reasoning: This is a governance-chain paragraph (Board → Audit Committee → CTO → VPCS) whose primary purpose is describing the oversight structure and how cybersecurity responsibility flows from the board downward. No personal credentials or qualifications are provided, so it is Board Governance, not Management Role. The CTO and VP of Cyber Security are cybersecurity-specific titles on the IS list, making it Firm-Specific, but named roles do not count toward QV.

thinking:
Let me analyze this paragraph carefully.

This is a governance-chain paragraph: Board → Audit Committee → CTO → VPCS → program.

Category: The paragraph describes the oversight structure - how the board delegates to Audit Committee, how management roles fit into the chain. Applying Rule 2 (board-line test): the purpose is describing the oversight/reporting structure, not who these people are (no credentials, experience, etc.). This is Board Governance.

Specificity:
- "Board" / "Audit Committee" → NOT list (generic governance)

- "Chief Technology Officer (CTO)" and "Vice President of Cyber Security (VPCS)" → both are IS list items (cybersecurity-specific titles)

So we have firm-specific facts here. Looking for QV-eligible facts: named roles don't count toward QV, and there are no dates, dollar amounts, headcounts, named firms, named tools, or certifications. This makes it Firm-Specific (3).

fact: Chief Technology Officer (CTO) oversees cybersecurity program

fact: Vice President of Cyber Security (VPCS) responsible for day-to-day cybersecurity


content_category: Risk Management Process

category_confidence: medium

specificity_confidence: high

reasoning: The opening sentences mention Board oversight, but the paragraph's dominant content describes the company's cybersecurity program: framework adoption (ISO, NIST), integration into operations, and a cross-functional approach focused on CIA triad objectives. The Board mention is a brief framing device; the substantive content is process description. Named frameworks (ISO, NIST) push specificity to Sector-Adapted, but no firm-specific facts (no named roles, committees, dates, or numbers) are present.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Board oversight mention, then pivots to describing the company's cybersecurity program - frameworks (ISO, NIST), cross-functional approach, CIA triad focus.

Category: The first two sentences mention Board oversight, but the bulk of the paragraph describes the risk management program - frameworks, integration into operations, cross-functional approach, CIA triad. The dominant content is RMP.

Specificity: Names ISO and NIST frameworks → Sector-Adapted. No firm-specific facts from the IS list (no CISO, no specific committees beyond generic Board, no dates, no numbers).

fact: International Organization for Standardization (ISO)

type: framework

fact: National Institute of Standards and Technology (NIST)


content_category: Strategy Integration

category_confidence: high

reasoning: The paragraph's primary content is a backward-looking materiality assessment ('have not materially affected us, including our business strategy, results of operations or financial condition') plus a forward-looking assessment via cross-reference ('reasonably likely to materially affect us'). Per Rule 6, both are materiality conclusions → Strategy Integration. The brief mention of past threats/breaches is incidental and generic. No specific facts from the IS list are present — no named roles, dates, tools, or numbers — so specificity is Generic Boilerplate.

thinking:
Let me analyze this paragraph carefully.

The paragraph contains:
1. "such risks have not materially affected us, including our business strategy, results of operations or financial condition" - backward-looking materiality assessment → SI
2. "experienced threats to and breaches of our data and systems, including malware and computer virus attacks" - brief incident mention
3. Cross-reference to Item 1A Risk Factors with forward-looking materiality language

The dominant content is the materiality assessment. Per Rule 6, the backward-looking assessment "have not materially affected us, including our business strategy, results of operations or financial condition" is a materiality conclusion → Strategy Integration.

The cross-reference also includes forward-looking language about what's "reasonably likely to materially affect us," and there are no specific facts, frameworks, or dates mentioned—just generic boilerplate language.


content_category: Board Governance

specificity_confidence: medium

reasoning: The paragraph describes how officers provide briefings TO the Board of Directors — the purpose is describing the oversight/reporting structure (how information flows upward to the board), making it Board Governance per the governance-chain rule. 'Vice President of Technology' is a cybersecurity-adjacent specific title that qualifies as a firm-specific fact, though the rest of the content (periodic briefings, recent incidents, testing, third-party activities) is generic.

fact: Vice President of Technology


reasoning: The paragraph contains a negative materiality assertion — 'the Company has not detected a significant compromise, significant data loss or any material financial losses related to cybersecurity attacks' — which is the company stating a conclusion about whether cybersecurity has affected business outcomes, triggering Strategy Integration per Rule 6. The surrounding generic risk warnings ('could experience a significant event', 'risks expected to remain high') are boilerplate speculation, not assessments. No named frameworks, roles, dates, or firm-specific facts appear, so specificity is Generic Boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph discusses: belief in robust security, can't be certain measures will be successful, threat is severe, no significant compromise/data loss/material financial losses detected to date, systems under constant threat, risks expected to remain high.

Content category: This contains a materiality assessment - "the Company has not detected a significant compromise, significant data loss or any material financial losses related to cybersecurity attacks." This is a negative assertion about material impact. But wait - it says "material financial losses" not "materially affected our business strategy, results of operations, or financial condition." Let me re-read...

The negative assertion about material financial losses qualifies this as Strategy Integration under Rule 6, while the surrounding generic risk language about potential significant events and elevated risks lacks any specific frameworks or concrete details, making it Generic Boilerplate.


reasoning: The CISO is the grammatical subject, but the paragraph's purpose is describing the oversight/reporting structure — how information flows upward to the Technology Risk Management Committee, Audit Committee, and full Board. This is a governance-chain paragraph focused on briefing structure and topics, not on who the CISO is. The Technology Risk Management Committee is a named non-generic committee (IS list), and CISO is a cybersecurity-specific title, yielding Firm-Specific; however neither counts toward QV.

thinking:
Let me analyze this paragraph.

The paragraph describes the CISO providing updates to various governance bodies (Technology Risk Management Committee, Audit Committee, Board, CEO). The purpose is describing how information flows upward - the reporting/oversight structure.

Category: This is a governance-chain paragraph. The CISO is the grammatical subject, but the PURPOSE is describing the oversight structure - how information flows to the board/committees. Per Rule 2, governance-chain paragraphs are almost always Board Governance. The content is about briefing cadence and topics, not about who the CISO is as a person.

→ Board Governance

Specificity: Let me check facts:

- "CISO" - cybersecurity-specific title → IS list ✓
- "Technology Risk Management Committee" - named non-generic committee → IS list ✓
- "Audit Committee" - NOT list (generic)
- "Board of Directors" - NOT list
- "CEO" - NOT list (generic C-suite)
- "periodic" - NOT list (generic cadence)

Two IS facts present, but named roles and committees don't count toward QV eligibility, so there are no QV-eligible facts. Since I have at least one IS fact, this is Firm-Specific.

fact: CISO

fact: Technology Risk Management Committee


reasoning: The paragraph spans multiple categories but the dominant communicative purpose is describing the governance/oversight structure: CFO directs cybersecurity, incidents are reported to the board, and the Audit Committee receives updates. The materiality assessment ('has not experienced any material cybersecurity incidents') and cross-reference are subordinate. CFO is generic C-suite (NOT list) and Audit Committee is generic governance (NOT list), but the specific year '2024' in the incident review statement qualifies as a firm-specific date reference, yielding one IS-list fact → Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

This is a multi-topic paragraph from a small company (Thunder Mountain Gold). Let me break down what's here:

1. "Our cybersecurity programs are under the direction of our CFO with assistance from the management team." - Management/governance
2. "Any significant Cyber incidents that they become aware of are reported to the board of directors." - Board governance (reporting structure)
3. "The Board of Directors does not have a designated cybersecurity committee, but the Audit Committee receives periodic updates on cybersecurity matters." - Board governance

4. "The Company has not experienced any material cybersecurity incidents to date and there were no material cybersecurity incidents discovered in 2024." - Materiality assessment
5. "Please refer to Item 1A: Risk Factors for further insights into cyber attack-related risks." - Cross-reference

The governance structure dominates here—three sentences cover board oversight, incident reporting, and committee updates—while the materiality statement and cross-reference each take one sentence. The CFO's role rounds out the management picture.

Actually, I need to think about this differently. The materiality assertion about no material incidents is a specific disclosure obligation that carries weight, but the paragraph's primary communicative purpose is really about the governance framework itself. The governance structure (who directs, how it reports, committee involvement) is what takes up most of the space and forms the core message. So Board Governance is the right dominant category here.

Now I'm checking the specificity requirements against the NOT list - CFO, Board of Directors, and Audit Committee are all generic governance roles that don't qualify as specific individuals or entities, so none of these trigger the specificity threshold.

But "2024" is a concrete year, which counts as a specific date and pushes this into Firm-Specific territory based on having at least one fact from the IS list.

fact: 2024 (specific year for incident review)


reasoning: The paragraph describes the governance chain: COO and management report to the full board and audit committee on cybersecurity programs, risks, and incidents. The communicative purpose is describing how oversight works and how information flows upward to the board — a classic governance-chain paragraph → Board Governance. COO and Audit Committee are on the NOT list (generic C-suite/governance), but 'beginning in 2024' is a specific date qualifying as one IS-list fact → Firm-Specific.

thinking:
Let me analyze this paragraph.

Content category: This describes the reporting/oversight structure - COO reports to the board and audit committee. The purpose is describing how information flows upward (governance chain). Per Rule 2, governance-chain paragraphs are Board Governance.

