reasoning: The paragraph primarily addresses how third-party cyber risks are managed through vendor assessments, categorization, and incident procedures, fitting the Third-Party Risk category. No specific facts (e.g., domain terms, firm-unique details, or verifiable claims) are present, so specificity is Generic Boilerplate.


content_category: Third-Party Risk

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily addresses oversight of third-party service providers, making Third-Party Risk the appropriate category. It contains no specific facts like named providers, quantified data, or domain-specific terminology, so specificity is Generic Boilerplate.

provider: xiaomi

stage: benchmark


content_category: Strategy Integration

reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality assessment (no material impact), which aligns with Strategy Integration per Rule 5. No specific facts are present—no domain terms that show expertise, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


content_category: Board Governance

reasoning: The paragraph primarily addresses board oversight of cybersecurity, including updates and approvals, fitting Board Governance; no specific facts are present, making it generic boilerplate as all statements are qualitative and non-unique.


content_category: Management Role

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the responsibilities of the Information Security Officer and Chief Information Officer, which aligns with Management Role. It contains no specific facts (e.g., verifiable claims, firm-specific details, or domain expertise terms) that elevate specificity beyond generic boilerplate language.


content_category: None/Other

reasoning: The paragraph is a cross-reference to risk factors and does not describe any substantive cybersecurity measures, incidents, or governance, so it falls under None/Other. It contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor oversight and additional scrutiny for sensitive data, directly fitting the Third-Party Risk category; specificity is Generic Boilerplate as it contains no specific facts that elevate above Level 1, such as named roles, quantified data, or verifiable claims.


reasoning: The paragraph primarily describes board oversight of cybersecurity through delegation to the Audit Review Committee, answering the Board Governance question. It contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims) that elevate specificity beyond generic boilerplate language.


reasoning: The paragraph primarily answers that the company, as a SPAC with no operations, has no cybersecurity program and faces no significant risk, which falls under None/Other per Rule 6 for SPACs with no substantive disclosure. No domain terms, firm-specific cybersecurity facts, or verifiable claims are present, so specificity is Level 1.


reasoning: The paragraph primarily explains why cybersecurity is not applicable due to the company being a SPAC with no operations, which aligns with None/Other per Rule 6 for no-operations companies; no specific cybersecurity facts, domain terms, or verifiable claims are present, so specificity is Level 1.


content_category: Incident Disclosure

fact: $14.3 million

reasoning: The paragraph primarily answers what happened in a cybersecurity incident by describing a specific event with date and costs, fitting Incident Disclosure. Specificity is Level 4 due to verifiable facts like the exact date and monetary amount, which could be independently confirmed.


reasoning: The paragraph primarily addresses materiality assessments and potential business impacts of cybersecurity, which aligns with Strategy Integration; it contains no specific facts (e.g., no verifiable claims, domain terms, or firm-specific details), so specificity is generic boilerplate.


reasoning: The paragraph primarily describes the company's general IT systems and data collection without addressing any cybersecurity-specific questions like oversight, risk management, or incidents, so it is classified as None/Other. No facts in the paragraph elevate specificity above Level 1, as the terms used are generic business operations language that do not demonstrate cybersecurity domain expertise, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality conclusion (have not materially affected and are not reasonably likely to materially affect), which aligns with Strategy Integration under Rule 5; it contains no specific cybersecurity facts, domain terms, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph is a cross-reference to risk factors with no substantive cybersecurity disclosure, fitting None/Other; and it contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so it is Generic Boilerplate.


reasoning: The paragraph is a cross-reference to another section of the filing, not describing any substantive cybersecurity governance, processes, or incidents, so it primarily answers none of the six questions and is classified as None/Other. No specific facts are present—such as domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph directly addresses managing third-party cybersecurity risks through due diligence and monitoring, making Third-Party Risk the primary category. It contains no specific facts—such as domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business through a materiality assessment (stating no material risks have affected or are likely to affect the company), which aligns with Strategy Integration per Rule 5. No specific facts are present—such as domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through reports and monitoring, fitting Third-Party Risk. It contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity by describing the presentation of findings to a board committee (ERC Committee), which is a governance-chain activity. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—making it generic boilerplate.


reasoning: The paragraph primarily addresses how cybersecurity incidents could materially affect business operations and finances, fitting Strategy Integration; it contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's discussions and annual reviews, fitting Board Governance; it contains no specific facts—only generic governance language—so specificity is Level 1.


content_category: Risk Management Process

reasoning: The paragraph primarily answers what the cybersecurity program does by describing information security processes for identifying, assessing, and managing risks, which aligns with Risk Management Process; it contains no firm-specific or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed, with central focus on vendor oversight processes, fitting Third-Party Risk. It contains no specific facts that elevate specificity above Level 1, as all language is generic process descriptions without domain expertise, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily answers none of the substantive questions—it is a general statement about cybersecurity importance and risks without addressing governance, management, processes, incidents, or strategy, so it is classified as None/Other. It contains no specific facts (no domain terms, firm-specific details, or verifiable claims), so specificity is Level 1 Generic Boilerplate.


reasoning: The paragraph primarily states that cybersecurity has not affected business outcomes, which directly answers the Strategy Integration question under Rule 5. It contains no specific facts—only generic assertions about absence of impact or incidents—so specificity is Level 1.


reasoning: The paragraph primarily answers that the company, as a SPAC with no operations, does not face significant cybersecurity risk and has no cybersecurity program, which falls under None/Other as it lacks any substantive cybersecurity disclosure. Since it is a None/Other paragraph, specificity is Generic Boilerplate with no specific facts elevating it above Level 1.


reasoning: The paragraph primarily describes the use of third-party experts and service providers in cybersecurity activities like risk assessment and incident response, which falls under Risk Management Process; no specific facts are present, as all terms are generic and lack firm-specific or verifiable details.


reasoning: The paragraph primarily describes board and committee oversight of cybersecurity risks, which directly answers the Board Governance question. It contains no specific facts—such as domain terms, firm-specific details, or verifiable claims—that would elevate specificity above generic boilerplate language common in SEC filings.


reasoning: The paragraph primarily describes the components and integration of the cybersecurity risk management program, answering what the program does, so it falls under Risk Management Process. It contains no specific facts that elevate specificity above Level 1, as it uses generic terms like 'assessments,' 'team responsible,' and 'external service providers' without any verifiable claims, firm-unique details, or domain-specific terminology that passes the ERM test.


reasoning: The paragraph describes business reliance on IT systems and data without addressing any specific cybersecurity question like governance, management, or processes, fitting None/Other. No specific facts are present to elevate specificity beyond generic boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed, with central focus on vendor oversight and risk identification, fitting Third-Party Risk; it contains no specific facts like named entities, numbers, or domain-specific terms that pass the ERM test, so specificity is Generic Boilerplate.


reasoning: The paragraph is a generic business statement about data collection in the normal course of business, not answering any cybersecurity-specific question (e.g., oversight, processes, incidents), and contains no specific facts, so it's classified as None/Other with Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing roles like CEO, MIS consultant, and MIS supervisor, which fits Management Role; specificity is Level 1 because no domain terms, firm-specific facts, or verifiable claims are present—only generic role descriptions that lack informative details.


specificity_confidence: medium

reasoning: The paragraph primarily addresses how third-party cyber risks are managed through vendor monitoring, evaluation, and a board-approved policy, fitting the Third-Party Risk category; it lacks specific facts like verifiable claims, named roles at VP level, or domain-specific terminology that would elevate specificity above generic boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's reporting and annual reviews, fitting Board Governance. It contains no specific facts (e.g., named roles, verifiable claims, or domain-specific terms), so specificity is Generic Boilerplate.


