reasoning: The paragraph describes how cybersecurity processes (prevention, mitigation, detection, remediation, incident response, disclosure controls) operate. Applying the person-removal test: removing 'InfoSec Leadership Team' leaves a coherent process description about monitoring, incident response plan operation, and material incident disclosure procedures → Risk Management Process. The named 'InfoSec Leadership Team' is a cybersecurity-specific team unique to this company, qualifying as a firm-specific fact, but no second hard verifiable fact exists to reach QV.

thinking:
Let me analyze this paragraph.

Content: Describes what the "InfoSec Leadership Team" does - monitors prevention, mitigation, detection, remediation through management of cybersecurity processes, and describes the incident disclosure process for material incidents.

Category analysis:
- "InfoSec Leadership Team" is the subject - this is about what they do functionally
- Person-removal test: Remove "InfoSec Leadership Team" → "prevention, mitigation, detection, and remediation of cybersecurity incidents through management of, and participation in, the cybersecurity risk management and strategy processes... including the operation of our incident response plan" - this is coherent as a process description

- The paragraph focuses on processes like incident response and disclosure controls rather than individual qualifications
- Applying the three-step chain confirms this: the team reference is removable, the remaining text describes coherent risk management processes, and there's no personal background information

This is clearly a Risk Management Process category.

Now I'm checking for specificity signals. The "InfoSec Leadership Team" is a named, cybersecurity-specific team, which counts as one firm-specific fact. The incident response plan and disclosure controls are generic program names without dates, numbers, or named external firms. Since there's only one IS fact and no hard verifiable data like dates or amounts, this falls into Firm-Specific with no Quantifiable Verification.

fact: InfoSec Leadership Team


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph contains a backward-looking materiality assessment ('not aware of any risks from cybersecurity threats that have materially affected the Company, including our business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration. The cross-reference to Item 1A is supplementary noise. No specific facts from the IS list are present — all terms are generic boilerplate.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Materiality assessment + cross-reference. The first sentence is a backward-looking materiality assessment ("not aware of any risks... that have materially affected"). Per Rule 6, this is Strategy Integration. The cross-reference is noise.

Specificity: No specific facts from the IS list. Generic boilerplate materiality language.


content_category: Risk Management Process

category_confidence: medium

reasoning: Applying the person-removal test: removing Mr. Daly's name and the team's credentials, the paragraph still coherently describes cybersecurity processes — ongoing monitoring, vulnerability scans, penetration tests, threat intelligence, incident escalation protocols, and tool usage. The dominant content is what the program does, not who the people are. Mr. Daly is mentioned as attribution and as the escalation endpoint, not as the subject of credential/background disclosure. Two QV-eligible hard facts: named CISSP certification and named GIAC certification from the SANS Institute.

thinking:
Let me analyze this paragraph carefully.

**Content Category Analysis:**

The paragraph mentions "Mr. Daly oversees a team" - a named individual. It describes the team's credentials (CISSP, GIAC from SANS Institute), then shifts to what the cybersecurity team does: monitors, evaluates, vulnerability scans, penetration tests, threat intelligence, tools, incident escalation.

Apply the MR vs RMP three-step test:

Step 1 — Subject test: Mr. Daly and "the cybersecurity team" are subjects. Person as subject → signal, continue to Step 2.

Step 2 — Person-removal test: Remove "Mr.

Daly oversees" and "escalating certain cybersecurity incidents to Mr. Daly" and "Mr. Daly is continually informed..." — the remaining text describes what the team does: monitoring, vulnerability scans, penetration tests, threat intelligence, tools, incident assessment. Yes, it's still a coherent cybersecurity disclosure. → Risk Management Process.

But the team's credentials (CISSP, GIAC from SANS) describe who the people are, not what they do. So I'm looking at a mixed paragraph here — the credentials sentence signals Management Role content, while the rest describes the actual processes and activities the team performs.

The dominant content is clearly the process description: monitoring, scans, pen tests, threat intelligence, tools, and incident escalation. The credentials and the framing about Mr. Daly being informed are secondary details. This points to Risk Management Process as the primary category.

Now I'm checking what's actually verifiable here. The CISSP certification is a named credential, and GIAC from SANS Institute gives me both a specific certification and the institution behind it. Those are the two hard facts I can point to—everything else is either a name reference or process description. So this falls into Quantified-Verifiable.

fact: CISSP credentials held by team members

fact: Global Information Assurance Certification from SANS Institute


specificity_confidence: medium

reasoning: The paragraph describes the organizational structure for managing cybersecurity risk — who drives the program (General Counsel), who identifies/assesses risks (management team), and how legal/compliance works with IT. Applying the MR three-step test: Step 2 (person-removal) shows the remaining content still describes a process for evaluating and addressing cybersecurity risks; Step 3 finds no qualifications, certifications, or career history — so this is RMP, not MR. For specificity, General Counsel, Assistant General Counsel, and CEO are all on the NOT list as generic C-suite/legal titles; 'IT leaders' is generic; no cybersecurity-specific roles (CISO, CIO, CTO), no named frameworks, no specific dates, numbers, or tools.

thinking:
Let me analyze this paragraph.

The paragraph describes who drives the cybersecurity program and who is responsible for risk management. Let me apply the decision chain.

Subject test: "Our General Counsel and Assistant General Counsel – Compliance" are the subjects. Then "executive leadership team" and "management team." Then "legal and compliance team works closely with our IT leaders."

Person-removal test: Remove all roles/titles. What remains? "drive the program. The [team], comprised of department leaders and subject matter experts, are responsible for identifying, assessing managing and mitigating risks. With respect to cybersecurity risk, [team] works closely with [leaders] to evaluate and address cybersecurity risks in alignment with our business objectives and operational needs." - This still describes a process/structure, but it's mostly about WHO is responsible.

The core issue is that this is fundamentally about organizational structure and responsibility allocation. The roles mentioned are standard C-suite and legal positions rather than cybersecurity-specific titles, and the language about managing risks and aligning with business objectives is fairly generic. But the paragraph's real purpose is establishing who owns what in the cybersecurity governance structure.

When I strip away the role assignments, the remaining process description stands on its own without needing specific people attached to it. There are no qualifications, certifications, or experience requirements mentioned—just titles and responsibilities. That points toward this being a Risk Management Process rather than a Personnel/Qualifications category.

Looking at the specific roles and departments mentioned: General Counsel and Assistant General Counsel aren't cybersecurity-specific titles, and they're already on the NOT list. The "legal and compliance team" working with "IT leaders" does describe a departmental composition, which the IS list flags as potentially specific. But these are generic functional areas without naming particular individuals or specialized cybersecurity roles like CISO or CTO. No frameworks, dates, numbers, or tools are specified either. The core content is really about how the organization structures its risk management responsibilities across these departments. I'm noticing "Assistant General Counsel – Compliance" is a fairly specific role title, though it's still a legal position rather than cybersecurity-focused. Since there are no named frameworks, cybersecurity-specific titles, or concrete details like dates or tools, I'm leaning toward Generic Boilerplate.


reasoning: The paragraph contains a negative materiality assertion ('we have not experienced any recent material cybersecurity incidents') which is the company stating a conclusion about materiality per Rule 6, triggering Strategy Integration. The remaining content is generic risk warning ('no assurance... will not materially affect us') and a cross-reference, neither of which override the materiality assessment. No firm-specific facts are present — all language is boilerplate.

thinking:
Let me analyze this paragraph carefully.

The paragraph contains:
1. Generic disclaimer about policies/procedures
2. "we have not experienced any recent material cybersecurity incidents" - this is a negative assertion about materiality
3. Generic risk language about facing cybersecurity risks
4. Reference to other casino companies having incidents
5. "We can provide no assurance that there will not be incidents in the future or that they will not materially affect us, including our business strategy, results of operations, or financial condition" - this is generic risk warning with "will not materially affect" but framed as "no assurance...

The key distinction here is that the negative assertion about not experiencing recent material incidents is actually a materiality assessment that triggers Strategy Integration, while the forward-looking language about future incidents is just speculation without a concrete assessment. The company references other casino companies' incidents but provides no specific facts about their own situation or any named standards they follow. This lack of specificity and firm-specific detail is notable.


reasoning: The paragraph contains a negative materiality assertion ('we have not experienced a material cybersecurity incident'), which is the company stating a conclusion about whether cybersecurity has affected business outcomes — triggering Strategy Integration per Rule 6. The first sentence is generic risk acknowledgment. No specific facts from the IS list are present.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. Generic risk acknowledgment about cyber threats
2. A negative materiality assertion: "we have not experienced a material cybersecurity incident"

The second sentence is a materiality assessment - the company is stating a conclusion that they have not experienced material incidents. Per Rule 6 and the codebook, negative assertions with materiality framing ("have not experienced any material cybersecurity incidents") → Strategy Integration.

Specificity: The language is boilerplate. No named entities, no specific facts from the IS list. → Generic Boilerplate.


content_category: Board Governance

reasoning: This is a governance-chain paragraph describing how cybersecurity information flows from the CTO upward to the Audit and Finance Committee and executive leadership — the purpose is describing the oversight/reporting structure, making it Board Governance. Contains firm-specific facts (CTO as cybersecurity-specific role, uniquely named 'Digital QBR' meetings, 'Digital Leadership team') but no two QV-eligible hard facts, so Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes how the CTO reports to the Audit and Finance Committee and leadership teams about cybersecurity matters. It describes briefing cadence, content of reports, and review processes.