Specificity: Let me check facts.
- COO: generic C-suite title (NOT list)
- "Board of Directors": generic (NOT list)
- "Audit Committee": generic (NOT list)
- "beginning in 2024": this is a specific date reference
- No named frameworks, no cybersecurity-specific titles (COO is not on the IS list)

- One IS fact with the specific date → Firm-Specific (3).

fact: beginning in 2024


reasoning: The paragraph describes how the management team supervises cybersecurity prevention, detection, mitigation, and remediation efforts using various information sources and security tools. Applying the person-removal test: removing 'Our management team supervises' leaves a coherent description of cybersecurity processes (threat intelligence gathering, security tool monitoring, consultant engagement), so the content is about the function, not the person. No named frameworks, specific roles (just generic 'management team'), named tools, dates, or firms appear — all entities are generic ('external consultants', 'security tools', 'internal security personnel').

thinking:
Let me analyze this paragraph.

Content: Management team supervises cybersecurity efforts, provides briefings from various sources including internal personnel, threat intelligence, external consultants, and security tools.

Category: The grammatical subject is "our management team." Let me apply the MR vs RMP decision chain.

Step 1 - Subject test: "Our management team" is the subject. This is a person/role signal, continue to Step 2.

Step 2 - Person-removal test: Remove "Our management team supervises" → "efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, and provides briefings from internal security personnel, threat intelligence... external consultants...

The sentence still makes sense without the management team as the subject—it's describing the underlying processes and information flows around alerts and reports from security tools. So this points toward Risk Management Process rather than Board Governance, since the paragraph is focused on operational monitoring and information gathering rather than board-level oversight. The language is generic too—no named frameworks, specific roles beyond "management team," dates, tools, or external firms. This is clearly Risk Management Process.


reasoning: The paragraph describes the escalation/reporting structure for how information flows from management to the Audit Committee and Board during a cybersecurity incident. Its communicative purpose is describing the oversight chain — who reports to whom and under what conditions — making it a governance-chain paragraph (Board Governance). No specific facts are present: 'Audit Committee,' 'Board,' 'management,' 'incident response plan,' and 'escalation protocols' are all generic terms on the NOT list.

thinking:
Let me analyze this paragraph.

The paragraph describes what management will do in the event of a material incident - report to the Audit Committee and Board per escalation protocols and incident response plan.

Category: This describes the governance/oversight structure - how information flows upward from management to the board in incident scenarios. The purpose is describing the reporting/escalation structure. This is a governance-chain paragraph describing how oversight works.

Actually, let me reconsider. The subject is "management" and the action is reporting to the Audit Committee and Board. The purpose is describing the escalation/reporting structure - how information flows to the board. Per Rule 2, governance-chain paragraphs are Board Governance when the purpose is describing oversight structure.

Now checking the specificity - the language here is all generic. "Audit Committee," "Board," "incident response plan," and "escalation protocols" are standard terms without any concrete details, named roles like a CISO or CIO, specific frameworks, or dates. This is Generic Boilerplate.


content_category: Management Role

reasoning: The paragraph identifies which management roles (CEO, CFO, IT team) are responsible for cybersecurity and enumerates their responsibilities (hiring, budgets, approving processes, reviewing reports). Applying the three-step chain: Step 1 — mixed subjects (processes + executive team); Step 2 — removing roles leaves a list of generic organizational responsibilities that lack coherence without knowing WHO performs them; Step 3 — no qualifications, certifications, or career history, but the paragraph's purpose is defining management responsibility rather than describing processes or tools. However, CEO and CFO are generic C-suite titles (NOT list), 'information technology team' is generic, and 'Board of Directors' is standard — no IS-list facts are present, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content category: This describes management's role in cybersecurity - CEO, CFO, executive team responsibilities. But let me apply the decision chain.

Step 1 - Subject test: "Our cybersecurity risk assessment and management processes" is the subject of the first sentence, but then "Our executive team including our CEO and CFO" becomes the subject. Mixed.

Step 2 - Person-removal test: Remove roles (CEO, CFO, IT team). "Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management... [team] is responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into the Company's overall risk management strategy, and communicating key priorities to relevant personnel.

The [team] also handles approving budgets, preparing for cybersecurity incidents, approving processes, and reviewing security assessments and reports. So the paragraph is really about the management structure and what oversight responsibilities fall to the executive level - it's describing the organizational function rather than listing specific people. The CEO, CFO, and IT team are just generic roles filling those functions.

Let me apply the person-removal test: if I strip out those names, I'm left with activities like hiring, integrating risk management, approving budgets, and reviewing reports. The paragraph still makes sense as a description of management responsibilities. There are no credentials, certifications, experience levels, or career details mentioned - just what these roles are accountable for. This is pointing toward a Risk Management Process classification rather than a description of specific people.

But the governance structure is significant here. The mention of "at the direction of our Board of Directors" establishes an oversight chain, and the focus is really on who in the organization is responsible for what. Even though CEO and CFO are on the exclusion list and the titles are generic, the core content is about the management structure overseeing cybersecurity. I'm leaning toward Management Role - it's describing the organizational responsibilities, not the people themselves.


reasoning: The paragraph describes how the CISO and CIO report to the Board and Audit Committee — a governance-chain paragraph whose purpose is describing the oversight/reporting structure (how information flows upward). Board is the recipient of briefings, making this Board Governance. CISO and CIO are cybersecurity-specific titles on the ✓ IS list, elevating to Firm-Specific, but neither qualifies as QV-eligible.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes how the CISO and CIO inform the Board about cybersecurity risks through briefings. The purpose is describing the oversight/reporting structure - how information flows from management to the board.

Category: This is a governance-chain paragraph. The CISO and CIO are mentioned as intermediaries reporting TO the board. The purpose is describing oversight structure. → Board Governance

Specific facts:
- CISO (cybersecurity-specific title) → ✓ IS
- CIO (cybersecurity-specific title) → ✓ IS

- Audit Committee and Board of Directors are generic roles without firm-specific details, and there are no quantifiable facts like dates, dollar amounts, headcounts, named firms, tools, or certifications present. This makes it Firm-Specific based on the named CISO and CIO roles alone.

fact: Chief Information Security Officer (CISO)

fact: Chief Information Officer (CIO)


reasoning: The paragraph's primary purpose is describing the board-level oversight structure: the Audit and Examination Committee's responsibility for overseeing cybersecurity and the reporting cadence from the Information Security Officer to that committee. The ISO is mentioned as the intermediary in the governance chain, not for their qualifications or background, making this Board Governance per the purpose test. The Information Security Officer is a cybersecurity-specific title on the IS list, yielding Firm-Specific; however, 'quarterly' and 'Audit and Examination Committee' are generic cadence/governance terms that do not add to specificity, and there are no QV-eligible hard facts.

thinking:
Board Governance vs Management Role analysis needed.

The paragraph describes the Audit and Examination Committee's oversight role and how information flows to the board via the Information Security Officer's quarterly reports. The purpose is describing the oversight structure.

Person-removal test: Remove "Our Information Security Officer" → the paragraph still describes the committee's oversight and reporting structure. The ISO is mentioned as the person who reports, not for their qualifications.

Category: Board Governance

Specific facts:
- "Information Security Officer" — cybersecurity-specific title → IS list ✓
- "Audit and Examination Committee" — this is a named non-generic committee (it's not just "Audit Committee", it's "Audit and Examination Committee") — actually, this is essentially the audit committee with a slightly different name.

I'll treat it as generic governance. "Quarterly reports" is just a standard cadence, not a specific fact. So the only firm-specific detail here is the Information Security Officer title itself.

No QV facts present. Specificity level: Firm-Specific (3).

fact: Information Security Officer


reasoning: The paragraph describes the Information Security team's internal processes for maintaining governance documents and a strategic three-year plan, with committee approval as a component of that process. Applying the person-removal test, removing the CISO references leaves a coherent description of document review cycles and strategic planning — the content is about the program's processes, not about any person. Specificity is Firm-Specific due to the CISO role, the non-generic Audit & Risk Committee, and named governance documents, but no QV-eligible hard facts (no dates, amounts, headcounts, or named external firms).

thinking:
Let me analyze this paragraph.

Content: Describes the Information Security team's governance document review cycle, presents to Audit & Risk Committee, maintains a three-year strategic plan, CISO provides progress reports.

Category analysis:
- The paragraph describes internal processes (reviewing governance documents, maintaining a strategic plan) and the governance structure (presenting to Audit & Risk Committee, CISO approval).
- The grammatical subjects are "the Information Security team" and "the plan" and "the CISO"
- Purpose: describing the process of governance document management and strategic planning
- Person-removal test: Remove CISO references → the paragraph still describes governance document reviews and strategic planning processes coherently → Risk Management Process

- But I'm noticing the Audit & Risk Committee plays a significant oversight role here—they're reviewing and approving both the documents and the strategic plan, not just receiving information. This suggests the paragraph is really about the governance chain and how oversight flows through the committee structure rather than just the IS team's internal processes. Checking for quantifiable facts—the CISO role and Audit & Risk Committee are both named entities that don't qualify, and the internal documents and three-year timeframe don't contain the specific metrics or third-party references needed for QV eligibility. This confirms it's firm-specific information.

fact: Audit & Risk Committee (non-generic committee name)

fact: Information Security Charter, Information Security Policy, Information Security Program Plan (named governance documents)

fact: Formal cybersecurity strategic three-year plan


reasoning: This is a governance-chain paragraph spanning board → Risk and Technology Committee → Enterprise Risk Committee → CISO/CRO → program. Per the board-line test, governance-chain paragraphs are Board Governance because the communicative purpose is describing the oversight structure — how information flows upward, who reports to whom, and how the Board exercises oversight. While two sentences describe the CISO's qualifications (15 years, CISSP), these are subordinate to the dominant framing of Board/committee oversight and escalation paths. QV is reached via two hard verifiable facts: specific years of experience (15 years) and a named certification (CISSP).