fact: CFO has been responsible for his oversight function as CFO to the Company for three years

fact: CFO has worked in the financial services industry for more than 30 years

fact: CCO has been responsible for oversight functions for the Company for three years

fact: Current CCO has been serving since April 2025

fact: CCO has worked in the financial services industry for more than 35 years

reasoning: The paragraph primarily addresses how management is organized for cybersecurity, detailing roles and experience of the CFO and CCO, which aligns with Management Role; specificity is Level 4 due to verifiable facts like specific tenure dates and lower-bound years of experience that could be independently checked.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through diligence, contractual protections, and monitoring services, making Third-Party Risk the central category. It contains no specific facts, dates, names, or verifiable claims, so it is generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily addresses the company's reliance on third parties for cybersecurity, which is the central topic of Third-Party Risk; for specificity, it contains no domain-specific terms, firm-specific details, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph primarily answers that the company has no operations and thus no cybersecurity threats, which is a forward-looking disclaimer or status statement fitting None/Other; as a None/Other paragraph, it contains no specific cybersecurity facts and is Generic Boilerplate.


reasoning: The paragraph defines the term 'Cybersecurity threat' and does not address any of the six substantive questions (e.g., board governance, management role), so it is classified as None/Other. As per rules, None/Other paragraphs always receive Generic Boilerplate specificity, resulting in no specific facts listed.


reasoning: The paragraph primarily answers the question of how cybersecurity affects business outcomes by stating a negative materiality assessment (no material incidents), which aligns with Strategy Integration under Rule 5. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the oversight chain (monitoring to management to Audit Committee to Board), which is Board Governance. It contains no specific facts like names, dates, or quantified data, so specificity is Generic Boilerplate.


reasoning: The paragraph is a general commitment statement about cybersecurity awareness and potential impacts, without answering any specific question about governance, management, processes, or incidents, thus fitting None/Other. It contains no specific facts—such as domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily states a conclusion about no material cybersecurity incidents affecting business outcomes, which directly answers the Strategy Integration question per Rule 5. Specificity is Generic Boilerplate because no specific facts (e.g., verifiable claims, firm-specific details, or domain terms) are present; all statements are generic or non-verifiable.


specificity_confidence: low

reasoning: The paragraph primarily answers what the cybersecurity program does by describing the use of third-party partners for services like cyber risk advisory, fitting Risk Management Process; it contains no specific facts that elevate specificity above Level 1, as it uses generic language without domain-specific terms, firm-unique details, or verifiable claims.


reasoning: The paragraph primarily answers a speculative question about potential cybersecurity impacts, but Rule 5 excludes 'could have a material adverse effect' as NOT Strategy Integration, and it describes no specific measures or incidents, so it falls under None/Other; no specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing the process for assessing vendors' data protection practices, which is central to Third-Party Risk. It contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing the Steering Committee's monitoring and review activities, which aligns with Risk Management Process; no specific facts are present to elevate specificity above Generic Boilerplate, as the language is generic oversight without domain-specific terms, firm-unique details, or verifiable claims.


category_confidence: medium

reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a negative assertion about incidents and speculating on potential impacts like disruptions and fines, which aligns with Strategy Integration per Rule 5; no specific facts are present, as the language is generic and not externally verifiable or firm-distinguishing, leading to Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how the board oversees cybersecurity by describing delegation to the Audit Committee, fitting Board Governance. It contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so it is Generic Boilerplate.


fact: phishing simulations

fact: malware detection

reasoning: The paragraph primarily answers what the cybersecurity program does by describing security awareness activities like phishing simulations and malware detection training, fitting Risk Management Process. Specificity is driven by domain-specific terms such as 'phishing simulations' and 'malware detection' that demonstrate cybersecurity expertise, but no firm-specific or verifiable facts are present.


reasoning: The paragraph primarily addresses how management is organized and responsible for cybersecurity risk, fitting Management Role. It contains no specific facts (e.g., named roles, dates, numbers, or verifiable claims), so specificity is Level 1 Generic Boilerplate.


reasoning: The paragraph primarily addresses board oversight through periodic meetings to assess cybersecurity status, fitting Board Governance; no specific facts are present, as the language is vague and generic, lacking domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating conclusions about material impacts (e.g., no incidents to date, potential material effects), which aligns with Strategy Integration; it contains no specific facts that elevate specificity above generic boilerplate, as all statements are speculative or industry-general without verifiable or firm-specific details.


reasoning: The paragraph primarily addresses materiality of cybersecurity incidents on business outcomes, fitting Strategy Integration per Rule 5. It contains no specific facts—negative assertions and cross-references are not verifiable—so specificity is Generic Boilerplate.


fact: CIO has more than twenty years of experience as an information technology professional

fact: CIO has been CIO since 2007

reasoning: The paragraph primarily addresses management organization and roles, such as the Cyber Risk Committee and CIO's responsibilities, fitting Management Role; specificity is Level 4 due to verifiable facts like the CIO's experience duration and tenure start date.


reasoning: The paragraph primarily answers how the board oversees cybersecurity risks by describing board review of risk factors, falling under Board Governance; it contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims) that elevate specificity above generic boilerplate.


reasoning: The paragraph primarily serves as a cross-reference to risk factors in another section, answering none of the substantive cybersecurity questions, and contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims) that would elevate specificity beyond generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality assessment (no risks have materially affected or are reasonably likely to affect operations), which aligns with Strategy Integration under Rule 5. It contains no specific facts—no verifiable claims, firm-specific details, or domain expertise—so specificity is Level 1 (Generic Boilerplate).


reasoning: The paragraph primarily answers what the cybersecurity program does by describing incident response processes, team collaboration, and testing activities, fitting Risk Management Process; no specific facts are present to elevate specificity, as all language is generic and not firm-specific or verifiable.


reasoning: The paragraph primarily addresses regulatory requirements and cross-references without answering any substantive cybersecurity questions about governance, management, or risk processes, hence None/Other. It contains no firm-specific or verifiable cybersecurity facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes management roles and committee structure for cybersecurity oversight, answering 'How is management organized to handle cybersecurity?', which aligns with Management Role. No specific facts (domain terms, firm-specific details, or verifiable claims) are present, as all language is generic and lacks distinguishing or verifiable elements, resulting in Generic Boilerplate specificity.


fact: penetration testing

fact: forensic analysis

fact: NIST framework

fact: Global Corporate Continuity Program

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor oversight and risk assessment, which aligns with Third-Party Risk; specificity is driven by the firm-specific named program 'Global Corporate Continuity Program' and domain terms like penetration testing and NIST framework, elevating it to Level 3.


fact: CISO has over 30 years of experience

fact: holds CISSP designation

fact: holds CIPP designation

fact: CIO Program Certificate from National Defense University

reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on the CISO's role, reporting lines, and credentials, which aligns with Management Role. Specificity is Level 4 due to verifiable claims such as the CISO's 30 years of experience and specific certifications (CISSP, CIPP, and a certificate from National Defense University).


reasoning: The paragraph primarily addresses how the board is overseeing cybersecurity by reshaping the board and intending to develop a cybersecurity risk management program, which aligns with Board Governance; it lacks any specific facts such as domain terms, firm-specific details, or verifiable claims, making it generic boilerplate for specificity.


fact: Chief Operating Officer and Chief Compliance Officer

reasoning: The paragraph primarily addresses management's responsibilities and expertise in cybersecurity, fitting Management Role; specificity is driven by the named leadership roles (COO and CCO), which are firm-specific facts distinguishing this company's cybersecurity organization.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through committee structure, fitting Board Governance. It contains no specific facts (e.g., domain terms that fail ERM test, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


fact: System and Organization Controls reports

reasoning: The paragraph centrally addresses managing third-party cybersecurity risks through vendor evaluation and SOC report requests, fitting Third-Party Risk; the mention of SOC reports is a domain-specific term that demonstrates cybersecurity expertise, driving specificity to Domain-Adapted.


