governance and information flow, which aligns with Board Governance. It includes firm-specific roles and a named committee, making it Firm-Specific.


reasoning: The paragraph describes the governance oversight structure with CISO and CIO reporting to the Board and Audit Committee, which aligns with Board Governance. It includes cybersecurity-specific roles (CISO and CIO), making it Firm-Specific per the criteria.


reasoning: The paragraph describes the governance structure with Board oversight delegated to the Audit and Compliance Committee and management reporting, which is central to Board Governance, and includes the specific CIO role.


reasoning: This paragraph is a cross-reference to risk factors and does not contain any substantive cybersecurity disclosure; it merely directs the reader to another section of the filing.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, such as the IS Program and incident response plan, with the Board and CISO mentioned as part of the oversight structure. After removing person-specific details, the processes remain coherent, indicating a focus on risk management.


reasoning: The paragraph states a negative materiality assessment ('we have not experienced any material cybersecurity threats or incidents'), which aligns with Strategy Integration per the tiebreakers. It lacks any verifiable facts, named entities, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the internal oversight structure for cybersecurity risk management processes by specific teams, which is core to Risk Management Process. It is Firm-Specific because it lists a unique composition of teams overseeing these processes.


reasoning: The paragraph describes a governance structure with CFO direction and Board oversight, focusing on oversight structure, which aligns with Board Governance. It contains no verifiable facts, named standards, or unique details, making it generic boilerplate.


reasoning: The paragraph is a cross-reference to risk factor disclosures in Item 1A, providing no substantive cybersecurity information on its own, which aligns with the None/Other category for non-substantive content.


reasoning: The paragraph describes the governance structure for risk management, including the Enterprise Risk Committee and reporting lines, which is central to Board Governance, and includes specific facts about committee composition and director qualifications.


reasoning: The paragraph describes the governance structure with the CISO leading the information security team and specific board committees providing oversight, aligning with Board Governance.


reasoning: The paragraph contains only generic cybersecurity risk warnings and potential material adverse effects without describing any specific governance, processes, or incidents, fitting the None/Other category.


reasoning: The paragraph describes the governance chain from board to management for cybersecurity oversight, which is the primary focus, and includes verifiable facts such as the CISO's years of experience and specific certifications.


reasoning: The paragraph's main point is a negative materiality assertion ('no material cybersecurity threats and incidents incurred to-date'), which is a materiality assessment, and it includes generic risk warnings and cross-references, fitting Strategy Integration.


reasoning: The paragraph describes the governance oversight structure where the board delegates cybersecurity oversight to a subsidiary committee, which is the core of Board Governance. It contains firm-specific details such as the named Information Security Committee and the CEO's name.


reasoning: The paragraph describes the governance/oversight structure, including how the Information Security team updates documents for Audit & Risk Committee review and how the CISO oversees a strategic plan with committee involvement, focusing on board-level oversight processes.


reasoning: The paragraph describes management's role in overseeing cybersecurity assessment and incident response procedures, which aligns with internal risk management processes rather than focusing on specific individuals, board governance details, or disclosed incidents.


reasoning: The paragraph primarily describes the company's internal security procedures and general cybersecurity threat landscape, with no specific governance, management roles, or incident details, making it a risk management process description.


reasoning: The paragraph primarily provides a materiality assessment by stating no material cybersecurity events have occurred and includes a generic risk warning, fitting Strategy Integration as it concludes on material impact without describing specific incidents or processes.


reasoning: The paragraph describes the oversight structure with the CISO and Cybersecurity Committee overseeing and being informed about cybersecurity policies, which is central to Board Governance rather than detailing individual roles or specific processes.


reasoning: The paragraph details the oversight responsibilities of a specific committee within the governance structure, including reporting to a board committee, which is characteristic of Board Governance.


reasoning: The paragraph describes the internal process for incident management, including team composition and communication protocols, without focusing on individual qualifications or actual incidents.


reasoning: The paragraph describes generic IT-dependence and data handling context without substantive cybersecurity disclosure, fitting 'None/Other'. It names recognized regulations (HIPAA and CCPA), making specificity 'Sector-Adapted'.


reasoning: The paragraph focuses on the oversight structure where the Management Team reports to the Board of Directors during cybersecurity incidents, which aligns with Board Governance. It contains no named frameworks, specific dates, or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph focuses on the IT Lead's qualifications and experience, which is central to Management Role, and includes firm-specific details like the role title and years of experience.


reasoning: The paragraph describes the organizational structure for managing cybersecurity risks through delegation to the General Partner and reliance on Blackstone, which aligns with Risk Management Process. It lacks specific dates, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes cybersecurity risk management processes such as defining work plans and setting improvement objectives led by the technology team and Director, aligning with Risk Management Process. It includes specific details like the Director's role and years of experience, making it Firm-Specific.