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

The paragraph covers:
1. Risk management process integrated into ERM
2. CISO and CRO oversight, reporting to Board and Risk and Technology Committee
3. CISO's ongoing oversight of cyber risk management
4. Risk escalations through ERM framework, Enterprise Risk Committee, Board via Risk and Technology Committee
5. Board's active role in overseeing cybersecurity program
6. CISO's qualifications (15 years experience, CISSP, prior senior roles at financial institutions)

7. Cybersecurity leadership team has expertise/certifications
8. Enterprise Risk Committee composition (CRO, CLO, CTO, CCO, CPO, Business Presidents)

The governance structure shows how cybersecurity oversight flows from the Board through the Risk and Technology Committee down to the CISO and their leadership team, with the Enterprise Risk Committee providing cross-functional coordination. The CISO brings substantial experience and relevant certifications, and the broader leadership team is similarly qualified to manage the program. The codebook is clear—governance-chain paragraphs default to Board Governance unless the officer's qualifications dominate, which they don't here since they're only a couple sentences in a much longer section about oversight structure. So this is Board Governance. Now I'm identifying the specific facts: CISO and CTO are cybersecurity-specific titles on the IS list, while CRO, Chief Privacy Officer, and Chief Compliance Officer aren't. The named committees—Risk and Technology Committee, Enterprise Risk Committee—count as IS facts, and the 15 years of experience plus CISSP certification are both specific and QV-eligible.

fact: Chief Information Security Officer

fact: Risk and Technology Committee

fact: Enterprise Risk Committee

fact: Over 15 years of technology and cybersecurity experience

type: quantified

fact: CISSP certification

fact: Chief Technology Officer

fact: Committee composition: CRO, CLO, CTO, CCO, CPO, FIS Business Presidents


reasoning: This is a governance-chain paragraph describing how cybersecurity information flows upward: CISO → CFO/President/CEO → Compliance Committee → Board. The purpose is describing the oversight and reporting structure, making it Board Governance. The CISO (cybersecurity-specific title) and Compliance Committee (non-generic committee) are firm-specific facts, but neither qualifies as QV-eligible.

thinking:
Let me analyze this paragraph.

The paragraph describes how the CISO reports to C-suite executives and how matters are escalated to the Compliance Committee and Board. This is about the governance/oversight reporting structure - how information flows upward from CISO → CFO/President/CEO → Compliance Committee → Board.

Category: Board Governance - this is a governance-chain paragraph describing oversight structure and information flow.

Specific facts:
- CISO (cybersecurity-specific title) → IS list
- Compliance Committee - this is a named non-generic committee (not just "Audit Committee") → IS list

- No quantifiable facts like dates, dollar amounts, or headcounts here, so this falls into Firm-Specific based on the two IS-list items I identified.

fact: CISO

fact: Compliance Committee


reasoning: The paragraph describes the reporting structure from management to the Board, including briefing cadence ('at least annually and more frequently as needed'). The communicative purpose is how oversight works — information flowing upward to the board — making this Board Governance per the governance-chain rule. No specific facts from the IS list are present: 'management,' 'the Board,' and 'at least annually' are all on the NOT list.

thinking:
Classify this paragraph.

The paragraph describes management's responsibility and reporting to the Board. Let me apply the decision rules.

Category: This spans management and board. The purpose is describing the oversight/reporting structure - how information flows from management to the board, briefing cadence. Per Rule 2, governance-chain paragraphs are Board Governance. The board is the recipient of reports, and the paragraph describes the reporting structure. → Board Governance.

Specificity: Let me check for specific facts.
- "Management" - generic, NOT list
- "the Board" - generic, NOT list
- "at least annually" - generic cadence, NOT list

- No named roles, no named committees beyond generic, no frameworks, no dates, no numbers, and no named standards. → Generic Boilerplate (1).


reasoning: This governance-chain paragraph spans Board Governance (Risk Committee oversight, reporting cadence) and Management Role (CISO qualifications). The CISO's personal qualifications—20+ years of experience, MBA, CISSP, CISM, GLAW, GSEC certifications, and industry background—constitute the most detailed and specific content block, making the officer's credentials the dominant content per the codebook's governance-chain exception. QV is clear: 20 years of experience + CISSP + CISM + GLAW + GSEC = well over two hard verifiable facts.

thinking:
This is a long paragraph spanning multiple categories. Let me analyze it.

The paragraph covers:
1. Board/Risk Committee oversight of cybersecurity (Board Governance)
2. Risk Committee receiving reports from Cybersecurity Committee (Board Governance)
3. Chief Risk Officer oversees risk management framework (Management Role)
4. CISO's responsibilities (Management Role)
5. CISO's experience - 20+ years, certifications (Management Role)
6. CISO reports to CRO (Management Role)
7. Cross-reference to another section (None/Other)

This is a governance-chain paragraph spanning board → committee → officer → program.

The content is heavily weighted toward management roles, particularly the CISO's qualifications and background—including extensive experience across healthcare, education, and financial consulting, plus multiple relevant certifications like CISSP, CISM, and others. While the paragraph opens with board-level oversight through the Risk Committee, the bulk of the text focuses on the CISO's credentials and professional history. The sentence count shows management role content is actually dominant here—four sentences focused on the CISO's qualifications and responsibilities versus three on the governance structure. Combined with the substantial credentials listed, this tips toward Management Role classification, even though it opens with governance framing. Rule 2 is clear that when personal qualifications become the dominant content, it shifts from Board Governance to Management Role. the overall oversight structure, with CISO qualifications as supporting detail about who fills that role in the chain. But when I count the actual text volume, the qualifications section takes up more space and includes much more specificity—20 years of experience, multiple certifications, degree type, industry background. That tips it toward Management Role. Though Case 5 suggests the framing matters too, and this does open with governance structure... I think the extensive detail on the CISO's credentials is the deciding factor here, so Management Role seems right. I'm counting up the word distribution across the sections—the Management Role content about the CISO's qualifications runs about 100 words compared to the Board Governance setup, making it the dominant focus. Now I'm working through the specific facts to identify what qualifies: the named committees and CISO title are cybersecurity-specific, the 20 years of experience and certifications like CISSP and CISM are all quantifiable and eligible, though the MBA without a named institution doesn't meet that threshold.

fact: Risk Committee of the board

fact: CISO role with primary responsibility

fact: Chief Risk Officer

fact: Over 20 years of cybersecurity experience

fact: CISM certification

fact: GLAW certification

fact: GSEC certification

fact: Master of Business Administration


reasoning: The paragraph's framing sentence positions cybersecurity as part of the company's overall ERM approach and describes 'key areas' of the cybersecurity program — governance structure and collaborative approach. While the first bullet covers board/committee oversight (BG territory), it is presented as one component OF the program description, and the second bullet describes internal cross-functional processes for threat identification and incident escalation. The dominant communicative purpose is describing the program's structure, not board oversight per se. The CIO (a cybersecurity-specific title on the IS list) provides one firm-specific fact; 'Audit and Compliance Committee' is essentially the generic Audit Committee, and 'Chief Compliance Officer' is generic C-suite — neither qualifies.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the company's cybersecurity program as part of ERM, covering two key areas: Governance and Collaborative Approach.

Category analysis:
- The paragraph starts by framing cybersecurity as part of ERM
- The "Governance" bullet describes board oversight delegation to Audit and Compliance Committee, CIO reporting, cybersecurity as standing agenda topic
- The "Collaborative Approach" bullet describes cross-functional approach to identifying/preventing/mitigating threats

This spans multiple categories. The dominant content is a mix of governance structure and risk management process. The governance bullet is about board/committee oversight (BG), and the collaborative approach bullet is about internal processes (RMP).

The opening frames this as a cybersecurity program focused on key areas, which signals RMP framing. While governance gets substantial coverage through the Audit and Compliance Committee delegation and reporting structure, it's presented as one component within the broader program. The second bullet on collaborative threat identification and mitigation reinforces the process-oriented focus. So Risk Management Process appears to be the dominant category here.

Looking at specificity, "CIO" is the only firm-specific identifier on the IS list—the Audit Committee is generic, Chief Compliance Officer isn't on the list, and ERMP is just a generic enterprise risk management program. No named frameworks, dates, or financial figures. So I'm seeing just one QV-eligible fact.

fact: Chief Information Officer (CIO)


reasoning: Applying the person-removal test: removing the IT Lead's experience (11 years) and the external agency's expertise (8 years) leaves only a bare statement that 'processes are implemented by management' — the paragraph is fundamentally about WHO manages the program and their qualifications, making it Management Role. Two QV-eligible numeric facts (11 years of experience, ~8 years of external agency expertise) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three sentences:
1. "Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management, including our IT Lead."
2. "Our IT Lead has 11 years of experience in roles that include oversight of cybersecurity risk management programs."
3. "In addition, the IT Lead is assisted by an external agency with about 8 years of expertise in cybersecurity."

**Content Category Analysis:**

Step 1 — Subject test: First sentence has "processes" as subject, but then attributes to "IT Lead." Second and third sentences have "IT Lead" as subject.

