content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph contains only generic cybersecurity threat acknowledgment and standard forward-looking disclaimer language ('could materially adversely affect') that appears in virtually every 10-K filing. There is no description of actual incidents, governance structures, management roles, internal processes, or any materiality assessment—the materiality phrase is boilerplate speculation, not a conclusion.

provider: minimax

stage: benchmark


content_category: Strategy Integration

reasoning: This paragraph is a negative materiality assertion — the company states it has not experienced any material cybersecurity incidents and is not aware of risks that have materially affected or are reasonably likely to materially affect the company. This is a backward-looking and forward-looking assessment of cybersecurity's impact on business outcomes, which is the hallmark of Strategy Integration. The paragraph contains only standard SEC boilerplate language with no named entities, specific dates, dollar amounts, frameworks, or other firm-specific facts.


reasoning: This paragraph is a forward-looking risk disclaimer containing only speculative language ('may be affected,' 'could result in losses,' 'have a material adverse effect') — standard boilerplate that appears in virtually every 10-K filing. It describes no actual incidents, no governance structure, no named processes, and no materiality assessment (only hypotheticals). This is classic risk warning language, not a substantive cybersecurity disclosure.


content_category: Board Governance

specificity_confidence: medium

reasoning: This paragraph describes the oversight structure—specifically how IT Management reports to the Risk Committee and what topics are covered in that reporting (risk assessment, incidents, service provider arrangements, etc.). The Risk Committee is a named non-generic committee, which is a firm-specific fact distinguishing this from generic governance language.


reasoning: The paragraph describes the board's oversight structure for risk management, including the CRO's reporting relationship to the board—classic Board Governance content about information flow and governance chain. There are no cybersecurity-specific titles (CISO, CTO, CIO, etc.), named non-generic committees, specific dates, or other firm-specific facts; the Chief Risk Officer is a generic C-suite role, and 'regularly' is vague cadence language.


reasoning: The paragraph describes the governance/oversight structure — specifically the information flow from CISO through the Cybersecurity Executive Steering Body to the Audit Committee of the Board — which is the core of Board Governance. The presence of the named 'Cybersecurity Executive Steering Body' and the CISO title are firm-specific facts that distinguish this from generic board oversight language.


reasoning: This paragraph is a forward-looking disclaimer with a cross-reference to Item 1A Risk Factors. It contains no description of actual governance structure, management processes, or incident details—just standard boilerplate language about evolving threats and the inherent limitations of any security program. No named entities, frameworks, dates, or other specific facts are present.


reasoning: The paragraph primarily describes the cybersecurity governance chain—how threats are reported up from third-party advisors to the VP of Tech, escalated to executive leadership and the Audit Committee, and ultimately to the Board of Directors for material incidents. This is a description of oversight structure and information flow, which is Board Governance. The paragraph contains firm-specific facts: a named cybersecurity-specific role (VP of Tech) and a specific team composition (IT specialists, accountants, and lawyers).


content_category: Risk Management Process

reasoning: The paragraph describes the organizational placement of cybersecurity risk management (Information Security Office) and the existence of an implemented plan (Incident Response Plan). While the CIO is mentioned, the paragraph's purpose is describing the internal process structure, not profiling the officer's qualifications. No hard verifiable facts present (no dates, amounts, certifications, named third-party firms, or unique identifiers).


reasoning: The paragraph's dominant function is a materiality assessment — the company explicitly concludes that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company (backward-looking negative assertion + forward-looking with SEC qualifier). This is a strategic/financial impact conclusion, not a description of a governance structure, process, or incident. The content is entirely boilerplate language that could appear in any SEC filing, with no company-specific details, named frameworks, dates, or other verifiable facts.


reasoning: This paragraph is a backward-looking materiality assessment stating that cybersecurity threats have not materially affected the company—a Strategy Integration disclosure. The cross-reference to Item 1A is a supporting citation, not the primary content. The paragraph contains no firm-specific details: no named frameworks, dates, dollar amounts, named firms, or specific numbers.


reasoning: The paragraph describes the governance/oversight structure — specifically how the Board exercises oversight, which committees are involved, and how information flows upward from management to the board. While specific officers (CLO, CTO, Information Security Manager) are mentioned, they appear as components of the governance chain rather than as the primary focus, so Management Role does not apply. The named committees (Board Risk Committee, Management Risk Committee, Executive Committee) and cybersecurity-specific title (Information Security Manager) distinguish this from generic boilerplate governance language.


reasoning: This paragraph is a standard forward-looking disclaimer acknowledging cybersecurity threats without providing any substantive disclosure. It contains no specific details about an incident (no dates, scope, or response actions), no governance structure description, no process details, and no materiality assessment — only boilerplate language about past attempts being 'prevented' and a cross-reference to Item 1A Risk Factors. This is generic risk warning language present in virtually every 10-K.


reasoning: The paragraph's primary purpose is describing the cybersecurity governance structure: the Audit Committee's role in directing oversight, the reporting chain from CIO/SIRT to Audit Committee to Board, and the cadence of reporting and meetings. While the CIO is mentioned prominently, the focus is on how the board exercises oversight through its committee, not on who the CIO is as a person. The paragraph references named standards (NIST, ISO, COBIT, ITIL) but lacks specific dates, dollar amounts, headcounts, named third-party firms, or named tools/products that would elevate it to Firm-Specific or Quantified-Verifiable.


reasoning: The paragraph contains a negative materiality assertion ('we have not experienced a material cybersecurity incident') which qualifies as a Strategy Integration assessment under the guidelines. No specific facts were identified — no named frameworks, dates, dollar amounts, named third-party firms, or unique identifiers to the company.


reasoning: The paragraph describes the governance/oversight structure — specifically how cybersecurity information flows from management (CIO, CISO, VP of Product Security) to board committees (Audit Committee, QRC) and how incidents are escalated to the Board. This is a board oversight structure description, not an internal process description. The named cybersecurity-specific roles (CISO, VP of Product Security) and named committee (QRC) provide firm-specific details beyond generic board governance language.


reasoning: The paragraph describes a governance structure — information flowing upward from internal teams through management to the Board/Audit Committee in alternating quarters — which is Board Governance. No named entities, specific tools, named external consultants, or company-specific details are present; all references are generic governance structures that appear in virtually every 10-K disclosure.


reasoning: The paragraph's main point is the backward-looking materiality assessment 'cybersecurity incidents have not materially affected our business to date,' which is the core of Strategy Integration category per tiebreaker rules. While 'Cyber Governance' appears at the end as a section header (which would be N/O on its own), it is incidental to the paragraph's primary purpose. There are no specific facts—'significant financial and personnel resources' is a vague quantifier, the rest is boilerplate disclaimer language found in virtually every 10-K filing.


category_confidence: medium

reasoning: The paragraph's grammatical subjects are 'the cybersecurity team' and its activities (monitoring, evaluating, vulnerability scans, penetration tests, threat intelligence feeds, tools/methodologies) — describing internal processes rather than who Mr. Daly is as an individual. Removing person-specific details leaves a coherent RMP disclosure. The certifications (CISSP, GIAC) qualify the team's capability but are incidental to the process description.


reasoning: The paragraph describes the governance/oversight structure — a Compliance Committee overseeing cybersecurity, its composition (including the CIO), meeting cadence, escalation processes, and how information flows to senior management and the Board. This is fundamentally about how the board exercises oversight, not about internal processes or who specific officers are. The named CIO is incidental to the governance structure being described.


reasoning: The paragraph describes the governance/oversight structure — specifically how cybersecurity information flows from management (ITSC, CIO) to the Board on a quarterly basis — which is the defining characteristic of Board Governance. No specific facts are present; 'ITSC' is an internal committee acronym without context, 'CIO' is a generic role, 'quarterly' is a vague cadence, and 'Board of Directors' is standard governance language found in every filing.


reasoning: The paragraph describes the governance/oversight STRUCTURE—specifically how cybersecurity oversight flows from the Information Security Department through the CISO and Chief Risk Officer up to the Board Risk Committee. The purpose is describing the oversight chain, not detailing internal risk management processes. The paragraph contains firm-specific content including the named CISO role, the named Risk Management Council with senior leadership composition, and the specific departmental reporting structure.


reasoning: The paragraph describes the company's internal CSWAT team, its composition across senior leaders, and the processes it uses to manage cybersecurity and operational risks—clearly an internal risk management process. While the team composition (senior IT, operations, risk, legal, compliance) and the functions reviewed (information security, third-party risk, vendor management, business continuity, disaster recovery) are described, the unique identifier 'Cyber Security Watch Team' (CSWAT) makes this firm-specific rather than generic boilerplate.


reasoning: The paragraph describes the company's internal risk management structure and processes—identifying, assessing, managing, and mitigating cybersecurity risks—which aligns with Risk Management Process. While specific roles are mentioned, the content focuses on what these teams do (processes) rather than who these people are (their qualifications or credentials). The specificity is Generic Boilerplate because it contains no named frameworks, specific dates, dollar amounts, named third-party firms, named products/tools, or any other fact that uniquely identifies this company's disclosure.


reasoning: The paragraph describes the company's internal risk management process — enterprise risk management team working with the CSO and IT risk management team to evaluate cybersecurity risks — with teams and processes as grammatical subjects, not individuals with qualifications. After removing role titles, the text remains a coherent description of an internal process. No specific dates, dollar amounts, headcounts, named third-party firms, or named products/tools appear; CSO and team references are generic governance language without unique identifiers or verifiable facts.