**Category Analysis:**
- The CTO is mentioned as attribution - providing reports TO the board committee
- The primary purpose is describing the oversight/reporting structure - how information flows from management to the board
- The Audit and Finance Committee is receiving reports
- This is a governance-chain paragraph: CTO → Audit and Finance Committee / executive leadership

Per Rule 2, governance-chain paragraphs are almost always Board Governance.

Now I'm looking at the specificity of the facts mentioned. The CTO is a cybersecurity-specific role, the Audit and Finance Committee is a standard board committee variant, and there's a named reporting mechanism called the Digital Quarterly Business Review. These are concrete details about the reporting structure and cadence.

→ **Board Governance**

I'm identifying which facts qualify as firm-specific versus QV-eligible. The CTO title, Digital QBR program, and Digital Leadership team are all named elements unique to this organization, but none of them reach the threshold for QV eligibility. That gives me three firm-specific facts but no qualifying QV facts.

fact: CTO provides cybersecurity reports

fact: Digital Quarterly Business Review ("Digital QBR") meetings

fact: Digital Leadership team


reasoning: This is a governance-chain paragraph describing how management supervises cybersecurity efforts, receives briefings from the internal security team and Disclosure Committee, and provides quarterly updates to the Board/Audit Committee in alternating quarters. Per the codebook, governance-chain paragraphs describing oversight structure and information flow to the board are Board Governance, even when management is the grammatical subject. No IS-list facts remain after filtering: 'Audit Committee,' 'Board of Directors,' 'management team,' and 'Disclosure Committee' are generic governance entities; 'quarterly' and 'Information Security team' are generic cadence/team references.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the management team's role in cybersecurity - supervising efforts, receiving briefings, and providing updates to the Board/Audit Committee.

Category analysis:
- The grammatical subject is "our management team" throughout
- It describes what management does: supervises efforts, receives briefings, provides updates to the board
- This spans management activities and governance chain (reporting to board)

Applying Rule 2 (Board vs Management):
- The purpose is describing the oversight/reporting structure - how information flows from security team → management → board
- This is a governance-chain paragraph. The management team is an intermediary.

- But the focus is really on what management does - supervises, receives briefings, provides updates - with the board appearing only as the final recipient. Management is the central actor here, not the board, so this is describing management's cybersecurity responsibilities and their role in the oversight chain rather than board governance itself.

Let me think about whether this is about the governance structure or management's internal processes. The paragraph describes how information flows upward - from security tools and the Disclosure Committee to management, then from management to the board. There are no personal details, no named individuals, just functional roles and processes. So the real question is whether this is board governance (oversight structure) or management role (internal processes). Applying the three-step test: "management team" is the subject, but when I remove those references, what's left is about briefings, threat intelligence, and quarterly updates - the process and structure itself. That could point to either direction, but since this is fundamentally a governance chain paragraph, I need to determine if it's describing the oversight structure for board purposes or the internal processes management follows.

The key insight is that the paragraph explicitly describes how information flows to the board through quarterly updates, and it details the alternating cadence between the Board and Audit Committee. That's a governance structure detail - it's about the oversight chain and reporting relationships. Even though management is the primary focus, the purpose is describing how information reaches the board, which makes this Board Governance. I'm going back and forth on this. The paragraph really is centered on what management does—they oversee cybersecurity efforts, receive briefings with specific types of information, and then report quarterly to the board. Even though board reporting appears at the end, the bulk of the content describes management's operational responsibilities and information sources, which points toward Management Role rather than Board Governance. is Board Governance. The paragraph's core purpose is describing how management receives cybersecurity information and reports findings to the board on a quarterly basis — that's the governance oversight structure, not a risk management process description. The specific mention of alternating quarterly updates to the Board versus Audit Committee is the key detail that anchors this as governance-focused rather than process-focused. to the board. But I'm second-guessing myself—the paragraph really emphasizes what management does supervisory-wise, and while the board appears at the end as a recipient, the core focus is on management's responsibilities. The codebook mentions reporting structure as part of MR, and this does describe how management reports to the board quarterly. This feels like it could genuinely fit either category, but I think Board Governance is the stronger call since the whole point is explaining the oversight chain and how information flows up to the board. I'm checking the codebook definition for Board Governance—it specifically calls out quarterly briefings and board committee oversight as key markers, which this paragraph does mention. But the bulk of the text is really about what management does and oversees, not about the board's role itself. The management activities take up most of the space here, so even though there's a governance reporting element, I think the dominant category is still Management Role.

Wait, actually the codebook notes that governance-chain paragraphs describing the oversight structure are almost always Board Governance. This paragraph does lay out that chain: management supervises, receives briefings from security and the Disclosure Committee, then reports quarterly to the Board or Audit Committee. That's describing the governance structure itself, not just management's internal activities.

I'm going with Board Governance as my final answer—the paragraph's purpose is explaining how oversight flows through the organization.

Now checking specificity: "Information Security team" is generic, not a cybersecurity-specific title. "Disclosure Committee" is a standard governance committee at public companies, so that's generic too. The quarterly cadence and alternating schedule are specific details, but "quarterly" itself is on the NOT list. No named individuals, no certifications, no specific dates, no named tools. So this looks like it should count as generic. being generic, like Audit Committee. Looking at the paragraph more carefully, I see it's really describing the flow of information and reporting structure—management gets briefings from internal security and the Disclosure Committee, those briefings cover threat intelligence and security tool alerts, and then management reports quarterly to either the Board or Audit Committee on a rotating basis. This is all governance and process detail without any specific named standards or technical facts. So this stays as Board Governance, Generic Boilerplate. I'm double-checking my classification against the Information Security list to make sure "Information Security team" doesn't qualify as a specific role—it's a team designation rather than an individual title like the ones listed, so it doesn't change my assessment.


content_category: Management Role

reasoning: The paragraph is organized around the Compliance Committee — a management committee responsible for cybersecurity — describing its composition (cross-functional, includes CIO), meeting cadence, responsibilities, and escalation processes. The codebook explicitly lists 'management committees responsible for cybersecurity' under Management Role. While removing the committee references leaves some process content (reviewing metrics, escalation protocols), the paragraph's primary communicative purpose is identifying WHO at the management level is responsible and HOW that committee is structured, not describing the cybersecurity program's technical processes. The Compliance Committee (named non-generic committee) and CIO (cybersecurity-specific title) are firm-specific facts, but neither qualifies for QV counting, so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph describes a cross-functional Compliance Committee that includes the CIO, and details what this committee does - assessing/managing cyber risks, meeting quarterly, reviewing metrics, making recommendations, escalation processes.

Category: This is about a management-level committee's role and responsibilities. The Compliance Committee is a management committee (not a board committee). It describes who is on it, what it does, how it operates. The last two sentences mention the Board but in the context of escalation/reporting structure.

Let me apply the decision rules:
- The primary subject is the Compliance Committee (management level)

- It describes the committee's composition, meeting cadence, responsibilities
- The purpose is describing the management structure for cybersecurity oversight

This spans Management Role and Risk Management Process. Let me apply the three-step test:
- Step 1: Subject is the Compliance Committee (a group/role), not a process/framework. Continue.
- Step 2: Remove all role/title/committee references. What remains? Descriptions of activities: reviewing security metrics, identifying risks, assessing enhancements, making recommendations on policies, escalation process, monitoring protocols. Yes, coherent process description remains.
- But the paragraph is fundamentally about WHO manages cybersecurity - the Compliance Committee structure and its composition are central to the content, not just incidental framing.

Re-reading the full paragraph: it's organized around the Compliance Committee itself - its cross-functional composition with executive and senior leadership including the CIO, its responsibilities, its meeting frequency, what it reviews. The escalation to the Board and Board oversight reinforce the governance chain. The dominant focus is clearly on the management committee structure.

Applying the person-removal test creates some ambiguity - removing "CIO" and "Compliance Committee" leaves process content about reviewing metrics, identifying risks, and escalation. But that's not the paragraph's primary purpose. The committee is the subject throughout, and the paragraph exists to explain the management structure responsible for cybersecurity oversight.

This is Management Role - the content centers on the committee's identity, composition, and responsibilities.

For specificity, "Compliance Committee" is a named non-generic committee and "Chief Information Officer" is a cybersecurity-specific title, so both count toward the IS list. "Quarterly" is just a generic cadence, so that doesn't. At minimum this qualifies as Firm-level specificity.

For QV, I need hard verifiable facts like dates, dollar amounts, or headcounts—named roles and committees don't count. There's nothing concrete enough here, so this lands at Firm-Specific (3).

fact: Cross-functional Compliance Committee comprised of executive and senior leadership

fact: Chief Information Officer (CIO)


reasoning: The paragraph's purpose is describing how cybersecurity oversight information flows upward to the Board — the ITSC and CIO are intermediaries in the governance chain, reporting quarterly to the Board. This is a governance-structure paragraph, making it Board Governance per the purpose test. The ITSC is a named non-generic committee and CIO is a cybersecurity-specific title on the IS list, yielding Firm-Specific; however, neither counts toward QV thresholds.

thinking:
Classify this paragraph.