Step 2 — Person-removal test: If I strip out the IT Lead, their experience, and the external agency, what's left is just "Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management" — which barely functions as a disclosure. The real substance here is about who's running the program and their qualifications.
Step 3 — Qualifications tiebreaker: The paragraph explicitly calls out 11 years of experience for the IT Lead and 8 years of expertise for the external agency.

→ **Management Role**

**Specificity Analysis:**

Now I'm evaluating whether these are specific facts. "IT Lead" is borderline — it's a cybersecurity-specific title, but not particularly granular.  Checking against the NOT list, generic IT leadership titles like "Head of IT," "IT Manager," and "Director of IT" aren't considered specific facts. "IT Lead" falls into that same category of generic IT leadership.

The experience numbers are clearly specific and QV-eligible: 11 years for the IT Lead and approximately 8 years for the external agency both count as concrete, quantifiable facts.

fact: IT Lead has 11 years of experience

fact: External agency with about 8 years of expertise in cybersecurity


reasoning: Person-removal test: removing the ISM/CIO titles, reporting line, and experience leaves a coherent disclosure about the IR team composition, risk reduction activities, GRC platform, and third-party managed detection—the process description stands on its own, making this RMP rather than MR. The paragraph's primary communicative purpose is describing the company's cybersecurity program operations, with the personnel serving as attribution. Specificity is Firm-Specific: multiple IS-list facts (cybersecurity-specific titles, specific team composition, quantified experience), but only one QV-eligible hard fact (50 years of experience), falling short of the two-fact QV threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Incident response team composition (IT, Finance, Legal, HR)
2. Information Security Manager role, reporting to CIO
3. Combined experience (50+ years)
4. What they do (manage risks, respond to incidents, harden attack surface)
5. GRC platform
6. Third-party assessors and 24/7 managed detection

Let me apply the decision chain for MR vs RMP:

Step 1 — Subject test: Mixed subjects - team, Information Security Manager, CIO, GRC platform. Not clearly one or the other. Continue to Step 2.

Step 2 — Person-removal test: Remove the titles and reporting structure, and I'm left with a coherent cybersecurity program description covering incident response, risk management, and detection capabilities. That points toward Risk Management Process. But Step 3 catches something important: the paragraph explicitly mentions years of experience tied to specific people, which is a person-specific detail that matters for classification.

The real question is what dominates the content. The paragraph opens with team composition, then pivots to describing the roles and experience of key leaders, but the bulk of the text focuses on what the program actually does—the processes, platforms, and capabilities. The people are there to establish credibility for the program, not as the main subject. Given that the process content is dominant and the person-removal test holds up, Risk Management Process is the right fit.

Now I'm checking the specificity markers: "Information Security Manager" and "Chief Information Officer" are both cybersecurity-specific titles that belong on the IS list.  The team composition across IT, Finance, Legal, and Human Resources is concrete. The "over 50 years of experience" is a specific quantifiable fact. But when I look at what counts toward QV eligibility, only the years of experience qualifies—the named roles and departmental composition don't count. That single QV-eligible fact means this lands as Firm-Specific rather than QV.

fact: Incident response team comprised of IT, Finance, Legal, and Human Resources

fact: Information Security Manager

fact: Chief Information Officer

fact: Over 50 years of combined experience in IT


reasoning: The paragraph spans Board Governance (Audit Committee oversight, reporting cadence, board training) and Management Role (CIO/CISO credentials, education, certifications, affiliations). However, the dominant content by volume and detail is the extensive person-specific credential disclosure for the CIO and CISO — multiple named universities (Purdue, Wayne State, Carnegie Mellon), CISSP certification, named professional groups, and editorial board service. This makes Management Role the dominant category. Specificity is Quantified-Verifiable with many hard verifiable facts: named universities in credential context (Purdue, Wayne State, Carnegie Mellon), CISSP certification, and named professional organizations.

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

The paragraph starts with Board governance (Board oversight, Audit Committee), then transitions to management reporting to the board, then shifts to detailed credentials of the CIO and CISO.

Let me apply the dominant category rule. The paragraph has roughly:
- Board/Audit Committee oversight structure (first few sentences)
- Management reporting to the board (governance chain)
- CIO credentials (education)
- CISO credentials (extensive - degrees, certifications, affiliations)

The second half is heavily focused on the CIO and CISO's qualifications, education, certifications, and professional affiliations.

Looking at the text distribution, the management role content—covering the CIO's background from Purdue and Wayne State, plus the CISO's extensive credentials including CISSP certification, Carnegie Mellon training, and professional affiliations—takes up a substantial portion of the paragraph. The credentials and qualifications content is actually quite substantial—multiple degrees, specific universities, CISSP certification, Carnegie Mellon program, professional memberships—and that specificity makes it feel like the dominant portion. The governance structure at the beginning is important but more generic in comparison. I'm leaning toward Management Role as the primary category since those person-specific details are what really distinguish this paragraph.

Now I'm identifying the QV-eligible facts scattered throughout: the named universities like Purdue, Wayne State, and Carnegie Mellon all count in a credentials context, plus the CISSP certification, and the professional affiliations like the Greater Pittsburgh CISO Group and Steel City OTSEC Information Sharing Group. There are quite a few verifiable facts here that could support a higher specificity rating.

fact: CIO role identified

fact: CISO role identified

fact: Bachelor of Science in electrical engineering technology from Purdue University

fact: Master of Business Administration from Wayne State University

fact: Doctorate in Instructional Management and Leadership

fact: CISO Certificate program at Carnegie Mellon University

fact: CISSP certification

fact: Greater Pittsburgh CISO Group membership

fact: Steel City OTSEC Information Sharing Group membership

fact: Editorial Review Board for International Journal of Cyber Research and International Journal of Information and Communication Technology Education

fact: 5-year cybersecurity threat assessment


reasoning: Applying the person-removal test: removing 'under the leadership of the Director of Information Technology, who has over 20 years of technology management experience' leaves a coherent process description (work plan, improvement objectives, third-party assessments, ongoing investments). The paragraph's primary content is what the technology team does — defining work plans, setting control objectives, implementing upgrades — not who the Director is. 'Director of Information Technology' is on the IS-NOT list as generic IT leadership (not cybersecurity-specific), but 'over 20 years' is a specific numeric duration qualifying as Firm-Specific. Only one QV-eligible hard fact, so not Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the Advisor's technology team, led by the Director of IT, and what this team does (defines work plan, sets improvement objectives, identifies investments, etc.).

**Category Analysis:**

Step 1 - Subject test: The subject is "Advisor and its affiliates have a technology team" - so it's about the team/program. The Director of IT is mentioned but let me apply Step 2.

Step 2 - Person-removal test: Remove "under the leadership of the Director of Information Technology, who has over 20 years of technology management experience" → "Advisor and its affiliates have a technology team which defines a work plan designed to maintain strong cybersecurity maturity, sets improvement objectives of key controls and systems, including feedback from third-party assessments, and identifies and implements on-going investments to replace or upgrade systems or technologies and proactively maintain strong security."

The core content remains coherent without the person details, so this is fundamentally about the risk management process rather than the individual's qualifications. The process itself—defining work plans, setting improvement objectives, incorporating third-party feedback, and making strategic investments—is what matters here. → **Risk Management Process**

**Specificity Analysis:**

The only specific fact is "Director of Information Technology," which is a generic title without distinguishing details.

Actually, wait—"over 20 years of technology management experience" is a quantified duration, which qualifies as a specific fact per the criteria. That's one QV-eligible fact. I need two for Qualified Vendor status, so with only one specific fact, this falls into Firm-Specific.


reasoning: The paragraph contains a negative materiality assertion ('we have not experienced a cybersecurity incident that we deemed to be material'), which is a company conclusion about materiality → Strategy Integration per Rule 6. The IT-dependence language and cross-reference to Item 1A are secondary; the materiality assessment is the substantive disclosure content. No firm-specific facts from the IS list are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three parts:
1. "We rely heavily on IT systems..." - generic IT-dependence language
2. "To date, we have not experienced a cybersecurity incident that we deemed to be material." - This is a negative materiality assertion → Strategy Integration per Rule 6
3. "For a discussion of whether and how risks from cybersecurity threats could materially and adversely affect us... refer to Item 1A" - cross-reference

The materiality assessment in sentence 2 is a clear negative assertion ("have not experienced... material"). Per the codebook, this is Strategy Integration.

The cross-reference and IT-dependence framing are just boilerplate filler. There are no named standards or firm-specific facts from the IS list—it's all generic materiality language, so this falls under Generic Boilerplate.


reasoning: This is a governance-chain paragraph describing how the CISO and CRO report to the risk committee and Board, including periodic reporting and escalation processes. The purpose is describing the oversight structure — how information flows upward to the board-level committee — making it Board Governance per the purpose test, even though officers are grammatical subjects. The risk committee (a non-generic named committee) and CISO (cybersecurity-specific role) are firm-specific facts, but no QV-eligible hard facts (dates, amounts, named firms) are present.

thinking:
Governance chain paragraph describing how information flows from CISO/CRO to the risk committee/Board.

Category: The purpose is describing the oversight structure - how the risk committee receives reports, how escalation works. The board/committee is the focus of oversight. Officers are intermediaries. → Board Governance

Specificity:
- CISO = cybersecurity-specific title → IS fact
- CRO = Chief Risk Officer... not on the IS list explicitly. But "risk committee" = named non-generic committee → IS fact
- "risk committee" is a named non-generic committee per the IS list

So we have CISO (named_role) and risk committee (named_committee) = Firm-Specific.