reasoning: The paragraph describes the governance structure and information flow to the board—specifically who reports (CIO and General Counsel) and what oversight topics they review. This is governance-chain content, not a description of internal processes or officer qualifications. The mention of the CIO (a cybersecurity-specific title) provides a firm-specific fact distinguishing this from generic boilerplate.


reasoning: The paragraph describes the governance structure—specifically the board-approved committee hierarchy, reporting chains (IT/Cybersecurity Committee → Enterprise Risk Committee; CISO → board committee), and oversight mechanisms—which is the defining characteristic of Board Governance disclosures. While roles like CIO and CISO are mentioned, they appear as participants in the governance structure rather than as subjects being described in terms of their qualifications or experience.


reasoning: The paragraph describes the governance chain (board delegate → committee → chair → member departments) and the ISC's oversight functions. Per the BG tiebreaker, board oversight mentioned as the main focus with committee structure as the primary subject maps to Board Governance, not Management Role. The named committee structure, CISO role, and specific departmental composition are firm-specific facts that identify Allstate's unique governance architecture.


reasoning: The paragraph's primary purpose is a negative materiality assertion — 'not aware of any previous cybersecurity threats that have materially affected' — which explicitly fits the Strategy Integration definition for backward-looking assessments and negative assertions. The remainder consists of generic vulnerability warnings ('security breaches,' 'computer viruses,' 'lost or misplaced data') that are boilerplate risk language common to virtually all SEC filings, plus a cross-reference to Item 1A.


reasoning: The paragraph describes internal processes for monitoring cybersecurity incidents and operating the incident response plan, with the InfoSec Leadership Team mentioned as a participant in these processes rather than as individuals with qualifications. No named officers with credentials, no specific dates, dollar amounts, named third-party firms, or unique framework references are present.


reasoning: The paragraph describes the company's internal risk management approach and framework ('three lines of defense' model, multi-disciplinary monitoring/assessment/response) but contains no named personnel, specific dates, dollar amounts, third-party firms, or other verifiable firm-specific facts that would elevate the specificity level.


reasoning: The paragraph describes internal cybersecurity processes—monitoring, an Incident Response Policy, and employee training—with no person-specific details beyond a generic title. The Incident Response Policy and associated procedures are the subject; the VP Infrastructure oversees them but the paragraph does not describe the person's qualifications, experience, or background.


reasoning: The paragraph's primary purpose is a backward-looking materiality assessment ('has not been materially affected by a cybersecurity breach') combined with forward-looking risk acknowledgment, which constitutes a Strategy Integration disclosure. The specificity is Generic Boilerplate because it contains no named frameworks, specific dates, dollar amounts, named third-party firms, named tools, or any other fact unique to this company — it could appear verbatim in virtually any 10-K filing.


reasoning: The paragraph describes the cybersecurity oversight structure—the escalation chain from third-party advisors through the Sr Director of Tech, cross-functional team, executive leadership, and Audit Committee, culminating in Board notification for material incidents. The governance chain and information flow to the Board is the primary focus, not the incident response process itself. Contains firm-specific facts: a named cybersecurity-specific role (Sr Director of Tech), specific team composition (IT specialists, accountants, lawyers), and named committee (Audit Committee).


reasoning: This paragraph is standard SEC forward-looking boilerplate ('reasonably likely to materially affect') combined with a cross-reference to Risk Factors. Per the classification rules, generic risk warnings and cross-references pointing to other sections are None/Other, not Strategy Integration or any substantive disclosure category.


reasoning: This is a cross-reference paragraph directing readers to Item 1A for cybersecurity risk disclosures. It contains no substantive cybersecurity disclosure and merely points to another section of the filing. Per the tiebreaker rules, cross-references with materiality language pointing elsewhere are classified as None/Other, not Strategy Integration assessments.


reasoning: The paragraph's primary focus is describing the company's internal cybersecurity risk management program and processes—the CTO's oversight role is presented as part of that governance structure, not as the main subject. Applying Step 2 of the MR/RMP decision chain, the process and program content remains coherent even after removing person-specific details, confirming RMP as the primary category.


content_category: Management Role

reasoning: The paragraph identifies a specific named role (CDO) and describes their functional responsibilities in directing information security activities and leading cybersecurity strategy development. This is fundamentally about WHO oversees cybersecurity rather than describing the internal processes themselves. No credentials, certifications, experience, or team composition are provided, so it falls short of Quantified-Verifiable despite naming a specific officer.


reasoning: The paragraph's primary focus is describing WHO leads the cybersecurity function and their specific qualifications (15+ years of experience, incident response and security operations background). While the committee structure and its quarterly reviews appear, they are incidental to describing the leadership and governance CHAIN rather than the board's own oversight mechanism.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for cybersecurity risk factors. It contains no substantive disclosure about the company's own cybersecurity governance, processes, or assessments—it merely points elsewhere. The included risk factor title is generic boilerplate that could appear in any company's filing.


reasoning: The paragraph describes the oversight structure — how the Chief Security and Trust Officer reports to executive leadership and how cybersecurity is integrated into the enterprise risk management program through internal audit. This is governance-chain description (officer → executive team → ERM), making it Board Governance rather than Risk Management Process, even though a named officer appears as grammatical subject.


reasoning: The paragraph primarily describes the governance/oversight structure, including how the board exercises oversight and how information flows upward from leadership to the board. Named cybersecurity officers (SVP/CTO, VP of IT, Senior Director of IT Security) serve as fixtures within this governance chain rather than being the primary focus. The paragraph explicitly states the board's oversight role over enterprise risk assessment and the quarterly/annual reporting cadence to the board.


reasoning: The paragraph describes the organizational structure and reporting relationships for cybersecurity oversight, with Union's ISO as the primary subject. While it mentions team composition, the grammatical focus on the ISO role and reporting line indicates Management Role rather than Risk Management Process. The paragraph contains firm-specific identifiers (ISO title, Senior Risk Officer role, internal team composition) but lacks hard verifiable facts like dates, dollar amounts, or named external tools/firms.


reasoning: The paragraph primarily describes IFF's cybersecurity governance/oversight structure through named committees (InfoSec Steering Committee, InfoSec Governance Review Board), reporting relationships (CIO → CISO → committees), and ERM integration—notably even the CISO is presented as part of the governance chain. The governance-chain framework applies even though officers appear as grammatical subjects, because the stated purpose is describing oversight structure. The paragraph contains multiple firm-specific identifiers (named committees, specific sub-functions, named framework) that are unique to IFF's disclosure.


reasoning: The paragraph describes the governance/oversight structure—specifically the ERC's role in the oversight chain (BRC → ERC), its cross-functional composition, and how cybersecurity information flows upward (CISO to ERC). While officers are mentioned, they appear as participants in the governance structure rather than as the primary subject. The CISO role and named ERC committee provide firm-specific details beyond generic boilerplate.


reasoning: The paragraph describes an internal monitoring process (information flow to management) rather than board oversight structure, making Risk Management Process the primary category. The cybersecurity-specific role titles (CISO, Sr. Director of Information Security) provide firm-specific detail, but no hard verifiable facts such as dates, dollar amounts, or named external firms/tools are present.


reasoning: This is a forward-looking risk disclaimer ('could lead to') describing potential hypothetical consequences of a data breach, not a description of any actual incident, governance structure, or process. Per calibration guidelines, generic risk warnings about what could happen are boilerplate speculation, not substantive disclosures.


reasoning: The paragraph describes management's internal cybersecurity responsibilities (hiring, budget approval, incident preparation, process approval, reviewing assessments) — these are organizational processes that stand independently of any specific person. Applying the person-removal test, the processes remain coherent without the named role, confirming RMP rather than Management Role. No board, committee, named officer, framework, date, or other specific identifier is present.


reasoning: The paragraph describes the governance structure for cybersecurity oversight—specifically how the CTO reports to the Audit and Finance Committee, the cadence (quarterly), and what information flows upward (threats, incidents, security controls, third-party review). The named Digital QBR program and specific Audit and Finance Committee designation provide firm-specific detail beyond standard governance boilerplate.


reasoning: This paragraph is a general introductory statement about the company's IT dependence and awareness of increasing cybersecurity risks. It contains no description of actual incidents, governance structures, management roles, specific processes, or materiality assessments—it is purely boilerplate language that could appear in any company's 10-K filing.


reasoning: This is a generic forward-looking risk warning about hypothetical operational consequences of cybersecurity incidents. It contains no description of actual incidents, no governance structure, no internal processes, and no materiality assessment—just boilerplate speculation ('could disrupt') that could appear in any company's filing. No specific facts or firm-unique details are present.


reasoning: The paragraph primarily describes the company's cybersecurity risk management infrastructure—protocols, policies, safeguards, third-party assessments, incident response plan, and employee training—with the CFO mentioned only as the responsible officer. Applying the decision chain, removing person details leaves a coherent disclosure of internal processes, confirming RMP. The explicit naming of ISO 27001 elevates this to Sector-Adapted; there are no firm-specific identifiers (no named third-party firms, no dates, no quantified metrics).


