reasoning: The paragraph's purpose is describing the oversight/reporting structure: how information flows from the IT team up to the Audit Committee. Per the board-line test, governance-chain paragraphs describing who reports to the board are Board Governance. 'Manager of Information Technology' is a generic IT title (akin to 'IT Manager' on the NOT list, not a cybersecurity-specific role like CISO/CIO), 'Audit Committee' is standard governance, and 'periodically' is a generic cadence — no specific facts survive the validation filter.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a governance/reporting structure: Manager of IT reports to Audit Committee, Audit Committee receives reports from IT team on cybersecurity risks.

Category analysis:
- The purpose is describing oversight structure - how information flows to the board committee
- "Manager of Information Technology" reports to Audit Committee - this is a governance chain
- Audit Committee receives reports - board committee is receiving oversight information
- Per Rule 2, governance-chain paragraphs are almost always Board Governance

The paragraph's communicative purpose is describing the oversight/reporting structure. → Board Governance

Now I'm checking the specificity of the language used. The title "Manager of Information Technology" is too generic—it's not a specialized cybersecurity role like CISO or CIO. "Audit Committee" is explicitly listed as a non-specific term, and "periodically" is vague without concrete dates or metrics. There are no named frameworks, specific numbers, or detailed facts that would elevate this beyond generic boilerplate language. → Generic Boilerplate


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: The paragraph contains a generic, hypothetical risk warning ('If we were to experience... may have an adverse effect') which is speculative boilerplate, not a materiality assessment (no backward-looking conclusion, no 'reasonably likely' SEC qualifier). The second sentence is a cross-reference to Item 1A Risk Factors. Neither component constitutes substantive cybersecurity disclosure.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. "If we were to experience a material cybersecurity incident in the future, such incident may have an adverse effect..." - This is a generic risk warning using "may have an adverse effect" - conditional/speculative, not a materiality assessment.
2. Cross-reference to Risk Factors.

Per Rule 6: "could have a material adverse effect" type language is speculation, not an assessment. The test is whether the company is STATING A CONCLUSION about materiality. "If we were to experience... may have an adverse effect" is speculative, not a conclusion.

The cross-reference just directs readers elsewhere without actually making any substantive assessment, so this falls into the None/Other category—it's just a generic risk warning with no real disclosure.


content_category: Strategy Integration

reasoning: The paragraph contains a forward-looking materiality assessment using the SEC's 'reasonably likely to materially affect' qualifier, connecting cybersecurity to business strategy, results of operations, and financial condition. Per Rule 6 and Case 9, this is Strategy Integration at Specificity 1 — it's boilerplate language that appears across thousands of filings with no firm-specific content.


content_category: Board Governance

category_confidence: medium

specificity_confidence: medium

reasoning: This is a governance-chain paragraph describing how oversight flows from the Board → Audit Committee/CFO → Director of IT → team. The communicative purpose is the delegation and oversight structure, making it Board Governance even though management personnel appear as subjects in later sentences. The mention of a 'certified information system security professional' (i.e., CISSP holder) on the team is a firm-specific certification claim, but it is the only IS-list fact, so specificity is Firm-Specific rather than Quantified-Verifiable. 'Director of IT' is generic IT leadership per the NOT list, 'Audit Committee' and 'CFO' are standard governance terms, and 'many years of experience' is a vague quantifier.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a governance chain: Board → Audit Committee/CFO/IT resources → Director of IT → team. Let me apply the decision rules.

**Content Category:**

This is a governance-chain paragraph spanning board oversight down to management details. Let me apply Rule 2 (Board vs Management):

The paragraph starts with Board oversight, delegates to Audit Committee/CFO/IT, then describes the Director of IT and team composition including a CISSP holder.

Purpose test: The paragraph describes the oversight STRUCTURE - how responsibility flows from board down through the organization. But it also includes details about the team (certified CISSP professional, years of experience).

The opening frames this as governance with the Board's delegation of oversight responsibility, establishing the structural flow from board through committee to officer to team. The team qualifications are presented as part of this governance chain rather than as standalone management details. Per the codebook, governance-chain paragraphs describing how oversight flows through the organization are classified as Board Governance, even when they extend down to team composition and credentials.

Now I'm checking whether the specific roles and qualifications count as distinct facts. The Director of IT is a generic IT leadership title, not cybersecurity-specific, so it doesn't meet the specificity threshold. The Audit Committee and CFO are also generic governance roles. The CISSP certification is the only specific credential mentioned, but I need to verify whether it's being presented as a distinct fact or simply as part of the governance structure description. I've identified one verifiable fact here—the CISSP certification reference—but I need at least two QV-eligible facts to classify this as QV. Since there's only one, this falls under Firm-Specific.

fact: certified information system security professional (CISSP) on the IT team


content_category: Risk Management Process

reasoning: Applying the person-removal test: removing the named roles (CTO, CAO/GC, CCO) leaves a coherent process description — the team maintains the cybersecurity program, monitors trends, and oversees training. The paragraph is about what the program/team does, not about who these individuals are (no credentials, experience, or career history). The specific team composition including the CTO (a cybersecurity-specific title per the IS list) makes it Firm-Specific, but no two QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content category: The paragraph describes a cybersecurity team composition and what the team does (maintains the program, monitors trends, oversees training).

Step 1 - Subject test: The Cybersecurity Team is the subject. It's a team/group, not a single person's credentials.
Step 2 - Person-removal test: Remove the named roles (CTO, CAO/GC, CCO/SRC). The remaining text: "Ladder leverages a senior cybersecurity team... comprised of... senior representatives from Ladder's outsourced technology firm.

The Cybersecurity Team maintains Ladder's cybersecurity program, which is designed to identify, detect and manage cybersecurity risks. The Cybersecurity Team monitors technology trends..." - still coherent as a process/program description.
Step 3 - No individual qualifications, certifications, experience years.

But wait - the paragraph's primary content is about the COMPOSITION of the team (who is on it) AND what the team does. The team composition is significant - it names specific roles. But the person-removal test suggests RMP since the process description stands alone.

Actually, let me reconsider. The first sentence is entirely about team composition - who comprises the Cybersecurity Team. That's organizational structure.

The remaining sentences describe what the team does (maintains program, monitors trends, oversees training). The dominant content is split between team composition and process activities. Removing the roles still leaves coherent process description, which points toward Risk Management Process classification.

Looking at specificity: the CTO is a cybersecurity-specific title from the IS list, making it firm-specific. The General Counsel falls under the NOT list as generic C-suite, and the Chief Compliance Officer is also on the NOT list. The named team composition including Legal, Compliance, and Finance equivalents represents firm-specific organizational structure. The CTO as a named role isn't QV-eligible, and there are no dates, dollar amounts, named firms, or specific tools mentioned—just the team structure itself.

fact: Chief Technology Officer (CTO) on the Cybersecurity Team

fact: Cybersecurity Team composed of CTO, Chief Administrative Officer/General Counsel, Chief Compliance Officer/Senior Regulatory Counsel, and outsourced technology firm representatives


reasoning: The paragraph is primarily generic risk acknowledgment language (susceptible to threats, could disrupt operations), but its closing statement—'committed to maintaining robust cybersecurity and data protection practices and continuously evaluate cybersecurity threats'—constitutes a minimal process claim, pulling it past the None/Other threshold per Rule 5. No named frameworks, roles, dates, or firm-specific facts are present, making it Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Generic risk language about cybersecurity threats, no specific processes, no materiality assessment, no named frameworks. It mentions threats (data breaches, ransomware, phishing), potential consequences, and a commitment to maintaining practices.

Category: This is generic risk language. No materiality ASSESSMENT (no "have not materially affected" or "reasonably likely to materially affect"). "Considering their immediate and long-term effects on our business strategy, operations, and financial condition" — this is describing what they do (evaluate threats considering effects), not stating a conclusion about materiality. No specific processes described.

The language about maintaining robust practices and continuously evaluating threats is so vague it could describe almost any company's approach—there's no real substance here beyond acknowledging that cybersecurity matters. The paragraph connects cyber risks to business impact but stops short of actually assessing whether those risks are material, making it mostly boilerplate risk acknowledgment rather than a genuine risk management process disclosure. The bulk of this paragraph is really about risk acknowledgment—they're susceptible to threats, threats could disrupt operations—rather than describing how they actually manage those risks. The brief mention of evaluating threats feels secondary to the main message. I'm reconsidering whether this is truly a Risk Management Process disclosure or just generic risk language that happens to mention cybersecurity, which would push it toward None/Other.

But looking at it again, the statement "we are committed to maintaining robust cybersecurity and data protection practices and continuously evaluate cybersecurity threats" does make claims about their approach, even if it's vague. That tips it toward RMP Specificity 1 rather than None/Other—they're disclosing that they have practices and evaluate threats, just in extremely generic terms without any real substance or detail.


reasoning: Applying the person-removal test: removing 'Director of Infrastructure' and replacing with 'the Company' leaves a coherent process description (monitoring, security measures, audits, incident response plan). The paragraph is about what the program does, not who the person is — no credentials, experience, or career history are provided. 'Director of Infrastructure' is not a cybersecurity-specific title on the IS list (it's a general IT/operations role), and no named frameworks, tools, dates, or quantified facts appear.

thinking:
Let me analyze this paragraph.

The paragraph mentions "Director of Infrastructure" repeatedly as the subject, but the content describes what the program/processes do - monitoring, security measures, audits, incident response plan. Let me apply the MR vs RMP decision chain.