reasoning: The paragraph describes the oversight structure from the board to a specific committee and officers, including reporting cadence and qualifications, which is primarily about governance. The specific years of experience (30 and 22) provide two hard verifiable facts, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph includes a materiality assessment concluding that no material cybersecurity incidents have occurred to date, which is characteristic of Strategy Integration. It lacks any specific dates, names, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph states materiality assessments about cybersecurity threats, including backward-looking and forward-looking conclusions, which is characteristic of Strategy Integration. It contains no specific dates, names, or quantifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes the oversight structure for cybersecurity, with the Board, CFO, and VP of Internal Audit involved in governance and reporting, fitting Board Governance. It contains no specific dates, named entities, or verifiable facts, using generic cadences and unnamed third parties, making it Generic Boilerplate.


reasoning: The paragraph contains materiality assessments stating no material cybersecurity incidents or threats, which aligns with Strategy Integration, and lacks any specific facts, making it generic boilerplate.


reasoning: The paragraph focuses on management members (CFO and others) receiving cybersecurity briefings to assess and manage material risks, which centers on their role and preparedness in cybersecurity governance rather than detailing a specific process or oversight structure.


reasoning: The paragraph primarily describes the cybersecurity organization's internal processes, controls, and third-party risk management, with management roles mentioned only as part of the oversight structure, not their qualifications.


reasoning: The paragraph describes the oversight structure of cybersecurity threats through the IT Steering Committee and its reporting to the Risk Management committee, which aligns with Board Governance.


reasoning: The paragraph describes a management-level committee that oversees cybersecurity policy approval and reporting, which is part of the governance/oversight structure, fitting Board Governance.


reasoning: The paragraph describes the CISO's quarterly reporting to the Risk Committee, focusing on the oversight structure and information flow, which is central to board governance.


reasoning: The paragraph describes the oversight structure where the Director of Compliance reports to the Board on cybersecurity risks, which is core to Board Governance. It contains no specific dates, verifiable facts, or named standards, making it generic boilerplate.


reasoning: The paragraph describes the cybersecurity risk management process, including integration into overall risk management, responsibilities, and third-party engagement, with management roles mentioned as part of the process structure, not as the primary focus.


reasoning: The paragraph primarily identifies management roles (Information Security Manager and Chief Information Officer) with their qualifications, reporting lines, and experience, which aligns with the Management Role category.


reasoning: The paragraph describes the oversight structure with specific committees and officers reporting on cybersecurity, which is the purpose of Board Governance. It includes firm-specific details like named committees and roles, making it Firm-Specific.


reasoning: The paragraph describes the cybersecurity oversight structure, including reporting lines from management to the board and various committees, which is characteristic of Board Governance. It contains firm-specific details such as named roles and internal committees.


reasoning: The paragraph describes cybersecurity risk management processes such as monitoring, system audits, and incident response planning led by management roles, not their qualifications or board oversight structure.


reasoning: The paragraph describes the board's oversight responsibility and the reporting chain for cybersecurity incidents, which is characteristic of Board Governance. It contains no specific facts, dates, or standards, making it generic boilerplate.


reasoning: The paragraph's primary content is a materiality assessment concluding that no cybersecurity incidents have materially affected the company, which is characteristic of Strategy Integration. It contains no specific details such as dates, names, or quantifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the cybersecurity program's oversight and processes, including risk management and incident reporting, led by specific management roles, which aligns with Risk Management Process. The mention of the vice president of information technology services provides a firm-specific detail.


reasoning: The paragraph describes the composition of a technology and operations committee that includes cybersecurity leadership, which is part of the governance structure for overseeing cyber risk.


reasoning: The paragraph focuses on the qualifications, certifications, and ongoing training of cybersecurity personnel, which aligns with Management Role. It includes specific certifications and industry group names, making it Firm-Specific but lacking quantifiable hard facts for higher specificity.


reasoning: The paragraph describes the cybersecurity risk oversight structure, detailing the Board's role through its Risk Committee and management's involvement via specific roles and committees, which aligns with Board Governance.


reasoning: The paragraph describes the Board's oversight responsibility and the reporting structure from the Director of Information Technology to the Board, focusing on governance structure rather than specific processes or management qualifications.


reasoning: The paragraph primarily identifies the CISO and CTO as key management roles, detailing their reporting lines and specific responsibilities in cybersecurity oversight, which aligns with the Management Role category.


reasoning: The paragraph describes general cybersecurity threats and the company's risk management measures, such as implementing security controls, disaster recovery processes, and obtaining insurance, without detailing specific governance, roles, incidents, or verifiable facts.


reasoning: The paragraph primarily describes the board oversight structure, including CFO direction of cybersecurity programs and Audit Committee updates, which aligns with Board Governance, while also containing a materiality conclusion.


reasoning: The paragraph describes the company's risk management processes and framework, including specific roles and activities like testing, assessments, and monitoring, with the VP, ISS title being part of the process structure rather than focusing on individual qualifications or governance oversight alone.