reasoning: The paragraph describes the governance/oversight structure — how the cybersecurity team reports to the Audit Committee and the Board on a quarterly basis. This is standard board governance language that could appear in any company's 10-K. No firm-specific facts are present: the Audit Committee is generic governance, 'quarterly' is a vague cadence (not a specific date), and 'third-party assessments' is an unnamed reference.


reasoning: This paragraph is a standard forward-looking risk disclaimer that could appear in virtually any 10-K filing. It contains no specific details about the company's actual cybersecurity governance, processes, or incidents—only generic warnings about cybersecurity threats and vague assertions that unspecified measures have been implemented.


reasoning: The paragraph's primary purpose is a backward-looking materiality assessment ('such risks have not materially affected us, including our business strategy, results of operations or financial condition'), which qualifies as Strategy Integration per the tiebreaker rules. The brief mention of experiencing 'threats and breaches' serves as context for the materiality conclusion rather than as substantive incident disclosure. The paragraph contains no named entities, specific dates, dollar amounts, or other verifiable facts—only generic cybersecurity language and boilerplate legal terminology.


reasoning: The paragraph describes the oversight structure — specifically how the board-approved IT Steering Committee operates, its membership composition, and the reporting chain (Information Security Officer → board). The named Information Technology Steering Committee and specific cybersecurity roles (CIO, CTO, ISO) identify this company's unique governance structure rather than generic boilerplate.


reasoning: The paragraph's grammatical subject is the governance and oversight STRUCTURE (Audit and Risk Committee, CIO, delegated positions), but the substantive content describes the company's cybersecurity processes: incident response strategy, monitoring/testing/reporting procedures, and risk measurement. The CIO's qualifications (15 years experience, degree) are incidental to describing the process. This is borderline with Board Governance since it begins with committee oversight, but the bulk of content describes internal cybersecurity processes rather than how the board exercises oversight.


reasoning: The paragraph describes the governance/oversight structure — specifically a named committee (TRCC) as a sub-committee of ERC, its composition (CISO, senior business stakeholders), its chair appointment process, and escalation pathways. While the CISO is mentioned, the grammatical subject is the committee and its oversight role, not the individual person's qualifications or credentials. The governance chain (TRCC → ERC) is the primary disclosure.


reasoning: The grammatical subject is 'Our cybersecurity risk assessment and management processes,' and applying the person-removal test, the remaining text still coherently describes that the company maintains these processes. The named role and experience are incidental context about who implements the program, not the primary subject. The cybersecurity-specific title (Senior Principal Security and Infrastructure Architect) and specific experience duration (over 20 years) elevate this beyond Sector-Adapted boilerplate about implementing NIST or generic frameworks.


reasoning: The paragraph primarily describes the governance structure — how the risk management program is organized, where cybersecurity fits within it, and the oversight chain from CISO to the board's IT/Cybersecurity Committee. The CISO is mentioned in their oversight capacity, not as the subject of a description about who they are or their qualifications. The named IT/Cybersecurity Committee and specific CISO title are firm-specific facts identifying this company's unique governance structure.


reasoning: The paragraph primarily describes the governance/oversight structure for cybersecurity risk management — which teams participate and their collective experience — making it Board Governance. It contains no firm-specific identifiers (no named cybersecurity officer, no named committee, no specific dates or named programs with unique identifiers), so it qualifies as Generic Boilerplate.


reasoning: The paragraph describes the company's process for identifying and assessing cybersecurity risks using a third-party firm and internal IT Lead, with the process itself (monitoring threat environment, evaluating risk profile) being the primary subject rather than the qualifications or identity of any individual. No specific firm is named, no dates/dollar amounts/percentages appear, and no recognized standards (NIST, ISO 27001) are mentioned—just generic descriptors like 'various methods and tools.'


reasoning: The paragraph's primary focus is describing the governance/oversight structure — how the Board and Audit Committee receive cybersecurity briefings on at least an annual cadence and for material incidents. While the CIO's 20 years of experience is mentioned, it is incidental context supporting the governance description, not the main point of the paragraph. The paragraph follows a board-to-committee-to-officer governance chain, which is Board Governance per the classification rules.


reasoning: The paragraph describes the governance/oversight structure — Board oversight responsibility, management's role, reporting chain (Principal Accounting Officer → audit committee → Board), and information flow. The governance chain is the central purpose even though multiple parties are mentioned. The negative assertion about no incidents is incidental to the governance description, not a standalone materiality assessment.


reasoning: This paragraph is a forward-looking disclaimer admitting the company lacks cybersecurity resources and capabilities—no substantive disclosure of a program, process, incident, or materiality assessment. For a SPAC with no operations, this is essentially a boilerplate risk warning about inability to manage cyber risks, which classifies as None/Other.


reasoning: The paragraph describes the structure and responsibilities of the company's Cyber Security Office and its governance function, which is an internal process description. While a CISO is mentioned, the focus is on the program's operational scope (implementation, monitoring, data protection) rather than individual qualifications or career history.


reasoning: Although the paragraph contains a negative assertion ('we have not experienced any recent material cybersecurity incidents'), the primary purpose is forward-looking risk disclaimers and a cross-reference to Risk Factors, not a substantive materiality assessment. The bulk of content is standard boilerplate speculation about future incidents that does not meet the threshold for Strategy Integration, which requires the company to actually conclude about past or future impact, not merely warn about hypotheticals.


reasoning: The paragraph describes the governance/oversight structure: how cybersecurity risk information flows from management/BDT & MSD up through the CTO to the board, including reporting cadence and topics covered. This is a governance-chain paragraph, making Board Governance the appropriate category. The specificity is Generic Boilerplate because: 'BDT & MSD CTO' is not a cybersecurity-specific role (it's a CTO at an affiliated entity, not a CISO or dedicated cyber role), 'our board of directors' and 'Audit Committee' are standard governance entities, 'periodically' and 'annually' are vague cadences rather than specific dates, and the report contents described are generic categories without named frameworks, specific tools, or unique organizational details.


reasoning: The paragraph describes the governance structure for cybersecurity oversight—the Executive Cybersecurity Steering Committee composition, its oversight function, quarterly meetings, and the decentralized local ISO designation at each business unit. This is a governance-chain paragraph (committee → business unit → local officer) describing how oversight is organized and exercised, not the technical processes of cybersecurity management.


reasoning: This paragraph contains a backward-looking negative assertion ('we are not aware of any risks from cybersecurity threats that have materially affected the Company') which qualifies as a materiality assessment under Strategy Integration. The second sentence is a standard cross-reference to Item 1A with no substantive disclosure.


reasoning: This paragraph describes the information flow for cybersecurity oversight — DIT and DIS report to the CFO, who then updates the full Board. This is governance structure (board receives oversight information from officers), fitting Board Governance. The paragraph contains no specific facts: CFO and Board are generic, 'upon request' is vague, and 'DIT'/'DIS' are unexplained abbreviations without firm-specific identifiers like named roles or specific programs.


reasoning: The paragraph's first sentence is primarily about the CISO's professional certification (CISSP) and the team's collective experience—classic Management Role content describing who these individuals are. The board oversight sentence provides governance context but is subordinate to establishing the human capital and expertise directing the cybersecurity program. The CISO's credentials and the team's experience level are the distinctive firm-specific facts anchoring the disclosure.


reasoning: The paragraph describes the company's internal cybersecurity protection program and management's role in incident response and risk management processes (mitigation, transference, acceptance), which is the company's own internal process. While the Director – Information Systems is mentioned as a grammatical subject, the content focuses on what the program does rather than who the person is. No named frameworks, specific dates, dollar amounts, named tools, or other verifiable facts are present.


reasoning: This paragraph describes the general threat landscape (hackers, cyber criminals, nation-state actors, social engineering, cyber extortion) without disclosing any company-specific processes, governance structure, actual incidents, or materiality assessment. It is standard boilerplate risk language that could appear in any company's 10-K. No materiality language is present.


reasoning: The paragraph describes the cybersecurity governance structure—specifically how oversight flows from the Board of Directors through the Audit Committee to the SVP, Head of Legal and Compliance and back up through reporting. While the SVP role is mentioned, the primary focus is the oversight mechanism and reporting chain, not the qualifications or identity of a specific cybersecurity officer. No cybersecurity-specific title (CISO, CIO, CTO) is named, the Audit Committee is standard governance, and no specific dates, named frameworks, or firm-unique details are present, making it Generic Boilerplate.


reasoning: The paragraph describes the governance structure for cybersecurity oversight — specifically how divisions conduct risk assessments and report upward through Honda's Risk Management Committee to the Risk Management Officer. This is governance-chain language (divisions → committee → officer), not process description. The paragraph focuses on WHO is involved and HOW information flows, not on the mechanics of risk assessment or vulnerability management.


reasoning: The paragraph describes an internal process — cybersecurity briefings flowing from the SVP of IT to senior management — which is the internal governance/oversight mechanism. While senior management is mentioned, the focus is on the process of how cybersecurity information is communicated, not on who the SVP of IT IS. No named standards, no firm-specific details.


reasoning: The paragraph describes the governance/oversight structure — specifically a management program for evaluating cybersecurity effectiveness and an executive security council that routinely reviews strategy, policy, and program effectiveness. The named 'executive security council' is a firm-specific governance body, distinguishing this from generic board oversight language.