This describes how cybersecurity risk management information flows to the board - the ITSC and CIO report to the Board quarterly. The purpose is describing the oversight/reporting structure.

Category: Board Governance - the purpose is describing how information flows upward to the board. The CIO and ITSC are intermediaries in the governance chain.

Specificity:
- "ITSC" - this appears to be a named internal committee (Information Technology Steering Committee?) - could be a firm-specific committee
- "Chief Information Officer" - CIO is on the IS list as a cybersecurity-specific title

- "quarterly" is just a generic reporting cadence, not a distinguishing factor

The CIO is a named role and ITSC is a named committee, neither of which count toward quantifiable verification. Since there are no hard verifiable facts here, this lands at Firm-Specific level.

fact: ITSC (Information Technology Steering Committee)

fact: Chief Information Officer


reasoning: The paragraph describes the management committee structure for cybersecurity: delegation from the Enterprise Risk and Return Council to the ISC, CISO as chair, committee composition (Privacy, Legal, Technology), and committee responsibilities. The codebook explicitly lists 'management committees responsible for cybersecurity' under Management Role. While the ISC's functions (monitoring, escalating, overseeing policy) are process-adjacent, the paragraph's primary purpose is describing the organizational structure and delegation chain at the management level, not the processes themselves. Multiple firm-specific facts (two named non-generic committees, CISO role, specific departmental composition) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms/tools).

thinking:
Let me analyze this paragraph.

Content: Describes delegation from Enterprise Risk and Return Council to ISC, CISO chairs ISC, composition includes Privacy/Legal/Technology, ISC monitors/mitigates/escalates risks, oversees policy and standards.

Category: This is about management committees and their structure. The CISO chairs the ISC, senior management representation. The purpose is describing the governance/oversight structure at the management level.

Let me apply the decision rules:
- The Enterprise Risk and Return Council delegated to ISC - this is management-level committee structure

- CISO chairs ISC - management role attribution
- ISC composition, responsibilities described

This is about the management committee structure and what it does. The CISO is mentioned as chair but no personal qualifications. The paragraph describes what the ISC does (monitors, mitigates, escalates, oversees policy).

Person-removal test: Remove CISO reference - the paragraph still describes the ISC's functions coherently. So it's about the function/process.

This is describing the management governance structure - the Enterprise Risk and Return Council delegates oversight to the ISC, which operates as a management-level committee with cross-functional representation that handles risk monitoring, mitigation, escalation, and policy governance. I'm applying the person-removal test here—if I strip out the CISO title, the paragraph still conveys the ISC's delegation chain, composition across Privacy, Legal, and Technology, and its core functions like monitoring and escalating risks. The real question is whether this is fundamentally about organizational structure or the processes those committees execute. The codebook does list management committees under Management Role, but the ISC's activities—monitoring, mitigating, escalating—sound more like Risk Management Process descriptions. I'm leaning toward this being about the organizational structure and delegation authority rather than the specific processes themselves.

Now I'm checking the specificity angle. The named committees (Enterprise Risk and Return Council, Information Security Council) and the CISO role are all hard facts, but the CISO title itself isn't quantitatively verifiable. The committee composition across those three functions is specific enough to count as an IS fact, though I need to verify whether there are actually two or more independently verifiable facts here beyond just the named entities.

Looking at what's actually verifiable: the ISC exists as a named entity, the CISO chairs it, and the three functional areas are defined. But none of these have dates, metrics, or third-party references that would make them quantitatively verifiable. So this lands as Firm-Specific without the QV qualifier.

On the category itself, I'm torn between Management Role and Governance. The paragraph is fundamentally about organizational structure and the delegation chain, which points toward Management Role. But the emphasis on how governance flows through these committees and their specific responsibilities makes it feel governance-adjacent. The codebook does explicitly call out management committees responsible for cybersecurity under MR, so I'll stick with that classification.

Final call: Management Role, Firm-Specific (3).

fact: Enterprise Risk and Return Council (named non-generic council)

fact: Information Security Council (ISC) — named internal program with unique identifier

fact: CISO chairs the ISC

fact: Representatives from Privacy, Legal and Technology (specific departmental composition)


content_category: None/Other

reasoning: The paragraph contains generic risk disclaimers ('no system is entirely secure,' 'may not be sufficient to prevent all incidents') and a cross-reference to Item 1A for materiality information. It makes no materiality assessment itself — it only points the reader elsewhere. 'Information Security Program' is a generic program name. No named frameworks, roles, dates, or firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: References frameworks informing security controls, acknowledges limitations, and ends with a cross-reference to Item 1A Risk Factors.

Category: This is mostly generic risk language about limitations of cybersecurity programs, plus a cross-reference. No materiality assessment - it says "may not be sufficient" and "may not be able to anticipate" which are generic warnings. The cross-reference says "please refer to Item 1A" for information on how cybersecurity risk may affect business strategy - this is pointing elsewhere, not making a materiality conclusion. → None/Other

Specificity: No named frameworks (says "these frameworks" referencing prior paragraph), no specific facts.

The program name itself is just generic boilerplate language without any distinctive details.


reasoning: The paragraph contains generic language about experiencing attempted breaches ('bots', unknown persons) that could apply to any company, a boilerplate no-assurance disclaimer, and a cross-reference to Item 1A Risk Factors. There is no substantive cybersecurity disclosure — no process description, no materiality assessment, no incident detail, and no governance content. The 'could' language ('there can be no assurance') is speculative, not a materiality conclusion.

thinking:
Let me analyze this paragraph.

Content: Generic statement about experiencing attempted breaches, saying they were prevented, no assurance for future, cross-reference to Risk Factors.

Category: This doesn't describe a specific incident (no dates, no details). It's generic language about experiencing attempts. No materiality assessment. The cross-reference points elsewhere. No process description. This is essentially generic risk language + cross-reference.

This is None/Other - generic language about experiencing threats (every company does), no substantive disclosure, cross-reference to Risk Factors.

The specificity here is just boilerplate—no named standards, no concrete facts, nothing that's actually firm-specific.


reasoning: The paragraph describes how information flows from management upward to a board-level committee (Risk Committee), including briefing cadence and scope of reporting — this is governance/oversight structure, making it Board Governance. The Risk Committee is a named non-generic committee (one IS-list fact), reaching Firm-Specific but not QV since 'annually' and 'quarterly' are generic cadences.

thinking:
Let me analyze this paragraph.

The paragraph describes reporting from IT Management team to the Risk Committee - this is about governance/oversight structure (how information flows upward).

Category: Board Governance - the purpose is describing the oversight/reporting structure between management and a board committee.

Specific facts:
- "Risk Committee" - named non-generic committee (IS list)
- "IT Management team" - not a cybersecurity-specific title
- "annually" and "quarterly" - generic cadences (NOT list)

Specificity: Risk Committee is a named non-generic committee → Firm-Specific (3). Only one IS fact, so not QV.

fact: Risk Committee


reasoning: The paragraph describes how cybersecurity risk management is embedded into business processes and how the ERM team collaborates with the CSO and IT risk management team to evaluate risks. Applying the person-removal test: removing the CSO reference leaves a coherent description of ERM integration and risk evaluation processes, so this is about the function, not the person. 'Material cybersecurity risks' uses 'material' as an adjective, not a materiality assessment. The CSO title is a cybersecurity-specific role on the IS list, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes how risk management is embedded in business processes, mentions ERM team working with CSO and IT risk management team to evaluate cybersecurity risks.

Category analysis:
- Mentions CSO role and ERM team working together
- Describes process of evaluating and addressing cybersecurity risks
- "in alignment with our business strategy and operational needs"

Person-removal test: Remove "our Chief Security Officer ('CSO')" - remaining text describes ERM integration and risk evaluation processes. It still makes sense as a process description. → Risk Management Process

But wait - does the mention of "material cybersecurity risks" + "business strategy" trigger Strategy Integration? No - "material" here is used as an adjective meaning "significant," not a materiality assessment.

Now I'm checking what specific facts support this categorization. The CSO is clearly a cybersecurity-specific role that appears on the IS list, making this firm-specific. The enterprise risk management team and IT risk management team are generic program names without specialized designations. There are no named frameworks or QV facts present, so this qualifies as a single firm-specific fact rather than QV.

fact: Chief Security Officer (CSO)


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any risks from cybersecurity threats... which have materially affected or are reasonably likely to materially affect our Company, including our business strategy, results of operations, or financial condition'), which is both a backward-looking and forward-looking conclusion per Rule 6 → Strategy Integration. The surrounding content (generic attack description and cross-reference to Item 1A) is noise. No firm-specific facts, named standards, or verifiable details — boilerplate materiality language.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. Generic description of attacks they face
2. A materiality assessment ("not aware of any risks... which have materially affected or are reasonably likely to materially affect")
3. A cross-reference to Item 1A

Per Rule 6, the materiality assessment is the key content. The paragraph explicitly states a conclusion: risks "have [not] materially affected or are reasonably likely to materially affect" their business strategy, results of operations, or financial condition. This is a backward-looking + forward-looking materiality assessment → Strategy Integration.