Step 1 - Subject test: Person/role as subject → continue to Step 2.

Step 2 - Person-removal test: Remove "Director of Infrastructure" and replace with "the Company" - the paragraph still describes monitoring, security measures, audits, incident response. YES, it's coherent without the person. → Risk Management Process.

Step 3 not needed.

Content category: Risk Management Process

Now checking the specificity - "Director of Infrastructure" isn't a cybersecurity-specific role like CISO or Director of IT Security would be, so it doesn't match the IS list. The paragraph also lacks any named frameworks, specific dates, tools, or metrics - just generic descriptions of standard practices. This falls into Generic Boilerplate.


reasoning: This is a governance-chain paragraph describing how the Audit Committee exercises oversight via COO briefings, ongoing dialogue, strategic decision participation, and annual program reviews. The purpose is describing the oversight structure (who reports to whom, what topics are covered, how the committee is involved), making it Board Governance per Rule 2. For specificity, COO is generic C-suite (not on the cybersecurity-specific IS list), Audit Committee is on the NOT list, 'Via Renewables, Inc.' is a company self-reference, and cadences like 'once per year' and 'annual' are generic — no firm-specific facts remain after filtering.

thinking:
Let me analyze this paragraph carefully.

This is a long paragraph about the relationship between the COO and Audit Committee regarding cybersecurity oversight.

**Content Category Analysis:**

The paragraph is titled "Management's Role Managing Risk" but let me look at the actual content:

- COO informs the Audit Committee on cybersecurity risks
- COO provides briefings to the Audit Committee
- Briefings cover landscape, initiatives, incidents, compliance
- Audit Committee and COO maintain ongoing dialogue
- Audit Committee participates in strategic decisions
- Audit Committee conducts annual review

This is a governance-chain paragraph: COO → Audit Committee → Board.

The structure here is describing how information flows from management through the Audit Committee to the board—the COO briefs the committee on cybersecurity matters, they maintain dialogue, and the committee participates in strategic decisions and conducts annual reviews. This is clearly Board Governance since it's about oversight mechanisms and the committee's role in governance.

**Specificity Analysis:**

The COO is a generic C-suite title rather than a cybersecurity-specific role like CISO or CIO, and the Audit Committee is also generic, so there aren't specific facts that would narrow the categorization further. The COO falls into the generic C-suite category that's explicitly excluded, so there are no firm-specific facts left to work with—this is just generic boilerplate.


reasoning: The paragraph contains a negative materiality assertion ('have not experienced any material cyber breaches'), which is the company stating a conclusion about whether cybersecurity has affected business outcomes — triggering Strategy Integration per Rule 6. The remainder about 'periodically reviewing policies and procedures' is generic RMP language but is subordinate to the materiality claim. No named standards, roles, dates, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: "have not experienced any material cyber breaches" = negative assertion with materiality framing → Strategy Integration per Rule 6. Plus "periodically reviewing our policies and procedures" which is generic RMP language.

The materiality assessment is the key substantive content here.

Specificity: No named standards, no firm-specific facts. "As of the date of this report" is not a specific date. Everything is generic boilerplate.


content_category: Management Role

reasoning: The paragraph's primary purpose is describing the management committee structure responsible for cybersecurity — its composition (CISO, CFO, COO, GC, CTO), responsibilities, and reporting/escalation lines. While it describes what the committee does, the dominant content is WHO comprises it and their organizational role. The board/Audit Committee appears only as an escalation target, not as the primary subject. Firm-Specific due to cybersecurity-specific roles (CISO, CTO), specific team composition, and a named internal program (InfoSec Roadmap), but no two QV-eligible hard facts.

thinking:
Let me analyze this paragraph carefully.

Content Category: This describes a management committee responsible for cybersecurity. Let me apply the decision rules.

The paragraph describes a committee comprising CISO, CFO, COO, General Counsel, and CTO. It describes what this committee does (oversees cybersecurity processes, approves policies, receives reports, assesses incidents, escalates to Board). It also mentions the InfoSec team supervised by the CISO.

Is this Board Governance, Management Role, or Risk Management Process?

The grammatical subject is a management committee (not the board). The board/Audit Committee is mentioned only as an escalation target.

So the core purpose here is defining the management-level oversight structure—who sits on the committee and what responsibilities they hold. The paragraph traces the governance chain from the committee through its responsibilities and up to the Board, making the oversight structure itself the primary focus rather than any single process. about the management committee structure and composition, not a governance process or framework. The key distinguishing factor is that removing the named roles significantly diminishes the content—the committee makeup is central to what's being described.

Looking at the specificity markers: CISO and CTO are cybersecurity-specific titles that qualify, while CFO, COO, and General Counsel are generic C-suite positions that don't. The InfoSec Roadmap is a named internal program, so it's not QV-eligible either. There are no dates, dollar amounts, headcounts, or named external firms to consider. This appears to be Management Role classification.

fact: Chief Information Security Officer

fact: Chief Technology Officer

fact: InfoSec Roadmap (named internal program)

fact: Committee comprising CISO, CFO, COO, General Counsel, and CTO


reasoning: The paragraph describes the governance chain: Director of IT reports to the audit committee (which oversees risk management including cybersecurity), and various officers participate in committee and board meetings. The communicative purpose is describing the oversight/reporting structure — how cybersecurity information flows upward to the board — making this Board Governance. No IS-list facts are present: 'Director of Information Technology' is a generic IT title (not cybersecurity-specific like CISO or Director of IT Security), and CPO/CLO/CFO/Audit Committee are all on the NOT list.

thinking:
Let me analyze this paragraph.

The paragraph describes a governance chain: Director of IT meets with CPO → reports to audit committee → audit committee oversees risk management → CFO, CPO, CLO participate in committee and board meetings.

Category: This is describing the oversight/reporting structure - how information flows from the Director of IT up through the audit committee to the board. The purpose is describing the governance chain. Per Rule 2, governance-chain paragraphs are almost always Board Governance.

Let me check: The paragraph describes who meets with whom, who reports to the audit committee, and who participates in audit committee and board meetings. This is oversight structure.

Board Governance. Now I'm checking the specificity of the roles and terms mentioned — Director of Information Technology is a generic IT title rather than a cybersecurity-specific one, and the other roles like Chief People Officer, Chief Legal Officer, and Chief Financial Officer are all standard C-suite positions. The audit committee, board of directors, and "periodically" are all generic governance terms without any named frameworks or specialized language.


reasoning: Governance-chain paragraph: Board → Audit Committee → CIO/HIS → cybersecurity program. Purpose is oversight structure, not person credentials. Two cybersecurity-specific roles (CIO, HIS) qualify as IS-list facts for Firm-Specific, but named roles are not QV-eligible, so specificity stays at Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

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

The paragraph describes:
1. Board's oversight supported by Audit Committee
2. CIO and Head of Information Security meet regularly to review risks
3. CIO and management meet with Audit Committee quarterly

Purpose test: This is describing the oversight/reporting structure - how information flows from management to the board/committee. The purpose is governance structure, not about who the people are (no credentials, experience, etc.).

Category: **Board Governance** - per Rule 2, governance-chain paragraphs are almost always Board Governance. The purpose is describing how oversight works.

Now I'm checking the specificity of the facts mentioned. The CIO and Head of Information Security are both cybersecurity-specific titles, so those count as IS facts. The Audit Committee and quarterly cadence are generic governance elements that don't qualify. Since I have at least one IS fact, this falls into Firm-Specific.

fact: Chief Information Officer (CIO)

fact: Head of Information Security (HIS)


reasoning: The paragraph describes how the ERM program incorporates cybersecurity risk and the organizational structure for managing it. Applying the person-removal test: removing the named roles (VP Internal Audit, CDIO, CISO), the paragraph still coherently describes the ERM program, risk categorization, and team structure — it's about the function, not the people. No qualifications, credentials, or career history are provided. Multiple firm-specific facts (CISO, CDIO, named GRC function) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the ERM program structure, naming specific roles and how they relate to cybersecurity risk management.

**Category Analysis:**

The paragraph describes:
1. ERM program with cybersecurity as a risk category
2. VP Internal Audit leads ERM
3. Process includes subject matter experts including cybersecurity leaders
4. Chief Digital and Information Officer supports the CISO
5. Information security team includes GRC function
6. Team collaborates on privacy and security governance

Applying the MR vs RMP three-step test:
- Step 1: Subject is "The Company" and "ERM program" initially, then shifts to roles

- Step 2: When I remove the specific titles and roles, the core message remains intact—the company has an ERM framework where cybersecurity is treated as a risk category, managed through a structured process involving various functional areas that work together on governance and risk oversight.
- Step 3: There are no qualifications, certifications, or career history mentioned.

This is fundamentally about the organizational structure and governance process for managing cybersecurity risk, where the roles serve to illustrate how that structure operates rather than to highlight individual credentials or backgrounds.

The "Chief Digital and Information Officer" title is more distinctive than "Vice President, Internal Audit," which is a standard function across most organizations. But even with those titles removed, the paragraph still conveys how the ERM program functions and how cybersecurity risk flows through the management structure.