reasoning: The paragraph's primary purpose is describing the cybersecurity governance chain (CISO → CIDO → Audit Committee → Board) and how oversight flows upward, which is Board Governance. While the CISO/CIDO experience (15 years) and vendor engagement are mentioned, they appear as components within the governance structure description rather than the central focus.


reasoning: The paragraph describes the governance/oversight structure — how information flows from an internal working group (CCO, COO, CISO) through senior management and ultimately to the Board for reporting when appropriate. This is a governance-chain description, not a description of internal processes standing alone, nor an assessment of who a specific person is. The inclusion of CISO and CCO in a cybersecurity-specific working group composition provides firm-specific content beyond generic board oversight language.


reasoning: The paragraph primarily describes the governance/oversight structure—specifically the reporting chain (management → audit committee → board) and the composition of the Rapid Response Team as part of the Board's oversight mechanism. While officers are mentioned, the purpose is to explain how the board receives cybersecurity information, not to describe who these individuals are as professionals. The named internal program (Rapid Response Team) and specific reporting cadence (at least quarterly) provide firm-specific detail beyond standard governance language.


reasoning: The paragraph's primary purpose is describing the oversight structure — how management oversees the cyber risk program and how the Audit Committee provides board-level oversight — making Board Governance the most applicable category. The paragraph contains no specific verifiable facts (no named firms, dates, amounts, or certifications), and all referenced entities are generic, resulting in Generic Boilerplate specificity.


reasoning: The paragraph contains a backward-looking negative assertion ('we have not experienced material adverse effects from cybersecurity threats to date') which is a materiality assessment about cybersecurity incidents—the defining feature of Strategy Integration. The forward-looking portion is generic boilerplate, but the core disclosure is the materiality conclusion about past experience.


reasoning: The paragraph describes the organizational structure for cybersecurity risk management (management team, including COO, responsible for assessing/managing risks, primary responsibility for the program, supervises external consultants). This is about the company's internal process for assigning accountability for cybersecurity oversight. No biographical details, credentials, or personal history are provided for the COO, so it is not Management Role. No cybersecurity-specific titles (CISO, CTO), named committees, specific dates, named programs, or other identifying facts are present.


reasoning: The paragraph describes how management supervises cybersecurity efforts through various means (briefings, threat intelligence, external consultants, security tools), which constitutes an internal risk management process. No specific persons, qualifications, or credentials are provided—just a generic description of oversight mechanisms.


reasoning: The paragraph describes the company's cybersecurity oversight structure and processes — the outsourcing arrangement, provider responsibilities (communicating issues, assessing/managing risk), and the PFO's oversight functions (prevention, detection, mitigation, remediation). No board is mentioned, and while a named role (PFO) appears, the paragraph focuses on the process flow rather than who the PFO is as a person, making this Risk Management Process rather than Board Governance or Management Role. The specificity is Sector-Adapted because it describes an outsourced security model without naming frameworks, products, or other hard verifiable facts.


reasoning: This paragraph describes the governance/oversight structure — how the Board exercises oversight, which committees have cybersecurity responsibilities, and how information flows upward (CISO reports to Governance and Compliance Committee, management reports to Audit Committee). The CISO is mentioned as part of the reporting chain, not as the subject of biographical description. Four firm-specific facts are present: the CISO role and three named committees (Governance and Compliance, Audit, and Technology), which uniquely identify this company's oversight structure beyond standard boilerplate.


reasoning: The paragraph's primary content is a negative assertion—'has not...experienced a cybersecurity threat or incident that materially affected'—which is a backward-looking materiality assessment qualifying as Strategy Integration. The forward-looking disclaimer and cross-references to Item 1A are secondary. No specific dates, dollar amounts, named firms, named tools, or other verifiable facts are present, making this Generic Boilerplate.


reasoning: This paragraph describes the governance/oversight structure of cybersecurity risk, including named committees (ORMC, ERMC, Risk Committee), specific officer roles (Chief Operational Risk Officer, Chief Risk Officer), and escalation pathways to the Board. The primary purpose is describing how oversight flows through the committee structure, which is Board Governance. The named committee identifiers (ORMC, ERMC) are company-specific, distinguishing this from generic boilerplate.


reasoning: The paragraph's primary focus is the governance oversight structure — how senior management leads the risk program, the reporting chain from EVP to CEO to Board of Directors, and the governance role of the Risk Subcommittee. While it describes the VP, CISO's operational responsibilities, these are presented within the context of the board-level oversight chain, making Board Governance the primary category. No firm-specific identifiers, dates, named standards, or hard verifiable facts are present; all roles and structures (Board of Directors, CEO, EVP, CISO, Risk Subcommittee) are generic governance elements common to any 10-K.


reasoning: The paragraph describes the composition and structure of the ISO Committee as part of the Board's cybersecurity oversight governance chain. While it mentions officers (CISO, CTO), their inclusion is in the context of the oversight structure, not as a description of who they are as individuals. The paragraph contains firm-specific facts including the named ISO Committee, specific division leadership roles, and a specific tenure claim (25 years), making it Firm-Specific rather than Sector-Adapted or Generic Boilerplate.


reasoning: The paragraph's primary focus is describing the company's cybersecurity risk management approach—policies, standards, processes, and practices integrated into an overall risk management program. While the Board is briefly mentioned, it functions as context for describing the oversight structure, not as the main subject. The named frameworks (NIST, ISO) elevate this to Sector-Adapted specificity; without them it would be Generic Boilerplate.


reasoning: This paragraph contains explicit backward-looking and forward-looking materiality assessments ('have not materially affected' and 'not reasonably likely to materially affect'), which are hallmarks of Strategy Integration classification. The cross-reference to Item 1A Risk Factors is incidental to the main purpose of concluding on materiality.


reasoning: The paragraph's primary purpose is to make a backward-looking materiality assessment ('have not materially affected us, including our business strategy, results of operations or financial condition'), which is the hallmark of Strategy Integration. The brief reference to experiencing 'threats to and breaches' is incidental to this conclusion. No specific facts about this company's cybersecurity posture are provided—no dates, named third parties, named tools, specific incident details, or quantified impacts.


reasoning: The paragraph's primary focus is describing the cybersecurity oversight structure and processes (CSIRT collaboration, risk assessment, incident response plan review, training, risk management efforts) rather than profiling the Director's qualifications as an end in themselves. Applying the decision chain: the Director and CSIRT are mentioned as leaders of the process, not as biographical subjects; removing them leaves a coherent description of the company's risk management approach. The 40 years of experience and cybersecurity-specific title are embedded in the governance description, not the main thrust.


reasoning: The paragraph's primary focus is describing board oversight structure—reporting relationships, cadence, and information flow between the CTO and a Board Committee regarding cybersecurity risks. While a named officer appears, the purpose is describing governance mechanics, not the officer's qualifications or background.


reasoning: The paragraph describes a monitoring process for incident prevention, detection, mitigation, and remediation — a risk management function — but contains no named frameworks, specific roles, dates, or other verifiable details. 'Service providers,' 'ISP personnel,' and 'Investment Manager' are generic references without named third-party firms or specific products/tools. No cybersecurity-specific incidents are described, no materiality assessment is made, and no personnel credentials are provided, making this standard governance language applicable to any company.


reasoning: This paragraph is an introductory risk warning about cybersecurity threats that contains no materiality assessment (no conclusion about whether cybersecurity has or will materially affect the company), no description of actual governance structures or processes, and no disclosure of any specific incident. It consists entirely of generic boilerplate language about cyber threats and their potential consequences that could appear in any company's 10-K filing.


reasoning: The paragraph describes the cybersecurity governance structure — reporting relationships, briefing cadences, and escalation protocols — making Board Governance the primary content. The presence of named internal programs (CSIRP) and specific team compositions elevates specificity beyond generic boilerplate.


reasoning: Paragraph primarily describes the cybersecurity governance structure (ITRGC → Director → ISO → CRO → Board), with explicit statement that the Board has oversight of cybersecurity risk. Named officers and their experience are mentioned as part of the governance chain description, not as standalone biographical disclosure.


reasoning: The paragraph describes the governance/oversight STRUCTURE of the Board over the IS Program, including the reporting chain (Board → CISO → IR Team) and the information flow upward (incident notification to functional areas, regulators, senior leadership, and Board). The Board's role as having 'approval and oversight' responsibility is the central theme. The CISO experience detail is incidental to describing the governance structure rather than the primary focus on the person's qualifications.


reasoning: This paragraph is a cross-reference directing readers to the Risk Factors section for cybersecurity threat disclosures. It uses generic materiality language ('materially affected or are reasonably likely to materially affect') but makes no substantive disclosure—it points elsewhere rather than concluding anything about the company's cybersecurity posture, incidents, or governance.


reasoning: The grammatical subject is 'cybersecurity risk assessment and management processes,' and after removing person details the process disclosure remains coherent. Although the paragraph mentions a VP with extensive experience, the primary purpose is describing how the company's risk management processes are structured and implemented rather than detailing the person's qualifications as a standalone biography.


reasoning: The paragraph describes the oversight structure—specifically how cybersecurity information flows from management to the Board through periodic briefings. The grammatical subject (Executive Officer and VP of Technology) are the briefers, not individuals being profiled for their qualifications, making this governance content. No specific facts are present: generic roles ('Executive Officer' is as boilerplate as titles get), vague cadence ('periodic'), and standard cybersecurity activities that could appear in any filing.