The language lacks any specificity—no named standards, firm-specific facts, dates, or identified roles. Even though there's a cross-reference to a specific risk factor, that's just a pointer without substantive detail → Generic Boilerplate.


reasoning: The paragraph opens with CFO attribution but the dominant content describes internal cybersecurity processes: protocols/policies/tools, annual third-party IT assessments, ISO 27001 alignment, incident response plan, ISMS oversight, and security awareness training. Applying the person-removal test, deleting the CFO reference leaves a fully coherent process description. CFO is on the NOT list (generic C-suite, not a cybersecurity-specific title), and all other entities are unnamed ('independent third party,' 'external consultant'). ISO 27001 is named as a framework but the company claims alignment rather than certification, so it triggers Sector-Adapted but not Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

The paragraph starts with "Disclosure of Management's Responsibility" and mentions the CFO's role, then shifts to describing the company's cybersecurity program processes.

**Category Analysis:**

Step 1 - Subject test: The CFO is mentioned first, but then the paragraph shifts to processes ("protocols, policies and tools," "IT general controls," "ISO 27001," "incident response plan," "ISMS process," "security awareness training").

Step 2 - Person-removal test: Remove "The Company's Chief Financial Officer is primarily responsible for overseeing the Cybersecurity Risk Management Program and leading the Company's efforts to mitigate technology risks in partnership with various business leaders in the organization.

For qualifications of the CFO refer to Item 10 of the form 10-K." The remaining text is a coherent description of cybersecurity processes. So this is Risk Management Process.

Wait - the CFO is mentioned but CFO is on the NOT list (generic C-suite). And the paragraph's dominant content is about processes: protocols, tools, third-party assessments, ISO 27001 alignment, incident response plan, ISMS, training. This is clearly **Risk Management Process** since the bulk describes internal processes.

**Specificity Analysis:**

Looking at the facts: CFO is generic C-suite (NOT list), ISO 27001 is a named framework (Sector-Adapted), but the third-party assessments and external consultants are unnamed and generic. The incident response plan is mentioned but cut off.

The key detail is "maintaining and improving our alignment with ISO 27001" - naming the standard without claiming certification makes this Sector-Adapted. There are no firm-specific facts, no cybersecurity-specific titles, no named committees, dates, tools, firms, or numbers.

Specificity: **Sector-Adapted** (ISO 27001 named)

type: framework


reasoning: Applying the person-removal test: removing 'The Director – Information Systems, in coordination with management' leaves a coherent description of a program to protect systems, respond to incidents, and manage risk (mitigation, transference, acceptance) — the content is about the function, not the person. 'Director – Information Systems' is a generic IT leadership title (comparable to 'Director of IT' on the NOT list, lacking the 'Security' qualifier), and no named frameworks, dates, tools, or other IS-list facts are present, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph describes the "Director – Information Systems" and management working to implement a cybersecurity program and respond to incidents. Let me apply the decision chain.

Step 1 — Subject test: "The Director – Information Systems" is the grammatical subject. Person/role as subject → signal, continue to Step 2.

Step 2 — Person-removal test: Remove "The Director – Information Systems, in coordination with management," and we get: "works collaboratively across the Company to implement a program designed to protect the Company's information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents in accordance with the Company's incident response plans.

Now looking at the rest of the content, management is actively involved in the incident response and risk management process—handling mitigation, transference, and acceptance. When I strip away the role references entirely, the core substance remains: a program designed to protect systems, respond to incidents, and manage risk. This suggests it's fundamentally about the Risk Management Process rather than a person-specific responsibility. But I should verify whether "Director – Information Systems" qualifies as a cybersecurity-specific title, since it reads more like a general IT role compared to titles like CISO, CTO, or CIO.

Checking against the specificity criteria: there are no named frameworks, no dates, no specific tools—just generic descriptions of risk management approaches. The title "Director – Information Systems" leans toward the generic IT leadership side rather than security-focused, which would place it closer to the NOT list. This points toward Generic Boilerplate with a Specificity score of 1.


reasoning: This is a governance-chain paragraph describing oversight structure: executive team and Audit Committee consider cyber risk as part of strategy, Board/Committee receive annual briefings, and the CIO reports to the Audit Committee on compliance and risk topics. The CIO's 20-year experience is one sentence of supporting detail, not the primary content. The purpose is describing how oversight flows from CIO → Audit Committee → Board. CIO is a firm-specific role (IS list), and '20 years' is a specific number, but only one QV-eligible fact (years of experience), so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Executive team + Audit Committee considering cyber risk as part of business strategy/financial planning
2. Audit Committee and Board briefing cadence (at least annually, plus for material incidents)
3. CIO reporting to Audit Committee - describes what the reports cover
4. CIO's background - 20 years experience in IT/security roles

This is a governance-chain paragraph spanning board → committee → officer. Let me apply the decision rules.

Purpose test: The paragraph describes the oversight structure - how the executive team and Audit Committee consider cyber risk, how the board gets briefed, how the CIO reports to the committee.

The dominant purpose is describing the governance/oversight structure - how information flows from the CIO to the Audit Committee/Board. The CIO's qualifications appear in one sentence at the end, but they support the credibility of the reporting structure rather than being the main focus.

Per Rule 2: "Governance-chain paragraphs are almost always Board Governance." The purpose is describing oversight structure.

Category: Board Governance

Specificity:
- CIO is a cybersecurity-specific title → Firm-Specific (✓ IS list)
- "over 20 years" → specific number → QV-eligible
- "at least once each calendar year" / "at least annually" → generic cadence (NOT list)
- Audit Committee is a standard governance body (NOT list)

Only one QV-eligible fact here: "over 20 years" of experience. The CIO title itself is a named role but doesn't count toward QV eligibility. That single quantified fact means this falls under Firm-Specific (3), not QV.

fact: Chief Information Officer (cybersecurity-specific title)

fact: Over 20 years of experience in senior IT/information security roles

type: quantified


reasoning: The paragraph identifies the specific teams (Information Security, Compliance, Legal, Internal Auditing) whose leaders oversee cybersecurity and describes their qualifications (average 20+ years experience in IT/security roles). Applying the three-step MR vs RMP test: Step 2 — removing the people's qualifications and team identities leaves generic process language ('monitor prevention, mitigation, detection...'); Step 3 — the paragraph includes years of experience and career background, which are MR-specific content. One QV-eligible fact (20+ years) plus one firm-specific fact (team composition) yields Firm-Specific, not QV (only one hard verifiable fact).

thinking:
Let me analyze this paragraph carefully.

This is about UHS' cybersecurity leadership team - their backgrounds and what they do.

Category analysis:
- Names specific teams: Information Security, Compliance, Legal and Internal Auditing
- Describes average experience: over 20 years
- Describes what these individuals do: monitor prevention, mitigation, detection, remediation

Step 1 (Subject test): "leaders" and "individuals" are subjects - person/role. Continue to Step 2.

Step 2 (Person-removal test): Remove the people details.

What remains is a description of processes - monitoring prevention, mitigation, detection and remediation of cybersecurity incidents through risk management and incident response operations. But that's not really the main point here. The paragraph is fundamentally about who these people are, their team structure, and their collective experience.

Step 3 (Qualifications tiebreaker): The career history is significant - over 20 years average across IT, security, auditing, compliance, systems and programming roles. This confirms the focus is on the people themselves.

So this is clearly a Management Role category - the paragraph's primary content is the team composition and their qualifications, not the processes they oversee.

Looking at specificity now: I see named teams (Information Security, Compliance, Legal and Internal Auditing) and a quantified experience metric (over 20 years). The team composition is firm-specific but doesn't meet QV criteria. The "over 20 years" is a specific number for years of experience, which does qualify as QV-eligible. That's only one QV fact, so this falls into Firm-Specific classification.

fact: Information Security, Compliance, Legal and Internal Auditing teams

fact: average of over 20 years of prior work experience


reasoning: This is a cross-reference directing readers to Item 1A. The materiality language ('may materially affect') describes what Item 1A covers, not the company's own materiality conclusion. Per the codebook, 'For risks that may materially affect us, see Item 1A' is None/Other — pointing elsewhere, not making an assessment.


reasoning: Applying the MR vs RMP decision chain: Step 1 — the grammatical subject is 'processes,' but the sentence pivots to identifying who implements them. Step 2 — removing the person ('Senior Principal Security and Infrastructure Architect with over 20 years...') leaves only 'processes are implemented and maintained by certain Company management,' which is barely coherent and loses the paragraph's substantive content. Step 3 — the paragraph includes years of experience ('over 20 years'), confirming Management Role. For specificity, the cybersecurity-specific title is an IS-list fact (Firm-Specific), and 'over 20 years' is one QV-eligible fact; with only one QV-eligible fact the paragraph stays at Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content category: The paragraph mentions "cybersecurity risk assessment and management processes" (RMP language) but then focuses on a specific person's role and qualifications ("Senior Principal Security and Infrastructure Architect with over 20 years managing large scale enterprise security systems").

Applying the three-step decision chain:
- Step 1: Subject is "processes" but the sentence pivots to describing who implements them
- Step 2: Remove the person detail: "Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management." — This is a coherent but very thin statement. The specific person and their qualifications are significant content.