This doesn't contain any quantifiable metrics like dates, dollar amounts, headcounts, or references to specific third-party vendors or tools, so it's not QV. That confirms this is Board Governance and Firm-Specific.

fact: CISO

fact: CRO (Chief Risk Officer)

fact: risk committee


reasoning: Applying the MR vs RMP three-step test: Step 2 (person-removal) shows that removing the CTO's qualifications and the team composition leaves only a thin shell about process integration and third-party use — the paragraph's dominant content is about WHO manages cybersecurity (the CTO's 30+ years IT / 20+ years cybersecurity experience, and the named team of Compliance Manager, ISM/ISO, Enterprise Risk Manager). Step 3 confirms: years of experience are MR-specific qualifications. Two QV-eligible hard facts (30 years experience + 20 years cybersecurity experience) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics: risk management process integration, management roles and qualifications, third-party engagement. Let me apply the decision rules.

First, let me identify what's in this paragraph:
1. Cybersecurity risk management process is integrated into overall risk management
2. Information security professionals have primary responsibility
3. CTO leads cybersecurity professionals - has over 30 years IT experience, over 20 years in cybersecurity
4. CTO works with Compliance Manager, Information Security Manager/ISO, Enterprise Risk Manager

5. They engage third parties for security products/services
6. Third-party providers managed by Information Security Manager/Officer

Now, applying the MR vs RMP three-step test:

Step 1 - Subject test: Mixed - "Our cybersecurity risk management process" is the first subject, but then "Our Chief Technology Officer" becomes the subject. Not decisive, continue.

Step 2 - Person-removal test: If I remove all role titles, qualifications, experience... the remaining text would be: "Our cybersecurity risk management process is integrated as part of our overall risk management program. [professionals] have primary responsibility. [They] develop and maintain the cybersecurity program. We engage third parties to provide security products and services. [They] are managed by [a manager]..."

The real substance here is the CTO's extensive background—30 years in IT, 20 in cybersecurity—and the specific team structure around them, which dominates the paragraph's focus even though it also touches on process integration and third-party engagement.

Step 3 - Qualifications tiebreaker: Yes - the CTO's credentials and team composition are the paragraph's primary content, making this fundamentally about management structure and who's responsible rather than the process itself. This is Management Role.

Specific facts documented:
- CTO (cybersecurity-specific title per IS list) ✓
- Over 30 years IT experience ✓
- Over 20 years cybersecurity experience ✓
- Information Security Manager/Information Security Officer ✓
- Team composition: Compliance Manager, ISM/ISO, Enterprise Risk Manager ✓

The two hard numbers—30 years and 20 years of experience—are quantified and verifiable facts, so this qualifies as Quantified-Verifiable.

fact: Chief Technology Officer leads cybersecurity professionals

fact: Over 30 years of experience in information technology

fact: Over 20 years of experience in cybersecurity


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity and how the CIO/CISO report upward to the committee — a governance-chain paragraph whose purpose is describing the oversight structure. The CIO and CISO are cybersecurity-specific titles on the IS list, triggering Firm-Specific, but there are no QV-eligible hard facts (named roles don't count toward QV).

thinking:
Let me analyze this paragraph.

Category: This describes the Audit Committee's oversight role and how information flows to the board via CISO/CIO updates. The purpose is describing the oversight structure. → Board Governance

The grammatical subject of the first sentence is "The Audit Committee" - board oversight. Second sentence describes reporting TO the committee. This is governance chain → Board Governance.

Specificity:
- "Audit Committee" — NOT specific (generic)
- "Chief Information Officer" / "CISO" — these are cybersecurity-specific titles → IS specific facts

- "regular updates" — generic cadence, no named standards or dates
- No dollar amounts, no named firms

Since CIO and CISO are on the IS list, that gives at least Firm-Specific. Only one type of fact present (named roles), no QV-eligible hard facts. → Firm-Specific.

fact: Chief Information Officer (CIO)


reasoning: The paragraph describes how information flows upward through the governance chain: CFO and IT consultant brief the audit committee, which in turn updates the full board. The communicative purpose is describing the oversight/reporting structure, making it Board Governance. No facts from the IS list are present — CFO is generic C-suite, 'audit committee' and 'the Board' are generic governance, 'periodic' is a generic cadence, and 'IT consultant' is an unnamed entity.

thinking:
Classify this paragraph.

The paragraph describes how the CFO and IT consultant brief the audit committee, and how the audit committee updates the board. This is about the governance/oversight structure - how information flows upward.

Category: Board Governance - the purpose is describing the oversight/reporting structure (who reports to whom, how information flows to the board).

Specificity: Let me check the facts.
- "Chief Financial Officer" - CFO is on the ✗ NOT list (generic C-suite)
- "IT consultant" - unnamed entity
- "audit committee" - generic governance

- "periodic briefings" - generic cadence
- "the Board" - generic

No specific facts from the IS list. No named standards. → Generic Boilerplate (1)


content_category: None/Other

reasoning: This paragraph lists generic consequences of cyberattacks (data breaches, service disruption, IP theft, remediation costs) that could apply to any company. It does not describe any process, program, governance structure, or materiality assessment — it is general risk language enumerating hypothetical negative outcomes without substantive cybersecurity disclosure content.


reasoning: The paragraph describes management committee structure: the Engineering Risk Steering Group's function, the CISO's role as its chair, and its reporting line to the Firmwide Technology Risk Committee. Per Rule 2b's table, 'Reporting lines as primary content (who reports to whom, management committee structure)' maps to Management Role, and the codebook explicitly lists 'management committees responsible for cybersecurity' under MR's coverage. No credentials or qualifications are given, but the primary content is organizational governance at the management layer. Multiple named non-generic committees and a cybersecurity-specific role (CISO) provide firm-specific facts, but none are QV-eligible (named committees and roles don't count toward the 2-fact QV threshold).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the "Engineering Risk Steering Group" - a committee that oversees engineering risk decisions, monitors controls, and reviews compliance approaches. It's chaired by the CISO and reports to the Firmwide Technology Risk Committee.

**Content Category:**
This is about a committee's oversight role. The Engineering Risk Steering Group is a named committee performing oversight functions. The CISO is mentioned as chairing it, and there's a reporting line to another committee.

Purpose test: The paragraph describes an oversight/governance structure - what the committee does, who chairs it, and where it reports. This is about governance structure.

This is describing a management-level committee structure, not board governance. The Engineering Risk Steering Group and its reporting relationship to the Firmwide Technology Risk Committee are both management committees, so the focus here is on how management organizes its risk oversight rather than board-level governance. the person or the function? The CISO is mentioned but there's no background on credentials or expertise—the focus is on what the committee actually does. Looking at the codebook again, Management Role explicitly covers "management committees responsible for cybersecurity," and this paragraph is describing exactly that: a management committee's structure and reporting lines. The board-line distinction matters here too—this is clearly at the management layer, not board governance. So applying the three-step test: the subject is an organizational entity (the committee), but when I remove the CISO reference, the paragraph still functions as a description of committee oversight and governance structure, which points toward Management Role rather than Risk Management Program. The three-step chain is really meant for distinguishing individual management roles from process descriptions, so when I'm looking at a management committee's structure and reporting lines, the Rule 2b table applies directly—that points to Management Role. For specificity, the named committees and the CISO title are both IS facts, but since named roles and committees don't count toward QV, I'm not hitting the threshold of 2 QV-eligible facts, so this lands as Firm-Specific.

fact: Engineering Risk Steering Group

fact: CISO (chairs the committee)

fact: Firmwide Technology Risk Committee


reasoning: The paragraph explains the corporate delegation chain through which cybersecurity risk management is organized—General Partner → Investment Manager → Blackstone parent—and discloses that the company relies entirely on Blackstone for assessing and managing cybersecurity threats. This is a substantive (though high-level) description of how cybersecurity risk management is structured, making it RMP rather than None/Other. However, all named entities (General Partner, Investment Manager, Blackstone, Board of Directors) are corporate structure references or generic governance terms on the NOT list, yielding no firm-specific cybersecurity facts.

thinking:
Let me analyze this paragraph.

The paragraph describes the organizational structure - General Partner, Investment Manager, Sponsor - and explains that the company relies on Blackstone for cybersecurity. It's essentially a preamble/introduction explaining the corporate structure and delegation before describing Blackstone's actual cybersecurity program.

Content category: This is describing the organizational/governance structure - who manages cybersecurity operations. The General Partner manages operations subject to board oversight, delegated to Investment Manager, and ultimately reliant on Blackstone. This is about governance structure and delegation chains.

But wait - is this really substantive cybersecurity disclosure? It's more of a structural preamble explaining that Blackstone (parent) handles cybersecurity.

The paragraph names specific entities and mentions board oversight rights, but doesn't actually describe any cybersecurity processes, activities, or management qualifications - it's really just setting up the organizational hierarchy and explaining that Blackstone handles their cyber risks. The final sentence is just a transition into the actual cybersecurity details that follow. So this feels like it could be categorized as organizational preamble with minimal substantive disclosure, though it does touch on governance through the delegation structure.

But wait - the paragraph does say they're "assessing, identifying and managing material risks" through Blackstone, which is a substantive disclosure about their risk management approach. That's telling investors who manages their cybersecurity and how. So it's probably closer to Risk Management Process or Board Governance rather than None/Other, since it does convey meaningful information about their cybersecurity structure.

The key question is whether the focus is on the governance chain itself or on how risk management is delegated. The paragraph emphasizes the delegation to Blackstone more than the board's role, so Risk Management Process seems like the better fit - it's explaining the organizational structure through which cybersecurity risks are managed.