→ **Risk Management Process**

Looking at the specificity now: CISO and CDIO are both named roles that appear on the IS list, and the GRC function is a named internal team. That gives us multiple firm-specific elements, though the named roles themselves don't count toward QV, and neither does the team composition. There aren't any hard verifiable facts like dates, dollar amounts, headcounts, or named external tools to push this toward QV.

fact: Chief Digital and Information Officer (cybersecurity-adjacent role overseeing CISO)

fact: Chief Information Security Officer (CISO)

fact: Governance, Risk, and Compliance (GRC) function within information security team


reasoning: The paragraph spans multiple topics but its dominant content is the company's risk management process — describing how cybersecurity is integrated into overall risk management and how the process identifies, prioritizes, and monitors risks. The board mention ('Our Board is responsible for overseeing risk management') is a single generic sentence subordinate to the RMP description. No named frameworks, no cybersecurity-specific roles, no firm-specific facts — all language is generic boilerplate that could appear in any filing.

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

The paragraph covers: data collection context, generic risk acknowledgment, board oversight mention, and risk management process description. It's a mixed paragraph.

Primary content: The paragraph starts with generic business context (data collection), then mentions board oversight briefly, then describes the risk management process in generic terms.

Category analysis:
- "Our Board is responsible for overseeing risk management" - brief board mention
- "Cybersecurity is an integral part of the Company's overall risk management program" - RMP
- "Our risk management process is designed to identify, prioritize, and monitor risks..." - RMP

The dominant content is clearly about the risk management process and program, with the board mention taking up just one sentence. Looking at the text distribution, the risk management process description occupies the most space, so this falls under Risk Management Process. There are no named frameworks, specific roles beyond a generic "Board" reference, or concrete facts from the information security list—it's all standard boilerplate language.


reasoning: The paragraph's core content is organizational: who runs the cybersecurity program (GIS team led by CISO with 20 years experience), committee structures (Enterprise Security Council with specific departmental composition, Enterprise Risk Council), and leadership qualifications (CEO's background as Deputy Secretary of Defense during 2018 DoD Cyber Strategy). While RMP elements bookend the paragraph (monitoring, controls), the dominant purpose is describing the people and management structure. QV is met with two hard verifiable facts: 'more than twenty years' of experience and the 2018 DoD Cyber Strategy reference (a verifiable historical role/date).

thinking:
Let me analyze this paragraph carefully.

This is a dense paragraph covering multiple topics. Let me identify the primary communicative purpose.

Content breakdown:
1. "We continuously monitor the cybersecurity landscape..." - RMP
2. "Our Global Information Security ("GIS") team has day-to-day responsibility..." - Named team/program
3. "This group is led by a Chief Information Security Officer ("CISO") with more than twenty years of audit and cybersecurity experience." - Management Role (person's qualifications)
4. "The CISO collaborates across the business, participates in internal audits, and is active in several leading industry groups..." - Mix of MR and RMP

5. "GIS receives and analyzes information..." - RMP
6. "An Enterprise Security Council comprised of GIS, Information Technology, Legal, Compliance, Internal Audit, and Enterprise Risk Management meets regularly..." - Management committee structure
7. "Significant risks are escalated to the Enterprise Risk Council which is chaired by our President and CEO, who was the Deputy Secretary of Defense during the development of the 2018 Department of Defense Cyber Strategy." - Management Role (person's background)
8. "We implement appropriate controls..." - RMP
9. "We evaluate our controls and systems against industry-recognized standards..." - RMP

The paragraph contains substantial MR content alongside RMP elements. The CISO's extensive background and the CEO's defense policy experience are key qualifications being highlighted, while the governance structure shows how security decisions flow through multiple committees up to executive leadership.

Applying the person-removal test, I can see that stripping out the specific credentials and named individuals still leaves a functional description of the monitoring processes and control evaluation. However, the paragraph's primary emphasis is clearly on establishing credibility through the people leading the program and the formal governance structure they've built. The organizational hierarchy and the individuals' qualifications are central to what's being communicated here. qualifications, the Enterprise Security Council and its composition, the Enterprise Risk Council and the CEO's background. The process elements are subordinate.

Applying the three-step test:
- Step 1: Mixed subjects (we, GIS team, CISO, Enterprise Security Council). Not decisive.
- Step 2: Remove all roles, titles, qualifications - "We continuously monitor... receives and analyzes information... meets regularly to discuss emerging cyber risks... We implement appropriate controls... We evaluate our controls." This is somewhat coherent but loses most of its substance. The paragraph is fundamentally about the organizational structure.
- Step 3: Yes - 20 years of experience, Deputy Secretary of Defense background.

→ Management Role

Specificity:
- CISO: named cybersecurity role ✓ IS
- "more than twenty years of audit and cybersecurity experience": specific number ✓ QV-eligible
- Global Information Security ("GIS"): named internal program with unique identifier ✓ IS
- Enterprise Security Council: named non-generic committee ✓ IS
- Composition: "GIS, Information Technology, Legal, Compliance, Internal Audit, and Enterprise Risk Management" ✓ IS (specific team composition)
- Enterprise Risk Council: named non-generic committee ✓ IS
- "Deputy Secretary of Defense during the development of the 2018 Department of Defense Cyber Strategy": specific background, specific date (2018)
- President and CEO: generic C-suite ✗ NOT

Two QV-eligible facts emerge: the twenty-plus years of experience and the 2018 DoD Cyber Strategy involvement, which pushes this toward Quantified-Verifiable classification.

fact: Global Information Security (GIS) team

fact: More than twenty years of audit and cybersecurity experience

type: quantified

fact: Enterprise Risk Council


reasoning: The paragraph identifies the DPIRC committee, its co-chairs (CCO and CIO), its departmental composition, and then devotes significant text to the CIO's qualifications (appointment year, 20+ years of experience). Applying the person-removal test: removing the CIO's credentials and the committee's named composition leaves only a generic ERM statement, so the paragraph is fundamentally about who these people are. Two QV-eligible hard facts: specific appointment date (2017) and specific years of experience (20+).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics: ERM integration, board oversight mention, the DPIRC committee, its composition, and the Vista CIO's qualifications.

Category analysis:
- Opens with cybersecurity as part of ERM and mentions Board/management focus
- Describes the DPIRC committee and its composition
- Ends with the Vista CIO's experience and qualifications

The dominant content is about WHO manages cybersecurity - the DPIRC committee composition and the CIO's qualifications. Let me apply the decision rules.

Board vs Management vs RMP:
- The board is mentioned briefly ("area of focus for the Board")

- The DPIRC is a named committee that oversees the processes
- The CIO's qualifications are described in detail

If I strip away the committee composition and CIO background, what remains is just a statement that cybersecurity is part of Vista's enterprise risk management. But the paragraph dedicates substantial space to the DPIRC's structure—its co-chairs and departmental representation—and the CIO's credentials, including their appointment date and two decades of experience. This emphasis on governance structure and leadership qualifications suggests the paragraph is fundamentally about management oversight rather than risk management processes themselves. I'm identifying two specific, quantifiable facts here: the 2017 appointment date and the 20+ years of experience. Both are concrete numbers that can be verified, so this qualifies as Quantified-Verifiable.

fact: Data Privacy and Information Risk Committee (DPIRC)

fact: Co-chaired by Vista CCO and Vista CIO

fact: Members from Information Security, Legal, and Human Resources departments

fact: Vista CIO appointed in 2017

fact: Over 20 years of cybersecurity, information security, and technology experience


reasoning: The paragraph identifies the cybersecurity sub-committee as the responsible body and emphasizes their qualifications (combined 45 years of experience, depth of expertise), which is MR-specific content per the Step 3 qualifications tiebreaker. The latter half describes their responsibilities (strategies, compliance testing, remediation, training), which is RMP-like, but the qualifications content is substantial enough to make this primarily about WHO these people are. Specificity is Firm-Specific: the cybersecurity sub-committee is a named non-generic committee (IS list), and 45 years is a specific number, but only one QV-eligible hard fact (the number), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph describes a "cybersecurity sub-committee" - their experience, expertise, and what they do. Let me apply the decision rules.

First, is this Board Governance, Management Role, or Risk Management Process?

The "cybersecurity sub-committee" - is this a board committee or a management committee? The paragraph says "Primary responsibility for assessing, monitoring and managing our cybersecurity risks rests with the cybersecurity sub-committee." This sounds like a management-level committee, not a board committee. There's no mention of "Board" or board-level oversight.

Applying the MR vs RMP three-step test:

Step 1 confirms the subject is the cybersecurity sub-committee. Step 2 is where I need to look carefully - if I strip away the roles and titles, what's left? The core activities are overseeing cybersecurity strategies, testing compliance with standards, remediating known risks, and leading employee training. That still reads as a coherent process. But the paragraph also emphasizes who they are - their combined 45 years of experience, their wealth of expertise, their in-depth knowledge. That's clearly Management Role content describing the qualifications of the people involved.

So this paragraph is actually mixing two categories: the qualifications and credentials of the committee members (Management Role), and the activities they perform (Risk Management Process).

The deciding factor is Step 3 - the explicit mention of "over a combined 45 years of experience" is a strong indicator of Management Role. Even though the paragraph describes what the committee does, the emphasis on their qualifications and experience tips this toward Management Role. The committee itself is a management structure responsible for cybersecurity, and the paragraph is establishing their credibility through their experience.

So Management Role is the right category. Now looking at specificity - "cybersecurity sub-committee" is a clear, specific designation of the responsible party.