- Step 3: Yes, includes years of experience ("over 20 years") — Management Role

The paragraph's primary content is identifying WHO manages the processes and their qualifications. The process mention is just context. Now I'm checking the specificity against the QV-eligible criteria. The cybersecurity-specific title is firm-specific, and the years of experience count as QV-eligible. Let me verify whether the role title itself qualifies — it's on the IS list but I need to confirm it's not on the QV-eligible list. Looking at what qualifies: specific dates, dollar amounts, headcounts or percentages, named third-party firms, named products or tools, named certifications, and years of experience. The role title doesn't fit these categories, but the "over 20 years" does.


reasoning: The paragraph describes how the company monitors and manages cybersecurity risks through briefings, threat intelligence, and security tools. Applying the person-removal test: removing 'Our management team supervises' leaves a coherent description of cybersecurity monitoring processes — the content is about the function, not the people. No named frameworks, roles, tools, firms, or other specific facts appear; all entities are generic ('internal security personnel', 'external consultants', 'security tools').

thinking:
Let me analyze this paragraph.

Content: Management team supervises cybersecurity efforts through briefings, threat intelligence, and security tools. No specific people named, no credentials, no specific tools or frameworks.

Category: The paragraph describes what the management team does to supervise cybersecurity. Applying the MR vs RMP test:
- Step 1: "Our management team" is the subject - a person/role, so continue to Step 2.
- Step 2: Remove "Our management team supervises" → "efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel; threat intelligence and other information obtained from governmental, public, or private sources, including external consultants engaged by us; and alerts and reports produced by security tools deployed in the IT environment." This is a coherent process description → Risk Management Process.

- Specificity check: Everything here is generic—no named frameworks, no specific tools mentioned, just vague references to "management team," "internal security personnel," "external consultants," and "security tools." This is standard boilerplate language.


reasoning: The paragraph lists management team responsibilities (hiring, budgets, incident prep, approving processes, reviewing assessments) — all functional/process descriptions. Applying the person-removal test: removing 'Our management team' leaves a coherent list of cybersecurity activities, so the content is about the function, not the person. No named roles, frameworks, or firm-specific facts; 'management team' is generic.

thinking:
Let me analyze this paragraph.

Content: Describes management team responsibilities - hiring, integrating cyber risk, budgets, incident prep, approving processes, reviewing assessments.

Category: This is about "management team" - generic, no named roles. Apply the MR vs RMP decision chain:
- Step 1: "Our management team" is the subject - a person/role. Continue to Step 2.
- Step 2: Remove "Our management team" references. What remains? Hiring personnel, integrating cyber risk into business processes, approving budgets, preparing for incidents, approving processes, reviewing assessments.

These are all process and function descriptions that stand on their own without the people reference. The paragraph is really about what the management function does rather than who fills those roles - there are no credentials, names, or experience qualifications mentioned. This points to Risk Management Process. And since there are no named frameworks or specific details, just generic management responsibilities, this falls into Generic Boilerplate.


reasoning: The paragraph describes the TRCC, a dedicated management risk governance committee — its composition (CISO, senior stakeholders), chair appointment process (by head of ERM), reporting structure (sub-committee of ERC), and responsibilities. Per the codebook, Management Role covers 'management committees responsible for cybersecurity.' The paragraph is fundamentally about the organizational structure of this management committee rather than the processes it oversees. Multiple named non-generic committees (TRCC, ERC) and the CISO role make it Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named third-party firms, tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the TRCC (Technology Risk Compliance Committee or similar), a management risk governance committee. It describes the committee's structure, membership, chair appointment, and responsibilities.

Category analysis:
- This is about a management-level committee (sub-committee of ERC), not a board committee
- The TRCC is a "management risk governance committee" - so this is management-level oversight
- It describes the committee's composition (CISO, senior business stakeholders), chair appointment (by head of ERM), and responsibilities
- This is about organizational structure and oversight at the management level

- The committee itself is the organizational structure being described, so even removing people references, the core content is about what the committee does and oversees

. This points toward Management Role since the paragraph is fundamentally about the TRCC committee structure and its responsibilities for cybersecurity oversight.

Now I'm checking the specificity criteria. The TRCC is a named non-generic committee, the CISO is a cybersecurity-specific title, and the ERC is another named committee—all of these qualify as firm-specific identifiers. For quantifiable verification, there are no dates, dollar amounts, headcounts, or named third-party firms mentioned, so this doesn't meet the QV threshold.

Given the firm-specific elements and the focus on the management committee's composition and role, this is Management Role, Firm-Specific.

fact: TRCC (Technology and cybersecurity risk governance committee)

fact: ERC (Enterprise Risk Committee)

fact: CISO as member of TRCC

fact: Chair appointed by head of Enterprise Risk Management


reasoning: This kitchen-sink paragraph spans BG (Audit and Risk Committee oversight, CIO reporting to committee), MR (CIO qualifications, Senior Director role), RMP (incident response plan, monitoring, detection/recovery), and SI (no material impact, cyber insurance). By volume, the dominant content describes the company's internal cybersecurity processes — incident response strategy, defined roles/communication protocols, detection/response/recovery prioritization, monitoring and testing procedures — making RMP the primary communicative purpose. The governance framing bookends the paragraph but serves as context rather than the central topic. Specificity is Firm-Specific: multiple IS-list facts (CIO, Senior Director of Information Security, Cybersecurity Infrastructure Committee, 15 years of experience), but only one QV-eligible hard fact (15 years); the degree in MIS lacks a named university and does not count toward QV.

thinking:
This is a complex, multi-topic paragraph. Let me analyze it carefully.

The paragraph covers:
1. Audit and Risk Committee oversight (Board Governance)
2. CIO and Senior Director roles (Management Role)
3. CIO's qualifications - 15 years experience, degree in MIS (Management Role)
4. Cybersecurity Infrastructure Committee meets monthly (could be BG or MR)
5. Incident response strategy and plan (Risk Management Process)
6. Past adverse IT events with no material impact (Strategy Integration)
7. Cybersecurity insurance (Strategy Integration)
8. Monitoring/testing processes, CIO reports to Audit and Risk Committee (Board Governance / RMP)

9. The paragraph spans multiple categories without a clear dominant one - it's a mix of governance oversight, management structure, risk management processes, and strategic integration elements.

Looking at the space allocation, the incident response plan details take up substantial real estate, but the governance framing bookends everything - it opens with the Audit and Risk Committee and closes with CIO reporting back to them. That structural choice suggests the primary purpose is describing the cybersecurity oversight chain, with the operational details serving as supporting evidence of how that governance actually functions. So this reads as a Board Governance disclosure at its core. The paragraph's real purpose is describing the company's overall cybersecurity risk management approach—from the oversight structure down through the actual processes and outcomes. While the governance framing bookends the content, the substance is really about what the company does operationally: incident response, monitoring, detection, and insurance review. That makes Risk Management Process the dominant category here.

Looking at the specificity, I've got several facts from the IS list: the CIO title, the Senior Director of Information Security role, 15 years of experience, and the Cybersecurity Infrastructure Committee. But when I check what counts toward QV eligibility, only the 15 years of experience qualifies as a specific quantified fact. The roles and committee are named but not QV-eligible, and the degree in management information systems is too generic without a named university. With just one QV-eligible fact, this lands at Firm-Specific level.

fact: Chief Information Officer (CIO)

fact: Senior Director of Information Security

fact: CIO has 15 years of experience in cybersecurity

fact: Cybersecurity Infrastructure Committee


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors. The materiality language ('may materially affect') describes what Item 1A discusses, not the company's own materiality conclusion. Per the codebook, 'For risks that may materially affect us, see Item 1A' is N/O because the paragraph points elsewhere rather than making an assessment.


reasoning: The paragraph describes how the company manages cybersecurity risks through an outsourced IT firm that monitors threats and assesses risks — this is the company's own risk management process, not oversight OF a vendor's cybersecurity posture. Per Rule 3, an external party hired to serve the company's security function is RMP, not Third-Party Risk. No specific facts from the IS list are present: the IT firm is unnamed, CFO is generic C-suite, 'IT Lead' is not a cybersecurity-specific title, and no frameworks, dates, tools, or numbers appear.

thinking:
Let me analyze this paragraph carefully.

Content: Describes a third-party IT firm that helps manage cybersecurity, reporting structure (IT Firm → IT Lead in finance/operations → CFO), and what the IT firm does (monitor, evaluate threats).

Category analysis:
- Third-party firm is central, but it's describing the company's risk management structure
- The IT firm is essentially functioning as the company's cybersecurity program (they're a small company outsourcing IT security)
- The paragraph describes how the company manages cyber risk through this third-party arrangement
- The reporting structure (IT Firm → IT Lead → CFO) is about how the company's risk management works

- The key distinction here is that the IT firm isn't being overseen for their own cybersecurity risk—they ARE the cybersecurity program itself. This is the company describing its own risk management process, just outsourced to a third party rather than managed in-house. So this falls under Risk Management Process, not Third-Party Risk.

Looking at the specificity now: the IT firm is unnamed, the "IT Lead" isn't a cybersecurity-specific role, the CFO is generic C-suite, and there are no named frameworks, tools, dates, or numbers. Even though the organizational structure of having an outsourced firm report through a finance/operations employee is somewhat distinctive, none of these details meet the specificity threshold—they're all generic descriptors. This qualifies as Generic Boilerplate.


reasoning: The paragraph is generic IT-dependence language ('our business depends on the proper functioning of our information technology platform') with no substantive cybersecurity disclosure — no processes, frameworks, governance structure, or materiality assessment. It acknowledges cybersecurity is important but discloses nothing about what the company actually does.

thinking:
Let me analyze this paragraph.