reasoning: The paragraph primarily identifies the COO and Senior VP for Operations and their cybersecurity responsibilities, fitting Management Role. It contains no verifiable facts, named standards, or unique details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for monitoring cybersecurity incidents, including the deployment of security measures, system audits, and an incident response plan, with the InfoSec Director overseeing these activities, which aligns with Risk Management Process.


reasoning: The paragraph is a standalone materiality assessment concluding that no cybersecurity threats have materially affected or are reasonably likely to materially affect the company, which is the defining characteristic of Strategy Integration. It contains no specific facts, frameworks, or unique details, making it generic boilerplate language.


reasoning: The paragraph includes a materiality assessment ('we have not experienced a cybersecurity incident that resulted in a material adverse impact') and generic risk warnings, which fits Strategy Integration. It contains no specific dates, names, or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph is a negative assertion about the materiality of cybersecurity weaknesses, which qualifies as a materiality assessment under Strategy Integration.


reasoning: The paragraph describes the cybersecurity risk management process, including monitoring and response activities, with the Director of IT as the responsible party, but the focus is on the process rather than individual qualifications or specific details.


reasoning: The paragraph describes the governance oversight structure, including board briefings and management responsibilities, fitting Board Governance. It lacks any specific verifiable facts such as dates, names, or metrics, making it Generic Boilerplate.


reasoning: This paragraph is generic IT-dependence language stating that information systems are vital and vulnerable, with no substantive disclosure, specific details, or materiality assessment, fitting None/Other and Generic Boilerplate.


reasoning: The paragraph describes the governance chain and oversight structure, with the board and committees actively overseeing cybersecurity risk, which aligns with Board Governance. It contains multiple verifiable facts, including specific years of experience and certifications, meeting the threshold for Quantified-Verifiable specificity.


reasoning: The paragraph describes the governance structure with specific committees and reporting lines to the board, which is the primary focus, fitting Board Governance. It contains firm-specific details like named committees and officer titles.


reasoning: The paragraph primarily describes the Audit Committee's oversight structure and reporting chain for cybersecurity, which aligns with Board Governance, and includes firm-specific details like the CIO's role and experience.


reasoning: The paragraph is a materiality assessment stating that no cybersecurity incidents have materially affected or are reasonably likely to materially affect the company's business, which is the defining characteristic of Strategy Integration.


reasoning: This paragraph is a generic warning about potential consequences of IT system compromise, with no description of actual incidents, governance, processes, or materiality assessments, fitting the 'None/Other' category for boilerplate language.


reasoning: The paragraph describes the governance structure with management overseeing cybersecurity and reporting to the board, which aligns with Board Governance. It lacks any specific details such as dates, names, or frameworks, making it Generic Boilerplate.


reasoning: The paragraph describes the governance structure of cybersecurity oversight through specific management committees (IT Steering Committee and IT Subcommittee) that include board representatives and cybersecurity-specific roles like CISO and CTO, aligning with Board Governance.


reasoning: The paragraph describes the CEO's role in providing cybersecurity risk briefings to the Audit Committee, which is part of the board governance oversight structure. It contains no specific facts beyond generic roles and cadences, making it Generic Boilerplate.


reasoning: The paragraph describes the cybersecurity governance structure, including Board oversight, the Cybersecurity Governance Council, and the CISO's role, which aligns with Board Governance. It contains firm-specific facts such as the CISO title, named council, and NIST CSF reference.


reasoning: The paragraph describes management-led cybersecurity risk assessment, mitigation, and monitoring processes with third-party involvement, focusing on internal procedures rather than specific roles or incidents.


reasoning: The paragraph describes the governance chain where a Co-President manages cybersecurity risk and reports to the Audit Committee, which oversees enterprise risk management, fitting the Board Governance category.


reasoning: This paragraph is a cross-reference to risk factors in Item 1A, containing no substantive cybersecurity disclosure and only generic risk language, fitting the 'None/Other' category.


reasoning: The paragraph describes the company's internal process for handling cybersecurity incidents, including team structure, communication to the board, and materiality evaluation, which aligns with Risk Management Process. It contains firm-specific details like named roles and internal teams, making it Firm-Specific.


reasoning: The paragraph describes the governance oversight structure where the Sponsor relies on BlackRock's ERM framework and the Sponsor's board receives cybersecurity reports from BlackRock, fitting Board Governance with firm-specific details about BlackRock's role.


reasoning: The paragraph describes the oversight structure where IT providers report to COO and CFO, who then update the Board, fitting Board Governance as it outlines governance flow. It lacks specific dates, names, or details, making it Generic Boilerplate.


reasoning: The paragraph describes management's adoption of a risk management framework and establishment of a committee chaired by a specific IT role, focusing on process and structure rather than board oversight or individual qualifications.