fact: forensic investigation completed on December 13, 2023

fact: last confirmed unauthorized activity on November 20, 2023

reasoning: The paragraph primarily answers what happened in a cybersecurity incident by describing specific dates and actions, fitting Incident Disclosure. Specificity is Level 4 due to verifiable dates (December 13, 2023, and November 20, 2023) that an external party could confirm.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating conclusions about the absence of material incidents and the unlikelihood of material impact, which aligns with Strategy Integration per Rule 5; specificity is Level 1 because the paragraph contains no specific facts—only generic materiality assertions and cross-references, with no domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph is a general statement about technology dependence without addressing any substantive cybersecurity questions like governance, management roles, risk processes, or incidents, so it fits None/Other; it contains no specific facts, so specificity is Level 1.


reasoning: The paragraph is a general commitment statement about security without addressing any specific cybersecurity questions (e.g., governance, management, processes), so it falls under None/Other; it contains no specific facts, making it generic boilerplate with no domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily addresses board oversight of cybersecurity through delegation to the Audit Committee and reporting flows, fitting Board Governance; it contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through a vendor risk management program, fitting the Third-Party Risk category. It contains no domain-specific terms, firm-specific facts, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity incidents affect business outcomes by stating a conclusion about no material adverse effect, fitting Strategy Integration; it contains no specific facts, so specificity is generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a materiality assessment (no material risks have affected or are likely to affect the Company), which aligns with Strategy Integration. It contains no specific facts—such as named roles, dates, numbers, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily states a materiality assessment about cybersecurity's impact on business outcomes, which directly answers the Strategy Integration question; it contains no specific facts (e.g., verifiable claims, firm-specific details, or domain expertise terms), so it is generic boilerplate.


reasoning: The paragraph is a generic statement about the importance of cybersecurity without answering any specific question about governance, management, risks, incidents, or strategy; it contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph directly addresses how third-party cyber risks are managed through selection, oversight, and contractual requirements, making Third-Party Risk the central topic. It contains no specific facts—such as domain terms, firm-specific details, or verifiable claims—so it is classified as Generic Boilerplate for specificity.


reasoning: The paragraph primarily answers how cybersecurity affects business by stating a conclusion about no material incidents and referencing potential financial impacts, fitting Strategy Integration under Rule 5. No specific facts are present that elevate specificity above Level 1, as the date is reporting context and negative assertions are not verifiable, resulting in Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business finances through materiality assessments (past impact and future likelihood), fitting Strategy Integration. It contains no specific facts—only general assessments and speculations—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by describing proactive detection, investigation, and prevention measures, fitting Risk Management Process; specificity is Level 1 because no domain terms, firm-specific facts, or verifiable claims are present—the language is generic boilerplate.


reasoning: The paragraph primarily answers whether cybersecurity has affected business outcomes by stating a negative assertion about material incidents, which under Rule 5 is classified as Strategy Integration; it contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses cyber risk insurance, which relates to how cybersecurity affects business finances, fitting Strategy Integration; it contains no specific facts (e.g., no quantified details, named roles, or verifiable claims), making it generic boilerplate.


reasoning: The paragraph is a cross-reference to Item 1A Risk Factors with speculative forward-looking language about potential cybersecurity impacts, which does not substantively answer any of the six core questions and is standard boilerplate, so None/Other is appropriate. It contains no specific facts—no domain terms that demonstrate expertise, no firm-specific details, and no verifiable claims—so specificity is Level 1.


fact: NIST CSF

reasoning: The paragraph primarily answers how the cybersecurity program is designed and assessed using NIST CSF, which is a core risk management process activity. Specificity is driven by the reference to NIST CSF, a domain-specific framework that demonstrates cybersecurity expertise beyond generic ERM language.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through a dedicated program, fitting the Third-Party Risk category; it contains no specific facts, dates, or verifiable claims, making it generic boilerplate for specificity.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality assessments (has not materially affected and is reasonably likely to materially affect), which aligns with Strategy Integration. It contains no specific facts—only generic statements about threats and materiality—so specificity is Generic Boilerplate.


fact: Chief Technology Officer reports to Executive Vice President – Operations

fact: cybersecurity incidents are reported to the legal department

reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on reporting lines and qualifications, which aligns with Management Role. Specificity is driven by firm-specific facts about the company's organizational structure, such as the CTO's reporting line and incident reporting process, elevating it to Level 3.


reasoning: The paragraph primarily describes the cybersecurity program's design to prevent, detect, and respond to incidents, which aligns with Risk Management Process, though it also mentions potential business impacts; specificity is Level 1 because no specific facts (e.g., names, dates, verifiable claims) are present, making it generic boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Risk Committee, fitting Board Governance; it contains no specific facts like numbers, dates, or unique details, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business through materiality assessments (e.g., stating that prior incidents have not had a material adverse effect), which aligns with Strategy Integration under Rule 5; it contains no specific facts, dates, numbers, or verifiable claims, making it generic boilerplate for specificity.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing employee training and integration into enterprise risk management, fitting Risk Management Process. It contains no specific facts that elevate specificity above Level 1, as it uses generic risk management language without firm-specific or verifiable details.


reasoning: The paragraph is a cross-reference to risk factor disclosures and does not answer any substantive cybersecurity question; it contains no specific facts about the company's cybersecurity posture, so it is classified as None/Other with Generic Boilerplate specificity.


fact: quarterly vulnerability scanning for PCI DSS compliance

fact: annual network assessments

fact: annual penetration testing

fact: vulnerability scans for cyber insurance underwriting

reasoning: The paragraph primarily answers what the cybersecurity program does by describing specific assessment activities, fitting Risk Management Process; it uses domain-specific terms like vulnerability scanning, PCI DSS, and penetration testing, which demonstrate cybersecurity expertise and pass the ERM test, driving Level 2 specificity.


reasoning: The paragraph primarily answers how cybersecurity affects business finances through a materiality assessment (stating no material impact or likelihood), which aligns with Strategy Integration. It contains no specific facts—such as dates, numbers, or verifiable claims—so specificity is Level 1 Generic Boilerplate.


fact: penetration testing

fact: vulnerability scanning

reasoning: The paragraph primarily answers what the cybersecurity program does by describing training, testing, and remediation activities, fitting Risk Management Process; specificity is driven by domain-specific terms like penetration testing and vulnerability scanning, which demonstrate cybersecurity expertise beyond generic risk management language.


fact: joined Workday in 2010

fact: served as CISO since April 2018

fact: more than 15 years of experience in cybersecurity

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the CISO's role, tenure, and qualifications, fitting Management Role. Specificity is Level 4 due to verifiable claims such as specific dates and quantified experience years that can be externally checked.


reasoning: This paragraph is a cross-reference to another disclosure section and does not describe any substantive cybersecurity content, so it falls under None/Other. It contains no specific facts, dates, numbers, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph primarily answers how the company is developing its cybersecurity processes and procedures through external assistance, which aligns with Risk Management Process. It contains no specific facts, names, dates, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business through a materiality assessment (stating no material impact and no anticipated significant effect), fitting Strategy Integration per Rule 5. It contains no specific facts that elevate specificity above Level 1, as the language is generic risk management boilerplate that fails the ERM test for domain expertise and includes no firm-specific or verifiable claims.


reasoning: The paragraph primarily addresses business impact through materiality assertions and cyber insurance, which aligns with Strategy Integration per Rule 5. It contains no specific facts (e.g., quantified data, firm-unique details, or verifiable claims), so specificity is Level 1.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing the implementation of a third-party risk management program, making it Third-Party Risk. It contains no specific facts, domain terms, or verifiable claims, so it is Generic Boilerplate.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, focusing on the CEO's responsibility and oversight, which aligns with Management Role. It contains no specific facts, domain terms, or verifiable claims, as all content is generic boilerplate language about roles and oversight.