This is generic language about the importance of cybersecurity and IT dependence. No specific processes, no named frameworks, no specific roles, no materiality assessment. It's general business language about IT importance.

This is None/Other - generic IT-dependence language with no substantive cybersecurity disclosure.


reasoning: The paragraph describes how the cybersecurity team reports to the Audit Committee, including briefing cadence and topics covered — this is about the oversight/reporting structure (how information flows to the board), making it Board Governance. No firm-specific facts from the IS list: 'Audit Committee' is generic, 'quarterly' is a generic cadence, and 'third-party assessments' are unnamed, yielding Generic Boilerplate.

thinking:
Classify this paragraph.

The paragraph describes how the cybersecurity team reports to the Audit Committee - briefing cadence, topics covered. This is about the oversight/reporting structure, how information flows to the board. Purpose = describing oversight structure → Board Governance.

Specificity: Let me check facts.
- "Audit Committee" - generic, NOT list
- "quarterly cybersecurity reports" - generic cadence
- "cybersecurity team" - generic
- "third-party assessments" - unnamed

No named standards, no firm-specific facts from the IS list.

This lands in Generic Boilerplate.


reasoning: The paragraph's primary content describes the company's cyber risk management process — prevention, detection, mitigation, investments in IT protection, and detection/response capabilities. Applying the person-removal test: removing the SVP Operations and VP Deputy General Counsel attributions leaves a coherent process description, so this is RMP, not Management Role. For specificity, 'SVP, Operations' is not a cybersecurity-specific title (not CISO/CTO/CIO/VP of IT Security), 'Vice President, Deputy General Counsel' is a legal role (General Counsel is on the NOT list), and 'CEO' is generic C-suite. No named frameworks, tools, dates, or quantified facts appear.

thinking:
Let me analyze this paragraph carefully.

Content Category: The paragraph describes cybersecurity processes (prevent, detect, mitigate, remediate) and mentions who manages them (SVP Operations, VP Deputy General Counsel). Let me apply the MR vs RMP decision chain.

Step 1 - Subject test: "we maintain a cyber risk management process" - the subject is the company/process. But then it names roles. Continue to Step 2.

Step 2 - Person-removal test: Remove "managed by our Senior Vice President, Operations ("SVP, Operations") who reports to our CEO.

The SVP, Operations works with the Vice President, Deputy General Counsel ("Legal")" — the remaining text still describes the cyber risk management process, investments in IT protection, and detection/response capabilities, so this is clearly a Risk Management Process disclosure. The roles are just attribution details.

Now checking specificity: "Senior Vice President, Operations" isn't a cybersecurity-specific title like CISO or VP of Security, so this doesn't meet the IS list criteria.  "Vice President, Deputy General Counsel" is also general corporate, not cybersecurity-focused. The General Counsel role is actually on the NOT list. There are no named frameworks, specific dates, tools, or numbers either. This looks like generic boilerplate without the specificity needed for the IS category.


reasoning: Applying the person-removal test: removing the Director of IT's title and 40 years of experience, the paragraph still coherently describes what the CSIRT does — executing risk assessments, reviewing incident response plans, compliance, training, and risk management. The dominant content is the team's process activities, not the person's credentials. The Director of IT (cybersecurity-specific title) and 40 years of experience are firm-specific facts, but only one QV-eligible fact (years of experience), so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content category: The paragraph describes a Director of IT leading a CSIRT team and what they do (risk assessment, management processes, incident response plan, compliance, training). Let me apply the MR vs RMP decision chain.

Step 1 - Subject test: The grammatical subject is the CSIRT (led by the Director of IT). It's a mix of person and program.

Step 2 - Person-removal test: Remove "Led by our Director of Information Technology and Security with over 40 years of experience in Information Technology" - the remaining text describes what the CSIRT does: reviews cybersecurity initiatives, incident response plan, compliance, training, risk management.

The core content is about the CSIRT's processes and responsibilities, so this looks like a Risk Management Process. But I need to weigh the person-specific details—the Director's 40 years of experience is notable. Looking at the structure, the person information is really just an introductory clause, while the bulk of the paragraph focuses on what the team actually does. Even if I remove the Director and their credentials, the paragraph still makes sense and describes the same processes. That suggests the person element is secondary to the process description, so this should be categorized as Risk Management Process. The team identifier and role are specific to this organization, but only the "40 years" qualifies as a quantified fact. Since I need two QV-eligible items for that classification and I only have one, this falls under Firm-Specific.

fact: CSIRT (cross-functional team)


reasoning: This is a governance-chain paragraph describing how information flows upward: management monitors cybersecurity → reports to the IT Steering Committee quarterly → summary to the full Board annually. The communicative purpose is describing the oversight/reporting structure, making it Board Governance. The Information Technology Steering Committee is a named non-generic committee (distinct from the standard Audit Committee), qualifying as a firm-specific fact. Generic cadences ('at least quarterly,' 'at least annually') do not count toward specificity.

thinking:
Let me analyze this paragraph.

The paragraph describes how members of management monitor cybersecurity incidents and report to the IT Steering Committee quarterly and to the Board annually. This is about the governance/oversight structure - how information flows upward from management to committee to board.

Category: This is a governance-chain paragraph. The purpose is describing the reporting structure - management reports to IT Steering Committee quarterly, then to the Board annually. Per Rule 2, governance-chain paragraphs are Board Governance when the purpose is describing oversight/reporting structure.

Wait - let me reconsider. The subject is "these members of management" and it describes what they do (monitor, manage, report).

But the PURPOSE is describing the oversight structure - how information flows from management → IT Steering Committee → Board. This is Board Governance.

For specificity, the "Information Technology Steering Committee" is a named non-generic committee, so that's a firm-specific fact. The quarterly and annual cadences are generic reporting frequencies, not specific. So this lands as Board Governance, Firm-Specific.


reasoning: This is a governance-chain paragraph describing how the board-approved IT Steering Committee provides oversight, its composition (CIO, CTO, ISO), meeting cadence, and how the ISO reports key issues back to the board. The communicative purpose is describing the oversight structure—how information flows from the management committee to the board—making it Board Governance rather than Management Role (no personal qualifications) or RMP (the focus is governance structure, not the processes themselves). Specificity is Firm-Specific due to the named non-generic committee and multiple cybersecurity-specific roles, but no QV-eligible hard facts (named roles don't count toward the two-fact QV threshold).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the Information Technology Steering Committee - its approval by the board, its composition, its meeting cadence, and its reporting to the board. Let me apply the decision rules.

**Category Analysis:**

This paragraph spans multiple layers:
- Board approved the committee
- The committee itself (IT Steering Committee) provides oversight
- Named officers chair/participate (CIO, CTO, Information Security Officer)
- The ISO reports to the board

Purpose test: The paragraph describes the governance/oversight STRUCTURE - how the IT Steering Committee works, who sits on it, what it oversees, and how information flows to the board. This is a governance-chain paragraph (board → committee → officers → program).

Per Rule 2, governance-chain paragraphs are "almost always Board Governance." The purpose is describing oversight structure, not the qualifications of the people involved.

But I need to reconsider - this is actually a management committee that the board approved, not a board committee itself. The committee is chaired by managers like the CIO and CTO, with the ISO reporting summaries back to the board. So the governance chain runs from the board down through this management committee to the officers. The primary focus is on the management committee's structure and role, not the board's direct actions.

Looking at the board-line test: the paragraph mentions the board's approval at the start and the ISO's reporting to the board at the end, but the bulk of it describes the IT Steering Committee's composition, meeting frequency, and oversight function. The communicative purpose is really about how this oversight structure works - who's involved, how often they meet, and how information flows back to the board. That's Board Governance.

Now checking the specificity: the committee itself is named, and the roles listed - CIO, CTO, Information Security Officer - are all firm-specific positions on the IS list. There are no quantifiable metrics like dates, dollar amounts, or headcounts, and "quarterly" is just a generic cadence. So this lands as Firm-Specific with multiple named roles and a named committee.

fact: Chief Information Officer

fact: Chief Technology Officer

fact: Information Security Officer


reasoning: The paragraph contains an explicit backward-looking materiality assessment ('such risks have not materially affected us, including our business strategy, results of operations or financial condition'), which per Rule 6 triggers Strategy Integration. The cross-reference to Item 1A and generic mention of past threats/breaches are subordinate to the materiality conclusion. No firm-specific facts from the IS list are present — 'malware and computer virus attacks' and 'third-party service providers' are generic language.

thinking:
Let me analyze this paragraph.

The paragraph contains:
1. A materiality assessment: "such risks have not materially affected us, including our business strategy, results of operations or financial condition" — this is a backward-looking materiality conclusion → Strategy Integration per Rule 6
2. Brief mention of past threats/breaches
3. A cross-reference to Item 1A

The dominant content is the materiality assessment. The cross-reference is noise per the codebook.

Category: Strategy Integration (backward-looking materiality assessment)

Specificity: The materiality language is boilerplate. No named standards, no firm-specific facts from the IS list.

