reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including named internal committees (Information Security Council, Executive Information Security Committee), the CISO's role in the governance chain, CEO reporting lines, and board/committee quarterly review cadences. This is governance structure description, not incident disclosure or process methodology.


content_category: Risk Management Process

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph describes cybersecurity risk assessment and monitoring activities (processes), not who the officer is as a person. While the Director of IT is mentioned, the substantive content focuses on what the team does (monitoring, investigating, acting on security events). No named frameworks, tools, dates, or other hard facts are present — all language describes generic security practices.

provider: minimax

stage: benchmark


specificity_confidence: medium

reasoning: The paragraph describes the company's internal processes for monitoring information systems, deploying security measures, conducting audits, and maintaining an incident response plan. While an InfoSec Director is mentioned as the grammatical subject, the substantive content describes what the monitoring and response processes DO (monitoring, detection, mitigation, remediation) rather than who the person IS. No hard verifiable facts (dates, dollar amounts, headcounts, named third-party firms, or named tools) are present, making this standard cybersecurity governance language applicable to any company.


category_confidence: high

reasoning: The paragraph's primary focus is describing the cybersecurity risk assessment and mitigation processes (continuous monitoring, routine meetings, reporting cadence) rather than profiling individuals. While management roles are mentioned as participants, the grammatical structure centers on the PROCESS being conducted. The 21 years of experience is a specific fact about the third-party partner, elevating this to Firm-Specific.


reasoning: The paragraph describes the company's internal risk management process (risk assessment → re-design → implement → maintain → monitor safeguards) with the Senior Director, Head of IT and Informatics as the designated role managing this process. The person is mentioned as the process manager, not as the subject being described for their qualifications or credentials, making this Risk Management Process. The cybersecurity-specific title (Senior Director, Head of IT and Informatics) moves it beyond generic boilerplate, but no named frameworks, tools, dates, or other verifiable external facts are present.


content_category: Strategy Integration

reasoning: The paragraph opens with a backward-looking materiality assessment ('We have not experienced a cybersecurity incident that resulted in a material adverse impact'), which is Strategy Integration. The remainder consists of boilerplate forward-looking risk warnings common to virtually all 10-K filings, containing no named entities, dates, frameworks, or other identifying details.


content_category: Board Governance

reasoning: The paragraph describes how management oversees cybersecurity risk and reports to the board of directors—information flowing upward through the governance chain—which is the hallmark of Board Governance. No cybersecurity-specific titles (CISO/CIO), named committees, specific dates, or other firm-identifying details are present, making this generic boilerplate about standard oversight structure.


content_category: None/Other

reasoning: This paragraph contains only forward-looking disclaimers and generic risk warnings about cybersecurity threats ("could have a material adverse impact"), threat descriptions applicable to any financial institution, and boilerplate consequence language. It does not describe an actual incident, governance structure, management roles, internal processes, vendor oversight, or a materiality assessment—it is standard risk-factor language that appears across financial institution filings.


reasoning: The paragraph's primary purpose is describing the governance/oversight structure—specifically the CISO's reporting line to the Risk Committee, the information flow upward to the Board, and the division of responsibilities between CISO and CTO. While CISO and CTO appear as grammatical subjects throughout, the content focuses on describing how cybersecurity oversight is organized rather than who these individuals are as persons (no credentials, experience, or qualifications are mentioned).


reasoning: This paragraph is a direct cross-reference to Item 1A Risk Factors containing only generic risk language ('operational risks,' 'system security risks,' 'cyberattacks') that appears verbatim in virtually every financial filing. It contains no substantive cybersecurity disclosure—no governance structure, management details, processes, incident description, or materiality assessment—and merely redirects readers elsewhere for risk information.


reasoning: The core substance is a backward-looking negative materiality assertion ('we are not aware of any cybersecurity threats or incidents that have materially affected our business'), which qualifies as a Strategy Integration assessment. The surrounding forward-looking disclaimer and Item 1A cross-reference are standard boilerplate with no substantive disclosure. No firm-specific facts, named entities, dates, or frameworks are present.


reasoning: This paragraph is a standalone materiality assessment stating that cybersecurity has not materially affected and is not reasonably likely to materially affect the company's business outcomes—a negative assertion and backward/forward-looking conclusion that is explicitly within Strategy Integration. No specific facts, dates, named entities, or verifiable details are present; the language is standard SEC boilerplate.


reasoning: The paragraph describes operational cybersecurity processes (monitoring, security measures, system audits, incident response plan) rather than the qualifications or background of the named officers. While CISO and CIO are mentioned as grammatical subjects, Step 2 confirms the process content stands independently as a disclosure about the company's risk management approach. No specific dates, dollar amounts, headcounts, named frameworks, third-party firms, or products are present, making this Generic Boilerplate.


reasoning: The paragraph contains a negative assertion ('not aware of any cybersecurity threats that have materially affected') and a forward-looking qualifier ('reasonably likely to materially affect'), which are SI-triggering materiality assessments. However, the content is entirely boilerplate language that could appear in any 10-K filing with no company-specific, framework, or verifiable fact present.


content_category: Management Role

reasoning: The paragraph identifies named individuals (COO and Senior Vice President for Operations) and describes their specific cybersecurity responsibilities (hiring, integrating risk considerations, communicating priorities, reviewing security assessments). While governance-chain language appears, the paragraph is fundamentally about WHO holds responsibility, not about board oversight structure or process frameworks.


reasoning: This paragraph is a generic description of an information-flow mechanism with no identifiable specifics—no named board, committee, officer, date, cadence, or framework. It is boilerplate language describing that management receives cybersecurity updates, which appears in countless filings without modification.


reasoning: This paragraph contains only generic IT-dependence language and standard boilerplate risk warnings ('could potentially have a material impact') that appear in virtually every 10-K filing. There is no substantive cybersecurity disclosure—no governance structure, no internal processes, no incident narrative, no actual materiality assessment, and no firm-specific details.


reasoning: The paragraph describes the governance/oversight structure — who reports to whom and how information flows from IT to the CFO to the Board — making Board Governance the primary category. The paragraph contains no firm-specific facts: all entities are generic (Board, CFO, VP of Internal Audit, third-party IT service provider), the communication cadences are vague ('quarterly,' 'periodically'), and the incident response plan is described generically without a unique identifier, specific dates, or named tools/firms.


reasoning: The paragraph describes the governance/oversight structure—specifically how information flows from the CEO to the Audit Committee regarding cybersecurity risks and the minimum briefing cadence. CEO and Audit Committee are both generic governance references applicable to any public company, and the topics covered ('current cybersecurity landscape,' 'emerging threats,' 'ongoing initiatives') are standard boilerplate language.


reasoning: The paragraph primarily describes the cybersecurity oversight structure—how the Board receives briefings, how management reports upward, and how internal staff and external consultants are supervised. While R. LaDuane Clifton is named and 40+ years of combined experience is mentioned, these appear within a governance description rather than as standalone qualifications. The governance elements (board reporting, management briefings, staff presentations) are standard public company disclosure language. No external verifiable facts (dates, dollar amounts, named third-party firms, specific tools) are present.