For QV-eligibility, I'm checking what facts are specific enough. The "45 years of experience" is a concrete number, making it QV-eligible. The committee name is firm-specific but not a quantifiable fact. That gives me one QV-eligible fact, which means this falls into Firm-Specific.

fact: cybersecurity sub-committee

fact: over a combined 45 years of experience in cybersecurity


reasoning: This paragraph is generic risk warning language about potential consequences of cyber-attacks (disruption, reputation harm, litigation, costs). It contains no materiality assessment (no 'materially affected' or 'reasonably likely to materially affect'), no description of processes, governance, or incidents. It uses speculative 'could' language, which is boilerplate found in virtually any 10-K.


reasoning: The paragraph describes how the Cybersecurity Plan and IRT operate — deploying multidisciplinary teams, monitoring prevention/detection/mitigation/remediation, and implementing incident response. Applying the person-removal test: removing the named roles leaves a coherent process description (IRT coordination, program implementation, real-time monitoring, reporting). The brief board-reporting mention at the end is subordinate to the process focus. The named IRT with its unique abbreviation and the specific team composition qualify as firm-specific facts, but there are no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph.

Content Category: This describes the Cyber Incident Response Team composition, how it works, and the cybersecurity program processes. Let me apply the decision chain.

The paragraph describes:
1. The IRT composition (EVP of IT, CFO, COO, CLO, outside advisors)
2. How the EVP of IT coordinates with IRT to implement protection programs
3. Multidisciplinary teams deployed for threats
4. Monitoring and reporting to the Board

This is primarily about the company's internal cybersecurity processes - how the IRT works, what the Cybersecurity Plan contemplates, how teams are deployed, monitoring activities.

Now I'm testing whether removing the named roles and titles would affect the core meaning. The paragraph would still coherently describe the IRT structure, the Cybersecurity Plan, multidisciplinary team deployment, and the monitoring and reporting framework - so this is fundamentally about the risk management process rather than the individuals themselves. The Board reporting is mentioned but secondary to the process description.

Looking at specificity, the Cyber Incident Response Team is a named internal program with a unique identifier, which qualifies for the IS list. The Executive Vice President of Information Technology is an IT leadership role that maps to the VP of IT/Security category.

The generic C-suite titles like CFO, COO, and CLO don't meet the criteria, and "Cybersecurity Plan" lacks the unique identifier needed. The team composition does reference specific departments and roles that align with the IS list standards.

There aren't enough hard verifiable facts like dates, dollar amounts, headcounts, or named tools to qualify this as quantitatively verified. Now I'm checking whether this contains firm-specific facts.

fact: Cyber Incident Response Team (the 'IRT') — named internal program with unique abbreviation

fact: IRT composition includes Executive Vice President of Information Technology, CFO, COO, CLO


reasoning: The paragraph's purpose is describing the oversight/reporting structure: how information flows from the ISO upward to management, the BRCC, and the full Board, with escalation policies. This is a governance-chain paragraph → Board Governance per Rule 2. The ISO (cybersecurity-specific title) and BRCC (a named non-generic committee) are firm-specific facts, but neither qualifies as QV-eligible hard facts, so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph describes a reporting structure: ISO reports to management and BRCC, with escalation to the full Board. This is about governance/oversight structure - how information flows upward.

Category: Board Governance - the purpose is describing the oversight/reporting structure, how information flows from ISO → management/BRCC → full Board.

Specific facts:
- ISO (Information Security Officer) - cybersecurity-specific title → IS list
- BRCC - this appears to be a named non-generic committee (Board Risk and Compliance Committee?) → IS list

No QV-eligible hard facts (no dates, dollars, headcounts, named firms, named tools, certifications).

Both facts are firm-specific, so this falls under Firm-Specific category.

fact: ISO (Information Security Officer)

fact: BRCC (Board Risk and Compliance Committee — named non-generic committee)


reasoning: Applying the person-removal test: removing the SVPF and Director of IT attributions leaves a coherent process description — monitoring, evaluating threats, conducting scans, audits, and third-party assessments. The paragraph is about what the program does, not who these people are (no credentials, experience, or career history). 'Senior Vice President of Finance' and 'Director of Information Technology' are generic corporate/IT titles on the NOT list, not cybersecurity-specific roles. No named frameworks, tools, firms, dates, or other specific facts remain after filtering.

thinking:
Let me analyze this paragraph.

The paragraph mentions SVP of Finance and Director of IT, then describes what they do - which is process activities (monitoring, evaluating, scanning, audits, assessments).

Step 1 - Subject test: Person/role as subject → continue to Step 2.
Step 2 - Person-removal test: Remove the roles. "The Company helps identify, assess and manage cybersecurity risk, including input from employees, and devotes resources to cybersecurity and risk management processes to adapt to the changing cybersecurity landscape and respond to emerging threats. [The Company] identifies and assesses risks from cybersecurity threats by monitoring and evaluating our threat environment and the Company's risk profile using various methods including, for example maintaining manual and automated tools, conducting scans of threats and actors, evaluating threats reported to us, completing internal and external audits, and completing third-party threat assessments." - Yes, this is coherent as a process description.

So this is really about risk management processes rather than the specific roles mentioned. The SVP of Finance and Director of IT aren't cybersecurity-specific titles—they're on the NOT list—and there's no mention of qualifications, credentials, or experience. The substance here is the processes themselves: monitoring, tools, scans, audits, and assessments, with no named frameworks or specific dates.


reasoning: The paragraph's framing ('our cybersecurity governance structure is integrated into several facets') and structure (Board → Audit Committee → CISO → teams) establish its purpose as describing the full governance chain, making it Board Governance per Rule 2's guidance that governance-chain paragraphs are almost always BG. The CISO detail (Casey O'Malley, credentials, career history) is one bullet among six structural components. QV is reached with three hard verifiable facts: two specific dates (cybersecurity since 2001, IT management since 2015) and a named university (Penn State University).

thinking:
This is a complex paragraph that spans multiple categories. Let me analyze it.

The paragraph describes the full governance structure: Board → Audit Committee → CISO → various teams. Let me apply the decision rules.

The paragraph's purpose is describing the overall cybersecurity governance structure - "our cybersecurity governance structure is integrated into several facets of us." It then lists multiple layers.

Per Rule 2 (Board vs Management), governance-chain paragraphs that describe the structure from board → committee → officer → program are Board Governance when the PURPOSE is describing the oversight structure.

The paragraph does include specific details about Casey O'Malley as CISO—background in IT management since 2015, cybersecurity since 2001, and a BS in IT from Penn State—but that's just one element within a broader description of the governance chain. The dominant framing remains the structural overview across Board, Audit Committee, CISO, and the three teams beneath them. Given that governance-chain paragraphs are almost always Board Governance, and the person-specific content is secondary to the structural purpose, this falls under Board Governance.

Looking at what qualifies as QV-eligible: the specific dates (2015 and 2001) and Penn State University as a named institution in a credential context both count, though Casey O'Malley's name itself isn't QV-eligible per the rules.

fact: CISO role identified

fact: Casey O'Malley named as CISO

fact: IT management positions since 2015

fact: Employed in cybersecurity field since 2001

fact: Bachelor of Science in Information Technology from Penn State University

fact: Information Security Governance team

fact: Cybersecurity Risk Management Team


reasoning: The paragraph's primary content is the composition and structure of the Cybersecurity Steering Committee — listing its members by title and defining its organizational responsibilities. This is about WHO comprises the management committee responsible for cybersecurity, making it Management Role. The CSC is a named committee with a unique identifier, and it includes a CISO and a detailed cross-functional composition, all firm-specific facts. However, none of these are QV-eligible (no dates, dollar amounts, headcounts, named third-party firms, or named tools), so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes a Cybersecurity Steering Committee (CSC), its composition, and its responsibilities for monitoring/managing cybersecurity risks and overseeing cybersecurity initiatives.

Category analysis:
- This describes a management committee structure with specific members listed
- The CSC is a management-level committee (not board-level)
- It lists the composition and responsibilities of this committee
- The purpose is describing WHO comprises this committee and what it does

Is this Management Role or Risk Management Process?

Step 1 - Subject test: The CSC (a committee/group) is the subject. But it's a management committee with named roles.

Step 2 - Person-removal test: Even without the specific role names, the core content describes a committee responsible for monitoring and managing cybersecurity risks and overseeing initiatives—which could sound like a process. However, the paragraph actually dedicates most of its space to listing committee members and their titles, making the organizational structure and composition the dominant focus. This is clearly Management Role content describing who holds responsibility in the organization.

The codebook defines Management Role as covering "management committees responsible for cybersecurity," and the Cybersecurity Steering Committee fits that definition exactly. The paragraph's primary purpose is identifying which specific roles comprise this management committee. Applying the specificity check: the CSC is a named committee with a unique identifier, the roles listed are cybersecurity-specific titles like "Group Vice President, IT and CISO," and multiple titled positions are enumerated—all indicators of a list. I have multiple hard verifiable facts here: the CISO is a named role, the committee has a specific name and structure, and the roles are explicitly tied to cybersecurity responsibilities.

fact: Cybersecurity Steering Committee (CSC)

fact: Group Vice President, IT and CISO

fact: Committee composition: EVP CFO, EVP CHRO, SVP General Counsel, SVP Global Operations, SVP Chief Accounting Officer, VP Internal Audit


reasoning: The paragraph contains a forward-looking materiality assessment using the SEC's Item 106(b)(2) threshold language: 'reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.' Per Rule 6 and Case 9, this is a materiality conclusion (not mere speculation like 'could have'), making it Strategy Integration. The cross-reference to Item 1A and the generic risk warning are subordinate. No specific facts are present — all language is boilerplate.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three parts:
1. "There can be no assurance that our cybersecurity risk management program..." - generic risk warning
2. "We face risks from cybersecurity threats that, if realized and material, are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition." - This is forward-looking materiality with SEC qualifier "reasonably likely to materially affect"
3. "See Item 1A, 'Risk Factors'" - cross-reference

Per Rule 6 and Case 9 in the codebook: "We face risks from cybersecurity threats that, if realized and material, are reasonably likely to materially affect us" → This uses the SEC's Item 106(b)(2) threshold language "reasonably likely to materially affect." This is a forward-looking materiality assessment → Strategy Integration.