reasoning: The paragraph primarily addresses how the company manages cybersecurity risks from third-party service providers, making Third-Party Risk the central topic; it contains no specific facts, domain terms, or verifiable claims, so it is generic boilerplate.


reasoning: The paragraph describes the Fund's processes for managing cybersecurity risks and the Adviser's cybersecurity program, which directly answers the Risk Management Process question; it contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims), so it is generic boilerplate.


reasoning: The paragraph primarily addresses managing cybersecurity risks from third-party service providers, making Third-Party Risk the correct category; it contains no specific facts, domain terms, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor oversight and reliance on Adviser personnel and the CCO, which aligns with Third-Party Risk. It contains no specific facts (e.g., named entities, quantified claims, or domain-specific terms) that elevate specificity above generic boilerplate.


reasoning: The paragraph primarily answers what the cybersecurity program does regarding employee training and awareness, fitting Risk Management Process. No specific facts are present—such as domain terms, firm-specific details, or verifiable claims—so it is generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through oversight structure and audit committee involvement, fitting Board Governance; it contains no specific facts, making it generic boilerplate with no domain expertise, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily addresses speculative risks and potential business impacts of cybersecurity breaches without describing concrete processes or assessments, making it None/Other; it contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business, which aligns with Strategy Integration per Rule 5 (negative assertion about material impact). It contains no specific facts—such as domain terms, firm-specific details, or verifiable claims—that would elevate specificity above Level 1, as it is a generic statement without any cybersecurity expertise or concrete details.


reasoning: The paragraph is a cross-reference to another section of the filing, which explicitly falls under None/Other per the N/O threshold for cross-references; it contains no specific cybersecurity facts, measures, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers the question of how cybersecurity affects business outcomes through a materiality assessment and mention of insurance, which aligns with Strategy Integration. No specific facts are present that elevate specificity above Level 1, as the statements are generic and lack verifiable details or domain-specific terminology.


reasoning: The paragraph primarily describes the company's activities in engaging third-party firms for cyber risk assessments, which answers what the cybersecurity program does, fitting Risk Management Process. No specific facts are present—such as named firms, quantified data, or domain-specific terms beyond generic risk assessment language—so specificity is Generic Boilerplate.


reasoning: The paragraph is a generic risk statement about IT system reliance and potential business impact, not addressing any specific cybersecurity questions like governance, management, or processes, so it falls under None/Other. No specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing incident response and recovery plans and their testing, which is Risk Management Process. It contains no specific facts like named roles, dates, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing requirements imposed on vendors, which is the central topic of Third-Party Risk. For specificity, the paragraph contains no specific facts, domain terms, firm-specific details, or verifiable claims—it uses generic boilerplate language that could apply to any company, so it is Level 1 Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business through materiality assessments, fitting Strategy Integration. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—making it generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business through materiality assertions and insurance coverage, fitting Strategy Integration; it contains no firm-specific or verifiable facts, making it generic boilerplate.


reasoning: The paragraph answers how management is organized for cybersecurity by detailing the responsibilities of the CFO and Head of IT, which aligns with Management Role; it contains no domain terms, firm-specific facts, or verifiable claims, making it generic boilerplate for specificity.


reasoning: The paragraph is speculative and does not describe any cybersecurity measures, governance, or incidents, so it fits None/Other; with no specific facts present, it is generic boilerplate language.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through committee responsibility and reporting, fitting Board Governance. It contains no specific facts, domain terms, or verifiable claims, so it is generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily addresses how management is organized for cybersecurity, detailing roles and responsibilities of executives, IT management, and the Cybersecurity Committee, which aligns with Management Role; it lacks any specific, verifiable facts or domain expertise that would elevate specificity beyond generic boilerplate language.


reasoning: The paragraph directly addresses how third-party cyber risks are managed through assessment processes and contractual requirements, fitting the Third-Party Risk category. Specificity is Generic Boilerplate because the text contains no specific facts—no domain terms, firm-specific details, or verifiable claims—using only generic language that any business professional could write.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through a vendor management program, making it Third-Party Risk. It contains no specific facts, dates, numbers, or verifiable claims, so it is generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by listing components like risk assessments, offsite backup, external service providers, and training, aligning with Risk Management Process. It contains no specific facts (e.g., no domain terms that pass the ERM test, no firm-specific details, no verifiable claims), so specificity is Level 1.


reasoning: The paragraph primarily answers a general question about cybersecurity threat trends rather than any company-specific governance, management, processes, incidents, or strategy, so it is classified as None/Other. It contains no specific facts that distinguish Autonomix Medical or provide verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing the process of reviewing and updating systems to safeguard against threats, which aligns with Risk Management Process. It contains no specific facts, domain terms, or verifiable claims, so specificity is Generic Boilerplate.


fact: service organization controls reports

fact: Risk Management, Legal and/or Information Security Departments review higher risk and material contracts with third party service providers

reasoning: The paragraph primarily answers how third-party cyber risks are managed through a vendor oversight program, central to Third-Party Risk category. Specificity is driven by the firm-specific mention of specific departments (Risk Management, Legal, and Information Security) involved in contract review, which distinguishes this company's structure from others.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing the use of external consultants for assessments and testing, which is a risk management activity. It contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers what happened in a cybersecurity incident by describing actual events like system shutdowns, operational disruptions, and restoration efforts, fitting Incident Disclosure. It contains no specific facts such as dates, numbers, or named entities that would elevate specificity above Level 1, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through a materiality assessment (backward-looking and forward-looking), which aligns with Strategy Integration per Rule 5. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so specificity is Level 1 (Generic Boilerplate).


reasoning: The paragraph primarily answers the question of how cybersecurity affects business outcomes by stating no incidents occurred, which aligns with Strategy Integration per Rule 5 (negative assertion about incidents). For specificity, it contains no domain terms, firm-specific facts, or verifiable claims—only generic commitments and a non-verifiable negative assertion—so it is Level 1.


reasoning: The paragraph primarily describes risk assessments as part of the cybersecurity program, answering what the program does, which aligns with Risk Management Process. No specific facts are present—such as firm-specific roles, verifiable claims, or domain terms that pass the ERM test—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a materiality assessment for 2024, fitting Strategy Integration under Rule 5; it contains no specific facts that elevate specificity above generic boilerplate, as it lacks verifiable claims, domain terms, or firm-specific details.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing activities like internal audits, evaluating readiness, hardening systems, and employee training, fitting Risk Management Process; no specific facts are present, as all statements are vague and lack domain-specific details, numbers, or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: The paragraph directly answers how the company manages third-party cybersecurity risks, central to the Third-Party Risk category. It contains no specific facts—such as names, dates, or verifiable claims—making it generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through partnerships, evaluations, and monitoring, directly answering the Third-Party Risk question. It contains no specific facts, names, numbers, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes the company's cybersecurity monitoring, development of IT networks, and risk mitigation efforts, which aligns with answering what the cybersecurity program does (Risk Management Process). It contains no firm-specific or verifiable facts, such as named roles, quantified data, or external verifiable claims, so specificity is Generic Boilerplate.


fact: security incident response plan

fact: cybersecurity incidents

fact: incident detection

fact: containment

fact: response

fact: remediation

reasoning: The paragraph primarily answers what the cybersecurity program does by describing incident response procedures, fitting Risk Management Process; it contains domain-specific terminology like 'security incident response plan' and 'cybersecurity incidents' that demonstrate cybersecurity expertise, elevating specificity to Domain-Adapted.


reasoning: The paragraph is generic boilerplate that recognizes cybersecurity risks without describing specific governance, management, processes, or impacts, fitting None/Other; no specific facts are present, so specificity is Level 1.