reasoning: The paragraph describes the governance/oversight structure for cybersecurity (Board → Audit Committee → Management → CEO/CFO), which is the defining characteristic of Board Governance. However, the content consists entirely of standard governance language without any firm-specific details — the Audit Committee, CEO, and CFO are generic roles present at every public company, and 'regular briefings' and 'significant assessments' are vague without specific cadences or dates.


reasoning: The paragraph describes a governance/oversight structure — specifically the reporting chain (IT Team Director → CFO → CEO) and incident notification hierarchy — rather than describing who the people are. The named roles (CFO, CEO, General Counsel) appear as recipients in the governance chain, not as individuals being characterized. The specificity is Generic Boilerplate because no named committees, specific dates, specific products/tools, or other firm-identifying facts are present; 'IT Team Director' is a generic title, and the meeting cadence and reporting structure described are standard across filings.


reasoning: The paragraph primarily describes the governance/oversight structure through a named Cybersecurity Committee, its composition, its role in the governance chain (connecting to the Board and Executive Leadership Team), and its oversight functions. While committee member qualifications are mentioned, they are incidental to describing the oversight structure itself, not the focus on individual credentials.


reasoning: The paragraph is fundamentally about the governance structure—how the board established committees, who chairs them, their composition, meeting cadence, and upward reporting to the board committee. While it mentions officers by title, the focus is on oversight architecture, not individual qualifications or experience.


reasoning: The paragraph primarily describes the company's cybersecurity risk management structure and processes (incident response team, GRC platform, third-party services), with individual qualifications mentioned as supporting context rather than the central focus. Applying the person-removal test, the core processes remain coherent without the named roles.


reasoning: The paragraph describes governance structure—specifically the composition of the Technology and Operations Committee, which includes cybersecurity-specific roles (CIO, CISO) and representatives from named departments. This is describing how oversight is structured, not individual qualifications or credentials, making Board Governance the appropriate category.


reasoning: The paragraph describes the governance/oversight STRUCTURE — how information flows from the CSO upward to the Management Board and the Supervisory Board's specialized committee. The primary purpose is describing board-level oversight, not describing who the CSO is as a person (no qualifications, experience, or credentials are provided). The named committee with specific technology/data/innovation responsibilities is a firm-specific fact distinguishing this from generic governance language.


reasoning: The paragraph's primary purpose is a negative assertion about past material cybersecurity incidents — 'we have not experienced any material cybersecurity incidents' — which is explicitly classified as Strategy Integration per the tiebreaker rules. The remaining language about monitoring and safeguarding is generic boilerplate with no specific dates, named frameworks, personnel, or firm-specific details.


reasoning: The paragraph describes the overall governance/oversight structure for cybersecurity risk management, with the board at the top overseeing risk and management operating under that framework. While the VP of Operations is mentioned, the purpose is to explain the oversight chain (Board → Audit Committee → VP → Cybersecurity Programs), not to describe who this person is. No cybersecurity-specific titles (CISO, CTO, CIO), no named committees beyond standard Audit Committee, no specific dates, amounts, named third-party firms, or named products/tools are present—making this generic boilerplate governance language.


reasoning: The paragraph primarily describes the company's internal incident response process — the CIMT's composition, scope of expertise, co-leadership structure, and operational responsibilities for coordinating containment, investigation, reporting, and recovery. The board appears only as a passive recipient of updates, not as an active governance structure, making Board Governance inappropriate. The IT Director, Cyber Security is mentioned as a team member (one IS fact), making this Firm-Specific rather than Sector-Adapted.


reasoning: The paragraph's primary function is a cross-reference to Item 1A Risk Factors ('See Item 1A. Risk Factors for more information'), which classifies it as None/Other. While it contains a backward-looking negative assertion about material incidents ('we did not experience a material cybersecurity incident during the year ended December 31, 2024'), this is incidental to the cross-reference, and the paragraph's structure is indistinguishable from the standard boilerplate used across most SEC filings.


reasoning: The paragraph describes the governance/oversight structure — specifically how the CFO serves as the bridge between cybersecurity risk management and Board oversight, including the reporting mechanism. While the CFO is mentioned as the grammatical subject, the purpose is describing the oversight chain (CFO reports to Board) rather than describing who the CFO is as an individual. The Coalition management platform is a named tool, but CFO is a generic C-suite title found at every company and the reporting relationship described is standard governance boilerplate.


reasoning: The paragraph describes that cybersecurity risk management processes are overseen by a specific combination of named internal departments. The subject is the company's risk management processes, with oversight structure as a component, not a standalone board governance disclosure.


reasoning: This paragraph is a forward-looking disclaimer cross-referencing Risk Factors; it contains no substantive disclosure about actual incidents, processes, roles, or materiality assessments—only generic speculation that could appear in any company's 10-K.


reasoning: The paragraph is primarily about identifying the CIO and detailing their qualifications (30 years of experience, prior career history, joining Huron in 2018), which is the core of Management Role; the ISMS Committee is described as part of the CIO's reporting chain but the CIO's biographical information dominates the paragraph's content and length.


reasoning: The paragraph describes the governance/oversight structure for cybersecurity threats — specifically how the Materiality Assessment Team (MAT) operates, what triggers it, and how it escalates to the Risk Committee. This is governance-chain content describing how board-level oversight is structured. No hard verifiable facts (no dates, dollar amounts, named external firms, or named products/tools) are present, making it generic boilerplate.


reasoning: The paragraph describes the governance chain of cybersecurity oversight—IT and C&RM operational teams, C&RM's oversight of IT, Internal Audit's independent validation role, and reporting to the Board Audit Committee—which is the structural description that defines Board Governance. The certifications are mentioned to establish team qualifications within the governance structure, not as the primary focus.


reasoning: The paragraph's primary focus is describing the company's cybersecurity governance structure (committee composition, meeting cadence, reporting line to CFO), which constitutes an internal oversight process. While named roles appear, the purpose is describing the mechanism, not individual qualifications.


reasoning: The paragraph primarily contains a negative assertion about past incidents ('We have not experienced cyber-attacks or other malicious activities that materially disrupted our business') which constitutes a backward-looking materiality assessment, qualifying as Strategy Integration. The remaining sentences are boilerplate forward-looking disclaimers and a cross-reference to Item 1A. No specific dates, named entities, frameworks, or verifiable facts are present.


reasoning: The paragraph describes a named role (CISO), their reporting line (to Chief Risk Officer), and the segregation between first and second line of defense — organizational structure rather than describing a process, framework, or personal qualifications. The CISO is the grammatical subject throughout, making this Management Role despite the program duties mentioned.


reasoning: This paragraph is a forward-looking risk warning covering generic cybersecurity threats and potential business impacts. It does not describe a specific incident, board oversight structure, named management roles, an actual risk assessment process, or a materiality conclusion—it only contains boilerplate speculation ('could have a material adverse effect'). The paragraph contains no named entities, specific dates, dollar amounts, or other identifiable firm-specific facts.