reasoning: This paragraph is dominated by a backward-looking materiality assessment ('we have not identified any risks from cybersecurity threats...that have materially affected the Company'), which is the core Strategy Integration content. The preceding investment and threat-description language and the trailing forward-looking disclaimer are generic boilerplate context.


reasoning: The paragraph's primary purpose is describing the cybersecurity governance structure—reporting lines from the IR team to executives and the Board, plus the composition and responsibilities of an information security advisory board. No individuals are described by their qualifications or experience, making this Board Governance rather than Management Role.


reasoning: The paragraph primarily describes the oversight structure—how the Board oversees cybersecurity, the Audit Committee's authority, and the reporting chain (IT Director → CFO → Board/Committee)—which is governance-chain description. The IT Director mention is incidental to the oversight structure, not the main focus of describing who the person is. No hard verifiable facts (dates, dollar amounts, headcounts, named external firms, or named tools) are present beyond the cybersecurity-specific role title.


reasoning: The paragraph's primary focus is the board's governance structure—specifically how oversight flows through an IT Steering Committee to the board—rather than the qualifications or background of named officers. Named roles appear as structural components of the committee, not as the subject being described. The presence of a named non-generic committee and specific cybersecurity-relevant roles establishes firm-specificity.


reasoning: The paragraph primarily describes the company's cybersecurity program structure, risk assessment processes, and control mechanisms. Applying the MR-vs-RMP decision chain: the grammatical subjects are predominantly 'We/the company' performing processes (implementing controls, conducting assessments, identifying threats); removing the named roles leaves a coherent RMP disclosure. The named officers (CISO, CTO, CIO) appear as incidental grammatical objects describing reporting structure, not as persons whose qualifications/experience are the focus. The paragraph is Firm-Specific because it names cybersecurity-specific titles (CISO/CTO/CIO) and a specific service arrangement (MSSSP), which go beyond generic governance language.


reasoning: The paragraph primarily describes the governance/oversight structure—how the board and Audit Committee exercise oversight of cybersecurity risk, the annual briefing cadence, and how information flows upward from the CIO to the Audit Committee. While the final sentence mentions the CIO's 20 years of experience, this is incidental context about the person in the governance chain rather than the paragraph's primary purpose.


reasoning: The primary purpose of this paragraph is a backward-looking materiality assessment — stating that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition to date. The brief acknowledgment of experiencing 'threats to and breaches' is incidental and lacks any incident-specific details (no dates, scope, or description of what happened); the paragraph's main point is the materiality conclusion, not an incident narrative.


reasoning: This paragraph is a materiality assessment combining a backward-looking negative assertion ('have not been materially impacted') with a forward-looking disclaimer about future risk. The language is standard boilerplate that appears in virtually every public company 10-K and contains no company-specific details—no named officers, frameworks, dates, incidents, or financial specifics.


reasoning: The paragraph's primary focus is describing the governance/oversight structure: the Board's role, the Audit Committee's involvement, and the Security Steering Group composition. While policies and processes are mentioned, they are presented as components of the overall governance framework overseen by the board, not as standalone internal processes. The CISO appears as a member of the SSG governance structure rather than being described for their qualifications or credentials.


reasoning: This paragraph describes the governance structure of the Information Security committee—its composition, oversight function, and approval authority—which is a Board Governance disclosure. Management roles (CDIO, CFO, CAO/GC, CISO) are mentioned as participants in the committee structure, not as the primary focus. The paragraph contains firm-specific facts: a named committee and a cybersecurity-specific title (CISO), meeting the threshold for Firm-Specific.


reasoning: The paragraph describes a governance/oversight structure for cybersecurity with the Board providing oversight and the CFO having ultimate direction—this is the board oversight structure. The specific mention of CFO direction combined with Board oversight places this in Board Governance. However, all elements are generic (CFO, Board, security governance structure, evaluate and address cyber risk) with no specific facts from the IS list—no cybersecurity-specific titles, named committees, specific dates, or named programs.


reasoning: The paragraph consists primarily of generic forward-looking risk disclaimers about evolving cyber threats and uncertainty—standard language found in virtually any company's 10-K. While it contains a brief negative assertion ('the Company has not detected... any material financial losses'), this is incidental boilerplate language appended to the main speculative warning rather than a substantive materiality assessment as the main point. No firm-specific details, named frameworks, roles, dates, or quantifiable facts are present.


reasoning: The paragraph primarily describes VF's cybersecurity program, incident response plan, training processes, and third-party risk management—not the CISO's credentials as a standalone subject. While the CISO's qualifications are mentioned, they serve to explain WHO oversees the program rather than being the paragraph's main purpose. The biographical details (30+ years, two prior CISO roles, COO's digital transformation experience) are firm-specific facts that go beyond generic boilerplate, but the paragraph's dominant subject is the program structure and processes, not the individuals themselves.


reasoning: This paragraph describes the governance structure for cybersecurity oversight — specifically the reporting chain (management → Information Technology Steering Committee → Board of Directors) and the cadence of reporting (at least quarterly, at least annually). While it references a committee by name, the overall content describes standard board oversight practices without hard verifiable facts (no specific dates, amounts, named third parties, or named tools/products).


reasoning: The paragraph primarily describes the governance/oversight structure: the CISO reporting to the audit committee and Board of Directors, and how information flows upward. This is a governance-chain paragraph where the purpose is describing oversight structure rather than the CISO's personal qualifications (which would be Management Role). There are no hard verifiable facts (no dates, dollar amounts, headcounts, named third-party firms, or named products), and the named entities—CISO, audit committee, Board of Directors—are all standard governance structures without unique identifiers.


reasoning: The paragraph describes the governance/oversight structure—the composition of the Risk Committee (a management-led committee reporting to a board committee) and how cybersecurity risk information flows upward through this chain. While specific executive roles are named, they describe committee membership rather than individual qualifications. The named university system entities (American InterContinental University System, Colorado Technical University) provide firm-specific identification.


reasoning: The paragraph describes the cybersecurity governance structure — the Information Security Governance Committee comprising senior management (including the CIO) that reports to the Board at least annually, with specific oversight responsibilities for incident communication and risk briefings. The named committee and CIO role make this firm-specific rather than generic boilerplate, but no hard external-verifiable facts (specific dates, named third-party firms, dollar amounts, or named products) are present to reach Quantified-Verifiable.


reasoning: The paragraph is primarily a forward-looking disclaimer about potential future cybersecurity risks, concluding with a cross-reference to Item 1A. While it contains a negative assertion about past incidents, the dominant content is speculative risk warnings about what could happen, not a backward-looking assessment of how cybersecurity has affected business outcomes.


reasoning: The paragraph's primary focus is the governance structure — how the CISO, CTO, and ERM Committee report upward to the Audit Committee and full Board, and what oversight role the Audit Committee plays. This describes board/committee oversight of cyber risk and information flow, not officer qualifications or internal processes. The paragraph contains firm-specific facts including cybersecurity-specific titles (CISO, CTO), a named internal committee (ERM Committee), and a specific program structure (six components of the Information Security program).


reasoning: The paragraph describes how the Fund's CCO and personnel from various internal departments (risk management, legal, IT, compliance) identify and oversee cybersecurity risks associated with third-party relationships—this is an internal risk oversight process. No board or committee structure is described, no named individuals' qualifications appear, and no specific process/framework is invoked as the grammatical subject.


reasoning: The paragraph's primary focus is describing Board oversight of cybersecurity risk management, with the opening sentences explicitly stating the Board's active involvement in oversight and the company's cybersecurity being a component of the overall risk management approach overseen by the Board.


reasoning: The paragraph describes the governance/oversight structure—specifically how information flows upward from management to the Audit Committee and Board during a cybersecurity incident, which is the core of Board Governance. All elements (Audit Committee, Board, management, escalation protocols, incident response plan) are generic governance language with no firm-specific details.


reasoning: The paragraph describes management's supervisory process for cybersecurity risk management through briefings, threat intelligence, and security tools—describing an internal process rather than an individual's qualifications or governance structure. No specific dates, named third-party firms, named products, dollar amounts, headcounts, or certifications are present, making this purely generic boilerplate applicable to any company.


reasoning: The paragraph is primarily about WHO implements and maintains the cybersecurity program—the CTO and CISO identified by name and their combined experience (25 years). While it describes a cross-functional structure, the grammatical subjects are the named officers and the core focus is their qualifications and collaboration, not the process itself. This meets the Management Role criteria under Step 3 (qualifications present). The 25 years of experience and specific departmental composition (Legal, Privacy, Finance, Regulatory, Quality, Compliance) provide two hard verifiable facts, crossing the threshold into Quantified-Verifiable.


reasoning: The paragraph describes the governance and oversight structure—how information flows from the CISO upward through management to the Compliance Committee and Board of Directors. This is a governance-chain description, which is Board Governance even though officers appear as grammatical subjects. The CISO title and named Compliance Committee elevate it beyond generic boilerplate.


reasoning: The paragraph describes the governance/oversight structure—specifically how information flows from management (COO) to the board and its Audit Committee regarding cybersecurity programs, risks, and incidents. This is board oversight structure, not incident description, financial materiality, or internal processes. There are no firm-specific facts: 'beginning in 2024' is a forward-looking calendar year (not month+year or exact date), COO is a generic C-suite role (not cybersecurity-specific like CISO), 'incident response processes' is generic, and 'Audit Committee' is standard for all public companies.