reasoning: The paragraph primarily addresses general cybersecurity awareness and forward-looking risk statements without describing specific governance, management roles, processes, incidents, or strategy integration, fitting None/Other; it contains no specific facts (e.g., named roles, verifiable claims, or domain expertise terms) that elevate specificity above generic boilerplate.


reasoning: The paragraph primarily addresses board oversight of cybersecurity risks, fitting Board Governance as it describes the board's role in receiving reports on due diligence and cybersecurity programs. Specificity is Level 1 because the paragraph contains no domain-specific terms, firm-specific facts, or verifiable claims; it uses generic risk governance language that any enterprise risk management professional could write.


reasoning: The paragraph primarily describes the company's cybersecurity program elements like third-party assessments and certifications, which aligns with answering 'What does the cybersecurity program do?' under Risk Management Process; it contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily states a negative assertion about no cybersecurity incidents, which per Rule 5 is classified as Strategy Integration; there are no specific facts that elevate specificity above Level 1, as the date is tied to an unverifiable claim and no domain terms or firm-specific details are present.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through a vCISO-compiled summary presented to leadership, making Third-Party Risk the central category. It contains no specific facts (e.g., verifiable claims, firm-specific roles, or domain expertise terms) that elevate specificity above generic boilerplate, as the language is standard for risk reporting disclosures.


reasoning: The paragraph primarily answers how the board committee oversees cybersecurity through reports from management, fitting Board Governance; it contains no specific facts, so specificity is generic boilerplate.


reasoning: The paragraph primarily addresses board oversight of cybersecurity, answering 'How does the board oversee cybersecurity?' which is Board Governance. It contains no specific facts—cadences like 'at least once a year' are generic and not verifiable, and no domain terminology or firm-specific details are present, so specificity is Level 1.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Board and Technology Committee, fitting Board Governance. It contains no specific facts (e.g., named individuals, quantified data, or domain-specific terms that pass the ERM test), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes the components and activities of the cybersecurity program, answering 'What does the cybersecurity program do?' which aligns with Risk Management Process; specificity is Level 1 because the language is generic and lacks any firm-specific or verifiable facts, failing the ERM test for domain expertise.


reasoning: The paragraph primarily describes the company's cybersecurity measures and potential inadequacies, answering what the cybersecurity program does, which aligns with Risk Management Process. It contains no specific facts—such as named roles, verifiable numbers, or domain-specific terms that pass the ERM test—making it generic boilerplate.


reasoning: The paragraph is a forward-looking disclaimer and cross-reference to another section, not answering any substantive cybersecurity question about governance, management, processes, incidents, or strategy, so it falls under None/Other. No specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through responsibility and reporting structure, fitting Board Governance; it contains no specific facts (e.g., named roles, verifiable claims, or domain expertise) that elevate it above generic boilerplate language.


reasoning: The paragraph primarily answers how cybersecurity affects business finances through insurance coverage, fitting Strategy Integration; it contains no specific facts (e.g., no quantified details, named providers, or firm-specific elements), so it is generic boilerplate.


reasoning: The paragraph primarily addresses board oversight of cybersecurity risks and their lack of experience, which directly answers the Board Governance question. It contains no specific facts—such as named roles, verifiable claims, or domain-specific terminology—so specificity is Level 1.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a negative assertion about no incidents and no impact, which aligns with Strategy Integration per Rule 5; specificity is Level 1 because the paragraph contains no verifiable, firm-specific, or domain-adapted facts, making it generic boilerplate.


reasoning: The paragraph is a cross-reference to another section, which falls under None/Other as it contains no substantive cybersecurity disclosure; specificity is Level 1 because there are no specific facts present in the text.


reasoning: The paragraph is a cross-reference to another section of the filing, so it primarily answers none of the substantive cybersecurity questions and falls under None/Other. It contains no specific cybersecurity facts, measures, or assessments, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes internal cybersecurity processes and safeguards, answering what the cybersecurity program does (Risk Management Process). It contains no specific facts—such as named roles, verifiable claims, or domain-specific terms—that would elevate specificity above Level 1, as the language is generic and could apply to any risk management context.


reasoning: The paragraph is a cross-reference to Risk Factors and does not answer any substantive cybersecurity question, so it is classified as None/Other. No specific facts are present in the text, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed, fitting Third-Party Risk as the central topic; it contains no specific facts (e.g., named entities, dates, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the cybersecurity program is integrated into enterprise risk management, which is a risk management process; it contains no specific facts, domain terms, or verifiable claims, so it is generic boilerplate.


reasoning: This paragraph is a cross-reference to risk factor disclosures in Item 1A and does not answer any substantive cybersecurity question, so it is classified as None/Other. It contains no specific facts about the company's cybersecurity posture, such as domain terms, firm-specific details, or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by focusing on engaging consultants and future requirements for third-party certifications, making Third-Party Risk the central topic. It contains no specific facts—such as named vendors, quantified data, or firm-specific roles—so it is generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily answers how the company manages third-party cyber risks, focusing on vendor oversight and limitations in monitoring service providers, which aligns with the Third-Party Risk category. It contains no specific facts that elevate specificity above Level 1, as it uses generic risk management language without domain expertise, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality assessments, fitting Strategy Integration. It contains no specific facts—only generic risk and insurance language—so specificity is Level 1.


reasoning: The paragraph primarily answers how the board oversees cybersecurity risk management through a governance chain (board and management responsibilities), so Board Governance is assigned. It contains no specific facts, domain terms, or verifiable claims—only generic governance language—so specificity is Generic Boilerplate.


reasoning: The paragraph is speculative forward-looking language about potential cybersecurity risks and impacts, not describing any concrete measures, assessments, or real events, so it falls under None/Other. No specific facts are present—no domain terms, firm-specific details, or verifiable claims—making it generic boilerplate.


reasoning: The paragraph primarily answers no substantive cybersecurity question—it is speculative language about potential risks and cross-references risk factors, fitting None/Other. No specific facts are present, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing risk management processes, fitting Risk Management Process; it contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily discusses business technology reliance without addressing any cybersecurity-specific questions (e.g., governance, risk management, incidents), and contains no specific facts that demonstrate domain expertise, firm-specific details, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed by imposing certification and reporting requirements on service providers, fitting Third-Party Risk. No specific facts (e.g., named vendors, quantified details, or firm-specific claims) are present, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through a materiality assessment (stating no material effect or reasonable likelihood), which aligns with Strategy Integration. It contains no specific facts—such as named roles, verifiable claims, or domain-specific details—so specificity is Generic Boilerplate.


reasoning: The paragraph is a cross-reference to another section of the report, not answering any substantive cybersecurity questions, so it falls under None/Other; it contains no specific facts that elevate specificity above Level 1, as all language is generic and standard for SEC filings.


reasoning: The paragraph primarily describes the oversight structure between the IT department and the Board, which answers how the board oversees cybersecurity, fitting Board Governance. It contains no specific facts (e.g., named roles, quantified data, or domain expertise beyond generic terms), so specificity is Generic Boilerplate.


reasoning: The paragraph directly answers how third-party cyber risks are managed by outsourcing IT and cybersecurity functions to a sub-contractor, making it Third-Party Risk; it contains no firm-specific or verifiable facts, and the language is generic, so specificity is Level 1.


reasoning: The paragraph primarily answers how cybersecurity affects the business through a materiality assessment ('have not materially affected our Company'), which aligns with Strategy Integration per Rule 5; it contains no specific facts that elevate specificity above Level 1, as all descriptions are high-level and lack verifiable or distinguishing details.


reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on the CFO's oversight role and reliance on external support, so it is classified as Management Role. It contains no specific facts that elevate specificity beyond generic boilerplate, as all statements are high-level, lack domain-specific terminology, and are not externally verifiable.