This falls into Generic Boilerplate with a Specificity score of 1.


reasoning: This is generic risk-factor language about cybersecurity threats that could appear in any company's filing. It does not describe any process, governance structure, or materiality assessment — it is boilerplate risk warning language ('could adversely affect,' 'could result in') without a materiality conclusion. No named frameworks, roles, dates, or firm-specific details.


reasoning: This is a governance-chain paragraph describing how oversight flows from the Board → management → Principal Accounting Officer → Audit Committee. The communicative purpose is describing the oversight structure, making it Board Governance despite touching on management responsibilities and a negative incident assertion. The specific fiscal years (2023, 2022, 2021) for the no-incidents claim are firm-specific dates, but there is no second QV-eligible hard fact (Audit Committee is generic, 'at least annually' is a generic cadence, '100% independent' is standard governance disclosure).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Board oversight of risk management including cybersecurity
2. Management's responsibility for cybersecurity risks
3. Principal Accounting Officer directing cybersecurity programs, receiving reports from consultants
4. Reporting chain to audit committee and board
5. No significant incidents in fiscal 2023, 2022, or 2021
6. Annual presentation to Audit Committee

This is a governance-chain paragraph spanning board → management → officer → committee. The PURPOSE is describing the oversight structure - how information flows, who is responsible at each level, reporting cadence.

Category: This spans Board Governance, Management Role, and has a brief incident/materiality note.

The dominant purpose here is the governance and oversight structure itself—the board sits at the top and bottom of the reporting chain, with management and officers flowing information upward. The negative assertion about no significant incidents is really just supporting detail within that governance framework rather than a standalone materiality assessment. This is clearly Board Governance.

Now I'm checking what counts as specific facts versus generic language. The fiscal years mentioned are concrete dates that appear on the IS list, but titles like "Principal Accounting Officer" and "audit committee" are standard corporate terminology, not cybersecurity-specific roles. The "100% independent" composition detail and "at least annually" cadence are more about the structure itself than firm-specific facts.

For the quantifiable verification threshold, I need at least two hard verifiable facts. The specific fiscal years could count as one category, but I'm not finding a second distinct verifiable fact that would push this into QV territory—the independence percentage and the Principal Accounting Officer's involvement are more governance structure than concrete, measurable facts.

fact: fiscal 2023, 2022, or 2021 (no significant incidents)


reasoning: The paragraph describes the SVP of IT's responsibility to brief senior management on cybersecurity matters — this is about the management reporting structure (who briefs whom), not about the person's credentials or about a specific process/tool/framework. Applying the person-removal test, removing the SVP of IT leaves a thin description of briefings that lacks coherence as a standalone process description; the role and its reporting relationship ARE the content. SVP of IT matches 'VP of IT/Security' on the IS list as a cybersecurity-adjacent leadership title, yielding one firm-specific fact. No second QV-eligible fact (cadence is 'periodic' = generic).

thinking:
Let me analyze this paragraph.

Content category: The paragraph describes the SVP of IT providing briefings to senior management. The purpose is describing information flow/briefing structure. But the recipient is "senior management team," not the board. This is about management-level briefing cadence.

Let me apply the decision rules:
- Subject: SVP of IT (a person/role)
- Step 2 (person-removal test): Remove "The SVP of IT" → "provides periodic briefings for our senior management team on cybersecurity matters, including the prevention, detection, mitigation, and remediation of cybersecurity incidents and cybersecurity threats." This still describes a process/briefing activity.

The key question is whether this focuses on the person or the process. Removing the SVP of IT leaves a description of the briefing activity itself—how information flows to senior management on cybersecurity. There are no qualifications or credentials mentioned, so this is really about the management reporting structure and oversight process, not about the individual's background. This falls under management's cybersecurity oversight role rather than a specific person's qualifications. I'm applying the person-removal test to see if this stands as a process description on its own, but the core content is really about management reporting lines and who briefs whom on cybersecurity matters—that's a management responsibility structure, not a risk management process. I'll categorize this as Management Role. I'm settling on Management Role because this describes the SVP of IT's function within the management structure and information flow, not a cybersecurity process itself. For specificity, SVP of IT is close enough to the IS list's "VP of IT/Security" to count as a firm-specific fact, though I'm noting the distinction between what the IS and NOT lists include—the role title qualifies, but generic terms like "periodic" and "senior management team" don't add specificity. I need to see the next thinking to rewrite it. Could you provide the next thinking chunk that follows the current rewritten thinking you've shared?

fact: SVP of IT


reasoning: This paragraph is generic risk language describing hypothetical consequences of a data breach (reputational harm, legal liabilities). It contains no substantive cybersecurity disclosure — no process, framework, governance structure, materiality assessment, or incident description. It reads as a generic risk factor that could apply to any company unchanged.

thinking:
Classify this paragraph.

This is generic risk language about data breaches. No materiality assessment, no specific processes, no firm-specific details. It's a generic consequence statement about what could happen.

Category: None/Other - This is generic risk language, not substantive cybersecurity disclosure. No process, no governance, no incident, no materiality assessment.

Specificity: Generic Boilerplate


reasoning: This is generic risk warning language about potential operational disruption from cybersecurity incidents ('could disrupt'). It contains no substantive cybersecurity disclosure — no process, governance, incident, or materiality assessment. The speculative 'could' language is boilerplate risk factor content, not an SEC materiality conclusion. None/Other with no specific facts.

thinking:
Classify this paragraph.

This is generic risk language about potential operational disruption from cybersecurity incidents. No materiality assessment, no specific facts, no named standards. It's a generic risk warning ("could disrupt") not a materiality assessment. No substantive disclosure content.

This is None/Other - it's generic risk language about potential consequences, not describing any program, governance, or making a materiality assessment.


reasoning: The paragraph's primary purpose is identifying WHO is responsible for cybersecurity — the Senior Director of HR & Infrastructure, CFO, General Counsel, and their collective Rapid Response Team — along with describing the team's composition and reporting lines. While the final sentence describes reporting to the audit committee and board (governance chain), the bulk of the paragraph is about the management layer's identity and structure. No specific credentials, years of experience, or certifications are given, so it narrowly favors MR over BG. The 'Rapid Response Team' is a named internal program providing firm-specific detail, but no second hard verifiable fact exists for QV.

thinking:
Let me analyze this paragraph carefully.

This is a complex paragraph spanning multiple categories. Let me apply the decision rules.

The paragraph covers:
1. Named roles responsible for cybersecurity (Senior Director, Human Resources & Infrastructure; CFO; General Counsel)
2. Third-party partnership (outside IT and cybersecurity consulting firm)
3. A named internal program (Rapid Response Team under Incident Response Policy)
4. Team composition and purpose
5. Reporting structure to audit committee and board

Let me apply the category decision rules:

**Purpose test:** What is this paragraph's primary communicative purpose? It describes WHO is responsible (roles), how they're organized (Rapid Response Team), and how information flows upward (reporting to audit committee and board). This is a governance-chain paragraph.

The paragraph is fundamentally about the management structure—which roles are responsible, what team they form, and how oversight flows to the audit committee and board. This is clearly a governance-chain paragraph describing the oversight structure. The governance structure with reporting to the audit committee and board reinforces this is about management roles and organizational hierarchy. The specific position title and team composition are the core content here, even though qualifications are mentioned only generically. This is clearly Management Role—it's fundamentally describing who holds responsibility, who they collaborate with, and how the reporting chain flows upward. The "Senior Director, Human Resources & Infrastructure" title doesn't match the standard cybersecurity roles on the IS list, so it's more of a generic corporate position. The "Rapid Response Team" under incident response could be a named internal program worth flagging, though "Incident Response Policy" itself is fairly generic. The consulting firm reference is unnamed, so that doesn't qualify. "Rapid Response Team" is specific enough as a named internal program to qualify as firm-specific, and while the HR & Infrastructure director title isn't a cybersecurity-specific role, it does reveal something distinctive about how this company structures its security leadership. There aren't enough hard verifiable facts like dates or dollar amounts to meet the QV threshold, so I'm classifying this as Management Role, Firm-Specific.

fact: Senior Director, Human Resources & Infrastructure has primary cybersecurity responsibility


reasoning: The first sentence is a backward-looking materiality assessment ('not aware of any risks from cybersecurity threats that have materially affected the Company, including our business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration. The cross-reference to Item 1A is noise and does not override the materiality conclusion. No specific facts remain after filtering — boilerplate materiality language used identically across thousands of filings.

thinking: Materiality assessment + cross-reference. The first sentence is a backward-looking materiality assessment ("not aware of any risks... that have materially affected"). Per Rule 6, this is Strategy Integration. The cross-reference is noise.


reasoning: The paragraph describes the governance chain: management and BDT & MSD evaluate risks, the CTO periodically reports to the board, and the reports cover controls, third-party oversight, and materiality evaluation. The primary purpose is describing how cybersecurity information flows upward to the board — a classic oversight/reporting structure paragraph. The CTO (a cybersecurity-specific title on the IS list) is the intermediary, not the focus. One firm-specific fact (CTO role) but no second QV-eligible hard fact, so Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes evaluation of cybersecurity risks by management and BDT & MSD, the CTO reporting to the board, and what those reports include.