The language here is purely boilerplate with no concrete details or specific facts about actual cybersecurity risks.


reasoning: The paragraph describes ERM integration and the organizational structure of the cybersecurity program (team composition, CIO reporting line) without any personal qualifications or credentials, placing it in RMP per the three-step decision chain. Firm-Specific due to cybersecurity-specific titles (CIO, Director of Information Security) and specific team composition, but no QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity risk management as part of ERM, the Information Security Team's role, reporting to CIO, and team composition.

Category analysis:
- Mentions ERM integration → RMP signal
- Information Security Team reports to CIO → reporting structure
- Team composition: Director of Information Security, managers, security analysts

Apply MR vs RMP three-step chain:
Step 1: Subject is "Cyber security risk management" and "Information Security Team" - mixed
Step 2: Remove roles/titles. "Cyber security risk management at Noble, along with all enterprise risks, is part of the Company's Enterprise Risk Management Program and risks from cyber security threats are assessed, identified, and managed by [removed].

[removed] reports to [removed]. [removed] is composed of [removed]." - Without the people, the first sentence still works as RMP, but sentences 2-3 are entirely about organizational structure/people.

This is borderline. The first sentence is RMP (ERM integration). Sentences 2-3 are about the team structure - reporting lines and composition. That's Management Role content. The paragraph splits between ERM integration and risk assessment on one hand, versus organizational hierarchy and team makeup on the other. The reporting line to the CIO and the specific roles like Director of Information Security are fundamentally about organizational structure rather than personal qualifications.

But applying the three-step chain: there are no personal credentials, certifications, years of experience, or career history mentioned. Step 3 says no qualifications means RMP. The team composition describes organizational structure, yes, but the content focuses on how the program is organized rather than who the people are in terms of their background. So this should classify as RMP.

Now I'm checking the specificity of the roles and titles mentioned. The CIO and Director of Information Security are both cybersecurity-specific titles that appear on the IS list, which makes them firm-specific facts. The Information Security Team is a named team but fairly generic, and the ERM Program is just a generic program name. There are no quantitative values—no dates, dollar amounts, headcounts, or named tools—so this doesn't meet the QV threshold. Since there's at least one IS-list fact present, this qualifies as Firm-Specific.

fact: Chief Information Officer (CIO)

fact: Director of Information Security

fact: Team composed of Director of Information Security, managers, and security analysts


reasoning: The paragraph describes the company's internal cybersecurity processes: team structure, cross-functional approach, training, audits, and third-party engagement. The CISO is mentioned once as attribution ('led by our chief information security officer') but the substantive content is about what the program does. Removing the CISO reference leaves a fully coherent process description → Risk Management Process. The CISO title is the sole IS-list fact, yielding Firm-Specific; no second hard verifiable fact exists to reach QV.

thinking:
Let me analyze this paragraph step by step.

**Content Category:**

Step 1 — Subject test: "We have an IT security team, led by our CISO" — the subject is the team/company, then describes what the program does.

Step 2 — Person-removal test: Remove "led by our chief information security officer" — the paragraph still describes the IT security team, cross-functional approach, training, audits, third-party engagement. It's coherent without the person reference.

This is Risk Management Process. The CISO is mentioned once as attribution. The bulk describes internal processes: training, reviews, tests, audits, third-party engagement.

Now I'm checking the specificity of the facts here. The CISO title is on the IS list, which signals firm-specific content, but everything else—the internal audit team, unnamed consultants, cross-functional approach, and standard practices like training and testing—are generic. There's only one IS-list fact and no quantifiable details like dates, budgets, headcounts, named vendors, or certifications, so this lands as Firm-Specific based on that single CISO reference.

fact: chief information security officer (CISO)


reasoning: The paragraph's primary purpose is identifying which specific management roles lead cybersecurity and delineating their responsibilities — this is SEC Item 106(c)(2) management role disclosure. While the listed responsibilities (hiring, budgets, integrating into risk management) are process-adjacent, the communicative purpose is telling the reader WHO is responsible. However, the absence of any qualifications, credentials, or career history (Step 3 of the MR vs RMP chain) makes this borderline; the firm-specific titles (President of P&T, CDO) anchor it as Management Role identification rather than pure process description. Specificity is Firm-Specific due to the cybersecurity-specific titles (CDO overseeing cyber, the named P&T role), but no QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

The paragraph names management team members (President of P&T, CDO, senior-most employee responsible for cybersecurity) and then describes what they DO - which is a mix of process activities (hiring, budgets, integrating into risk management, overseeing reports, preparing for incidents).

Let me apply the three-step decision chain for MR vs RMP:

Step 1 — Subject test: "Members of our management team" are the grammatical subject. Person/role as subject → signal, continue to Step 2.

Step 2 — Person-removal test: Remove the roles.

When I strip away the specific roles, the remaining text still reads as a coherent description of processes and activities rather than role assignments. This points toward Risk Management Process. But I'm noticing the paragraph actually identifies specific named roles first, then lists what they do—which suggests the primary purpose is management role identification. The tension here is whether the focus is on WHO is responsible or WHAT processes exist.

Looking at the qualifications tiebreaker: there's no mention of experience, certifications, education, team size, or career history—just generic responsibilities like hiring, budgeting, and overseeing. That leans toward Risk Management Process rather than management identification.

But I keep coming back to the core purpose: the paragraph is fundamentally about *which* management roles are responsible for cybersecurity. The President of P&T, the CDO, and the senior-most employee are the subjects. If I strip away those role identifications, I'm left with a disconnected list of activities with no actor. That's the person-removal test—and it fails because the roles are essential to the disclosure's meaning.

I think this is Management Role. The paragraph's primary function is identifying the responsible management structure, not describing a process. The paragraph names specific roles like the President of P&T and Chief Digital Officer overseeing cybersecurity, which are firm-specific titles rather than generic ones. The senior-most employee reference is unnamed and generic, so I'm looking at whether this qualifies as Firm-Specific. Named roles don't count as quantifiable facts, so there aren't multiple QV-eligible items here—this lands at Firm-Specific.

fact: President of P&T

fact: CDO (Chief Digital Officer)

fact: senior-most employee responsible for cybersecurity management


reasoning: The opening sentence is a backward-looking negative materiality assertion ('have not identified any indication of a cybersecurity incident that would have a material impact on our business and consolidated financial statements'), which constitutes a materiality assessment per Rule 6 → Strategy Integration. The remainder is generic risk warning and a cross-reference to Item 1A, which do not override the materiality conclusion. No specific facts are present — all language is boilerplate.

thinking:
Materiality assessment: "have not identified any indication of a cybersecurity incident that would have a material impact" — this is a backward-looking negative assertion about materiality → Strategy Integration per Rule 6.

The second sentence is generic risk warning ("could" style speculation) + cross-reference to Item 1A. But the first sentence contains the materiality assessment, which is the substantive content.

Specificity: No specific facts. Generic boilerplate materiality language. → Specificity 1.


reasoning: The paragraph's primary content is about WHO comprises the management team (specific departmental composition: IT, finance, legal, operations), their supervisory structure (overseeing internal security personnel and retained consultants), and a qualification note about personnel ('prior work experience in cybersecurity'). Applying the person-removal test: removing the team composition and personnel descriptions leaves only 'leads all efforts for our overall cybersecurity risk management program,' which is a shell — the team's identity and structure IS the content. The specific departmental composition (IT, finance, legal, operations) is a firm-specific fact per the IS list, but no QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

The paragraph describes the management team's composition and what they do (lead cybersecurity risk management program, supervise personnel and consultants).

Category analysis:
- Grammatical subject: "our management team"
- Content: describes who comprises the team (senior staff from IT, finance, legal, operations), what they do (lead cybersecurity risk management program), and who they supervise (internal security personnel and retained consultants)

MR vs RMP decision chain:
- Step 1: Person/role as subject → continue to Step 2
- Step 2: Remove roles/titles/qualifications. Remaining: "leads all efforts for our overall cybersecurity risk management program and supervises both our internal information security personnel and our retained cybersecurity consultants." This is still coherent as a process/structure description.

But I'm second-guessing myself here. The core of this paragraph is really about the team's composition and organizational structure across departments, not about the processes they manage. Even though removing the team designation leaves a coherent statement about what they do, the paragraph's primary focus is on who comprises the team and how they're organized. The qualifications mentioned are structural details about the personnel, not individual credentials. This feels more like a structural/organizational description than a process one. not specific enough to qualify as a qualification detail. The team composition with those specific departments is what matters here - that's the firm-specific fact. Since there's only one concrete detail, this falls under Firm-Specific rather than Qualifications/Verification.

fact: Management team comprised of senior staff from IT, finance, legal, and operations departments


reasoning: The paragraph opens by framing audit committee oversight of cybersecurity risks—briefing cadence, board reporting, escalation protocols—establishing governance structure as the organizing purpose. The second half introduces management personnel (CDTO, CIO, CISO consultant) and their qualifications, but these are presented as components of the governance structure rather than standalone personnel profiles. Board Governance edges out Management Role as the framing category, though it is genuinely borderline. Specificity is Quantified-Verifiable: two QV-eligible facts (25+ years experience for CDTO/CIO, ~15 years for CISO consultant).