reasoning: The paragraph primarily describes the governance oversight structure (Board, Audit Committee, management reporting) as part of a governance chain, with detailed management qualifications provided to illustrate roles within that structure.


reasoning: The paragraph outlines the cybersecurity governance chain from management to the board, focusing on oversight responsibilities and reporting lines, which is central to Board Governance.


reasoning: The paragraph describes the oversight structure with specific reporting lines and cadence to a named committee, focusing on how cybersecurity matters are communicated to governance bodies, which aligns with Board Governance.


reasoning: The paragraph describes a process of informing management about cybersecurity posture and risks, which aligns with internal risk management processes. It contains no verifiable facts, named standards, or specific details, making it generic boilerplate.


reasoning: The paragraph describes the oversight structure from the Board to the Audit Committee and management, which is characteristic of Board Governance. It contains only generic roles and processes with no specific dates, names, or verifiable facts.


reasoning: The paragraph includes a negative assertion about no cybersecurity incidents in 2024, which is a materiality-related disclosure under Strategy Integration, and the specific year provides a firm-specific fact.


reasoning: The paragraph is a generic risk warning describing ongoing cyber threats and potential material impacts, with no specific details about governance, management, processes, or actual incidents, fitting boilerplate disclosure.


reasoning: The paragraph describes the internal risk management process, including team responsibilities, oversight between IT and C&RM, and audit reporting, with specific team names and certifications indicating firm-specific details.


reasoning: The paragraph primarily focuses on the CIO's qualifications, including years of experience and career history, which aligns with Management Role; it contains two hard verifiable facts (duration of experience and specific year) meeting the Quantified-Verifiable threshold.


reasoning: The paragraph is a generic cybersecurity risk warning with no specific details, materiality assessments, or descriptions of actual incidents, fitting boilerplate language common in filings.


reasoning: The paragraph is a materiality assessment stating that no material cybersecurity incidents have occurred, which is a core element of Strategy Integration. It contains no specific facts or details, making it Generic Boilerplate.


reasoning: The paragraph states a backward-looking materiality assessment about past incidents and describes a specific committee structure, aligning with Strategy Integration due to the materiality conclusion and Firm-Specific details.


reasoning: The paragraph describes the CFO's oversight role and reporting to the Board, which is a governance structure, and it includes a named tool (Coalition platform) as a specific fact.


reasoning: The paragraph primarily describes the company's internal risk management processes—risk assessments, safeguard implementation, and monitoring—with roles specified to indicate responsibility, fitting Risk Management Process. The named role 'Senior Director, Head of IT and Informatics' is a cybersecurity-specific title, making it Firm-Specific.


reasoning: The paragraph is a generic risk warning about past cyber-attacks and future disruptions without any substantive disclosure on governance, processes, or specific incidents, aligning with None/Other for boilerplate language.


reasoning: The paragraph primarily describes the governance structure for cybersecurity, including the board's oversight responsibility and management roles, even in the absence of formal programs, with a concluding materiality assessment.


reasoning: The paragraph describes the IT department's responsibilities for cybersecurity risk assessment, security controls, and incident response, which are internal processes central to Risk Management Process. It lacks any specific details such as dates, names, or numbers, making it generic boilerplate.


reasoning: The paragraph describes the board's annual review of the security program and the COO's reporting to the board, focusing on governance oversight structure.


reasoning: The paragraph describes the oversight structure of cybersecurity risk management by a specific committee with defined roles, which aligns with Board Governance.


reasoning: The paragraph focuses on the incident response team (CIMT) and its operational responsibilities, detailing the process for managing cybersecurity incidents, which aligns with risk management processes. It includes firm-specific elements like the named team and departmental composition.


reasoning: The paragraph describes the governance oversight structure from board briefings to management responsibilities, fitting Board Governance. It includes a specific duration of experience for IT staff, making it Firm-Specific.


reasoning: The paragraph details the Cybersecurity Committee's composition and its role in providing oversight and assistance with cybersecurity programs, which is central to describing the governance structure.


reasoning: The paragraph makes a materiality assessment by stating no material cybersecurity incident occurred during a specific period, which aligns with Strategy Integration. The inclusion of the specific date 'December 31, 2024' makes it Firm-Specific.


reasoning: The paragraph describes the CISO's role in assisting the ERM Committee with monitoring cybersecurity risks, which is part of the governance oversight structure. It includes a cybersecurity-specific title (CISO) and a named non-generic committee (ERMC), making it firm-specific.


reasoning: The paragraph is a forward-looking materiality assessment using the SEC qualifier 'reasonably likely to materially affect,' which fits Strategy Integration. It contains no specific facts, frameworks, or company details, making it Generic Boilerplate.


reasoning: The paragraph primarily describes the company's internal processes for developing, maintaining, and updating cybersecurity protocols and controls to prevent incidents, which aligns with Risk Management Process. The materiality language at the end is a cross-reference and does not override the primary focus on processes.