reasoning: The paragraph primarily addresses board oversight of cybersecurity risks through delegation to the Audit Committee, which is a governance-chain structure, fitting Board Governance. It contains no specific facts—such as domain terms, firm-specific details, or verifiable claims—so specificity is Level 1.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through vendor qualification and management programs, fitting the Third-Party Risk category. It contains no specific facts—such as named programs, verifiable claims, or domain expertise beyond generic descriptions—resulting in Generic Boilerplate specificity.


reasoning: The paragraph is a general statement about the importance of cybersecurity without addressing any specific question like board oversight, management roles, or risk processes, fitting None/Other; no domain terms, firm-specific facts, or verifiable claims are present, so specificity is Generic Boilerplate.


reasoning: The paragraph is a speculative, forward-looking disclaimer about potential cybersecurity incidents and lack of insurance, which does not describe any concrete measures or answer substantive questions about governance, management, process, etc., fitting None/Other; it contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the audit committee and information flow, fitting Board Governance; it contains no specific facts—only generic oversight language—so specificity is Level 1.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality assessments (backward-looking and forward-looking), aligning with Strategy Integration; it contains no specific facts, making it generic boilerplate for specificity.


reasoning: The paragraph primarily answers how the company uses external experts for cybersecurity evaluations, which falls under risk management processes; however, it contains no specific facts, dates, numbers, or verifiable claims, making it generic boilerplate with no domain-specific details.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by detailing requirements imposed on service providers, fitting Third-Party Risk; however, it contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so specificity is Level 1.


reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the CEO's responsibilities in leading and overseeing risk assessment, incident response, and reporting, which aligns with Management Role. It contains no firm-specific or verifiable facts—such as named roles beyond generic CEO, domain terms that pass the ERM test, or quantified claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating materiality assessments (backward-looking and forward-looking), which aligns with Strategy Integration per Rule 5. It contains no specific facts, domain terms, or verifiable claims—only generic boilerplate language about threats and material impact—so specificity is Level 1.


reasoning: The paragraph primarily addresses the business and financial impacts of cybersecurity threats, including materiality assessments and forward-looking resource expenditure, fitting Strategy Integration. It contains no specific facts, domain terms, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers whether cybersecurity has affected the business through a negative assertion about material impact, which aligns with Strategy Integration per Rule 5. It contains no specific facts—only generic statements and a cross-reference—so specificity is Level 1.


reasoning: The paragraph primarily answers how the board oversees cybersecurity risk through periodic information and responsibility for monitoring strategic risk, fitting Board Governance; it contains no specific facts, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business finances through a materiality assessment (stating past non-impact and future risks), fitting Strategy Integration. It contains no specific facts—no verifiable claims, domain terms, or firm-specific details—making it generic boilerplate for specificity.


reasoning: The paragraph primarily addresses board and management oversight of cybersecurity investments and compliance, which aligns with Board Governance. It contains no specific facts—such as named roles, quantified investments, or verifiable details—making it Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a conclusion about the materiality of cybersecurity risks, which aligns with Strategy Integration. There are no specific facts in the paragraph—such as domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers the question of whether cybersecurity has or is likely to materially affect business outcomes, which aligns with Strategy Integration per Rule 5; for specificity, no specific facts are present that elevate above Level 1, as the language is generic and lacks verifiable or firm-specific details.


fact: combined over 35 years of IT management experience

reasoning: The paragraph primarily addresses management organization and qualifications, answering how management is structured for cybersecurity, with the CIO and ISO roles and responsibilities; specificity is Level 4 due to the verifiable claim of over 35 years of combined IT management experience.


reasoning: The paragraph primarily answers how the board oversees cybersecurity, focusing on strategic oversight and updates from officers, which aligns with Board Governance. It contains no specific facts that elevate specificity above generic boilerplate, as it uses high-level governance language without domain expertise, firm-specific details, or verifiable claims.


reasoning: The paragraph describes vCIO services without directly answering any substantive cybersecurity question (e.g., governance, risk management, incidents), so it falls under None/Other; for specificity, no domain-specific, firm-specific, or verifiable facts are present, making it generic boilerplate.


reasoning: The paragraph primarily answers the question of whether cybersecurity has affected business outcomes by stating a negative assertion about no material incidents or expenses, which falls under Strategy Integration per Rule 5. It contains no specific facts that elevate specificity above Level 1, as all claims are non-verifiable negative assertions without domain terminology, firm-specific details, or quantified data.


reasoning: The paragraph primarily answers how the board oversees cybersecurity and describes the governance chain to management, fitting Board Governance; it contains no domain-specific terms, firm-specific details, or verifiable claims, making it generic boilerplate for specificity.


reasoning: The paragraph primarily addresses materiality of cybersecurity incidents and business impact, stating conclusions about past incidents and future risks, which aligns with Strategy Integration per Rule 5. It contains no specific facts—no domain terminology showing expertise, no firm-specific details, and no verifiable claims—so specificity is generic boilerplate.


reasoning: The paragraph primarily addresses the company's lack of current cybersecurity programs and future commitment, which does not answer any of the six substantive questions (e.g., it is not about governance, management roles, or specific processes), so it falls under None/Other. Specificity is Generic Boilerplate because the paragraph contains no specific facts—such as domain terms, firm-specific details, or verifiable claims—that would elevate it above Level 1; all statements are generic and forward-looking.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, detailing senior management's responsibilities and reporting lines, which aligns with Management Role. It contains no domain-specific terms, firm-unique details, or verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business through materiality assessments (backward-looking and forward-looking), which is the core of Strategy Integration. It contains no specific facts—no domain terms that demonstrate expertise, no firm-specific details, and no verifiable claims—so it is generic boilerplate for specificity.


reasoning: The paragraph primarily answers how the board oversees cybersecurity by describing delegation to the Audit Committee, which is a governance-chain structure, so it is Board Governance. It contains no specific facts such as names, dates, numbers, or verifiable claims, and the language is generic risk oversight terminology that any enterprise risk management professional would use, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a backward-looking materiality assessment (no unauthorized access with materially adverse effects), fitting Strategy Integration. It contains no specific facts—no domain terms that demonstrate expertise, no firm-specific details, and no verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily states a materiality assessment about cybersecurity impacts, which directly answers the Strategy Integration question per Rule 5; no specific facts (e.g., verifiable claims, firm-specific details, or domain terms) are present, so specificity is generic boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through assessments and evaluations of service providers, making Third-Party Risk the central category. It contains no specific facts (e.g., named roles, verifiable claims, or domain-specific terms that pass the ERM test), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses the business impact of cybersecurity, stating no material effects in 2024 and potential future effects, which aligns with Strategy Integration. It contains no specific facts, making it generic boilerplate.


reasoning: The paragraph is classified as Third-Party Risk because it centrally addresses managing cybersecurity risks from service providers through due diligence and contractual requirements, answering how third-party cyber risks are handled. Specificity is Generic Boilerplate because the paragraph contains no specific facts—using only aspirational language like 'strives to' and generic process descriptions without domain-specific terminology, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily answers how cybersecurity affects the business through materiality assessments (stating no past material incidents and assessing future likelihood), which aligns with Strategy Integration; it contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through a materiality assessment, fitting Strategy Integration; it contains no specific facts like named roles, verifiable claims, or domain terms, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business through a negative assertion about no material incidents, which Rule 5 classifies as Strategy Integration; it contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by describing the CEO's and executive team's responsibilities, which aligns with Management Role; it contains no specific facts (e.g., named roles, verifiable claims, or domain-specific terms) that elevate specificity above generic boilerplate language.