reasoning: The paragraph's primary purpose is describing the governance and oversight structure—how cybersecurity risk flows through the ERC to Co-CEOs and how information reaches the board. The named individuals and Ms. Murray's specific credentials (NACD program, CERT Certificate from Carnegie Mellon) are verifiable firm facts that go beyond generic boilerplate governance language.


reasoning: The paragraph's primary purpose is describing the company's cybersecurity risk management structure and how the team oversees prevention, detection, mitigation, and remediation efforts through briefings, threat intelligence, and security tools—not profiling the SVP as an individual. While a named officer appears as the grammatical subject, the content describes what the program and team do, not who the person is. No Step 3 qualifications (certifications, career history) are present.


reasoning: This paragraph is primarily forward-looking disclaimer language with a cross-reference to Risk Factors. While it contains a negative assertion about past incidents ('we have not experienced any material cybersecurity threats or incidents in recent years'), this is embedded within a boilerplate risk disclaimer rather than presented as a standalone materiality assessment. The paragraph lacks any description of actual cybersecurity governance, processes, or incident response.


reasoning: The paragraph describes a standard governance chain (Board of Directors → executive team including CEO and CFO → IT team) with standard oversight responsibilities (approving budgets, reviewing security assessments, preparing for incidents). All named roles (Board, CEO, CFO) are generic corporate governance titles that appear in every company filing. No firm-specific details such as named cybersecurity officers, specific committees, named frameworks, or unique organizational structure are present.


reasoning: The paragraph describes the governance/oversight structure — specifically how management reports to the Board and the cadence of those updates. This is a description of oversight flow, fitting Board Governance. There are no specific facts: the cadence uses vague qualifiers ('at least annually', 'as needed', 'notable changes') with no hard dates, named entities beyond 'the Board' and 'management', or any firm-specific details.


reasoning: This paragraph describes hypothetical cybersecurity risks using speculative language ('could lead,' 'could disrupt,' 'could steal') rather than describing actual incidents, governance structures, or risk management processes. It is a standard risk factor disclosure that could appear verbatim in any tech company's 10-K filing, with no company-specific details, named entities, or factual content.


reasoning: The paragraph's primary content is a process description (risk assessments, safeguard evaluation, monitoring), with officers identified as the managers of that process. The two hard verifiable facts (25 years + 15 years of experience) qualify this as Quantified-Verifiable.


reasoning: The paragraph primarily describes the governance/oversight structure—how cybersecurity risk management integrates into the enterprise risk framework, reporting lines (CISO/CRO to Board quarterly), and board oversight role—making Board Governance the main category. While the CISO's qualifications are mentioned, they function as supporting context for the governance structure rather than the primary focus. Multiple firm-specific facts present: cybersecurity-specific titles (CISO/CRO), named non-generic committees (Risk and Technology Committee, Enterprise Risk Committee), specific experience duration (15 years), named certification (CISSP), and specific committee composition.


reasoning: This paragraph describes a SPAC explicitly stating it has no operations, no cybersecurity program, and no formal processes for assessing cybersecurity risk. Per calibration guidelines, SPACs and shell companies explicitly stating the absence of a cybersecurity program are classified as None/Other regardless of any incidental references to risk acknowledgment. The paragraph contains no substantive cybersecurity disclosure, only a disclosure of absence.


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors for additional cybersecurity risk information. It contains no substantive cybersecurity disclosure, governance structure description, or company-specific assessment — only a pointer to another section. The quoted 'material adverse effect' language is from a section header/description in Item 1A, not the company's own materiality conclusion.


reasoning: The paragraph describes the governance/oversight structure: how information flows from the CFO and IT consultant upward through the audit committee to the Board. This is the Board's oversight mechanism for cybersecurity, making it Board Governance. It contains no firm-specific details—no named individuals, specific cadences, named frameworks, dates, or other identifying facts—just generic governance language that could appear in any company's 10-K.


reasoning: The paragraph describes the governance/oversight structure—how information flows from the CISO and CRO upward to the board's risk committee, including reporting cadences and an escalation process. Per the BG definition, governance-chain paragraphs describing oversight structure are Board Governance even when officers appear as grammatical subjects. The paragraph contains firm-specific facts: named cybersecurity-specific roles (CISO, CRO) and named committee (Risk Committee) that distinguish this from generic boilerplate.


reasoning: The paragraph's primary purpose is a cross-reference directing readers to Item 1A Risk Factors for substantive cybersecurity risk discussion — not providing its own disclosure. The negative incident assertion ('we have not experienced a cybersecurity incident that we deemed to be material') is incidental context, not the main point. No board oversight, management roles, processes, named frameworks, or other substantive cybersecurity disclosure content is present.


reasoning: The paragraph describes the company's internal process for identifying and assessing cybersecurity risks—monitoring threat environments, using tools, analyzing intelligence, conducting scans. While a person (Director of Information Technology) is mentioned as leading the process, the content describes what the program does, not who the person is; the process stands alone after removing the role reference (Step 2). The specificity is Generic Boilerplate because no named frameworks, tools, third-party firms, dates, or other distinctive facts appear—just generic descriptions of common cybersecurity practices.


reasoning: This paragraph is entirely composed of forward-looking boilerplate warnings about cybersecurity threats and their potential impact. It contains no description of actual oversight structures, processes, incidents, or assessments—it simply states that threats 'could have a material adverse effect,' which is generic risk speculation found in virtually every 10-K, not a substantive disclosure.


reasoning: The paragraph's primary focus is describing the governance structure — the CGC's establishment, composition, and oversight responsibilities — rather than describing who the CISO is as a person. The governance-chain language ('to support the CISO, we have established...') and the CGC's oversight duties (approving risk assessments, reviewing NIST alignment) indicate this is fundamentally about the oversight mechanism, not the individual's credentials.


reasoning: This paragraph describes a governance/oversight structure with the Board and specific committee providing oversight to the IT management team and named C-suite officers. Named non-generic committees and specific named roles identify this company, making it Firm-Specific.


reasoning: The paragraph's primary focus is describing the Board's oversight role and the governance/reporting chain (Board → CIO → Executive Leadership Team), which is the core of Board Governance. Multiple hard verifiable facts are present (specific cadence, named cybersecurity-specific roles, specific experience count), qualifying as Quantified-Verifiable.


reasoning: This is a SPAC/shell company that explicitly states it has 'not adopted any cybersecurity risk management program or formal processes.' Per classification guidance, SPACs and shell companies explicitly stating they have no cybersecurity program fall into None/Other regardless of incidental mentions of board oversight or risk acknowledgment.


reasoning: This is a cross-reference paragraph that directs readers to Item 1A Risk Factors for cybersecurity risk disclosures. It contains no substantive cybersecurity disclosure and merely points to another section for information, consistent with the None/Other classification for cross-references with materiality language.


reasoning: This paragraph describes the governance structure for cybersecurity oversight—specifically how the board's Audit and Examination Committee oversees the cybersecurity program and how the Information Security Officer reports to that committee quarterly. Per the tiebreaker rules, governance-chain descriptions (board → committee → officer → program) are Board Governance even when officers appear grammatically, because the PURPOSE is describing oversight structure rather than describing the officer's qualifications (Management Role) or internal processes (Risk Management Process).


reasoning: The paragraph primarily describes internal cybersecurity processes—ongoing threat monitoring and a written incident response runbook—which is the core of Risk Management Process; while the CICSO is mentioned as grammatical subject, the paragraph describes what the program does, not the officer's qualifications or experience.


reasoning: This paragraph describes the Board's oversight structure — which committee oversees cybersecurity (Audit Committee) and how information flows upward (CIO/CISO provide regular updates on specific topics like vulnerability management and ransomware readiness). The mention of CISO as the reporting officer identifies a cybersecurity-specific role, making this Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph describes the governance/oversight structure—specifically how cybersecurity information flows from CISO and CIO up to the Board and Audit Committee. While officers are the grammatical subjects, the purpose is describing the oversight mechanism, not describing who these people are. The CISO and CIO are cybersecurity-specific roles (per the IS list), making this at least Firm-Specific.


reasoning: This paragraph is a forward-looking disclaimer ('there can be no guarantee') paired with a negative assertion about past incidents, which together form standard boilerplate risk language found in virtually every 10-K. The forward-looking disclaimer portion contains no substantive disclosure, and the negative assertion about not having experienced material incidents, while technically a Strategy Integration trigger, is subsumed by the dominant forward-looking disclaimer framing that characterizes this as boilerplate risk warning rather than a standalone materiality assessment.


reasoning: The paragraph's core disclosure is a negative assertion about not having experienced material cybersecurity incidents, which qualifies as a backward-looking materiality assessment under Strategy Integration. The remaining content is generic boilerplate disclaimer language with no company-specific facts.


reasoning: The paragraph describes internal processes for cybersecurity oversight and incident notification procedures, with no identification of specific personnel, their qualifications, or credentials. Applying the MR vs RMP decision chain: 'management' functions as a generic subject overseeing 'assessment and management of cybersecurity threats' — a process description, not a person description. No hard verifiable facts, named frameworks, specific dates, dollar amounts, headcounts, or named third-party firms are present.