reasoning: This paragraph is purely speculative risk language describing what a cybersecurity incident 'could potentially' or 'may' result in. It contains no description of actual incidents, no governance or management structures, no risk management processes, and no materiality assessment about the company's own business or financial condition. The language consists entirely of generic warnings about hypothetical threats and does not constitute substantive disclosure under Item 1C.


reasoning: This paragraph contains only generic cybersecurity risk acknowledgments (data breaches, ransomware, phishing) and a boilerplate commitment to maintaining robust practices, with no actual disclosure of board governance structure, specific processes, named officers, incidents, or materiality assessments. The reference to evaluating threats 'on our business strategy, operations, and financial condition' is generic language about considering effects, not a materiality conclusion — the paragraph lacks any backward-looking or forward-looking SEC-style materiality language.


reasoning: This is standard SEC forward-looking boilerplate language ('reasonably likely to materially affect us') that appears verbatim across virtually all 10-K filings. It contains no description of actual governance, processes, incidents, or materiality conclusions—just a generic risk warning with no company-specific facts.


reasoning: The paragraph describes the governance structure for board-level oversight of cybersecurity risk—specifically how the CISO serves as a conduit to inform and assist the ERMC in monitoring risks. The governance-chain relationship (CISO → ERMC) is the primary focus, not the CISO's personal qualifications or the internal risk management processes themselves. The paragraph contains two firm-specific identifiers (CISO and ERMC) but lacks hard verifiable facts like named third parties, specific dates, or dollar amounts.


reasoning: The paragraph describes the company's internal cybersecurity review and assessment processes (periodic reviews, annual board approval, audits, annual risk assessment using a framework). This is RMP as it details the company's own internal risk management and monitoring processes. The use of the FFIEC Cybersecurity Assessment Tool (a sector-specific framework for financial institutions) elevates this beyond generic boilerplate, but there are no firm-specific facts such as named officers, specific dates, or unique program identifiers.


reasoning: The paragraph's primary purpose is a backward-looking negative assertion ('we have not experienced any material cyber breaches'), which qualifies as a materiality assessment under Strategy Integration. The secondary mention of reviewing policies is incidental and vague ('periodically reviewing'), making the paragraph essentially a boilerplate negative assertion that could appear in any company's 10-K.


reasoning: This paragraph is a broad introductory risk acknowledgment stating that Dell faces cybersecurity threats and spends resources on cybersecurity without describing any specific governance structure, risk management process, incident, or materiality assessment. It contains no named entities, frameworks, dates, or other identifying details that would make it substantive.


reasoning: This paragraph is a forward-looking risk disclaimer with no substantive cybersecurity disclosure. It mentions past cyber-attacks only in passing without describing what happened, when, or the scope. The primary content is speculative language about future potential failures that 'could harm our business' — standard boilerplate that appears in virtually every 10-K filing regardless of the company's actual cybersecurity posture.


reasoning: The paragraph's primary focus is the governance structure—describing which committees exist, their composition, and how they exercise oversight of cybersecurity risk. The named Information Governance and Privacy Committee is a non-generic committee identifier unique to TripAdvisor's disclosure, making this Firm-Specific rather than generic boilerplate about board oversight.


reasoning: The paragraph primarily describes the company's risk assessment process (re-designing, implementing, monitoring safeguards) with a brief mention of who oversees it. Applying the MR decision chain: Step 2 (person-removal) is borderline but the governance mention is incidental to the process description. The paragraph contains no hard verifiable facts (no dates, dollar amounts, named tools, or named third-party firms) and names no specific frameworks — it describes generic cybersecurity risk management activities applicable to any company.


reasoning: This paragraph describes the governance/oversight structure — specifically how information flows from the IT Risk Committee → CISO → Management Risk Committee → Board. Although management roles appear as grammatical subjects, the purpose is describing the oversight chain rather than describing who the CISO is as a person. Per the BG tiebreaker, governance-chain paragraphs are classified as Board Governance even when officers are mentioned. The paragraph contains firm-specific facts: a named IT risk committee established in a specific year, and a specific departmental composition (IT, loan origination, loan servicing, accounting, legal).


reasoning: The paragraph's primary focus is describing the OVERSIGHT STRUCTURE — how the Board administers cybersecurity oversight through committees and reporting cadences. While there are substantial details about the CIO and CISO (their experience, certifications, career history), these are mentioned in the context of the governance chain (who reports to whom), making Board Governance the primary category. The governance framework with named committees and specific review cadences identifies this as firm-specific disclosure rather than boilerplate.


reasoning: The paragraph primarily describes the governance and oversight STRUCTURE for cybersecurity risk — the ERM function, how individuals flow into it, and the reporting relationship between the CDIO, CISO, and information security team. While named officers appear, they function as structural placeholders describing how oversight is organized rather than being described themselves. This is a governance-chain paragraph where the PURPOSE is describing oversight structure, not describing who the officers are.


reasoning: The paragraph describes the cybersecurity governance structure—specifically how the board has delegated oversight to a subsidiary's Information Security Committee and how updates will flow upward to the board. This is governance/oversight structure, not a description of individual qualifications or experience. The named committee and named CEO provide firm-specific identifiers.


reasoning: The paragraph describes the company's risk-based cybersecurity program, ERM integration, and oversight structure, making Risk Management Process the primary content. Applying the person-removal test, the core disclosure about the cybersecurity program remains coherent after removing role titles, confirming the process—not the person—is the subject. No hard verifiable facts appear: no specific dates, dollar amounts, named frameworks (NIST, ISO), named products/tools, third-party firms, certifications, or unique program identifiers that would elevate specificity beyond generic boilerplate.


reasoning: The paragraph primarily describes the oversight structure—specifically how information flows from the Manager of Information Technology to the Audit Committee and what the Committee receives. Per the BG tiebreaker, governance-chain paragraphs are BG even when officers appear as grammatical subjects because the PURPOSE is describing oversight structure. The paragraph contains no named standards, specific dates, named tools, or other firm-specific details that would elevate it beyond generic boilerplate.


reasoning: This paragraph is a forward-looking disclaimer describing hypothetical consequences of a cyber-attack (business disruption, reputational harm, litigation, regulatory exposure). It contains no description of actual incidents, governance structures, management roles, processes, or materiality assessments—only generic risk speculation that could appear in any company's 10-K filing.


reasoning: The paragraph describes a named cross-functional governance committee (not a standard board committee), its chair (CISO), membership composition, and oversight purpose. The committee's composition with named departments distinguishes it from generic governance language.


reasoning: The paragraph's primary purpose is describing the governance/oversight structure—specifically the composition and leadership of the cybersecurity committee that oversees risk management. The named officer roles (VP of IT, CFO, General Counsel) and specific departmental composition (IT, legal, finance, internal audit) are firm-specific facts about the governance chain.