Category analysis:
- The paragraph describes a governance chain: management evaluates risks → CTO reports to board → reports include overview of controls, third-party oversight, materiality evaluation
- The purpose is describing oversight structure and how information flows to the board
- Board is the recipient of reports, CTO is the intermediary
- Per Rule 2, governance-chain paragraphs are Board Governance when the purpose is describing oversight/reporting structure

- This is Board Governance

For specificity, I'm checking what counts as firm-specific facts. The CTO title appears on the IS list, so that's one firm-specific detail. BDT & MSD is mentioned as an entity, but it seems to be the external manager rather than a third-party cybersecurity firm. There are no specific dates, dollar amounts, headcounts, or named tools, so the only firm-specific fact here is the CTO reference.

Looking at QV eligibility, the CTO is a named role but doesn't qualify as a QV-eligible fact. So I'm left with just one firm-specific fact total.

fact: BDT & MSD CTO


reasoning: The paragraph's primary content is about the management team's qualifications and experience ('prior experience selecting, deploying, and overseeing cybersecurity technologies, initiatives, and processes'). Applying the three-step test: Step 1 — management team is the subject, proceed to Step 2. Step 2 — removing the management team's experience and role, the remaining content (third-party providers, threat intelligence, Audit Committee) is thin and fragmented; the paragraph is fundamentally about who is responsible and their qualifications. Step 3 confirms with 'prior experience' language. The Audit Committee mention is a brief coda, not the dominant topic. No cybersecurity-specific titles (CISO, CIO, etc.), no named individuals, no named frameworks, no specific dates or numbers — all references are generic ('management team,' 'Audit Committee,' unnamed third parties).

thinking:
Let me analyze this paragraph.

Content: Describes management team's responsibility for cyber risk management program, mentions third-party IT providers, management's experience, and Audit Committee oversight.

Category analysis:
- Management team is the subject, describing their responsibilities and experience
- "prior experience selecting, deploying, and overseeing cybersecurity technologies" - this is about the management team's qualifications/experience
- Audit Committee mention at the end is brief

Step 1 (Subject test): Management team is the subject. Continue to Step 2.
Step 2 (Person-removal test): Remove management team references and experience.

What remains? Third-party providers help with cyber risk management program, prevention/detection/mitigation of incidents, threat intelligence, external consultants, Audit Committee oversight. There's still some content but the core of the paragraph is about management's role and experience.

Actually, let me reconsider. The paragraph has two main parts:
1. Management team's responsibility for the cyber risk management program (describing what the program does - prevention, detection, mitigation, remediation)
2. Management team's prior experience with cybersecurity technologies

The second part is about qualifications ("prior experience selecting, deploying, and overseeing cybersecurity technologies"). Step 3: Yes, experience is mentioned.

Now I'm reconsidering whether the paragraph's primary focus is on management's qualifications or on the actual cyber risk management program itself. The program description—prevention, detection, mitigation, remediation—seems substantial, but it's framed entirely through management's responsibility for it. The experience component is definitely a qualification element that would trigger the exclusion criteria.

Looking at the specificity: "management team" is generic without a specific cybersecurity title, "Audit Committee" is generic, and the third-party providers aren't named. There are no frameworks, dates, individuals, or specialized titles mentioned. This all points toward Management Role as the category, since the paragraph is fundamentally about who's responsible and what they've done before, not about specific governance structures or named expertise.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of cybersecurity risks arising from the Fund's use of third-party service providers, making Third-Party Risk the dominant category. The specific departmental composition (risk management, legal, IT, and compliance personnel of the Investment Adviser) used to oversee these third-party risks qualifies as a firm-specific team composition fact, lifting specificity above Generic Boilerplate. CCO is not a cybersecurity-specific title per the IS list.

thinking:
Let me analyze this paragraph.

The paragraph discusses how the Fund relies on third parties and how it oversees cybersecurity risks from those third parties. It mentions the CCO and various personnel of the Investment Adviser.

Content Category: This is about oversight of third-party cybersecurity risks. The central topic is managing risks from third-party service providers. But let me think more carefully...

The paragraph has two parts:
1. The Fund uses third-party service providers
2. The Fund relies on CCO and Investment Adviser personnel to identify and oversee risks from cybersecurity threats associated with those third parties

The central topic is oversight of third-party cybersecurity risks.

Looking at this more carefully, the entire paragraph centers on how the Fund oversees external parties' cybersecurity risks through its CCO and Investment Adviser personnel, making this clearly a Third-Party Risk category rather than just a component of a broader risk management process.

For specificity, the CCO title alone isn't cybersecurity-specific, but the paragraph does identify a concrete team composition—"risk management, legal, information technology, and compliance personnel"—which matches the IS list's criteria for specific departmental compositions. That single concrete fact qualifies this as Firm-Specific.

fact: Relies on risk management, legal, information technology, and compliance personnel of the Investment Adviser


reasoning: This is a governance-chain paragraph describing oversight structure: Board → Audit Committee → SVP, Head of Legal and Compliance → back to Audit Committee → Board. The purpose is describing how cybersecurity oversight flows, not the person's qualifications. The SVP, Head of Legal and Compliance is not a cybersecurity-specific title (it's a generic corporate/legal role like General Counsel), 'Audit Committee' and 'Board of Directors' are on the NOT list, and 'quarterly' is a generic cadence — no IS-list facts remain after validation.

thinking:
Let me analyze this paragraph from Talis Biomedical Corp's 10-K filing.

This is a governance-chain paragraph spanning board → committee → officer → program. Let me apply the decision rules.

**Category Analysis:**

The paragraph describes:
1. Board focus on cybersecurity
2. Audit Committee has oversight responsibility
3. SVP, Head of Legal and Compliance - responsibilities and reporting structure
4. Quarterly reporting to Audit Committee
5. Audit Committee reports to full Board

This is a governance-chain paragraph. The PURPOSE is describing the oversight structure - how information flows from the SVP up to the Audit Committee and then to the Board. Per Rule 2, governance-chain paragraphs are almost always Board Governance.

The SVP role is presented as part of the reporting chain rather than highlighting individual qualifications or background, and the title itself—Head of Legal and Compliance—is a general corporate position, not a cybersecurity-specific role like CISO or CIO. Combined with the explicit mention of Audit Committee and Board of Directors, both on the NOT list, this confirms Board Governance classification.


reasoning: Applying the person-removal test: removing CCO, COO, and CISO references leaves a coherent description of an internal working group implementing a program to protect systems, monitor threats, and respond to incidents. The paragraph is about the function (program activities, monitoring, prevention, detection, remediation) rather than the people's qualifications. The Board mention at the end is subordinate — the primary content is the management-level program operation. CISO is a cybersecurity-specific title on the IS list, giving one firm-specific fact; CCO and COO are generic C-suite titles on the NOT list.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes an internal working group at the Adviser level that includes CCO, COO, and CISO. It describes what this group does (implement a program to protect systems, respond to incidents) and how the CISO and senior management monitor and report to the Board.

Category analysis:
- The paragraph spans multiple layers: it mentions the Board (reporting), management roles (CCO, COO, CISO), and process (program to protect systems, incident response).
- Primary purpose: describes the management structure and how the working group operates, with reporting to the Board mentioned at the end.
- Applying the person-vs-function test: Remove the named roles (CCO, COO, CISO) - would it still be coherent? "The Adviser has established an internal working group that includes relevant representation from senior management who work collaboratively to implement a program designed to protect..." - Yes, it still describes a process.

- The core focus is really on the organizational structure and how oversight flows from the working group through senior management up to the Board. The governance chain matters here - it's not just about the program itself, but who's accountable and how information moves through the hierarchy. The Board reporting clause isn't incidental; it's part of the governance framework being described. The core of this is really about the working group implementing a cybersecurity program, so it's Risk Management Process rather than Board Governance—the Board reporting is just mentioned in passing. The only specific detail that qualifies is the CISO title, which is on the information security list, making this Firm-Specific with just that one concrete fact.

fact: CISO is part of the internal working group


reasoning: Applying the MR vs RMP decision chain: Step 1 — management team/COO as subject, continue. Step 2 — removing the role references, the paragraph still describes program responsibilities (assessing risks, managing program, supervising consultants), so it stands as a coherent process description. Step 3 — no qualifications, certifications, experience, or career history mentioned → Risk Management Process. COO is generic C-suite (NOT list), 'external cybersecurity consultants' are unnamed, and no frameworks or firm-specific facts are present, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content category: The paragraph mentions management team and COO responsible for cybersecurity. Let me apply the MR vs RMP decision chain.

Step 1 — Subject test: "Our management team, including our COO" is the subject. Person/role as subject → signal, continue to Step 2.

Step 2 — Person-removal test: Remove "Our management team, including our COO" → "is responsible for assessing and managing our material risks from cybersecurity threats. The team has primary responsibility for our overall cybersecurity risk management program and supervises our retained external cybersecurity consultants." This still describes responsibilities and program oversight.

Step 3 — The paragraph focuses on responsibility assignments and what the management team oversees, with no mention of credentials, certifications, or personal qualifications. When I remove the people, what remains is a description of program responsibilities and oversight functions, which points toward Risk Management Process rather than Management Representation.

But I need to check the codebook more carefully. Management Role requires the paragraph to actually describe who the person is, and here we only have responsibility assignment. The COO is mentioned but without any qualifications, and "external cybersecurity consultants" are generic unnamed entities. "Material risks" is standard boilerplate language.

Looking at specificity: COO falls under the NOT list as generic C-suite, and there are no named standards or specific facts from the IS list. This is generic boilerplate with specificity level 1.