reasoning: The paragraph is a general risk statement and cross-reference to risk factors, not answering any substantive cybersecurity questions like governance, management, or incidents, so it's None/Other. It contains no specific facts, dates, names, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily answers whether cybersecurity incidents have affected business outcomes by stating a negative assessment of material impact, which aligns with Strategy Integration per Rule 5; it contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph is a cross-reference to another section and does not answer any substantive cybersecurity question, so it is classified as None/Other. No specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a conclusion about material impact on strategy and operations, fitting Strategy Integration under Rule 5; it contains no domain-adapted, firm-specific, or verifiable facts, as all statements are generic and non-verifiable negative assertions, so specificity is Level 1.


reasoning: The paragraph primarily states a conclusion about no material adverse effects from cybersecurity incidents, which aligns with Strategy Integration per Rule 5; no specific facts are present, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality assertions (e.g., 'do not believe we have been materially affected'), aligning with Strategy Integration; it contains no verifiable, firm-specific, or domain-adapted facts, making it generic boilerplate for specificity.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating conclusions about material impacts (or lack thereof), which aligns with Strategy Integration. For specificity, it contains no verifiable or firm-specific cybersecurity facts—only generic assertions and a business activity mention that does not demonstrate domain expertise or elevate above boilerplate language.


reasoning: The paragraph primarily addresses senior management's responsibilities and reporting lines for cybersecurity, which is about management organization, fitting Management Role. It contains no specific facts such as names, numbers, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality assessments (backward-looking and forward-looking), fitting Strategy Integration. It contains no specific facts—only generic assertions and a cross-reference—so it is generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily answers how cybersecurity incidents are managed through processes and communication protocols, fitting Risk Management Process; it contains no specific facts, domain terms, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality assessment (risks have not materially affected operations), which aligns with Strategy Integration; it contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through delegation to the audit committee, fitting Board Governance; it contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so it is generic boilerplate.


reasoning: The paragraph is a cross-reference to another section of the filing and does not describe any substantive cybersecurity measures, incidents, or processes, fitting None/Other; no specific facts are present, making it generic boilerplate with Level 1 specificity.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through contractual requirements and audits, directly aligning with the Third-Party Risk category. It contains no specific facts—no firm-specific roles, verifiable claims, or domain expertise beyond generic process descriptions—so specificity is Level 1 (Generic Boilerplate).


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's briefing and review activities, which is Board Governance. It contains no specific facts that elevate specificity beyond Level 1, as all language is generic governance terminology without firm-specific or verifiable claims.


fact: Chief Information Security Officer role

fact: over 25 years' experience in the cybersecurity field

reasoning: The paragraph focuses on the CISO's responsibilities, qualifications, and oversight structure, directly answering how management is organized for cybersecurity, hence Management Role. Specificity is Level 4 because the claim of 'over 25 years' experience' is a verifiable lower-bound fact that an external party could check.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor oversight and requirements, making it Third-Party Risk. It contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


fact: CDO has more than 20 years of executive IT leadership experience (verifiable lower bound)

fact: CDO joined MPC in 2021

fact: CDO was employed by GE and its subsidiary companies for over 20 years

fact: CDO was named Senior Vice President and Chief Information Officer of Services for GE in 2017

fact: CDO was named Vice President and Chief Information Officer of GE Healthcare

fact: CDO holds a Bachelor's degree in Business Administration, Management and Information Systems

reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing roles and qualifications of the CISO and CDO, thus fitting Management Role; specificity is driven by multiple verifiable facts such as specific dates, employment history, and degrees, elevating it to Quantified-Verifiable.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing the IT Committee's activities and engagement of experts for improvements, aligning with Risk Management Process. No specific facts are present that elevate specificity above Level 1, as the language is generic and lacks domain-specific terms, firm-specific details, or verifiable claims.


reasoning: The paragraph is a cross-reference to another section of the filing, which does not answer any of the six substantive cybersecurity questions and thus falls under None/Other. It contains no specific facts—only generic risk language and a reference—so specificity is Level 1 (Generic Boilerplate).


fact: over twenty years of experience managing information technology and cybersecurity matters

fact: Master of Science degree in Telecommunications and Computer Networks

fact: Project Management Professional certification

fact: Certified Scrum Master certification

fact: IT Infrastructure Library certification

reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on the Head of IT's reporting line, experience, and certifications, which fits Management Role; specificity is Level 4 because it contains multiple verifiable facts like specific certifications and a lower-bound experience claim that external parties could confirm.


reasoning: The paragraph directly describes a cybersecurity incident (access, exfiltration, release of information, and response), answering 'what happened,' so it is Incident Disclosure. It contains no specific, verifiable, or firm-unique facts—only generic incident descriptions—making it Level 1 specificity.


reasoning: The paragraph is a cross-reference to another section (Item 1.A), which does not answer any substantive cybersecurity question and falls under None/Other. No specific facts are present, so specificity is Generic Boilerplate.


reasoning: The paragraph is a cross-reference to a risk factor section and does not describe any substantive cybersecurity governance, processes, incidents, or impacts, so it falls under None/Other. It contains no specific facts, domain terms, firm-specific details, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by describing senior leadership's monitoring and participation in risk management processes, which aligns with Management Role. It contains no specific facts—such as named roles, verifiable claims, or domain-specific terminology that passes the ERM test—so specificity is generic boilerplate.


reasoning: The paragraph primarily addresses cybersecurity insurance, which is a financial strategy under Strategy Integration; it contains no specific facts, making it Generic Boilerplate.


reasoning: The paragraph primarily describes the company's cybersecurity risk management activities, such as implementing controls and engaging third-party specialists, which answers 'What does the cybersecurity program do?' under Risk Management Process. It contains no specific facts that elevate specificity above generic boilerplate, as it lacks domain-specific terminology, firm-specific details, or verifiable claims.


fact: regular scanning of internal and externally facing systems

fact: annual third-party penetration testing

fact: implementation of security technologies for malware risks

fact: active monitoring of logs and events for network perimeter and internal systems

fact: due diligence of third-party vendors' information security

reasoning: The paragraph primarily answers what the cybersecurity program does by listing specific activities like scanning, penetration testing, and monitoring, fitting Risk Management Process; specificity is Domain-Adapted because it uses cybersecurity-specific terms (e.g., penetration testing, log monitoring) that demonstrate expertise beyond generic risk management language.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through reporting structures from committees to the board, fitting Board Governance. It contains no specific facts, such as names, dates, or verifiable claims, making it generic boilerplate with no domain-adapted, firm-specific, or quantified-verifiable elements.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through supplier assessments and contract addendums, fitting the Third-Party Risk category. It contains no specific facts (e.g., named roles, dates, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph focuses on management's roles, responsibilities, and organizational structure for cybersecurity, directly answering 'How is management organized to handle cybersecurity?' which is Management Role. It contains no specific facts like named individuals, dates, or verifiable claims, and the language is generic risk management terminology that any enterprise professional could use, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by describing the IT employee's monitoring role, consultation with the CEO, and reporting to the Board, which aligns with Management Role; it contains no specific facts, domain terms, or verifiable claims, making it generic boilerplate for specificity.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing the incident response plan, which is a core element of risk management processes. It contains no specific facts—such as named roles, dates, numbers, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board and audit committee oversee cybersecurity, fitting Board Governance. It contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), making it generic boilerplate language.


reasoning: The paragraph primarily answers whether cybersecurity risks have materially affected the company, which is a materiality assessment under Strategy Integration. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality assessment—that risks have not materially affected the company—which aligns with Strategy Integration. For specificity, it contains no specific facts (e.g., no verifiable claims, firm-specific details, or domain expertise terms), so it is Generic Boilerplate.


fact: On February 23, 2023, DISH Network experienced a network outage that affected its internal servers and IT telephony.

fact: On February 28, 2023, we further disclosed that certain data had been extracted from the DISH Network IT systems.