reasoning: This paragraph describes the governance/oversight structure—specifically how cybersecurity information flows from IT providers through the COO and CFO to the Board—which is Board Governance. No specific facts are present; the named roles (COO, CFO) are generic C-suite positions that exist at every company, making the paragraph indistinguishable from generic governance boilerplate.


reasoning: The paragraph describes the company's internal risk management structure—a named cross-functional committee with specific departmental compositions and defined oversight responsibilities across multiple risk categories including cybersecurity. The grammatical subject is the ISSC process itself, not a person or role. While 'management oversight' appears in the text, the focus is on the committee's functions (assessing and managing risks) rather than individual qualifications, credentials, or career history of specific officers.


reasoning: This paragraph describes a cybersecurity governance structure — the composition of a committee overseeing cybersecurity, its responsibilities (approving strategy, policies, incident assessment, escalation to the board), and the oversight chain from the InfoSec team to this committee to the Audit Committee/Board. Per the classification guidance, governance-chain paragraphs describing how oversight flows upward are Board Governance even when officers appear as grammatical subjects. The named committee composition, the InfoSec Roadmap, and the specific escalation path to the Audit Committee or Board provide firm-specific identifying details.


reasoning: The paragraph describes the oversight structure for cybersecurity risk, detailing how the Board of Directors receives quarterly briefings and how management (CEO, COO, CIO, CLO) receives monthly or event-driven briefings on cybersecurity risks. This describes the governance chain and cadence for cybersecurity oversight, making it Board Governance. The specificity is Generic Boilerplate because the content (regular briefings to management and board on cybersecurity risks) is a universal governance practice found in virtually all cybersecurity disclosures. The named roles (CEO, COO, CIO, CLO) are generic C-suite titles, not cybersecurity-specific; the cadences ('monthly' and 'quarterly') are organizational details without specific dates; and there are no named committees, programs, tools, or hard verifiable facts.


reasoning: The paragraph's grammatical subject is 'Our Board' and its primary purpose is establishing the Board's oversight role over cybersecurity risk, with the risk management process described as a component of that governance structure. The language—'continually evolving cybersecurity risks,' 'integral part of the Company's overall risk management program,' 'identify, prioritize, and monitor risks'—contains no firm-specific details such as named frameworks, specific roles, named programs, or verifiable facts.


reasoning: This paragraph is a forward-looking disclaimer with no substantive disclosure. It contains only boilerplate speculation ('reasonably likely to materially affect us') and a cross-reference to Item 1A Risk Factors. The 'reasonably likely' language is standard SEC disclaimer language, not a materiality assessment the company has made about its cybersecurity situation — it applies equally to any company and does not constitute a Strategy Integration conclusion.


reasoning: The paragraph describes a structured risk assessment process (quarterly council reviews, executive management assessment with input from technical leaders), with the named Cybersecurity Council as the primary subject. The specific cross-functional composition of the council (five named departments) provides one firm-specific fact, but no hard verifiable facts such as dates, dollar amounts, headcounts, or named third-party firms are present.


reasoning: This paragraph is a generic forward-looking disclaimer warning that cybersecurity incidents 'could materially adversely affect' operations—a boilerplate risk statement found in virtually every 10-K filing. It contains no description of actual incidents, governance structure, management roles, internal processes, or substantive cybersecurity disclosure.


reasoning: This paragraph is a forward-looking regulatory risk disclaimer with no substantive cybersecurity disclosure — it describes what could happen if non-compliance occurs rather than describing actual governance, processes, or assessments. No named entities, specific dates, named frameworks, or materiality conclusions are present.


reasoning: The paragraph describes the governance/oversight structure—how information flows from management to the audit committee and board—making Board Governance the appropriate category. The content contains only generic role titles and standard governance bodies without any hard verifiable facts (no dates, dollar amounts, named frameworks, or named tools), qualifying it as Generic Boilerplate.


reasoning: The paragraph describes the governance/oversight structure—specifically how the Audit Committee receives briefings from the COO and conducts annual reviews. The Audit Committee and COO are standard governance roles, the annual review cadence is generic, and the briefing topics (cybersecurity landscape, incident reports, compliance) are standard content categories found in virtually any company's board governance disclosure. There are no firm-specific identifiers such as named internal programs with unique identifiers, specific dates, named third-party firms, or unique organizational compositions.


reasoning: The paragraph describes the company's internal cybersecurity processes (monitoring, prevention, detection, incident response planning) with the Director of Infrastructure mentioned as the person who oversees them. The content is about WHAT the processes do, not WHO the person IS. No hard verifiable facts (dates, dollar amounts, headcounts, named third-party firms, named products/tools) are present, and no recognized cybersecurity standards are named.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for cybersecurity risk disclosures. It contains no substantive cybersecurity disclosure — it merely points to where such information can be found elsewhere in the filing. Per calibration guidelines, cross-references with materiality language (like 'For risks that may materially affect us, see Item 1A') classify as None/Other.


reasoning: The paragraph describes the governance/oversight structure of the Information Security Management Committee, including its responsibilities and how it reports upward to the Board of Directors' Compliance and Information Security Committee—this describes the governance chain structure. While no specific dates, dollar amounts, named third-party firms, or named products/tools appear, the named committee composition makes this firm-specific in character but the responsibilities themselves remain generic boilerplate.


reasoning: This is a negative assertion about cybersecurity incident history — the company states it has not experienced any incidents resulting in operational interruptions or breaches. Per the guidelines, negative assertions about incident history are classified as Strategy Integration, as they constitute a backward-looking materiality conclusion. The paragraph contains no incident narrative, no process description, and no governance structure discussion.


reasoning: Despite the CTO being mentioned as the grammatical subject in portions of the paragraph, the primary focus is on the GOVERNANCE STRUCTURE — how the Board oversees risk directly and through the Audit Committee, and how the CTO feeds into that oversight chain (reports quarterly to the committee). The CTO qualifications (25 years experience, committee memberships) serve to establish the credibility of the reporting officer within the governance framework, not to describe the person as an individual. The governance-chain description (Board → Committee → Officer → Program) is the substantive disclosure.


reasoning: The paragraph's primary purpose is describing the governance/oversight structure — how the Board (via Audit Committee) oversees cybersecurity risk and the reporting cadence from management up to the board. Named cybersecurity-specific roles (CIO, HIS) and specific meeting cadences distinguish this from generic boilerplate.


reasoning: The paragraph contains only generic statements about the importance of data security to business operations, listing what systems rely on cybersecurity without describing any actual process, governance structure, risk assessment, or program. It is pure IT-dependence boilerplate with no substantive cybersecurity disclosure.


reasoning: The paragraph describes how cybersecurity risk information flows from management to board committees (Audit Committee and Enterprise Risk and Compliance Committee), which is the governance/oversight structure — the core of Board Governance. The named committee 'Enterprise Risk and Compliance Committee' elevates this from generic boilerplate to Sector-Adapted, as it names a specific committee beyond the standard Audit Committee.