Looking at specificity, the entities mentioned are all company self-references and parent company names, which don't count toward the specificity threshold. There are no cybersecurity-specific facts, frameworks, dates, or numbers. This lands it at Generic Boilerplate with Specificity 1. This is asking me to rewrite the next thinking, but you haven't provided the next thinking content yet. I'm ready to rewrite it once you share what comes after the current rewritten thinking about the RMP categorization and Blackstone disclosure.


reasoning: Colombier Acquisition Corp. II is a SPAC/early-stage company that explicitly states it lacks 'significant investments in data security protection' and 'sufficient resources to adequately protect against, or to investigate and remediate any vulnerability to, cyber incidents.' Per the SPAC/no-operations rule, this absence of a program is not substantive disclosure. The incident reporting structure and board mention are perfunctory. The 'material adverse consequences' language uses 'could have' (generic risk warning, not a materiality assessment), and 'have not encountered any cybersecurity incidents' is a negative incident assertion without materiality framing tied to business strategy/financial condition, so it does not trigger Strategy Integration.

thinking:
Let me analyze this paragraph from Colombier Acquisition Corp. II, a SPAC.

The paragraph contains:
1. Incident reporting structure (Management Team reports to Board)
2. Admission of being early-stage with insufficient data security
3. Lack of resources for cybersecurity
4. Generic risk warning about material adverse consequences
5. "We have not encountered any cybersecurity incidents since our Initial Public Offering"

This is a SPAC/early-stage company explicitly stating they lack sufficient resources and investments in data security. Per the codebook's SPAC rule, companies that explicitly state they have no operations or insufficient programs get None/Other.

The statement about no incidents since IPO isn't a materiality assessment—it's just a negative assertion without the language about materially affecting business strategy or financial condition. And the "material adverse consequences" phrasing is boilerplate speculation ("could have"), not an actual assessment. Since this SPAC explicitly lacks a real cybersecurity program and sufficient resources, this falls under None/Other per the SPAC rule.


reasoning: The first sentence is a negative materiality assertion ('no material cybersecurity threats and incidents incurred to-date'), which constitutes a materiality assessment per Rule 6 → Strategy Integration. The subsequent 'could materially affect' is generic speculation (not an assessment), and the cross-reference to Item 1A is noise. No firm-specific facts are present.

thinking:
Let me analyze this paragraph carefully.

First sentence: "There have been no material cybersecurity threats and incidents incurred to-date at the Company." — This is a negative assertion about materiality ("no material cybersecurity threats and incidents"). Per the codebook, negative assertions like "we have not experienced material incidents" are materiality assessments → Strategy Integration.

Second sentence: Generic risk warning about policies not being followed.

Third sentence: "Cybersecurity threats could materially affect our business strategy, results of operations, or financial condition" — This uses "could" which is generic speculation, NOT an assessment per the codebook.

The first sentence is definitely a materiality assessment triggering Strategy Integration under Rule 6, and there's a cross-reference to Item 1A. Looking at specificity, I don't see any concrete details from the IS list—no named frameworks, specific roles, dates, or tools mentioned. This reads as generic boilerplate language.


reasoning: SPAC/shell company explicitly stating it has no business operations, no cybersecurity program, and no formal processes. Per the codebook's SPAC rule, the absence of a program is not a description of a program — this is None/Other regardless of any incidental mentions.


reasoning: Constellation Acquisition Corp I is a SPAC that explicitly states it has no cybersecurity risk management program and no formal processes. Per the codebook's SPAC rule, the absence of a program is not a description of a program. The board mention is perfunctory ('ultimately responsible... as deemed necessary'), and the trailing materiality sentence does not override the None/Other classification for a company with no operations or program to disclose.

thinking:
SPAC/shell company with no operations and no cybersecurity program. Let me analyze.

The paragraph explicitly states: no cybersecurity program, no formal processes. Board mention is perfunctory. There's a materiality statement at the end.

Per the codebook: "SPACs and shell companies explicitly stating they have no operations, no cybersecurity program, or no formal processes → None/Other regardless of incidental mentions of board oversight or risk acknowledgment."

The materiality sentence at the end doesn't override because this is a SPAC with no program. The codebook Case 8 example is almost identical.

So this maps to None/Other with a specificity score of 1.


reasoning: The paragraph describes the governance structure for cybersecurity oversight: the board has delegated oversight to a subsidiary's Information Security Committee, which reports back to the board. This is a governance-chain paragraph whose purpose is describing how oversight is structured, making it Board Governance. The named non-generic 'Information Security Committee' and the named individual heading it are firm-specific facts, but neither qualifies as QV-eligible (named committees and individuals without QV-eligible attributes like dates, dollar amounts, or named third-party firms don't count toward the two-fact QV threshold).

thinking:
Let me analyze this paragraph carefully.

Content: The paragraph describes board delegation of cybersecurity oversight to a subsidiary's Information Security Committee, headed by the CEO. It mentions occasional updates to the board.

Category: This is about governance structure - who oversees cybersecurity, delegation from board to committee, reporting back to board. The purpose is describing the oversight structure. Even though the CEO is named, the paragraph is about the governance chain, not about who the CEO is as a person. → Board Governance

Specific facts:
- "Information Security Committee" - named non-generic committee → IS fact

- "Mr. Tao Guolin" - a named individual, which typically qualifies as an IS fact based on the codebook examples, though he's identified primarily by his CEO role
- "CEO" - generic C-suite position, not a specific fact
- "PRC subsidiary" - too generic to count as specific
- "occasional updates" - vague cadence, not specific enough

The key distinction here is whether the named individual counts as a specific fact independent of his title, or whether naming him doesn't add specificity beyond the generic CEO role already mentioned.

Looking at the Information Security Committee - that's clearly a named, non-generic committee, so it's firm-specific. For QV purposes, neither the named individual nor the committee would qualify since they're not on the QV-eligible list. The specificity assessment comes down to whether the named individual pushes this into firm-specific territory, which it likely does given the committee is also named and non-generic.

fact: Information Security Committee

fact: Mr. Tao Guolin named as head of the committee


reasoning: This is a cross-reference pointing the reader to Item 1A Risk Factors. The materiality language ('could have a material adverse effect') describes what those risk factor sections discuss, not a company conclusion about whether cybersecurity has materially affected the business. Per the codebook, cross-references with materiality language describing what another section covers are None/Other.


reasoning: The paragraph contains a negative materiality assertion ('have not experienced any material cybersecurity threats or incidents'), which is the company stating a conclusion about whether cybersecurity has affected business outcomes — triggering Strategy Integration per Rule 6. The second clause is generic forward-looking caveat. No specific facts are present.

thinking:
Classify this paragraph.

"While we have not experienced any material cybersecurity threats or incidents in recent years, there can be no guarantee that we will not be the subject of future threats or incidents."

This contains a negative assertion about material incidents: "have not experienced any material cybersecurity threats or incidents" — this is a materiality assessment (negative assertion). Then followed by generic forward-looking caveat.

Per Rule 6 and the codebook: "we have not experienced any material cybersecurity incidents" → SI.

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


reasoning: This is a governance-chain paragraph describing oversight structure: Board provides oversight, CFO directs the security governance structure. The purpose is describing how oversight is organized, making it Board Governance per Rule 2. No IS-list facts are present — CFO is generic C-suite, 'Board' is generic governance, and 'security governance structure' is a generic program name.

thinking:
Classify this paragraph.

Content: "Under the ultimate direction of our CFO, with oversight from the Board, we maintain a security governance structure to evaluate and address cyber risk."

Category analysis:
- Mentions CFO directing, Board oversight, and a "security governance structure"
- This is a governance-chain paragraph spanning board → CFO → structure
- Purpose test: describing the oversight structure - who directs, who oversees
- CFO is not a cybersecurity-specific role (it's generic C-suite)
- Board oversight is mentioned
- The paragraph is about governance structure

This is a short paragraph describing the governance chain.

The Board provides oversight while the CFO directs the security governance structure. Checking specificity: CFO and Board are both generic governance terms per the exclusion list, and "security governance structure" is a generic program name with no named frameworks or specific details. This falls under Generic Boilerplate.


reasoning: The paragraph describes generic management responsibilities for overseeing cybersecurity threats and notifying the board of incidents. No named individual, no specific role title (just 'our management'), no credentials or qualifications — purely about management's generic duties. The trailing 'Public Offering' is erroneous text extraction. Person-removal test is borderline since 'management' is so generic, but the paragraph's purpose is defining management's responsibilities (assess threats, notify board), making it Management Role rather than RMP. No specific facts per the IS list — 'management' and 'board of directors' are both on the NOT list.

thinking:
Let me analyze this paragraph.

The paragraph describes management's role in overseeing cybersecurity threats and notifying the board in case of incidents. The last two words "Public Offering." seem like erroneous text extraction.

Category: The paragraph describes management overseeing cybersecurity threats and notifying the board. There's no named person, no credentials, no specific processes. It's generic language about management's responsibility.