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

The paragraph covers:
1. Management responsibility for cybersecurity program
2. Audit committee oversight of cybersecurity risks (receiving reports, meeting semi-annually)
3. Board consideration of IT/cyber expertise for audit committee members
4. Cyber Incident Response Plan escalation protocols
5. Chief Digital and Technology Officer role - recently hired, oversees technology
6. CIO reporting to CDTO
7. Qualifications of CDTO and CIO (25+ years experience, industries, degrees, MBA)

8. Third-party CISO consultant with 15 years of experience and prior CISO roles

The paragraph spans Board Governance, Management Role, and Risk Management Process. It starts with oversight structures and governance, then shifts into detailing the qualifications and backgrounds of the key players—the CDTO, CIO, and external CISO consultant who bring substantial cybersecurity and technology leadership experience to the organization. CISO consultant), specific qualifications like 25+ years of experience, advanced degrees, and an MBA for one role, 15 years for the consultant. The person-specific content really dominates here in terms of unique information compared to the more generic governance language. I'm leaning toward Management Role as the primary category since the bulk of the detailed, substantive content focuses on who these people are and what they bring to the table.

But Rule 2 does flag governance-chain paragraphs as almost always Board Governance. This one starts with governance structure but then pivots heavily into personnel credentials. Let me look at what's actually being communicated—the opening establishes the oversight chain, but the real meat of the paragraph is describing the qualifications and experience of the management team members themselves.

The next thinking mentions a Cyber Incident Response Plan with escalation protocols, which would be a separate governance element. So I'm seeing this as primarily Management Role with some governance framing, not the other way around. I'm applying the purpose test from Rule 2 — the governance chain elements clearly describe oversight structure, but the second half shifts to detailing these individuals' qualifications and experience, which is distinctly person-focused. Since it's roughly split between the two categories, the credentials and specific expertise details are more granular and substantive, so Management Role seems like the stronger fit. 0.5 confidence, since the paragraph frames itself as a governance overview and the management details are presented as supporting the governance narrative.

Now I'm thinking about what this is really communicating to investors—it's describing both the governance structure and the qualified people executing it, with the board oversight as the primary frame. Looking at the specificity, I see some cybersecurity-relevant titles like Chief Digital and Technology Officer and CIO that would count toward the IS-list.

For the qualifications themselves, I'm finding two facts that meet the QV threshold: the specific years of experience mentioned—over 25 years and approximately 15 years in IT roles. The degrees listed are too generic without institutional names, and while the industry experience is specific, it doesn't clearly align with the IS-list criteria. So I'm working with those two experience-based qualifications as my QV-eligible facts.

fact: Chief Digital and Technology Officer

fact: Chief Information Officer

fact: Third-party consultant providing CISO advisory services

fact: Cyber Incident Response Plan

fact: over 25 years of information technology experience (CDTO and CIO)

fact: approximately 15 years of experience in cybersecurity leadership (CISO consultant)

fact: semi-annual meetings with cybersecurity leaders


reasoning: The paragraph is a negative assertion stating the company has not experienced any cybersecurity incidents that resulted in business interruptions or breaches — this is the company stating a conclusion about whether cybersecurity has affected business outcomes, which qualifies as a materiality assessment under Rule 6 (analogous to 'have not experienced any material cybersecurity incidents' → SI). The date 'December 31, 2024' is merely the standard fiscal year-end reporting period, not a cybersecurity-specific fact; the language is generic boilerplate that could appear in any company's filing unchanged.

thinking:
Classify this paragraph.

"The Company has not experienced any cybersecurity incidents during the year ended December 31, 2024, or in any prior year that resulted in interruptions to normal business operations or breaches of systems."

This is a negative assertion about incidents - "has not experienced any cybersecurity incidents... that resulted in interruptions or breaches." This is a materiality/impact assessment - stating that no incidents have materially affected operations. Per Rule 6, negative assertions like "have not experienced material incidents" → Strategy Integration.

Actually, I'm noticing the statement doesn't explicitly use the word "material," but it's making a conclusion about whether cybersecurity incidents affected business outcomes by specifying they didn't result in interruptions or breaches. That's still a Strategy Integration classification.

On the date specificity question, "December 31, 2024" is technically a specific date, but it's just the standard fiscal year-end reporting period rather than a cybersecurity-specific fact. The codebook does list specific dates as IS facts, but contextually this feels more like generic boilerplate since every company reports on a fiscal year end. The real substance here is the negative assertion about incident impact, not the date itself.


reasoning: This is a generic risk warning stating cybersecurity incidents 'could materially adversely affect' operations — boilerplate speculation found in any 10-K, not a materiality assessment (no conclusion stated). It describes no process, governance structure, incident, or strategy; it is general risk language with no substantive cybersecurity disclosure content.

thinking:
Let me analyze this paragraph.

Content: Generic risk warning about cybersecurity threats affecting the company, customers, and suppliers. Uses "could materially adversely affect" - this is speculative boilerplate, not a materiality assessment.

Category: The phrase "could materially adversely affect" is a generic risk warning, NOT a materiality assessment per the codebook. No actual incident, no process description, no governance structure. This is generic risk language. → None/Other

Specificity: No named entities, frameworks, roles, dates. → Generic Boilerplate


reasoning: This is a governance-chain paragraph describing how information flows upward from management to the Enterprise Risk and Compliance Committee and the Board's Audit Committee. The communicative purpose is describing the oversight/reporting structure, making it Board Governance. The Enterprise Risk and Compliance Committee is a named non-generic committee unique to this company, triggering Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph describes how management reports cybersecurity risks upward - to the Enterprise Risk and Compliance Committee and to the Board's Audit Committee. The purpose is describing the reporting/oversight structure - how information flows upward to the board level.

Category: This is a governance-chain paragraph. The purpose is describing oversight structure - how management reports to committees, how information flows to the board. Per Rule 2, governance-chain paragraphs are almost always Board Governance. The board's Audit Committee is the ultimate recipient of these reports. → Board Governance

Now I'm checking the specificity of the facts mentioned. The Enterprise Risk and Compliance Committee is a named committee specific to this firm, while "Audit Committee" and "management" are generic terms. That gives me one firm-specific fact, placing this in the Firm-Specific category.


reasoning: The paragraph's purpose is describing the oversight/reporting structure — how information about cybersecurity flows upward to the CEO and Board of Directors, including briefing cadence ('at least annually') and topics covered. This is governance structure description, making it Board Governance. No specific facts from the IS list are present: 'CEO', 'Board of Directors', 'management', and 'at least annually' are all generic per the NOT list, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: CEO and management oversee strategic direction including cyber risk. Company will update CEO and Board periodically/annually on cybersecurity program.

Category: This describes oversight structure - how information flows to leadership (CEO and Board). The purpose is describing the governance/reporting structure. The board is receiving updates. This spans board governance and management, but the purpose is describing the oversight/reporting structure.

Wait - the grammatical subject is "CEO and management" in the first sentence. The second sentence describes reporting TO the CEO and Board. This is about the oversight structure - how the board and CEO get informed.

Per Rule 2: "Purpose = describing oversight/reporting structure (who reports to whom, briefing cadence, committee responsibilities, how information flows to the board) → Board Governance"

Now I'm checking the specificity. There are no named roles like CISO or CIO, no frameworks mentioned, no specific dates or tools - just generic references to the CEO, Board of Directors, and vague cadences like "periodically" and "at least annually." This is all boilerplate language without concrete details.


reasoning: The paragraph describes the governance chain between management and the Board — charter for periodic reviews, reporting to the Board, recommending actions. Per the codebook, governance-chain paragraphs describing oversight structure and how information flows to the board are Board Governance, even when 'Management' is the grammatical subject. There are no named individuals, no qualifications or credentials, so this is not Management Role. All terms are generic ('Management,' 'the Board,' 'periodic,' 'charter') with nothing firm-specific, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Management oversees cybersecurity risk management, has a charter for periodic review with the Board, may receive training, and reports to the Board.

Category: This spans management and board governance. The paragraph describes management's role in overseeing cybersecurity and reporting to the board. Let me apply the decision rules.

The grammatical subject is "Management" throughout. But what is the purpose? It describes management's oversight process and reporting structure to the board. There are no personal qualifications, no named individuals, no credentials.