reasoning: The paragraph describes the governance/oversight structure — specifically how information flows from management to the CEO and Board of Directors regarding cybersecurity (what topics are covered, the reporting cadence of 'at least annually'). This is a description of board oversight structure, not of management qualifications (Management Role), internal processes (Risk Management Process), or financial/materiality assessments (Strategy Integration). The paragraph contains no specific facts: no named frameworks, no specific dates, no dollar amounts, no named programs, no third-party firms, and no cybersecurity-specific titles beyond the generic 'CEO' and 'Board of Directors.' All language is standard boilerplate that could appear in any company's filing.


reasoning: The paragraph describes the cybersecurity governance structure with board and Audit Committee oversight of the CEO, who consults with the CFO and unnamed third-party consultants. The primary focus is the oversight chain (board → CEO → consultants), which is the defining characteristic of Board Governance. All elements are generic—no named committees beyond the standard Audit Committee, no named third-party firms, no specific processes, dates, or metrics.


reasoning: The paragraph's primary focus is describing the governance/oversight structure — the escalation chain from GIS team to CISO to Enterprise Security Council to Enterprise Risk Council chaired by the President and CEO — which is the core of Board Governance. While a named CISO and President/CEO appear as subjects, the content describes the oversight architecture and information flow, not who these individuals are as people. The paragraph contains several firm-specific facts: named Enterprise Security Council with specific department composition (GIS, IT, Legal, Compliance, Internal Audit, ERM), named Enterprise Risk Council, and the CEO's specific prior role as Deputy Secretary of Defense during the 2018 DoD Cyber Strategy.


reasoning: The paragraph describes the company's internal cybersecurity governance structure and processes — IT security team, cross-functional approach, training, reviews/tests, internal audits, and third-party consultants — without providing any person-specific qualifications, named frameworks, or verifiable details. Applying the MR vs RMP decision chain: while 'CISO' is mentioned as a grammatical anchor, the paragraph describes what the cybersecurity PROGRAM does (implementation, maintenance, coordination, testing, audits), not who the CISO IS. After removing titles and roles, the text remains a coherent disclosure of internal processes. No specific dates, dollar amounts, headcounts, named third-party firms, named tools, certifications, or recognized frameworks appear, making this Generic Boilerplate applicable to any company.


reasoning: The paragraph's grammatical subject is 'Members of our management team' and the primary purpose is to identify which key personnel lead cybersecurity efforts and enumerate their responsibilities, rather than to describe a standalone cybersecurity process. Applying the person-removal test, deleting the roles leaves a description of organizational structure focused on who leads, not how the process works. This is Management Role because it emphasizes the governance-chain structure and role assignments rather than the risk management methodology itself.


reasoning: The paragraph's primary content is a backward-looking negative assertion (no material cybersecurity incidents identified to date), which matches the Strategy Integration definition of 'we have not experienced any material cybersecurity incidents.' The second sentence is generic forward-looking risk disclaimer that explicitly cross-references Item 1A, making it boilerplate. No named entities, frameworks, dates, or other specific facts appear — the language is standard across virtually all 10-K cybersecurity sections.


reasoning: The paragraph is primarily about identifying WHO manages cybersecurity (executive officers, third-party consultant, SOC Manager) and describing the SOC Manager's qualifications (technical certifications, background in IT infrastructure, risk mitigation, and incident response). The emphasis on the advisory relationship between consultant and SOC Manager, and the qualifications-based characterization of the SOC Manager, makes this a personnel/role description rather than a description of an internal process. No named committee or formal reporting structure appears; instead, the governance is described through individual roles and their qualifications.


reasoning: The paragraph describes an internal IT department's responsibilities for cybersecurity risk assessment, security controls, and incident response—which are internal processes. No named roles (CISO/CIO), no qualifications, no hard verifiable facts—just generic organizational language describing what the department manages.


reasoning: The paragraph is primarily about who comprises the incident response team (IRT) — naming specific executive roles (CFO, COO, CLO, EVP of Information Technology) and describing their composition. While there is a governance chain ending with Board reporting, the bulk of the paragraph describes the team structure and internal roles, making this a Management Role disclosure. The paragraph is Firm-Specific because it names the EVP of Information Technology (cybersecurity-specific role) and identifies a specific internal program (Cyber Incident Response Team).


reasoning: The paragraph describes the governance/oversight structure of the Cybersecurity Steering Committee—its composition, responsibilities, and oversight function—which is Board Governance. The committee name (CSC) and the specific listed roles across Finance, HR, Legal, Operations, Audit, and IT/CISO constitute firm-specific identifying facts about how Lumentum organizes its cybersecurity oversight.


reasoning: The paragraph describes the governance/oversight structure—how the Board receives updates, the Audit Committee's role, and how management reports upward. This is a classic board governance disclosure describing the information flow from management to the Audit Committee to the Board. The specificity is Generic Boilerplate because it contains only standard entities (Board, Audit Committee, CEO, Management) with vague cadences ('periodic', 'regularly') and no firm-specific details such as named programs, specific dates, numbers, named frameworks, or unique identifiers.


reasoning: The paragraph primarily describes the Vista CIO's qualifications, experience, and appointment date — meeting the Management Role definition of describing who a person IS. The bulk of substantive content (three of five sentences) focuses on the CIO's career history. While the DPIRC oversight structure appears briefly in opening sentences, the detailed qualifications of the CIO are the main focus.


reasoning: The paragraph describes the governance/oversight structure for cybersecurity, specifically the management team's role in leading and supervising the cybersecurity program, with composition from multiple departments (IT, finance, legal, operations). The focus is on HOW the organization is structured for oversight, making Board Governance the appropriate category. No specific dates, dollar amounts, named third-party firms, named tools/products, named cybersecurity-specific roles (CISO/CIO not mentioned), or specific qualifications appear—the management team members are described only generically as 'senior staff and executives.'


reasoning: The paragraph describes the governance/oversight STRUCTURE—specifically a hierarchical escalation process from threat identification through management to the Risk Committee and Board—with named executive roles and a named committee providing the firm-specific identifiers. While the paragraph mentions that leaders have expertise and 15+ years of experience, these details support the governance narrative (why these individuals are appropriate escalation points) rather than constituting standalone biographical/qualification content.


reasoning: The paragraph contains explicit backward-looking and forward-looking materiality assessments ('have not materially affected us' and 'reasonably likely to materially affect us'), which are the hallmark of Strategy Integration. However, the forward-looking portion reads as standard SEC risk-disclosure boilerplate rather than a substantive company-specific conclusion, and the paragraph lacks any firm-specific facts, named entities, or specific details.


reasoning: The paragraph describes the internal structure for managing cybersecurity functions (risk assessment, security controls, incident response) rather than describing who the IT manager IS. Under the MR vs RMP decision chain, removing person details leaves a coherent description of cybersecurity management structure. The IT Manager title is cybersecurity-specific (CISO/CIO/CTO-level equivalent), making this Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph contains only generic forward-looking risk disclaimers ('could have a material adverse effect') and boilerplate acknowledgments about facing cybersecurity threats. It does not describe any specific governance structure, management roles, processes, frameworks, incidents, or materiality assessments—the company merely states it 'believes' cybersecurity is important and warns of potential risks. No substantive cybersecurity disclosure is provided.