reasoning: This paragraph describes the oversight committee structure and reporting lines (Engineering Risk Steering Group → Firmwide Technology Risk Committee), with the CISO as chair of the committee — a classic governance-chain description. The named committees and CISO role are firm-specific identifiers distinguishing this from generic boilerplate governance language.


reasoning: The paragraph primarily describes the governance and oversight STRUCTURE — how governance documents flow from the Information Security team to the Audit & Risk Committee for review/approval, and how the three-year strategic plan is reviewed and approved by both the CISO and the Committee. While the CISO appears, the grammatical subjects across sentences are 'the Information Security team' and 'the plan,' and the paragraph's core purpose is describing the board oversight chain rather than describing who the CISO is as a person. The named 'Audit & Risk Committee' (a non-generic committee name) and cybersecurity-specific 'CISO' role provide firm-specificity beyond generic governance language.


reasoning: The paragraph is background/introductory language describing IT importance and data-handling scope without substantive disclosure of governance, processes, roles, or materiality assessments. The naming of HIPAA and CCPA standards elevates specificity to Sector-Adapted.


reasoning: The paragraph is primarily about WHO the CISO is—their qualifications (20 years of experience, MBA), certifications (CISSP, CISM, GLAW, GSEC), industry background (healthcare, education, financial consulting), and reporting line to the CRO. While the governance structure is present, the CISO's professional credentials and experience comprise the majority of substantive content and are the signal content in this paragraph.


reasoning: This SPAC explicitly states it is an early-stage company without significant investments in data security protection and lacks sufficient resources for cybersecurity. Rather than describing an existing cybersecurity program, the paragraph disclaims the existence of adequate protections. The incident response reference is incidental to this acknowledgment, and the 'material adverse consequences' language is standard forward-looking boilerplate, not a firm-specific materiality assessment.


reasoning: The paragraph describes the governance/oversight structure — tracing how cybersecurity risk oversight flows from the Board down through the Audit Committee and Management to the Principal Accounting Officer, including reporting cadences and escalation paths. While the governance chain is described in detail, the content uses only standard, non-distinguishing elements (Board, Audit Committee, Management, cybersecurity programs) without any hard verifiable facts, named frameworks, specific dates, named third-party firms, or quantified metrics. The governance structure is the standard organizational model found in most filings, making this Generic Boilerplate despite the firm-specific organizational context.


reasoning: This paragraph is a cross-reference statement directing readers to Item 1A for substantive cybersecurity risk disclosures, including materiality assessments. It contains no substantive disclosure itself—only an incorporation by reference mechanism. Per the guidance, cross-references pointing to materiality language elsewhere are None/Other.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity—specifically how the Board, General Partner, and Investment Manager interact in overseeing cyber risk. Although the company explicitly states it relies on Blackstone rather than operating its own cybersecurity program, the core purpose is explaining the oversight chain. The named entities (General Partner, Investment Manager) are the company's own corporate structure rather than external third parties or cybersecurity-specific roles, and there are no named frameworks, dates, or hard verifiable facts.


reasoning: The paragraph describes the governance structure (Board oversight + CFO direction over cybersecurity) which is the defining characteristic of Board Governance content. It contains no specific facts—no named cybersecurity-specific roles (CISO), no specific committees, no dates, numbers, named tools/firms, or other firm-identifying details—making it Generic Boilerplate.


reasoning: The grammatical subject is 'Our cybersecurity risk assessment and management processes' — an impersonal process — and the primary purpose is describing how these processes are implemented and maintained, with the IT Lead and external agency serving as components within that process description. The qualifications (years of experience) are incidental details supporting the process narrative rather than the main point. While the IT Lead is mentioned by title, the paragraph does not focus on who this person IS (credentials, career history, reporting lines) but rather what the program entails.


reasoning: The paragraph's primary purpose is to provide a forward-looking risk disclaimer and cross-reference to Item 1A Risk Factors. While it contains a negative assertion ('has not experienced any material cybersecurity events'), this functions as context for the risk warning rather than the main disclosure point. The forward-looking boilerplate 'could have a material and adverse impact on the business' is generic and indistinguishable from every other 10-K. The cross-reference structure with materiality language mirrors the None/Other examples.


reasoning: The paragraph primarily describes the company's cyber risk management process and its organizational structure. While it names roles (SVP Operations, VP Deputy General Counsel), these are generic business titles applied to cybersecurity oversight, not cybersecurity-specific positions like CISO or CTO. The roles serve as descriptors of process ownership, not as the paragraph's main subject. No hard verifiable facts (dates, amounts, named third-party firms, tools, or certifications) are present.


reasoning: The paragraph describes management undergoing briefings to assess cybersecurity risks — an internal capability-building process — making it Risk Management Process rather than Board Governance (no board mentioned) or Management Role (no person qualifications described). It contains no dates, named firms, dollar amounts, headcounts, or other hard facts; CFO and advisory firm references are generic.


reasoning: The paragraph's primary focus is describing the governance/oversight structure—CFO directing cybersecurity, board reporting for incidents, and Audit Committee receiving periodic updates. While the statement about no material incidents could suggest Strategy Integration, it functions here as a supporting note about program effectiveness within a governance description. All entities mentioned (CFO, management team, Board of Directors, Audit Committee) are standard generic roles found in any company, with no specific dates, named frameworks, or verifiable facts that would elevate the specificity beyond Generic Boilerplate.


reasoning: The paragraph describes an oversight structure — the IT Steering Committee's composition and its reporting relationship to the Risk Management committee — showing how cybersecurity information flows through the governance chain. While the Risk Management committee is not explicitly identified as a board committee, the reporting structure describes an oversight mechanism. The IT Steering Committee is a named committee with specific membership composition, and the quarterly reporting cadence is organizational detail specific to this company.


reasoning: The paragraph's primary purpose is describing the qualifications, education, certifications, and professional memberships of the CIO and CISO. While the opening describes board governance structure, the substantial second half focuses on who these officers are — their academic credentials (degrees from named universities), professional certifications (CISSP), completed programs (CMU CISO Certificate), and industry affiliations — which is the hallmark of Management Role content. The extensive credential detail (doctorate degree, coaching role, editorial board positions) goes well beyond mere role identification.


reasoning: The paragraph describes internal cybersecurity management processes (work plans, improvement objectives, system investments) with the Director of IT mentioned as part of the structure rather than as the subject of description. No hard verifiable facts (dates, dollar amounts, named firms, named products) are present, making it generic boilerplate.


reasoning: The paragraph describes the internal cybersecurity governance structure and operational processes—the security team's responsibilities for measuring/managing risk, incident handling, and policy implementation. While it mentions reporting lines, no named individual has credentials or career history, so it is not Management Role. The cybersecurity-specific VP title and description of cross-functional team composition provide firm-specific identifying details beyond generic boilerplate.


reasoning: This paragraph describes the governance/oversight structure — specifically how cybersecurity information flows from the CISO to the board's Risk Committee — which is the defining characteristic of Board Governance. While it mentions the CISO as the presenter, the primary purpose is describing the board's oversight mechanism, not who the CISO is as a person. The CISO and Risk Committee are firm-specific identifiers that prevent this from being generic boilerplate.


reasoning: The paragraph describes the company's internal processes for maintaining cybersecurity personnel competence—training programs, simulated exercises, and certification maintenance—rather than profiling a specific named officer or describing an actual incident, making Risk Management Process the appropriate category.


reasoning: The paragraph describes the governance/oversight structure — how cybersecurity information flows from the CISO to board committees and senior management. This is Board Governance because the purpose is describing the oversight mechanism, not describing who the CISO is as an individual. The specificity is Firm-Specific because it names the CISO role and the Technology Risk Management Committee, both of which are identifiable firm facts.


reasoning: The paragraph describes the company's cybersecurity controls and processes (firewalls, vulnerability management, third-party risk processes) — internal risk management activities. While it mentions a CISO and CIO, they serve as structural anchors for the program description, not as the subject of biographical detail. The controls and processes listed are generic industry practices with no company-specific identifiers, named frameworks, or hard verifiable facts.


reasoning: The paragraph describes the governance structure for cybersecurity oversight — specifically two named committees (OROC and IT Steering Committee), their leadership roles (CRO, CIO), compositions, and meeting cadence. This is oversight structure description, not the risk management process itself, making Board Governance the correct category.


reasoning: The paragraph describes how cybersecurity initiatives are coordinated (Senior Director directing through IT personnel) and mentions procedures exist for incident investigation, which constitutes a description of internal processes. While a named role appears, the content focuses on what the program does rather than who the person is. Step 2 confirms the process stands alone as a disclosure about incident response coordination and initiative direction.


reasoning: The paragraph contains a backward-looking materiality assessment ('have not materially affected us') — a negative assertion about past incidents that qualifies as Strategy Integration. The forward-looking risk language ('reasonably likely to materially affect us') and risk factor cross-references are standard boilerplate, but the materiality conclusion anchors the category to SI. No specific facts, dates, dollar amounts, named firms, or product/role names are present.


reasoning: The paragraph begins with board governance content but the substantive detail centers on the CIO's personal qualifications (10 years of experience, tenure at multiple public companies) and the supporting team's credentials (certifications, 13 years average experience). Under the MR vs RMP three-step decision chain, the person-removal test reveals the qualifications are essential to the paragraph's purpose, not incidental. Two specific numbers (10 years, 13 years) qualify this as Quantified-Verifiable.