reasoning: The paragraph describes the oversight structure through specific committees (OROC and IT Steering Committee) that manage cybersecurity risk, which aligns with Board Governance as it details governance mechanisms rather than individual roles or processes.


reasoning: The paragraph is a generic forward-looking disclaimer about potential future cybersecurity incidents and cross-references the Risk Factors section, with no substantive disclosure on governance, processes, or actual events.


reasoning: The paragraph describes the cybersecurity oversight structure, including the establishment of a risk committee and reporting lines to the Board, which is central to Board Governance.


reasoning: The paragraph is generic cybersecurity boilerplate discussing threats and commitment without substantive disclosure on governance, processes, incidents, or materiality assessments, and contains no specific verifiable facts.


reasoning: The paragraph is a generic risk warning about potential cyber-attack consequences without any specific incident, governance, process, or materiality assessment, making it boilerplate language with no substantive disclosure.


reasoning: The paragraph describes the company's internal risk assessment, safeguard implementation, and monitoring processes, which are core cybersecurity procedures, fitting Risk Management Process. It contains no specific dates, amounts, named standards, or verifiable facts, and the roles mentioned are generic, making it Generic Boilerplate.


reasoning: The paragraph describes a named cybersecurity steering committee with specific member roles, indicating a governance structure for oversight and strategy, which aligns with Board Governance.


reasoning: The paragraph describes the ERMC's role in overseeing risk management processes, including cybersecurity, through quarterly meetings and reports from stakeholders, which aligns with internal process disclosure rather than board governance or management roles.


reasoning: The paragraph describes the internal process for assessing materiality of cybersecurity threats through the MAT, which aligns with risk management, and includes specific internal identifiers like the MAT and Risk Committee.


reasoning: The paragraph describes the Board of Directors' oversight structure, including annual review and approval of the Information Security Program and receiving risk assessment reports, which is central to Board Governance.


reasoning: The paragraph describes the company's internal risk assessment (belief in minimal risk) and basic cybersecurity measures (use of standard software with security features), which are core elements of risk management processes, without focusing on governance structure, management qualifications, or materiality assessments.


reasoning: The paragraph describes the governance chain where the COO reports to the Audit Committee on cybersecurity risks, focusing on oversight structure rather than specific processes or incidents, and contains no unique details about the company.


reasoning: The paragraph describes the cybersecurity oversight structure, including reporting cadence and information flow to the Management Board and Supervisory Board's Committee, which is characteristic of Board Governance.


reasoning: The paragraph primarily describes the management team supporting the CIO and Director of Cybersecurity, detailing their roles and quantified experience, which is characteristic of Management Role content.


reasoning: The paragraph describes the governance oversight structure from the Board to the Audit Committee to the CTO, focusing on how cybersecurity risk is managed through this chain, and includes firm-specific details like the CTO's role and committee memberships.


reasoning: The paragraph describes the internal process for cybersecurity risk discussions and incident reporting, which aligns with risk management processes. It includes a specific role (IT Team Director), making it firm-specific, though it lacks multiple hard verifiable facts.


reasoning: The paragraph describes a committee overseeing cybersecurity processes and escalation to the board, focusing on governance structure, and includes the CISO role, which is a firm-specific fact.


reasoning: The paragraph primarily states a negative assertion about material cyber breaches, which is a materiality assessment classified as Strategy Integration. It contains no specific dates, names, or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph focuses on the oversight structure with the Board and Audit Committee reviewing cybersecurity risks and management reporting, which is characteristic of Board Governance.


reasoning: The paragraph is a generic statement about cybersecurity threats and resource expenditure with no specific details, processes, governance structures, or materiality assessments, fitting None/Other.


reasoning: The paragraph primarily describes the company's risk management process for identifying, prioritizing, and monitoring cybersecurity risks, with a brief mention of board oversight as part of the overall program. It contains no specific facts, frameworks, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the cybersecurity team's composition and its functions in maintaining the program, monitoring trends, and overseeing training, which are core elements of the company's risk management process for cybersecurity.


reasoning: The paragraph includes a negative materiality assessment ('have not experienced... that materially disrupted'), which is a key component of Strategy Integration. It contains no specific facts, named entities, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the governance oversight structure with reporting lines from officers to the audit committee and board, but it contains no specific verifiable facts such as dates, numbers, or named standards, making it generic boilerplate.


reasoning: The paragraph describes the governance structure with management overseeing cybersecurity risk and reporting to the Board, which aligns with Board Governance. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph describes the governance/oversight structure for cybersecurity through executive committees and their roles, which aligns with Board Governance. It contains firm-specific details such as named committees and their compositions.


reasoning: The paragraph describes the company's ERM program and cybersecurity risk management process with specific roles and functions, fitting Risk Management Process. It includes cybersecurity-specific titles and a named internal function, making it Firm-Specific.