reasoning: Paragraph primarily describes the cybersecurity governance hierarchy (Board → Audit Committee → CISO → specialized teams), which is the Board's oversight structure. Named CISO qualifications are incidental to the governance description.


reasoning: This paragraph is primarily a cross-reference directing readers to Item 1A for cybersecurity risk disclosures, combined with generic boilerplate about the possibility of material adverse impacts from cybersecurity incidents. While it contains a brief negative backward assertion ('no such incident has had any such impact to date'), this is embedded within a cross-reference disclaimer rather than functioning as a standalone materiality assessment, making the paragraph's main purpose to point readers elsewhere rather than provide substantive disclosure.


reasoning: The paragraph primarily describes the operational functions of the Cybersecurity Team (maintaining the cybersecurity program, monitoring trends, overseeing training) rather than focusing on individual qualifications or personal attributes of named officers, making it Risk Management Process. The Cybersecurity Team composition—with specific named roles and explicit inclusion of outsourced technology firm representatives—provides firm-specific identifiers that distinguish this from generic boilerplate.


reasoning: This paragraph is a forward-looking risk acknowledgment describing why the company faces cybersecurity risks (scope of operations, technical complexity, attractiveness to threat actors, third-party use). It contains no discussion of governance structure, management roles, actual processes, incidents, or materiality assessments—just generic speculation about potential threats that could appear in virtually any company's filing.


reasoning: The paragraph's primary subject is the board's oversight structure and reporting cadence (semiannual updates from CISO/CIO to the Board, periodic updates from external experts), not the identity or qualifications of named individuals. The CISO is mentioned as part of the governance chain, not described as a person. CISO is the only firm-specific fact present; no named frameworks, tools, dates, or hard numbers would elevate to Quantified-Verifiable.


reasoning: The paragraph's primary subject is the CEO's responsibility for overseeing cybersecurity, with basic security controls mentioned as supporting context. The CEO-oversight language points to management-level governance, but the security features described ('standard commercial software,' 'password protection,' 'data encryption') are universally applicable boilerplate. No specific tools, named frameworks, dates, amounts, or cybersecurity-specific titles beyond CEO are present.


reasoning: The paragraph describes the company's cybersecurity risk management process (assessment, monitoring, incident response, materiality determination) rather than profiling individuals or naming specific frameworks. Named officers appear as structural placeholders for accountability, not as persons being described for their qualifications, making this RMP rather than Management Role. All content is standard governance language with no firm-specific identifiers, dates, named tools, or named third parties.


reasoning: The paragraph is primarily about WHO the named officers are — their qualifications (25+ years experience, MIS degree, MBAs), the third-party CISO consultant's background (15 years experience, prior CISO roles at other public manufacturing companies). While the opening discusses governance structure, the majority of content focuses on officer credentials and experience, making Management Role the primary category. The paragraph contains at least six hard verifiable facts (specific years of experience for multiple individuals, named degree, certifications), meeting the Quantified-Verifiable threshold of two or more.


reasoning: The paragraph's primary focus is describing the information security program's design, purpose (overseeing information security risk, ensuring CIA triad), and function (implementing controls aligned with industry guidelines). Applying the three-step decision chain: the grammatical subject is the program itself (Step 1), the person-removal test yields coherent disclosure about program functions (Step 2), and while the CISO's experience is mentioned, it is incidental to describing the program structure rather than the person's qualifications as the main topic (Step 3). The mention of a CISO reporting to a GCSO with specific experience credentials provides at least one firm-specific fact, though the overall disclosure focuses on programmatic risk management.


reasoning: While the paragraph mentions the Board and describes a reporting relationship, the grammatical subject is 'Management' and the substance focuses on internal processes (adopting a charter, reviewing guidelines, training, reporting) — consistent with describing a company's own cybersecurity management approach rather than the board's oversight structure. The content lacks any named frameworks, specific dates, named third-party firms, products, or quantitative details, making it generic boilerplate that could appear in any company's filing.


reasoning: The paragraph describes the board's oversight structure and information flow—monthly reporting cadence, report content topics, and evaluation results flowing to senior management and the Board. These are generic governance mechanics with no named cybersecurity-specific roles, committees, or external parties.


reasoning: The paragraph contains a backward-looking materiality assessment ('we have not yet experienced any material impacts from a cyber-attack') combined with forward-looking risk speculation — the opening assertion is a negative materiality conclusion about past incidents, which is characteristic of Strategy Integration. The paragraph contains no company-specific facts, named entities, dates, or framework references; all risk factors cited (loss of trust, reputation, litigation) are standard boilerplate applicable to any company.


reasoning: The paragraph describes the oversight structure—how information flows from ISO to management to BRCC and potentially to the full Board. While the ISO is mentioned, the paragraph's primary focus is on governance chains and board-level oversight mechanisms, not on who the ISO is as a person. The presence of the cybersecurity-specific title (ISO) and a named committee (BRCC) provides firm-specific identification beyond generic boilerplate governance language.


reasoning: The paragraph describes the CIRT's functional responsibilities (policy management, threat detection, incident classification, reporting) rather than individual qualifications or governance structure. Following the MR-vs-RMP decision chain, the process/team is the grammatical subject, and removing person details leaves a coherent description of internal cybersecurity processes. No hard verifiable facts remain after filtering (CIRT is an internal program name, not a third-party firm or tool; 'over 20 years' is vague; roles are generic IT titles).


reasoning: The paragraph's primary focus is describing the governance/oversight structure — board policy adoption, reporting lines (CTO reports to CEO, briefs audit committee), audit committee oversight of ERM, and board training — which is the core of Board Governance. The CTO's qualifications are mentioned incidentally to support why this oversight structure is credible, not as the primary purpose. The policy name, CTO's 25+ years of experience, and specific reference to directors having cybersecurity risk management experience provide firm-specific facts that differentiate this disclosure.


reasoning: The paragraph primarily describes the governance/oversight structure — how the board provides oversight and how executive officers report to the board — making it Board Governance. While the CEO's qualifications are mentioned, they are contextual detail supporting the governance disclosure. The CEO's 15 years of IT experience and cybersecurity focus are firm-specific facts that distinguish this paragraph from generic boilerplate governance language.


reasoning: The paragraph primarily describes the governance/oversight structure — how the Committee reports to the full Board, how the Board receives briefings, and the chain of responsibility for cybersecurity oversight — which is Board Governance. The named roles (CFO, Senior Director of IT, SVP Quality Assurance) appear as part of the governance chain description rather than being the focus of the paragraph, which is about how oversight flows upward to the Board.