Applying the MR vs RMP three-step chain:
- Step 1: Subject is "Management" (generic, not a named role)

- Step 2: Removing role references still leaves a coherent process description about charter reviews and board discussions
- Step 3: No qualifications, certifications, or experience mentioned

The core issue is that this describes a governance structure—how management and the board interact on oversight—rather than defining a specific role. The grammatical subject is "Management," but the real purpose is explaining the reporting chain and information flow between management and the board. The reporting structure pointing upward to the board tips this toward Board Governance rather than Management Role. Since there are no named frameworks, specific roles, dates, or unique identifiers—just generic references to "Management" and an unnamed charter—this lands squarely in Generic Boilerplate at Specificity 1.


reasoning: This paragraph acknowledges that regulations exist and non-compliance would be bad — a truism for every public company. It does not describe any process, program, or framework the company uses to comply, names no specific regulation, and makes no materiality assessment. Per the codebook's Case 10 guidance, generic regulatory compliance language with no company-specific program description is None/Other.


reasoning: This is a governance-chain paragraph titled 'Leadership and Governance' that spans board oversight, management roles, and process descriptions. The primary communicative purpose is describing the oversight structure: the Board receives semiannual updates from the CIO and CISO, and periodic updates from external experts, with the cybersecurity team regularly briefing executive management. While RMP content (monitoring, incident response plan) is present, it is subordinate to the governance framing. Per Rule 2, governance-chain paragraphs describing how information flows to the board are Board Governance. Specificity is Firm-Specific due to CISO and CIO (cybersecurity-specific roles on the IS list); 'semiannual' is a generic cadence and 'external cybersecurity experts' are unnamed, so neither qualifies. Named roles do not count toward QV.

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

The paragraph covers:
1. CISO leads a team (Management Role)
2. Board oversight, semiannual updates from CIO and CISO (Board Governance)
3. Monitoring, security measures, audits (Risk Management Process)
4. Incident response plan (Risk Management Process)
5. Cybersecurity team meets with executive management (Board Governance / Management Role)

This is a governance-chain paragraph spanning board → management → processes. What's the primary communicative purpose?

The header signals this is about governance structure overall. The board oversight piece is substantial—semiannual updates, periodic external expert input—but there's also meaningful content on risk management processes like monitoring, security measures, and incident response. The distribution is fairly balanced across management roles, board oversight, and RMP elements, with a touch of management briefings at the end. Given the governance-chain structure, this seems primarily focused on describing how oversight flows from the board down through the CISO and management team to the actual security processes. The CISO and CIO titles are both information security-specific, which pushes this toward Firm-Specific. There are no quantifiable details like dates, amounts, or named tools, so it doesn't reach QV. This lands at Firm-Specific (3).

fact: Chief Information Security Officer (CISO)


reasoning: This multi-topic paragraph spans MR (CIO credentials/certifications), BG (committee oversight structure, transition, briefing cadence), and RMP (monitoring, incident response). The board governance content occupies the largest continuous block (5+ sentences describing the Sustainability & Safety Committee's role, the transition from full board oversight, and quarterly briefing cadence), making it the dominant communicative purpose. QV is clear: multiple named certifications (CISM, CISSP), specific date (2025), and quantified experience (three decades) yield well over two hard verifiable facts.

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

The paragraph covers:
1. Team description + CIO credentials (experience, certifications)
2. Board oversight structure (Sustainability & Safety Committee)
3. Risk management processes (monitoring, incident response)
4. Management reporting to executive team

This is a complex paragraph spanning multiple categories. Let me determine the dominant one.

Breaking it down by content:
- Sentences 1-2: Management Role (CIO credentials, team certifications)
- Sentences 3-7: Board Governance (committee oversight, briefing cadence, transition of oversight)

- Sentences 8-9: Risk Management Process (monitoring, incident response plan)
- Sentence 10: Management reporting to executive leadership

The paragraph spans board governance, management role, and risk management processes. The board governance section is the largest block, covering the committee structure, transition timeline, and briefing frequency. The management credentials portion is dense with certifications, and there's a smaller risk management component at the end.

Board Governance is the dominant category since it occupies the most continuous text and describes the primary oversight structure, even though the management credentials are substantial.

Looking at the specific facts, I've identified several quantified or verifiable details: the CIO and CISO titles, over three decades of experience, ISA 62443, CISM, and CISSP certifications, the Sustainability & Safety Committee, and the 2025 start date. With four or more of these facts being quantifiable or verifiable, this qualifies as Quantified-Verifiable.

fact: Vice President of Information Technology, CIO and CISO role

fact: over three decades of experience in information security

fact: ISA 62443 Cybersecurity Expert certification

fact: CISM certification

fact: CISSP certification

fact: Sustainability & Safety Committee

fact: Beginning in 2025, oversight moved to Sustainability & Safety Committee


reasoning: This paragraph is a cross-reference directing readers to Item 1A for materiality discussion. While it contains materiality language ('materially affected or are reasonably likely to materially affect'), the paragraph's purpose is pointing the reader elsewhere — it describes what Item 1A covers rather than making its own materiality conclusion. Per the codebook: 'For risks that may materially affect us, see Item 1A' = N/O (pointing elsewhere, not concluding).


reasoning: This governance-chain paragraph spans Board Governance and Management Role. While the framing is governance structure (board oversees, officers report to board), the most substantive and distinctive content is about the people — the CEO's 15+ years of IT experience with cybersecurity relevance and the explicit acknowledgment that other officers have limited cybersecurity experience. The governance framing is entirely generic boilerplate; the qualifications content is what gives this paragraph its communicative purpose under Item 106(c)(2). CEO is on the NOT list (generic C-suite), but '15 years of experience' is a specific quantified fact, yielding Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

This is a multi-topic paragraph spanning board oversight, management roles, and some process elements. Let me apply the decision rules.

The paragraph covers:
1. Board oversight of cyber risks (sentence 1)
2. Executive officers oversee processes and report to board (sentence 2)
3. CEO's IT/cybersecurity experience - 15+ years (sentence 3-4)
4. Other officers have limited experience (sentence 5)
5. External advisers consulted when necessary (sentence 6)
6. Officers will inform board of material incidents (sentence 7)

Now I'm breaking down the content by category. The first two sentences establish the governance structure, then sentences three through five focus on the qualifications and experience levels of the management team itself—particularly the CEO's extensive background in software development and cybersecurity. The external advisers and incident reporting round out the picture, but the real weight of the paragraph sits on describing who these people are and what they bring to the table.

The core purpose seems to be explaining the cybersecurity governance arrangement—the board's oversight role, the officers' execution responsibilities, and the specific expertise they possess to handle that work. It's a mixed paragraph, but the governance framing bookends it while the management qualifications occupy the middle and carry substantial weight. I'm wrestling with whether the qualifications content tips this toward Management Role. The CEO's specific experience—15 years in IT, software development focus, cybersecurity knowledge—is genuinely substantive, not just boilerplate. But the codebook warns that governance-chain paragraphs are almost always Board Governance, and the overall structure does frame this as a management hierarchy reporting back to the board. The qualifications feel like supporting evidence for governance capability rather than the main point, so I'm leaning Board Governance, though it's genuinely borderline.

Actually, looking at the specificity angle: the CEO title itself is on the NOT list as generic C-suite, so that doesn't help. The experience description is quantified (15+ years) but lacks named certifications or specific dates. Without stronger cybersecurity-specific credentials, the qualifications content alone might not be enough to override the governance framing. Looking at the structure of this paragraph more carefully, the real substance here is about the officers' qualifications and experience levels—or rather, the lack of cybersecurity expertise among most of them. The governance framework itself (board oversight, reporting lines) is entirely generic boilerplate. Since the SEC's rule 106(c)(2) is specifically asking about management qualifications, that's what makes this disclosure distinctive, so I should categorize this as Management Role with Firm-Specific facts.

fact: CEO has more than 15 years of experience in information technology


reasoning: This is a governance-chain paragraph describing the oversight structure: Board and Audit Committee provide oversight, CEO directs, CFO and third-party consultants are consulted. The purpose is describing how the governance/oversight structure works (who oversees whom, how information flows), making it Board Governance per Rule 2. No IS-list facts are present — CEO, CFO, Board, and Audit Committee are all on the NOT list as generic titles, and the third-party consultants are unnamed.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a governance structure spanning board → CEO → CFO → third-party consultants. Let me apply the decision rules.

Category analysis:
- Mentions Board and Audit Committee oversight (BG signals)
- Mentions CEO and CFO roles (but these are generic C-suite, not cybersecurity-specific)
- Describes consulting with third-party IT consultants (could be TPR or RMP)
- Describes developing strategies to assess and address threats

This is a governance-chain paragraph. The purpose is describing the oversight structure - how the company's security governance works, flowing from the Board down through the CEO.

But I need to reconsider the grammatical focus here. The CEO is actually the main subject doing the work - consulting with the CFO and third-party consultants to develop strategies. The board is mentioned only in passing. Since there are no specific qualifications or credentials for the CEO and CFO, and the emphasis is on what they do rather than who they are, this reads more like a process description than a management role profile. The person-removal test would show the paragraph is really about the consulting and strategy-development process itself. The paragraph establishes governance oversight flowing from the Board and Audit Committee down through the CEO, who then directs cybersecurity strategy in consultation with the CFO and external security consultants. Since it's describing the oversight structure and chain of command rather than listing specific roles or frameworks, this falls under generic boilerplate with no substantive IS-list facts.


reasoning: This paragraph describes generic IT-dependence language — the importance of data integrity, privacy, and security to business operations. It contains no substantive cybersecurity disclosure: no processes, frameworks, governance structures, incidents, or materiality assessments. It is general business language that could apply to any company.

thinking: Generic IT-dependence language, no cybersecurity disclosure.


reasoning: Applying the person-removal test: removing 'led and supervised by our information technology manager' leaves a coherent description of the team's process responsibilities (risk assessment, security controls, incident response). The paragraph describes what the function covers, not who the person is — no credentials, experience, or career history. 'Information technology manager' falls under the generic IT leadership NOT list, so no firm-specific facts are present.

thinking:
Classify this paragraph.