reasoning: The paragraph is a generic risk warning about cybersecurity threats and potential material adverse effects, with no specific disclosure about governance, processes, or incidents, fitting None/Other as boilerplate language.


reasoning: The paragraph describes the governance oversight structure, detailing how the ISO reports to management and the BRCC with escalation to the Board, which is central to Board Governance.


reasoning: The paragraph describes the oversight structure for cybersecurity, with regular briefings to management and the board, focusing on governance and information flow rather than individual roles or processes.


reasoning: The paragraph focuses on the CISO's role and the Information Security Department's processes, which are internal cybersecurity risk management activities, not board oversight or incident details.


reasoning: The paragraph describes the oversight structure where the Manager of Information Technology reports to the Audit Committee on cybersecurity risks, focusing on governance and information flow rather than individual qualifications or detailed processes.


reasoning: The paragraph focuses on the Director of Infrastructure's role in monitoring, implementing processes, and incident response, which are generic risk management activities without specific company details or qualifications.


reasoning: The paragraph describes the governance structure with a Cybersecurity Council and executive management team overseeing cybersecurity risk assessment, which fits Board Governance. It includes firm-specific details like named committees, roles, and departmental compositions.


reasoning: The paragraph describes the oversight structure involving the CEO, management, and Board of Directors in cybersecurity governance, which is characteristic of Board Governance. It contains only generic terms and cadences with no verifiable specific facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management process, including team structure and reporting lines, which is central to Risk Management Process. It contains specific roles and team composition, making it Firm-Specific.


reasoning: The paragraph describes a hierarchical escalation process for cybersecurity threats that includes management roles and potential board oversight, which aligns with Board Governance as it outlines the oversight structure and information flow to decision-makers.


reasoning: This paragraph is a cross-reference to Item 1A for materiality assessments and contains no substantive cybersecurity disclosure, making it None/Other with Generic Boilerplate specificity.


reasoning: The paragraph describes internal cybersecurity processes such as team structure, training, reviews, and third-party engagement, which aligns with Risk Management Process, and it mentions the CISO role, a cybersecurity-specific title.


reasoning: The paragraph describes the Cybersecurity Steering Committee's composition and its oversight role in managing cybersecurity risks, which is a governance structure rather than individual management roles or specific processes.


reasoning: The paragraph describes the governance oversight structure where the board oversees the ERM program encompassing cybersecurity, with specific management roles as part of that chain, aligning with Board Governance.


reasoning: The paragraph contains a forward-looking materiality assessment ('reasonably likely to materially affect us') with an SEC qualifier, which aligns with Strategy Integration. It includes no specific details about incidents, processes, or governance, and is generic boilerplate language.


reasoning: The paragraph is a materiality assessment concluding no material cybersecurity incidents to date, which falls under Strategy Integration, and it contains no specific facts, making it Generic Boilerplate.


reasoning: The paragraph is a generic statement about regulatory compliance risks with no specific details about the company's cybersecurity governance, processes, or incidents, fitting boilerplate risk warnings.


reasoning: The paragraph describes the cybersecurity governance structure with oversight from the Board and Audit Committee, fitting the Board Governance category. It contains no specific facts such as named entities, dates, or frameworks, making it generic boilerplate.


reasoning: The paragraph primarily describes the Director of IT and team qualifications, including a specific certification, indicating a focus on management roles rather than just oversight structure. The mention of a certified information system security professional provides a firm-specific detail.


reasoning: The paragraph is generic IT-dependence language emphasizing the importance of data security to business operations, with no specific governance, processes, incidents, or materiality assessments.


reasoning: The paragraph describes cybersecurity processes and responsibilities led by management, not individual qualifications, fitting Risk Management Process. It lacks specific dates, names, or standards, making it generic boilerplate.


reasoning: The paragraph describes the board and committee oversight structure for cybersecurity, including the formation and responsibilities of the Cybersecurity Disclosure Committee, which aligns with Board Governance and contains firm-specific details.


reasoning: The paragraph primarily states materiality assessments regarding cybersecurity risks (both backward and forward-looking), which aligns with Strategy Integration, and contains no specific details about governance, processes, or incidents, making it generic boilerplate.


reasoning: The paragraph describes the oversight structure where management reports cybersecurity risks to committees, which is core to Board Governance. The named 'Enterprise Risk and Compliance Committee' is a specific, non-generic committee, making it Firm-Specific.


reasoning: The paragraph is a generic enumeration of cybersecurity risks without any specific details about governance, processes, incidents, or materiality assessments, making it non-substantive boilerplate.


reasoning: The paragraph describes the oversight structure where the Board and Audit Committee receive updates from management, with the CEO directing cybersecurity programs, which is characteristic of Board Governance. No specific dates, amounts, named frameworks, or unique facts are present, making it generic boilerplate.


reasoning: The paragraph describes a security team managing cybersecurity risk assessment, controls, and incident response processes, which aligns with Risk Management Process. It contains no verifiable facts, named standards, or company-specific details, making it generic boilerplate.