reasoning: The paragraph's primary purpose is describing the governance and oversight STRUCTURE — how information flows from the ISMS Governance Committee (co-chaired by interim CSO and DPO) through the Data Protection Governance Committee to the audit committee. This describes the oversight chain rather than the qualifications or identities of the officers themselves. The paragraph contains several firm-specific facts: named cybersecurity-specific roles (CSO, DPO), a named internal program (ISMS Governance Committee), and a named non-generic committee (Data Protection Governance Committee), making it Firm-Specific.


reasoning: The paragraph describes the governance/oversight STRUCTURE — specifically how cybersecurity oversight flows through the Enterprise Risk Council, with the CISO as a standing member and VP Internal Audit as chair. The purpose is describing the oversight mechanism, not describing who the CISO is as a person (credentials, experience), which would be Management Role. The paragraph contains two firm-specific facts: a named internal committee (Enterprise Risk Council) and a cybersecurity-specific role (CISO), giving it Firm-Specific rather than Generic Boilerplate specificity.


reasoning: The paragraph describes the company's internal cybersecurity risk management process—identifying and assessing risks through monitoring, automated tools, scans, audits, and third-party assessments. While it names the SVPF and Director of IT, the substance is about what the process entails, not who these individuals are (no qualifications, experience, or credentials are provided). Applying the person-removal test, the remaining text coherently describes the company's RMP, confirming this classification. The specificity is Generic Boilerplate because it contains no named frameworks (NIST, ISO, etc.), no specific tools/products, no dates, no named third-party firms, and no firm-specific details—it describes generic cybersecurity risk management practices that could appear in any company's filing.


reasoning: The paragraph describes the governance/oversight structure for cybersecurity incidents, detailing how information flows upward from the cybersecurity team and Incident Response Team to the Strategy Board, Audit Committee, and Board. While the CISO is mentioned, the paragraph's primary purpose is describing the oversight chain and reporting structure, not who the CISO is as a person. The CISO appears as a structural element in the governance chain rather than as the subject of biographical description. Specific firm-identifying facts include the named CISO role, the named Strategy Board composition (CEO, CFO, General Counsel, CIO), and the specific departmental composition of the Incident Response Team.


reasoning: The paragraph describes the organizational structure supporting cybersecurity risk management—specifically that the company established a cross-functional team to implement the cybersecurity program—and uses a hard number (85 years combined experience) as a qualification detail, making it Risk Management Process rather than Management Role.


reasoning: The paragraph primarily describes the Board's cybersecurity oversight structure and delegation chain (Board → Audit Committee/CFO/IT resources → Director of IT → team), which is governance content; while the Director of IT is mentioned, the purpose is describing the oversight structure rather than the person's credentials.


reasoning: The paragraph describes a governance structure — how the VP of Information Technology reports to the Audit and Reserves Committee, the reporting cadence (at least semi-annually, annually), and the topics covered in board briefings. This is Board Governance as it details the oversight structure and information flow to the board level. The presence of a named cybersecurity-relevant title (VP of IT) and a named committee (Audit and Reserves Committee) provides firm-specific content beyond generic boilerplate, though no hard external facts (dates, dollar amounts, named third parties) are present.


reasoning: The paragraph describes the company's internal process for evaluating and escalating cybersecurity incidents, with the process/incident as the grammatical subject rather than any named person. The escalation chain (cybersecurity org → CISO → senior leadership) is generic boilerplate with no unique firm identifiers, named frameworks, dates, or other verifiable specifics.


reasoning: The paragraph describes the governance/oversight structure for cybersecurity, detailing how audit results flow upward from IAD through named committees (BAC, BOTC) to the board of trustees. While it references Morgan Stanley's internal audit function, it describes the Company's own board oversight structure and uses named committee identifiers (BOTC, BAC) that are not generic boilerplate.


reasoning: The paragraph describes internal cybersecurity processes (education, monitoring, audits, incident response plan) with the CIO mentioned only as the implementer/overseer of these programs, not as the subject of biographical description. After removing the role reference, the process description remains coherent and intact, confirming RMP. No specific dates, dollar amounts, named tools, headcounts, certifications, named third-party firms, or other verifiable facts unique to this company appear—the paragraph reads as standard cybersecurity risk management language applicable to any company.


reasoning: The paragraph describes the company's internal risk assessment and evaluation process (re-examining systems, continuous evaluation of cybersecurity risks), which is the core of Risk Management Process. No named cybersecurity-specific roles (CISO, CTO), no qualifications, no dates, no named frameworks, no third-party firms, and no named products or tools are present, making it Generic Boilerplate. The mention of reporting to CFO is organizational context supporting the process, not the focus.


reasoning: The paragraph describes internal cybersecurity processes (risk management, incident response, policy development, compliance) that management oversees. While 'management team' is the grammatical subject, the content describes processes rather than identifying or qualifying specific individuals. No named officers, credentials, team composition, or firm-specific details are present—just standard governance responsibilities applicable to any company.


reasoning: The paragraph describes internal risk management processes for monitoring and assessing cybersecurity threats, with the CFO as the responsible party. While the CFO is named, no cybersecurity-specific credentials, certifications, or qualifications are provided—only a description of what the process does. No specific dates, dollar amounts, named frameworks, or other hard verifiable facts are present, making this generic boilerplate.


reasoning: The paragraph describes an oversight structure — quarterly briefings from management to the audit committee with enumerated reporting topics — which fits the governance-chain description for Board Governance. The specific items listed (policy updates, threat assessments, incident reporting, compliance) are generic topic headings commonly found in SEC cyber governance disclosures, with no named officers, specific dates, dollar amounts, named frameworks, or other hard-verifiable facts.


reasoning: The paragraph describes a standard cybersecurity governance escalation structure (severity thresholds triggering notification to management, Audit Committee, and Board) without any hard verifiable facts. Named governance bodies are generic, not cybersecurity-specific committees, and no dates, dollar amounts, named third-party firms, or named tools are present. The final sentence about an independent board member's IT experience lacks any hard verifiable detail.


reasoning: The paragraph describes the governance/oversight structure for cybersecurity monitoring and reporting to the Audit Committee, including committee composition, the monitoring process (real-time), and reporting cadence. This is Board Governance because it details how information flows upward through the organization. No hard verifiable facts are present (no specific dates, dollar amounts, headcounts, named third-party firms, or named products/tools) — the committee name and roles are organizational structure details that do not constitute independently verifiable external facts.


reasoning: The paragraph's primary focus is identifying WHO manages the cybersecurity program and detailing their specific qualifications (25 years and 20 years of experience, specific expertise domains), which are person-specific content rather than a description of the process itself. The inclusion of two specific experience counts (25 years, 20 years) alongside named cybersecurity-specific roles (CTO, Head of Technology Infrastructure) and a named committee (C-ROC) provides multiple independently verifiable facts.


reasoning: This paragraph describes the governance/oversight structure: the Board's authorization of the Audit Committee to oversee cyber risk, the establishment of a Risk Committee chaired by the CISO, and the reporting chain (CISO → Audit Committee quarterly). The purpose is describing how oversight flows upward through the governance chain, which is Board Governance. The paragraph contains firm-specific identifiers (Fortrea Audit Committee, Risk Committee, CISO) that distinguish it from generic boilerplate, without meeting the two-hard-fact threshold for Quantified-Verifiable.