Applying the MR vs RMP decision chain:
- Step 1: "Our management" is the subject - generic, not a specific role
- Step 2: Remove "our management" - "oversees the assessment and management of cybersecurity threats" - still coherent as process description

- This is really about governance structure and incident escalation—management oversees threats and escalates to the board. Since "management" is generic rather than a named role, and the core function is describing how incidents flow through the organization, this leans toward a Risk Management Process rather than a Management Role. The board isn't really the one overseeing here—management is the primary actor, responsible for assessing threats and notifying the board of incidents. This is clearly about management's procedural responsibilities, even if the language is extremely generic with no specific facts or frameworks. I'll stick with Management Role, Specificity 1.


reasoning: The first sentence is a negative materiality assertion ('has not experienced any material cybersecurity events'), which per Rule 6 is a materiality assessment → Strategy Integration. The 'could have a material and adverse impact' is generic speculation (not an assessment), and the cross-reference to Item 1A is noise. No firm-specific facts are present — all language is boilerplate.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three parts:
1. "has not experienced any material cybersecurity events" - negative assertion with materiality framing
2. "could have a material and adverse impact" - generic risk warning with "could"
3. Cross-reference to Item 1A

Per Rule 6: "we have not experienced any material cybersecurity incidents" is a negative assertion → Strategy Integration. The "could have" language is generic speculation (not an assessment). The cross-reference is noise.

The materiality assessment in the first sentence is the substantive content → Strategy Integration.

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

This scores low on specificity since there are no concrete details about the company's actual cybersecurity practices or any reference to established frameworks.


reasoning: The grammatical subject is 'processes,' and the paragraph describes which teams oversee cybersecurity risk management. Applying the three-step MR vs RMP test: Step 1 — subject is 'processes' (RMP signal); Step 2 — removing team names leaves a coherent but empty process statement; Step 3 — no qualifications, credentials, or career history → RMP. The specific departmental composition (IT, Information Security, Product Security, Compliance, Legal) is a firm-specific fact per the IS list.

thinking:
Classify this paragraph.

Content: describes who oversees cybersecurity risk management processes - lists specific teams/departments.

Category: This mentions leadership from specific teams overseeing processes. Apply the MR vs RMP decision chain:
- Step 1: Subject is "processes" - "Our cybersecurity risk management and strategy processes are overseen by leaders from..."
- The grammatical subject is "processes" being overseen by leaders. This points to RMP. But wait - the paragraph is about WHO oversees, not what the processes do.

Actually, this is describing organizational structure - who is responsible. But it doesn't describe any person's qualifications, credentials, or background.

The core issue here is that while the sentence structure mentions processes, the actual content is about which teams hold responsibility for oversight. It's organizational structure rather than a description of the processes themselves or any individual's role. The paragraph identifies team compositions involved in oversight, but doesn't elaborate on what those teams actually do or how the processes function.

Given the three-step test: the subject is "processes" which points toward RMP, removing the team names still leaves a coherent statement about process oversight, and there are no individual qualifications or credentials mentioned. That confirms Risk Management Process as the category.

For specificity, the paragraph names five distinct teams—Information Technology, Information Security, Product Security, Compliance, and Legal—which is clearly firm-specific information rather than generic guidance.

fact: Overseen by leaders from Information Technology, Information Security, Product Security, Compliance, and Legal teams


reasoning: This paragraph contains generic risk warnings about cybersecurity threats using speculative 'could have a material adverse effect' language, which per the codebook is boilerplate speculation, not a materiality assessment. It describes no processes, governance structures, incidents, or firm-specific details — it is general business language that could appear in any company's filing unchanged. The company name suggests a SPAC, reinforcing the lack of substantive disclosure.

thinking:
Let me analyze this paragraph from Arogo Capital Acquisition Corp., which appears to be a SPAC based on the name.

The paragraph contains generic risk language about cybersecurity threats. Let me check for materiality assessment vs. generic risk warning.

"could have a material adverse effect" — this is generic speculation ("could"), not an assessment. Per the codebook, "could have a material adverse effect on our business" is NOT a materiality assessment.

"could materially adversely affect our operations" — same, generic speculation.

No substantive disclosure of any program, process, governance, or incident. This is generic risk language that could apply to any company.

This is clearly None/Other — no specific facts disclosed, just boilerplate language. Specificity score is 1.


reasoning: The paragraph describes management's preparedness to handle cybersecurity risks — the CFO and other managers underwent briefings to qualify them for assessing cyber threats. This is about WHO is responsible and their readiness, mapping to Management Role. However, no specific facts appear: CFO is generic C-suite (NOT list), the advisory firm is unnamed, and the third-party certifications are unspecified. All details are generic boilerplate.

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses the CFO and management receiving briefings from a cybersecurity advisory firm, and mentions third-party service providers having cybersecurity experience/certifications.

Category analysis:
- Mentions CFO and management undergoing briefings - this is about preparing management to handle cyber risks
- The briefings are FROM a cybersecurity advisory firm (unnamed)
- Second sentence mentions third-party service providers having experience/certifications

Step 1 (Subject test): CFO and management are subjects. Continue to Step 2.
Step 2 (Person-removal test): Remove "Our Chief Financial Officer and other members of management" - remaining: "have undergone various briefings from our cybersecurity advisory firm to prepare them to effectively assess and manage material risks from cybersecurity threats." This doesn't stand alone well as a process description - it's about WHO was trained.

The tiebreaker test shows no specific certifications or experience details for the named individuals themselves—only for the third-party providers. So this is really about management's readiness and preparation for cyber risk, though the CFO reference is generic C-suite and "other members of management" is vague. The paragraph's core focus is describing how management has been trained and prepared, but it's thin on substantive detail about their actual qualifications. I'm moving on to evaluate the next piece of content against the same criteria—checking for specificity, named frameworks, and whether it qualifies as generic boilerplate or contains substantive details from the IS list.


reasoning: This is a cross-reference directing the reader to Item 1A Risk Factors. The materiality language ('may materially affect') describes what Item 1A discusses, not a company conclusion about whether cybersecurity has materially affected business outcomes. Per the codebook, 'For risks that may materially affect us, see Item 1A' is None/Other — pointing elsewhere, not making an assessment.


reasoning: The paragraph describes the company's internal cybersecurity controls (firewalls, endpoint detection, vulnerability management, backups) and third-party risk processes. The CISO and CIO are mentioned as attribution for who oversees the organization, but the substantive content is about what the program does. Person-removal test: removing the CISO/CIO references leaves a fully coherent process description → Risk Management Process. CISO and CIO are cybersecurity-specific titles on the IS list, giving Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes the cybersecurity organization, its placement under CISO/CIO, lists security controls, and mentions third-party risk processes.

Category analysis:
- Mentions CISO and CIO but as attribution for the organization
- Primary content is about what the cybersecurity organization does: security controls, processes
- Person-removal test: Remove CISO/CIO references → "We have a dedicated cybersecurity organization... which operates within our information technology department. Our cybersecurity organization employs multiple security controls..." — still coherent
- → Risk Management Process

The third-party mention is one component of the broader program description, not the central topic.

Now I'm checking the specificity level. The paragraph references CISO and CIO roles from the IS list, but there are no named frameworks, specific dates, dollar amounts, or named tools—just the organizational structure and general control descriptions. Since named roles alone don't qualify as QV-eligible hard facts, this falls into Firm-Specific without qualifying for QV.

fact: Chief Information Security Officer (CISO)


reasoning: This paragraph is general IT-dependence and business context language describing the importance of IT systems, the types of sensitive data collected (PHI, PII), and acknowledging the regulatory landscape ('we are subject to... HIPAA and CCPA'). It does not describe any cybersecurity process, program, framework, governance structure, or materiality assessment. While HIPAA and CCPA are named, they appear only in the context of 'we are subject to' — acknowledging a regulatory landscape rather than describing what the company does to manage cybersecurity risk. The paragraph's primary purpose is introductory business context, not substantive cybersecurity disclosure.

thinking:
Let me analyze this paragraph from ModivCare Inc's 10-K Item 1C filing.

The paragraph describes the importance of IT systems, the types of data collected (PHI, PII, etc.), regulatory requirements (HIPAA, CCPA), and how IT supports business operations.

Category: This is general IT-dependence language. It describes what data the company collects and that they're subject to privacy regulations. It doesn't describe any cybersecurity process, program, or framework. No materiality assessment. No incident. No board/management governance. It mentions HIPAA and CCPA but only in the context of "we are subject to" these regulations - not describing what the company does to comply.

Now I'm checking the codebook against this language. The paragraph names specific regulations like HIPAA and CCPA, which would normally trigger the Risk Management Process category per Case 10, but the actual content is really just about IT importance and data types—the regulatory mention feels almost incidental. The codebook's None/Other category seems more appropriate here since there's no actual description of company-specific compliance programs or risk management processes, just acknowledgment that these regulations apply. I'm wrestling with whether naming specific regulations like HIPAA and CCPA is enough to trigger Risk Management Process Specificity 2, or if this paragraph is really just introductory business context. The codebook Case 10 suggests naming those regulations should push it to RMP Spec 2, but the paragraph's actual substance is about IT importance and data types—it doesn't describe any actual cybersecurity program or process. I'm leaning toward None/Other since this reads as general contextual language rather than substantive disclosure, even though the regulatory mentions create some ambiguity. I'm reconsidering the classification here. The definition for None/Other explicitly calls out "generic IT-dependence language" as a key indicator, and this paragraph fits that pattern perfectly—it's essentially saying IT is critical to operations, we handle sensitive data, we're subject to regulations, and IT enables our business. There's no actual description of security processes or activities, just contextual framing. So None/Other with Specificity 1 is the right call.


reasoning: Applying the person-removal test: removing the VP title and reporting line to Chief Strategy Officer, the paragraph still coherently describes what the cybersecurity program does — ensuring CIA, mitigating threats, measuring/managing risk, prevention/detection/mitigation/remediation, and implementing policies. The roles are incidental attribution; the dominant content is the security team's programmatic functions. The VP of IT services title (analogous to 'VP of IT/Security' on the IS list) provides one firm-specific fact, but no QV-eligible hard facts (no dates, dollar amounts, named firms, or tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the IT Department's role in cybersecurity, led by a VP of IT services who reports to the Chief Strategy Officer. It describes what the security team does - oversees the cybersecurity program, measures and manages risk, prevention/detection/mitigation/remediation, implements policies/programs/procedures.