reasoning: The paragraph outlines the cybersecurity governance structure from the Board down to specialized teams, emphasizing oversight roles and responsibilities, which aligns with Board Governance. It contains multiple hard verifiable facts, including specific years of experience and educational details, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the roles of the SVPF and Director of IT in cybersecurity risk management processes, but after applying the person-removal test, the content remains focused on general risk identification and assessment methods, fitting Risk Management Process. It contains no verifiable hard facts, named standards, or unique details, making it generic boilerplate applicable to many companies.


reasoning: The paragraph is a negative assertion about cybersecurity incidents (stating none have occurred that affected operations), which aligns with materiality assessments under Strategy Integration. It includes a specific date reference (the year ended December 31, 2024), making it Firm-Specific.


reasoning: The paragraph contains only generic risk warnings and materiality language without describing any specific cybersecurity processes, governance, incidents, or strategies, making it boilerplate with no substantive disclosure.


reasoning: The paragraph describes the risk management process led by the CFO, focusing on methods and responsibilities for identifying and assessing threats, with no personal qualifications or specific details. It contains no verifiable facts such as dates, names, or numbers, making it generic boilerplate applicable to many companies.


reasoning: The paragraph describes the information security program's design and processes, led by the CISO, which centers on internal risk management activities rather than governance oversight or individual qualifications.


reasoning: The paragraph contains a materiality assessment ('we have not yet experienced any material impacts') and generic risk warnings about future cyber-attacks, which aligns with Strategy Integration, but it lacks any specific dates, names, or verifiable details, making it Generic Boilerplate.


reasoning: The paragraph describes the governance structure where management provides regular cybersecurity reports to the Board, indicating board oversight, and it contains no specific verifiable facts such as dates, names, or numbers.


reasoning: The paragraph describes the cybersecurity risk oversight structure, detailing management-level committees, escalation paths, and reporting lines to the board, which aligns with Board Governance.


reasoning: The paragraph focuses on the governance structure with Board oversight and a named committee (DPIRC), making it Board Governance. It contains two hard verifiable facts: the CIO's appointment year (2017) and quantified years of experience (over 20 years), qualifying as Quantified-Verifiable.


reasoning: The paragraph focuses on the governance structure for cybersecurity, detailing board policy adoption, oversight by the CTO, and audit committee responsibilities, which aligns with Board Governance. It includes firm-specific facts like the CTO role and experience years, making it Firm-Specific.


reasoning: The paragraph describes management's responsibilities in cybersecurity processes such as risk assessment, incident response, and compliance, which are core elements of Risk Management Process, and it lacks any specific details like dates, names, or frameworks that would make it firm-specific.


reasoning: The paragraph focuses on the Board's oversight of cybersecurity programs and the reporting structure from the CISO and CIO, which aligns with Board Governance. It includes cybersecurity-specific titles, making it Firm-Specific.


reasoning: The paragraph describes the company's cybersecurity program, processes, and policy implementation, with management roles mentioned as part of the operational structure, making Risk Management Process the primary category.


reasoning: The paragraph outlines the Board's oversight responsibility and the Risk Committee's role in managing cyber risks, which is core to governance structure. The named 'Risk Committee' is a specific fact from the IS list, making it Firm-Specific.


reasoning: The paragraph primarily identifies specific management roles (e.g., Executive Vice President of Information Technology, CFO) involved in the Cyber Incident Response Team and their functions, with brief mention of board reporting, making it focused on who is responsible rather than solely on the process.


reasoning: The paragraph describes the cybersecurity sub-committee's role in overseeing risk assessment, compliance testing, and employee training, which are core risk management processes, with specific details about the committee and its experience.


reasoning: The paragraph focuses on the management team's role in leading the cybersecurity risk management program, describing the process and organizational structure rather than individual qualifications or board oversight.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including monitoring, team responsibilities, risk escalation through councils, and control evaluation, with specific verifiable facts such as years of experience and historical dates.


reasoning: The paragraph focuses on management's role in implementing cybersecurity processes like monitoring and training, and the person-removal test shows the processes stand alone without the officer details, confirming it as Risk Management Process.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, focusing on committee composition, responsibilities, and reporting lines, which aligns with Board Governance. It includes named committees and specific roles but no verifiable hard facts like dates or numbers.


reasoning: The paragraph focuses on the oversight structure, detailing how cybersecurity threats and incidents are reported upward to the Audit Committee and Board, which is characteristic of Board Governance. The mention of the CISO, a cybersecurity-specific role, makes it Firm-Specific.


reasoning: The paragraph primarily identifies the management team (CEO, COO, Chief Accounting Officer) as responsible for cybersecurity and describes their general experience and roles, fitting Management Role. It contains no verifiable facts, named standards, or unique details, making it Generic Boilerplate.