reasoning: The paragraph describes the oversight structure for cybersecurity, specifically identifying the CISO and Cybersecurity Committee as the bodies that oversee policies and are informed about incident monitoring processes. This is governance structure description rather than a description of who these individuals are or what their qualifications are.


reasoning: This paragraph describes items (g. and h.) within what appears to be a board committee's oversight responsibilities—specifically, the committee's review of personnel capabilities/qualifications and cybersecurity strategy/resources. This describes the governance structure (what the board oversees) rather than internal management processes or specific roles. The language is standard governance boilerplate with no named committees, specific roles, named frameworks, dates, or other firm-specific details.


reasoning: The paragraph describes the board oversight structure—specifically how cybersecurity information flows from the Director of Compliance to the Board of Directors and what those reports address. This is governance description, not an incident narrative, risk process, or management qualification disclosure.


reasoning: The paragraph describes the governance structure for cybersecurity oversight — the board's overall responsibility, the Audit Committee's supporting role, and the information flow between officers and the committee. While officers are mentioned, they appear as part of the governance chain (who reports to whom), not as the subject being described in terms of their qualifications or experience. All content is standard governance disclosure language applicable to any public company.


reasoning: The paragraph describes the governance/oversight structure — how the Board delegates to the Audit Committee, which oversees management's implementation, with a defined chain flowing through CTO to VPCS. The VPCS is a cybersecurity-specific role (per the IS list), making this firm-specific rather than generic boilerplate governance language found in every public company.


reasoning: This paragraph is primarily a forward-looking risk description with generic cybersecurity threat language and a brief negative assertion about material incidents. The brief materiality statement is incidental to the main purpose of describing potential risks and cross-referencing Risk Factors, not an assessed conclusion about cybersecurity's impact on the business. Contains no firm-specific details, named frameworks, or verifiable facts.


reasoning: This paragraph describes the governance/oversight structure—specifically the reporting chain from the CTO to the Audit Committee and Board, the role of the ERM Committee, internal audit's independent assessment role, and the ARB/PMO oversight bodies. The organizational structure (reporting cadences, named internal committees, accountability relationships) is the primary topic, making it Board Governance. The specificity is firm-specific because it names multiple internal governance bodies (GLT, ERM Committee, ARB, PMO) unique to this company's disclosure, though it lacks hard verifiable facts (specific dates, dollar amounts, named external firms, or headcounts) to reach Quantified-Verifiable.


reasoning: The paragraph centers on identifying WHO leads cybersecurity risk management, explicitly stating the SVP/CTO title and their qualification (20+ years experience), satisfying the MR qualifications tiebreaker. The process description is secondary to establishing the leader's credentials.


reasoning: The paragraph's primary purpose is describing the company's risk management framework and the governance structure through which cybersecurity is overseen—specifically how the Director of Information Security integrates into operational committees and reports to the board's Risk Committee. No individual's qualifications, experience, or credentials are provided, so Step 2 of the MR tiebreaker confirms the process/program is the subject. The named committees (Operational Risk, IT Steering, Risk Committee) and specific reporting relationships distinguish this as firm-specific rather than generic.


reasoning: The dominant theme is the company's explicit statement that it has NO formal cybersecurity risk management program or processes—a significant negative disclosure that cannot be classified as describing a program, process, or governance structure that exists. While governance elements (board oversight, management roles, materiality assessment) appear, they are incidental to the core disclosure that no formal cybersecurity infrastructure exists. This matches the tiebreaker for companies explicitly stating they lack formal processes.


reasoning: The paragraph primarily describes the company's internal risk management framework (identification, analysis, response) and committee structure. The Executive Director of Information Technology is mentioned as the committee chair but the paragraph's purpose is describing the governance process, not profiling the individual. The named cybersecurity-specific role (Executive Director of IT) makes this Firm-Specific.


reasoning: The paragraph primarily describes the governance structure for cybersecurity oversight—specifically how a crisis management team (led by CIO/CISO) communicates incidents to the Board and how a cyber incident disclosure committee evaluates materiality. This is about the oversight chain and reporting structure (crisis team → Board), which is the defining feature of Board Governance.


reasoning: This paragraph describes the governance/oversight structure—specifically the board's delegation to the Audit and Compliance Committee, the reporting chain (CIO and Chief Compliance Officer reporting to the committee), and the governance cadence (periodic basis, standing agenda topic). These are all standard governance descriptors without firm-specific detail. No named frameworks, standards, specific dates, or unique program identifiers are present.


reasoning: The paragraph's primary substance is a backward-looking negative assertion ('The Company did not experience any cybersecurity incident during 2024'), which is a materiality assessment under Strategy Integration. The board commitment language is generic boilerplate with no firm-specific details.


reasoning: The paragraph primarily describes the Board's oversight structure for cybersecurity risk, including the reporting chain (Director of IT reports to Board) and the types of information reported. While risk assessments and audits are mentioned, the central purpose is explaining governance—not the processes themselves. The only firm-specific fact is the Director of Information Technology title; without this role, the paragraph would be generic board-oversight boilerplate.


reasoning: The paragraph describes a governance oversight structure—specifically a named management committee, its composition, responsibilities for cybersecurity policy approval, and reporting lines from the director of information security upward. This is Board Governance, not Management Role (which would focus on who these people are as individuals), and not Risk Management Process (which would focus on internal processes like vulnerability management or risk assessment).


reasoning: Paragraph describes the governance structure for cybersecurity oversight, including a crisis management team, communication flow to the Audit Committee, and a materiality evaluation process — fitting Board Governance. Named cybersecurity-specific roles (CIO, CISO) and a named internal disclosure committee provide firm-specific details beyond generic governance language.


reasoning: The paragraph describes governance structure—specifically the committee hierarchy and information flow from the cybersecurity committee to the ERM committee—making it Board Governance. It is not Management Role because it does not describe who these people are (credentials, experience, qualifications); rather it describes the governance structure they participate in. The specificity is Firm-Specific because it names two non-standard committees (cybersecurity committee, ERM committee) and identifies the specific senior officers who serve on the cybersecurity committee, which goes beyond generic boilerplate about board oversight.


reasoning: The Trust explicitly has no independent cybersecurity program—it relies entirely on BlackRock's ERM framework and periodic reporting to the Sponsor's Board. This is a shell-company structure disclosure, not a substantive cybersecurity disclosure. The paragraph acknowledges the absence of an independent program rather than describing an actual governance or risk management process.


reasoning: This paragraph is a negative assertion about the company's current awareness of system weaknesses, which constitutes a forward-looking disclaimer rather than a substantive disclosure. It does not describe any actual cybersecurity processes, governance structures, incidents, or materiality assessments about business impact.


reasoning: The paragraph describes the company's cybersecurity risk management framework and operational processes (testing of controls, risk assessments, third-party due diligence, monitoring, reviews) rather than focusing on individual qualifications or incident disclosure. All elements — the three lines of defense, internal/external audits, regular assessments, monitoring of email and remote connections — are standard practices stated generically without named frameworks, specific dates, dollar amounts, named third-party firms, or quantified metrics.


reasoning: This paragraph is a standard forward-looking risk warning using generic speculative language ('could be subject to,' 'could significantly harm') with no reference to actual incidents, assessments, or specific details. It contains no substantive cybersecurity disclosure.


reasoning: The paragraph is primarily about who leads the cybersecurity program and their qualifications—the CTO is identified by name with specific experience counts (30+ years IT, 20+ years cybersecurity), and the supporting team composition is explicitly named. While a process is described, the emphasis on the individuals' roles and credentials (not a process/framework) makes this Management Role.


reasoning: The paragraph primarily describes the governance/oversight structure: how cybersecurity risk is overseen by the Audit Committee of the Board of Trustees, the reporting chain from the Co-President to the committee, and the committee's review process. This is governance structure description, not about who the officer is or their qualifications. No firm-specific facts are present — 'Co-President' is not a cybersecurity-specific title, 'Audit Committee' is a standard committee, 'at least annually' is a vague cadence, and 'independent trustees' is generic governance language.


reasoning: The paragraph's primary substance is a negative assertion about past material incidents ('not aware of having experienced any material cybersecurity incidents') and a forward-looking materiality assessment ('reasonably likely to materially affect'), both of which are SI assessments per the tiebreaker rules. The brief mention of third-party security experts is incidental, not the central topic. No specific dates, dollar amounts, named firms, named products, or other hard verifiable facts are present—only generic cybersecurity risk language that could appear in any 10-K filing.


reasoning: The paragraph primarily describes the governance structure for cybersecurity oversight — committee composition, participant roles, and monitoring functions — including Board representatives in the IT Steering Committee, making Board Governance the appropriate category. The paragraph is firm-specific because it names internal committees (IT Steering Committee, IT Subcommittee) and specific executive roles that are unique to this company's organizational structure.


reasoning: The paragraph primarily describes the governance structure for cybersecurity oversight: the Board conducts annual reviews of the Information Systems Security Program, and the COO reports to the Board. While the COO's experience is mentioned, it supports the governance narrative (explaining the qualification of the reporting officer) rather than being the main focus. The named internal program and specific experience level make this Firm-Specific.