**Category Analysis:**

Step 1 - Subject test: The IT Department and security team are the subjects. Mixed - person/role and program.

Step 2 - Person-removal test: Remove "vice president of information technology services," "reports to our Chief Strategy Officer," and the team description. The remaining content describes what the program does: ensuring CIA, mitigating threats, measuring/managing risk, prevention/detection/mitigation/remediation, implementing policies.

Looking at the structure more carefully, I see this is actually a mixed paragraph with both organizational hierarchy and functional responsibilities. The reporting lines are woven throughout - the VP reporting to the Chief Strategy Officer and the security team's reporting structure for incidents - but the dominant content focuses on what the cybersecurity program actually does rather than who's in charge. "Vice president of information technology services" is essentially a VP of IT role, which matches the specific title on the IS list, so I'd count that as cybersecurity-specific. Let me verify against the NOT list to make sure it's not excluded—it's not listed there, so this should qualify. VP of IT. The IS list says "VP of IT/Security" counts. I think this qualifies.

- "Chief Strategy Officer" - This is a generic C-suite title, on the NOT list.
- "cross-functional group" - generic, NOT list
- "senior management, internal legal advisors, communication specialists" - somewhat specific team composition but fairly generic

So I have one specific fact: VP of information technology services (cybersecurity-specific title per IS list). That gives Firm-Specific.

Wait, is "VP of information technology services" really a cybersecurity-specific title? The IS list says "VP of IT/Security." This person is VP of IT services, not specifically cybersecurity. But the IS list includes "VP of IT/Security" and "CIO" and "CTO" as cybersecurity-specific. I think VP of IT services is close enough to VP of IT to count.

Actually, looking more carefully at the NOT list: "Head of IT", "IT Manager", "Director of IT" are explicitly excluded as general corporate titles, not cybersecurity roles. The "/Security" qualifier in "VP of IT/Security" seems important. But then again, the IS list also includes "CTO" and "CIO" which are general IT titles too, so I think the VP of IT services title still counts as firm-specific.

No QV-eligible facts here—no dates, dollar amounts, named firms, tools, certifications, or headcounts. The specific incident reporting structure to senior management and legal advisors doesn't add anything new either.

So my conclusion: Firm-Specific (3) based on the VP of IT services title.


reasoning: The paragraph's primary purpose is identifying WHO oversees cybersecurity — the CISO and Cybersecurity Committee — and their scope of responsibility. Applying the three-step MR vs. RMP chain: Step 1, person/role as subject → continue; Step 2, removing roles leaves only skeletal text ('key cybersecurity policies and processes are overseen... policies to monitor prevention, detection, mitigation, and remediation') with minimal standalone process substance → borderline, favoring MR; Step 3, no qualifications → would push toward RMP. However, the paragraph contains virtually no process detail — it describes oversight roles, not processes themselves. The communicative purpose is establishing management responsibility, not describing methodology. CISO (cybersecurity-specific title) and Cybersecurity Committee (named non-generic committee) are both firm-specific facts but neither is QV-eligible.

thinking:
Let me analyze this paragraph.

The paragraph mentions the CISO and Cybersecurity Committee overseeing policies and processes, and being informed about monitoring prevention, detection, mitigation, and remediation.

Category: This is about who oversees cybersecurity policies. The CISO and Cybersecurity Committee are the subjects. Let me apply the decision chain.

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

The Cybersecurity Committee could be a board-level or management-level committee. The paragraph pairs CISO with Cybersecurity Committee as joint overseers. There's no mention of the Board of Directors.

This looks like management-level oversight. Testing the person-removal approach: if I strip out the CISO and Cybersecurity Committee, what remains is thin—it's fundamentally about the oversight structure and who holds responsibility, not about describing the actual processes themselves.

The paragraph doesn't detail qualifications or credentials, and it's not laying out the risk management processes in depth. It's really about the governance layer—establishing that these specific roles oversee cybersecurity policies and incident response. That points toward Management Role, though it's borderline since there are no qualifications mentioned.

But stepping back: the codebook defines Management Role as describing "who the person is"—their experience, certifications, education, team size. This paragraph doesn't do that. It describes what the CISO and Committee oversee, not who they are or what they bring to the role. The processes mentioned are vague and generic. So this actually fits Risk Management Process better, even though the content feels more like an oversight structure.

I'm going to classify this as Management Role though, because the paragraph's core purpose is identifying who holds responsibility—the CISO and Cybersecurity Committee—and what their oversight scope covers. The process details are just window dressing.

Now I'm checking the specificity level. The CISO is a cybersecurity-specific title and the Cybersecurity Committee is a named non-generic committee, so both are firm-specific facts, but neither qualifies as quantifiable or verifiable. There are no dates, dollar amounts, headcounts, named external firms, tools, or certifications mentioned, which puts this squarely in the Firm-Specific category.

fact: Chief Information Security Officer

fact: Cybersecurity Committee


reasoning: The paragraph describes management-level committee structure for cybersecurity: the IT Steering Committee's composition (senior management, IT team, operations personnel), its functions (strategic planning, cybersecurity threats), and reporting from the IT manager to the Risk Management committee. There is no board reference; the codebook assigns management committees responsible for cybersecurity to Management Role. No individual credentials or career history are provided, but the organizational structure and reporting lines are the primary content. Two named non-generic committees (IT Steering Committee, Risk Management committee) make it Firm-Specific, but neither counts toward QV.

thinking:
Let me analyze this paragraph.

Content: Describes an IT Steering Committee's composition and function, plus reporting to Risk Management committee.

Category analysis:
- Mentions "IT Steering Committee" - a named committee
- Describes its composition and function
- Mentions "IT manager" reporting to "Risk Management committee"
- This is about governance structure - how oversight works, committee composition, reporting lines

The paragraph describes a committee structure and reporting. The IT Steering Committee discusses cybersecurity threats, and the IT manager reports to the Risk Management committee. This is about oversight structure.

Is this Board Governance or Management Role or RMP?

The key distinction is whether these are board-level or management-level committees. The IT Steering Committee is clearly a management committee handling cybersecurity oversight, and since the codebook defines Management Role as "management committees responsible for cybersecurity," this fits that category rather than Board Governance. the paragraph is fundamentally about organizational governance—the committee's makeup, what it oversees, and how it reports up the chain. This fits Management Role since it describes a management-level committee responsible for cybersecurity oversight. The IT Steering Committee appears to be a named, non-generic committee, so I should check if it matches the specificity criteria.

Both the IT Steering Committee and Risk Management committee qualify as named non-generic committees, which points to Firm-Specific classification. The IT manager title and quarterly cadence are generic descriptors that don't add specificity. Since named committees don't contribute to the QV threshold and there are no dates, amounts, or other quantifiable markers, this lands at Firm-Specific (3) with no QV designation.

fact: IT Steering Committee

fact: Risk Management committee


reasoning: The paragraph's dominant content is about WHO the CIO is — 30 years of experience, career history in professional services, joining in 2018, and prior roles — making the person's qualifications and background the primary subject (Management Role per Step 3 qualifications tiebreaker). The ISMS Committee is a management committee (covered by MR definition), and its composition and reporting structure reinforce MR over RMP. Two QV-eligible hard facts: specific years of experience (30 years) and specific date (2018).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. CIO's qualifications (30 years experience, joined 2018, prior roles)
2. CIO's reporting to ISMS Committee
3. ISMS Committee composition and responsibilities

Let me apply the decision rules.

**Step 1 - Subject test:** "Our cybersecurity program is overseen by the leaders..." - starts with program but quickly shifts to the CIO. The CIO is a major subject.

**Step 2 - Person-removal test:** Remove CIO details (30 years experience, joined 2018, prior roles, reporting line).

What remains is the ISMS Committee description—its composition, responsibilities, and goals. That's still coherent, but a significant chunk of the paragraph is devoted to the CIO as a person.

Looking at the content distribution, there's roughly equal weight given to the CIO's background and qualifications versus the ISMS Committee's structure and role. The paragraph spends considerable space on the CIO's credentials—over 30 years of experience, the 2018 joining date, and detailed prior roles in information security and technology across large public companies and global implementations. Then it transitions to describing the committee itself.

If I strip away the CIO's background, the ISMS Committee description remains intact. But if I remove the committee details, there's still substantial content about the CIO's credentials and experience. The opening frames this as oversight of the cybersecurity program, then establishes who provides that oversight and why they're qualified. The CIO's qualifications—the years of experience, career trajectory, and specific industry background—constitute meaningful content here.

This points toward a Management Role classification because the paragraph emphasizes years of experience, career history, and professional background, which are management-specific indicators.

The ISMS Committee itself is a management committee responsible for cybersecurity governance, which also fits the Management Role category.

Looking at specificity: the CIO title is cybersecurity-specific, the 30 years of experience is a concrete number, the 2018 joining date is a specific date, and the ISMS Committee is a named internal program. The reference to professional services is vague by comparison.

This is clearly Management Role with strong specificity markers.

fact: CIO (Chief Information Officer)

fact: over 30 years of relevant work experience

fact: joined Huron in 2018

fact: Information Security Management System (ISMS) Committee