reasoning: The paragraph describes the governance structure for cybersecurity oversight through a Steering Committee co-chaired by specific officers, which aligns with Board Governance as it focuses on oversight mechanisms.


reasoning: The paragraph describes the governance structure with the CISO-led cybersecurity team, Incident Response Team composition, and reporting lines to the Disclosure Committee, Strategy Board, Audit Committee, and Board, focusing on oversight and escalation mechanisms.


reasoning: The paragraph describes the governance structure with the Audit Committee overseeing cybersecurity risks and a Risk Committee chaired by the CISO, focusing on oversight and reporting lines rather than specific processes or individual qualifications.


reasoning: The paragraph primarily details the qualifications and experience of the management team (CTO and Head of Technology Infrastructure) leading the cybersecurity program, with specific years of experience that are quantifiable and verifiable.


reasoning: The paragraph describes the Cyber Incident Response Team's responsibilities in managing cybersecurity threats and incidents, which is a core internal risk management process, with brief mention of leaders' experience that does not override the process focus.


reasoning: The paragraph describes the oversight responsibilities of the DPIRC committee and the reporting line from the CISO to the Enterprise Risk Committee, which is a governance structure focused on board/committee oversight of cyber risk.


reasoning: The paragraph describes the internal process of the Risk Management Steering Committee monitoring and reporting cybersecurity threats, which is centered on the company's risk management procedures rather than individual qualifications or board oversight structure.


reasoning: The paragraph describes the cybersecurity oversight structure from the board to executive officers, including reporting lines and consultation processes, which aligns with Board Governance. The mention of the CEO's specific years of experience adds a Firm-Specific detail.


reasoning: The paragraph describes the oversight structure where management provides quarterly briefings to the audit committee on cybersecurity topics, which is a governance process. It contains no specific dates, names, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph primarily describes the oversight structure from the board and audit committee to management, including escalation protocols and expertise considerations, fitting the Board Governance category. It contains two hard verifiable facts (specific years of experience), meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the organizational structure for managing cybersecurity risks through committees and management positions, focusing on the process rather than individual qualifications or board oversight.


reasoning: The paragraph describes management's cybersecurity responsibilities and reporting lines to the Cybersecurity Committee and Board, which is focused on governance oversight structure.


reasoning: The paragraph describes cybersecurity processes such as ongoing education, monitoring, and incident response planning, with the CIO mentioned as the lead but without personal qualifications, making it Risk Management Process. The mention of the CIO, a cybersecurity-specific title, provides a firm-specific fact.


reasoning: The paragraph emphasizes the design of reporting channels to the Board (via Chief Risk Officer and Chief Compliance Officer) and their purpose in providing a clear risk picture, making governance structure the primary focus.


reasoning: The paragraph describes the internal process for monitoring, evaluating, and escalating cybersecurity incidents, which is a core risk management activity. The mention of the CISO, a cybersecurity-specific role, provides firm-specific detail.


reasoning: The paragraph describes the oversight structure where a specific officer reports to the board on cybersecurity matters, focusing on governance and information flow upward, which aligns with Board Governance.


reasoning: The paragraph focuses on the Enterprise Risk Council's function in strengthening risk management processes, including cybersecurity, with the CISO mentioned as part of the structure, making it primarily about internal processes rather than governance oversight or management roles.


reasoning: The paragraph describes the cybersecurity incident notification and escalation process to the board and audit committee, which is central to governance oversight structure, and includes firm-specific details about the manager and board expertise.


reasoning: The paragraph describes the oversight structure for cybersecurity through committees and coordination with the Audit Committee, which aligns with Board Governance. It includes named committees and specific roles, making it Firm-Specific.


reasoning: The paragraph describes the cybersecurity oversight structure, including the CISO-led team, Incident Response Team, and reporting to the Strategy Board, Audit Committee, and Board, which aligns with Board Governance. It contains firm-specific details such as the CISO role and team composition, making it Firm-Specific.


reasoning: The paragraph describes internal cybersecurity processes like training and exercises, and after removing management role details, the disclosure remains coherent, focusing on risk management activities.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risks, such as risk assessments and safeguards, with the IT head's reporting line adding firm-specific organizational detail.


reasoning: The paragraph focuses on the Board's oversight structure through committees and reporting lines from senior leaders, fitting Board Governance. It contains multiple hard verifiable facts, including specific years of experience and named professional certifications, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the oversight structure of the cybersecurity program, including reporting to specific committees and boards, which is characteristic of Board Governance.


reasoning: The paragraph focuses on the CIO's extensive experience and specific certifications, which are core to Management Role, and includes firm-specific details like the named Sustainability & Safety Committee.


reasoning: The paragraph describes a cross-functional committee with specific departmental composition that oversees cybersecurity and other risks, which is part of the company's internal risk management processes.


reasoning: The paragraph primarily describes the governance structure, including board oversight, reporting lines from management to the board, and the board's role in risk assessment, making Board Governance the appropriate category.