This describes a security team led by an IT manager, responsible for risk assessment, security controls, and incident response. Let me apply the decision chain.

Category: The paragraph describes who leads the security team and what they're responsible for. Let me apply the MR vs RMP test.

Step 1 — Subject: "a security team led and supervised by our information technology manager" - person/role as subject. Continue to Step 2.

Step 2 — Person-removal test: Remove "led and supervised by our information technology manager" → "a security team, which is principally responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls, and (3) our response to cybersecurity incidents" — this is still a coherent description of what the team does. → Risk Management Process.

Though I'm second-guessing myself here. The paragraph seems primarily focused on identifying who's responsible and their scope rather than describing the actual process. Even though removing the IT manager reference leaves a coherent description, the real emphasis appears to be on establishing the management structure and accountability. Since this looks like a fragment from a bullet list, the intent might be more about clarifying the responsible party than detailing how the processes work.

Looking at the specifics: "information technology manager" isn't a cybersecurity-specific title like CISO or Chief Information Security Officer would be—it's closer to the generic "IT Manager" that wouldn't count as a specific fact. There are no frameworks mentioned, no certifications or experience requirements listed, and no concrete details that would distinguish this from generic boilerplate. So this is Risk Management Process content, but it's written in a generic way without the specificity that would make it substantive.


reasoning: The paragraph contains both a backward-looking materiality assessment ('have not materially affected us') and a forward-looking assessment with the SEC qualifier ('reasonably likely to materially affect us'), both triggering Strategy Integration per Rule 6. The cross-references to specific risk factor titles in Item 1A are noise and do not override the materiality conclusions. No firm-specific facts from the IS list are present — risk factor titles and filing references are company self-references on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Contains a materiality assessment ("have not materially affected us") and a forward-looking materiality statement ("reasonably likely to materially affect us"). Also has a cross-reference to Item 1A risk factors.

Category: Strategy Integration - per Rule 6, backward-looking "have not materially affected us" and forward-looking "reasonably likely to materially affect" are both materiality assessments → SI.

Specificity: No named frameworks, no firm-specific facts from the IS list. The cross-references to specific risk factor titles are just cross-references. No dates, no dollar amounts, no named roles, no named tools.

This lands in Generic Boilerplate territory given the lack of any concrete details or company-specific information.


reasoning: The paragraph describes the governance/oversight structure: board → Audit Committee → Cybersecurity Disclosure Committee (CDC), including the CDC's composition and responsibilities for materiality assessment and disclosure recommendations. The purpose is describing how oversight is structured, making this Board Governance. The named non-generic committee (CDC) and specific departmental composition (IT, Legal, Internal Audit, Accounting and Reporting) are firm-specific facts, but neither qualifies as QV-eligible (committees and team compositions don't count toward the two-fact QV threshold).

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes board oversight structure, the Audit Committee's role, and a Cybersecurity Disclosure Committee (CDC). Let me apply the decision rules.

The paragraph has multiple layers:
1. Board/Audit Committee oversight of cybersecurity risks
2. CDC composition and responsibilities

The purpose is describing the governance/oversight STRUCTURE - how the board exercises oversight, the committee structure, and how information flows. The CDC is a named non-generic committee that's part of the governance structure.

This is Board Governance - it describes the oversight structure from board → Audit Committee → CDC.

The CDC itself is a named, firm-specific committee, and the specific departmental composition—Information Technology, Legal, Internal Audit, and Accounting and Reporting—are concrete facts about this organization's structure, neither of which qualify as QV-eligible. This falls under Firm-Specific facts.

fact: Cybersecurity Disclosure Committee ("CDC")

fact: CDC includes representation from Information Technology, Legal, Internal Audit, and Accounting and Reporting teams


reasoning: Applying the person-removal test: removing 'The Company's CFO... is responsible for' leaves a coherent process description (monitoring, evaluating threat environment, automated tools, escalation protocols). The paragraph is about what the program does, not who the CFO is — no credentials, experience, or career history. CFO is generic C-suite per the NOT list, and 'third-party cybersecurity vendors' are unnamed, so no specific facts remain.

thinking:
Let me analyze this paragraph.

Subject test: CFO is the grammatical subject, but the content describes what the program does - monitoring, evaluating, assessing risks, using tools, etc.

Person-removal test: Remove "The Company's Chief Financial Officer, or CFO, with assistance from our third-party cybersecurity vendors, is responsible for" and you get process descriptions about identifying risks, monitoring, evaluating, implementing protocols. It stands on its own as a process description.

No qualifications, credentials, or career history mentioned.

→ Risk Management Process

Specificity: No named frameworks. No specific dates, dollar amounts, headcounts. No named firms or tools.

CFO is generic C-suite language that's on the NOT list, and the vendors and tools mentioned are all unnamed and generic. This is boilerplate language without any specific facts.

→ Generic Boilerplate


reasoning: Applying the person-removal test: removing 'CEO, COO, and Chief Accounting Officer' leaves a coherent process description — third-party IT provider monitoring, incident response workflow, materiality determination, and escalation to the Audit Committee. The paragraph is about the function (how cybersecurity risk is managed), not the people. The brief note about lacking specialized backgrounds is an absence of qualifications, not MR-qualifying credential content. No IS-list facts are present: CEO/COO/CAO are generic C-suite titles, 'Audit Committee' is standard, and the third-party provider is unnamed.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the management team's role in cybersecurity, their backgrounds, use of third-party IT providers, and incident response process.

**Content Category Analysis:**

The paragraph covers multiple topics:
1. Management team composition (CEO, COO, Chief Accounting Officer) - but these are generic C-suite titles, not cybersecurity-specific
2. Their responsibility for cybersecurity risk management
3. Lack of specialized cybersecurity backgrounds
4. Use of third-party IT service provider
5. Incident response process
6. Materiality determination and disclosure process

Applying the MR vs RMP three-step test:

The management team is the grammatical subject. When I strip away the role titles, what remains is a coherent description of the program and process—they're responsible for assessing and managing cybersecurity risks, overseeing the risk management program, retaining external IT providers, and utilizing third-party monitoring. The paragraph doesn't include specific certifications, years of experience, education, team size, or career history. So this is describing what the management team does and how the program operates, not who they are or their individual credentials.

The mention that they lack specialized cybersecurity backgrounds is interesting—it's noting the absence of qualifications rather than listing qualifications themselves. But actually, that statement does describe who these people are: they don't have specialized cybersecurity expertise, though they do have general experience managing financial, insurance, legal, and operational risks. The bulk of the paragraph though is really about the process—how they manage cyber risk through third-party providers, how they respond to incidents, how they determine materiality. The management team is the subject, but the content focuses on the function and process.

So the dominant category here is the risk management process. Now looking at specificity, I see CEO, COO, and Chief Accounting Officer—these are generic C-suite titles that don't add specificity. The third-party outsourced IT service provider is mentioned but without naming the actual provider.  The Audit Committee is just generic governance language. There are no named frameworks, no specific dates, no named firms, no specific numbers. This is clearly generic boilerplate with no IS-list facts or named standards.


reasoning: The paragraph spans process description, personnel qualifications, and committee operations, but the dominant content is identifying WHO leads the cybersecurity program and their credentials — the CTO's 25 years of experience and areas of expertise, and the Head of Technology Infrastructure's 20 years of experience and focus areas. Removing the people and their qualifications would gut the paragraph's core content. Two QV-eligible hard facts (25 years, 20 years of experience) push specificity to Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. The cybersecurity program and what it does (monitoring, alert response, vulnerability management, etc.)
2. The CTO's qualifications (25 years experience, areas of expertise)
3. The Head of Technology Infrastructure's qualifications (20 years experience, areas of expertise)
4. The C-ROC committee meeting and forming teams

Let me apply the decision rules.

**Category determination:**

This paragraph spans multiple categories. Let me apply the person-vs-function test.

Step 1 — Subject test: "Blue Owl's cybersecurity program" is the initial subject, but then it shifts to describing the people who lead it.

Step 2 — Person-removal test: If I strip out all the named roles, titles, qualifications, and experience descriptions, I'm left with content about the cybersecurity program's processes and responsibilities—monitoring, alert response, vulnerability management, policy implementation—plus information about regular team meetings and cross-enterprise collaboration. The middle section is almost entirely biographical, so the paragraph is roughly split between process content and personnel qualifications.

Looking at the structure more carefully, the paragraph really breaks down into three distinct parts: the program's scope and oversight structure, the two leaders' backgrounds and expertise, and the C-ROC's meeting cadence. The qualifications section is substantial—two specific roles with years of experience and detailed areas of expertise. The opening does contain meaningful process content, but the dominant purpose seems to be establishing who manages the program and why they're qualified, with operational details serving as supporting context. The leaders' backgrounds occupy the bulk of the middle section, which makes this lean toward MR territory, though it's borderline.

For specificity, I'm noting the concrete details: CTO appears on the IS list, the "over 25 years" figure is a specific number that qualifies for QV, Head of Technology Infrastructure is somewhat specific though not explicitly listed, "over 20 years" is another QV-eligible number, and C-ROC is the governance body. These specific qualifications and role titles are what anchor this as MR content.

fact: Chief Technology Officer

fact: over 25 years of experience

fact: Head of Technology Infrastructure

fact: over 20 years of experience

fact: C-ROC (Cyber Risk Oversight Committee)