reasoning: The paragraph primarily describes a specific cybersecurity incident with dates and response actions, fitting Incident Disclosure; it contains externally verifiable facts like specific dates and event details, driving specificity to Level 4.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a negative assessment of material risks and incidents, which aligns with Strategy Integration under the materiality rule; it contains no specific facts, domain terminology, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor due diligence factors, fitting Third-Party Risk. It contains no specific facts (e.g., firm-specific roles, verifiable claims, or domain terms that pass the ERM test), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily provides regulatory context and a cross-reference to another section, not answering any substantive cybersecurity question like governance, management, or risk processes, so it's None/Other. It contains no specific facts—only generic statements about regulatory oversight—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed by discussing agreements with vendors for IT services and exploration of cybersecurity support, fitting the Third-Party Risk category. No specific facts are present—such as named vendors, quantities, or verifiable claims—so it is generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing BNY Mellon's governance framework for evaluating and mitigating risks from service providers, making it Third-Party Risk. It contains no specific facts about CHKR or verifiable claims, and the language is generic risk management terminology that does not demonstrate cybersecurity domain expertise, so specificity is Level 1.


reasoning: The paragraph primarily addresses materiality assessments and insurance coverage regarding cybersecurity's business impact, fitting Strategy Integration. It contains no specific facts—no domain terms that pass the ERM test, no firm-specific details, and no verifiable claims—making it generic boilerplate for specificity.


reasoning: The paragraph focuses on requirements imposed on third-party service providers for cybersecurity certifications and breach reporting, directly answering how third-party cyber risks are managed. For specificity, the language is generic with no domain-specific terms, firm-unique details, or verifiable claims, so it remains at Level 1.


fact: On February 23, 2023, experienced a network outage affecting internal servers and IT telephony

fact: On February 28, 2023, disclosed that certain data had been extracted from DISH Network IT systems

reasoning: The paragraph primarily describes a specific cybersecurity incident with dates and events, fitting Incident Disclosure; specificity is driven by verifiable facts like the exact dates of the outage and data extraction, which could be externally confirmed.


reasoning: The paragraph primarily answers the question of whether cybersecurity risks are likely to materially affect business outcomes, which is a materiality assessment under Strategy Integration. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—making it generic boilerplate.


reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by describing its components and management with outside advisor support, fitting Risk Management Process; no specific facts like named roles, dates, or verifiable claims are present, making it generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through a materiality assessment, fitting Strategy Integration; it contains no specific facts (e.g., no verifiable claims, domain terms, or firm-specific details), so specificity is Generic Boilerplate.


reasoning: The paragraph is centrally about managing third-party vendor risks through policies and programs, directly answering the Third-Party Risk question. It contains no specific facts—such as named roles, quantified data, or verifiable claims—that would elevate specificity beyond Generic Boilerplate, as all descriptions are generic and lack distinguishing details.


reasoning: The paragraph primarily states a materiality assessment about cybersecurity risks not affecting the business, which directly answers the Strategy Integration question. Specificity is Generic Boilerplate because the paragraph contains no specific facts—only vague assertions and standard disclosure language that lack verifiable or firm-specific details.


fact: Incident occurred in March 2023

fact: Recognized $2.7 million loss from the incident

reasoning: The paragraph primarily describes a real cybersecurity incident with specific timing, response actions, and financial impact, directly answering 'what happened,' so it is Incident Disclosure; the quantified loss of $2.7 million is an externally verifiable fact, driving specificity to Level 4.


reasoning: The paragraph primarily answers whether cybersecurity incidents have affected the business by stating a negative materiality assertion, which aligns with Strategy Integration per Rule 5; it contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily serves as a cross-reference to risk factors in Item 1A and a general statement about cybersecurity risks, not answering any substantive questions like governance or incidents, so it's None/Other. No specific facts are present, such as domain terms, firm-specific details, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph is generic boilerplate that states the importance of cybersecurity and having a program without describing specific governance, management, processes, or incidents, so it answers none of the substantive questions and falls under None/Other. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so specificity is Level 1.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through diligence, monitoring, and contractual requirements, making Third-Party Risk the correct category. It contains no specific facts that elevate specificity above Level 1; the language is generic risk management terminology that does not demonstrate domain expertise or firm-specific details.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor due diligence and monitoring, making Third-Party Risk the central topic. It contains no specific facts, domain terms, or verifiable claims, so it is Generic Boilerplate for specificity.


fact: CISO has over 18 years of experience in information technology leadership

fact: eight years of which is experience in leading information security oversight

reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on the CISO's role, responsibilities, and reporting lines, which aligns with Management Role; specificity is driven by verifiable quantified experience claims (over 18 years and eight years) that an external party could check.


reasoning: The paragraph primarily answers how cybersecurity affects business finances through insurance, fitting Strategy Integration; it contains no specific facts that elevate specificity above generic boilerplate, as it merely states the existence of a policy without details like coverage amounts or verifiable claims.


reasoning: The paragraph primarily describes the cybersecurity program's activities of developing, maintaining, and monitoring protocols, which answers what the risk management process does. It contains no specific facts, domain terms, or verifiable claims, so specificity is Level 1 Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through oversight committees and security assessments, central to Third-Party Risk; it contains no specific facts (e.g., named committees, quantified data, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on the CFO's coordination and escalation process to senior management and the board, which aligns with Management Role. It contains no specific facts that elevate specificity above Level 1, as all references (e.g., CFO, CEO, Audit Committee) are generic roles and processes without domain-specific terminology or verifiable claims.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating materiality assessments (e.g., no material effects to date and elevated future risks), fitting Strategy Integration. It contains no specific facts like named roles, tools, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes cybersecurity risk assessment and management processes, fitting Risk Management Process; it contains no specific facts that elevate specificity above Level 1, as the language is generic and common in enterprise risk management contexts.


reasoning: The paragraph primarily answers how cybersecurity risks affect business outcomes through materiality assessments (backward-looking no-impact assertion and forward-looking risk statement), fitting Strategy Integration; specificity is Level 1 because it contains no verifiable, firm-specific, or domain-expert facts—only generic materiality claims and cross-references.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's reporting and access, which is governance-focused; it contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so specificity is generic boilerplate.


fact: threat modeling

fact: vulnerability testing

fact: information security maturity assessments

fact: independent reviews of information security control environment

reasoning: The paragraph primarily describes the company's cybersecurity assessment and testing activities, which aligns with Risk Management Process; it uses domain-specific terms like threat modeling and vulnerability testing that demonstrate cybersecurity expertise, driving specificity to Domain-Adapted.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through contractual requirements and vendor oversight, directly answering the Third-Party Risk question. It contains no specific facts such as named entities, quantifiable data, or verifiable claims, so specificity is Level 1.


fact: Software Approval Board

fact: cross-functional members from Quality, Internal Audit, Information Security, Business Systems, and R&D

reasoning: The paragraph primarily addresses how the company manages third-party cyber risks through diligence, software evaluation, and contractual requirements, making Third-Party Risk the appropriate category. Specificity is Firm-Specific due to the named Software Approval Board and its specific departmental composition, which distinguish this company's cybersecurity posture.


reasoning: The paragraph primarily describes the audit committee's oversight of cybersecurity, answering how the board governs cybersecurity risks, which aligns with Board Governance; it contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's role, fitting Board Governance; it contains no specific facts that elevate specificity above generic boilerplate, as it uses standard oversight language without firm-specific or verifiable details.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality assessment (no material effects), which aligns with Strategy Integration per Rule 5. It contains no specific facts—only a generic negative assertion—so specificity is Level 1.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor requirements and diligence, making it Third-Party Risk; it contains no specific facts like named roles, quantified data, or domain-specific terms, so it is Generic Boilerplate.


reasoning: The paragraph primarily addresses how cybersecurity risks could materially affect business strategy, operations, or finances, which aligns with Strategy Integration. It contains no specific facts, domain terms, firm-specific details, or verifiable claims, so specificity is Generic Boilerplate.