reasoning: The paragraph's primary purpose is describing the governance/oversight structure — specifically how information flows from management (Chief Security & Cash Operations Officer, Chief Compliance Officer, Chief Risk Officer) upward to the Board and its committees. The closing sentence explicitly states this structural purpose: 'All of these channels to the Board are designed to... provide a clear and accurate picture of the Company's evolving risk landscape.' This is BG content even though named officers appear as grammatical subjects; the purpose is describing the oversight chain, not the individuals themselves.


reasoning: The paragraph describes the cybersecurity governance structure—committee hierarchy, escalation paths, and reporting relationships to the board—making Board Governance the primary category. Named committees (Non-Financial Risk Committee, Firm Risk Committee, BOTC, MS Board) and the specific 'Head of Operational Risk' role distinguish this from generic boilerplate.


reasoning: The paragraph describes the ERMC's structure and how it integrates cybersecurity into enterprise risk management processes, which is an internal risk management process. The named committee and cybersecurity-specific roles (CISO, CDO) provide firm-level specificity, but there are no specific dates, dollar amounts, or named third-party firms to reach Quantified-Verifiable.


reasoning: The paragraph describes the governance/oversight STRUCTURE — tracing how cybersecurity incidents flow upward from the cybersecurity team to the Incident Response Team, Disclosure Committee, Strategy Board, Audit Committee, and Board. The named roles (CISO, Incident Response Team) and the specific Strategy Board composition (CEO, CFO, General Counsel, CIO, other management) identify this company's unique governance chain rather than generic oversight language.


reasoning: The paragraph describes board-level cyber risk oversight structure and the establishment of a Risk Committee, which is governance architecture rather than operational processes. While the committee is named ('Risk Committee'), this is standard corporate governance terminology; the paragraph lacks any specific individuals, named third-party firms, dates, or cybersecurity-specific tools that would elevate it to firm-specific. The materiality assessment role mentioned is part of the governance function, not a disclosed conclusion about a specific incident.


reasoning: The paragraph describes the cybersecurity oversight STRUCTURE — committee compositions, roles, reporting relationships, and meeting cadences — rather than describing the company's internal processes for assessing or managing risk. The governance chain (Director of IT → committees → Audit Committee) is the primary focus. Contains multiple firm-specific facts including named cybersecurity-specific roles (CISO, Director of IT), named committee structures, and specific meeting cadences.


reasoning: This paragraph describes the governance/oversight structure for cybersecurity, specifically identifying the cybersecurity sub-committee as having primary responsibility for assessing, monitoring, and managing cybersecurity risks. The committee's stated functions (overseeing strategies, testing compliance, remediating risks, leading training) describe how the company structures its cyber oversight. While the paragraph mentions experience, it is used to describe the committee's collective qualifications in service of its governance role, not to profile an individual officer.


reasoning: The paragraph describes the governance/oversight structure — specifically how information flows from management (Vice President) to the board on a regular cadence regarding cybersecurity risks and mitigation programs. The subject is the board's oversight mechanism, not the qualifications or role of a specific cybersecurity officer. The paragraph contains no specific dates, dollar amounts, named frameworks, or other identifiable details — only generic governance language about reporting to the board of directors on cybersecurity matters.


reasoning: This paragraph establishes the governance/oversight structure for cybersecurity risk management, introducing that committees and management positions are responsible for assessing and managing cybersecurity risks. The specific naming of the 'Enterprise Risk Management Committee' as a body with cybersecurity oversight responsibility makes this Firm-Specific rather than generic boilerplate, since the ERM Committee is a named internal committee (not the standard Audit Committee or Board of Directors). The paragraph functions as an opening statement of the oversight structure before elaborating on specific roles or processes.


reasoning: The paragraph primarily describes how cybersecurity risk management is integrated into the company's ERM program and how the Information Security Team structuredly assesses and manages risks — this is an internal process description, not an assessment of who specific people are. No credentials, experience, or qualifications for individuals are provided; the team composition details exist to illustrate the organizational structure supporting the process, not to describe the individuals themselves.


reasoning: The paragraph's primary purpose is describing the governance/oversight structure — specifically how management reports cybersecurity risks and progress upward to the Cybersecurity Committee and Board. No officer qualifications or biographical content appear; the Executive Vice President is described by function, not credentials. No specific dates, named firms, dollar amounts, or framework citations are present.


reasoning: The paragraph describes the governance/oversight structure — how cybersecurity information flows from the CISO to the Audit Committee and Board — making it Board Governance. The CISO role is a cybersecurity-specific identifier, qualifying this as at least Firm-Specific.


reasoning: The paragraph describes the governance/oversight structure — how oversight flows from the board level through the Audit Committee to the Cybersecurity Disclosure Committee — which is the defining characteristic of Board Governance. The named CDC with its specific team composition constitutes firm-specific content beyond generic boilerplate governance language.


reasoning: The paragraph describes the oversight structure and governance mechanisms for cybersecurity, with DPIRC as the central subject managing policies, capabilities, and incident monitoring, and the Enterprise Risk Committee receiving quarterly updates from the CISO. This is governance-chain description rather than detailed process documentation.


reasoning: The paragraph's grammatical subject is the 'cybersecurity program' and its associated processes, systems, and safeguards—not the named individuals. When the person references are removed, the paragraph remains a coherent description of the company's cybersecurity risk management approach. The subject is a process/framework, not a person. Additionally, NIST is named as the informing framework, which elevates specificity from Generic Boilerplate to Sector-Adapted.


reasoning: The paragraph opens with substantial biographical detail about the CIO — over three decades of experience, named certifications (ISA 62443, CISM, CISSP) — establishing WHO this person IS and their qualifications. While the paragraph also covers board governance structure and internal processes, the initial focus on individual credentials and the person's qualifications anchors it as Management Role. The paragraph qualifies as Firm-Specific because it contains multiple non-generic facts: a named committee (Sustainability & Safety Committee, not generic Audit Committee), a specific transition date (2025), specific reporting cadences (quarterly/annual), and named cybersecurity certifications — none of which appear in standard boilerplate.


reasoning: The paragraph primarily describes a governance structure (the Cybersecurity Steering Committee and its oversight responsibilities), not the company's internal risk management processes. The committee's enumerated functions (ownership of risks, policy review, initiative assessment, strategic sponsorship) are governance oversight functions rather than operational security processes. The Cybersecurity Steering Committee name and the co-chair arrangement between the interim Chief Legal Officer and CSO are facts specific to this company's disclosure, distinguishing it from generic governance language.


reasoning: The paragraph primarily identifies the Information Security Officer, describes their qualifications (over a decade of experience), and outlines team credentials — making the individual and their qualifications the central topic rather than describing an internal process that merely mentions a role. While governance structure (reporting to the Board) and processes (tabletop exercises, training) appear, the explicit qualification details in sentences 2-3 anchor this as Management Role.