content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: The paragraph is a cross-reference to another section, answering none of the substantive cybersecurity questions, so it is classified as None/Other; it contains no specific facts, making it Generic Boilerplate.

provider: xiaomi

stage: benchmark


reasoning: The paragraph is a cross-reference to risk factors in Item 1A and does not answer any substantive cybersecurity question about governance, management, process, incident, or strategy; it contains no specific facts, so specificity is Generic Boilerplate.


content_category: Strategy Integration

reasoning: The paragraph primarily answers the question of how cybersecurity affects business outcomes by stating a materiality assessment (no material incidents or likelihood), which aligns with Strategy Integration per Rule 5. It contains no specific facts that elevate specificity above Level 1, as it is a negative assertion without verifiable claims, domain terms, or firm-specific details.


reasoning: The paragraph primarily addresses materiality assessments and insurance impact on business outcomes, fitting Strategy Integration; it contains no specific facts (e.g., numbers, dates, or verifiable claims), so specificity is Generic Boilerplate.


content_category: Risk Management Process

reasoning: The paragraph primarily answers what the company does to protect assets, aligning with Risk Management Process; it contains no specific facts, tools, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a conclusion about the lack of material impact from past incidents, which aligns with Strategy Integration under Rule 5. It contains no specific facts—no verifiable claims, firm-specific details, or domain expertise terms—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers 'what the cybersecurity program does' by listing its components like risk assessments, team responsibilities, and incident response, fitting Risk Management Process. It contains no firm-specific or verifiable facts—only generic descriptions—so specificity is Level 1.


reasoning: The paragraph is a cross-reference to another section of the filing, which explicitly falls under None/Other as it contains no substantive cybersecurity disclosure. It has no specific facts, so specificity is Generic Boilerplate.


content_category: Third-Party Risk

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor oversight and compliance, which aligns with the Third-Party Risk category. It contains no specific facts, firm-specific details, or verifiable claims, so specificity is Generic Boilerplate (Level 1).


reasoning: The paragraph is a cross-reference to another section of the 10-K and does not answer any substantive cybersecurity questions, so it is classified as None/Other. No specific facts are present, as it only points to risk factors without describing any cybersecurity measures, processes, or assessments, resulting in Generic Boilerplate specificity.


content_category: Board Governance

reasoning: The paragraph primarily addresses how the board oversees cybersecurity, fitting Board Governance as it describes oversight structure and processes. It contains no specific facts like named roles, 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 incidents have occurred or are likely), which aligns with Strategy Integration under Rule 5; it contains no specific facts that elevate specificity above Level 1, as all language is generic and non-verifiable, with no domain terms, firm-specific details, or quantified claims.


reasoning: The paragraph provides general business context about technology reliance and data storage without answering any specific cybersecurity questions (e.g., governance, management, processes, or impacts), making it None/Other. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers a general risk statement about being a target of cyber threats, without describing any substantive cybersecurity disclosure such as governance, processes, or incidents, so it is classified as None/Other. It contains no specific facts that elevate specificity above Level 1, as the language is generic boilerplate applicable to any company in the sector.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by discussing enhancements to monitoring and a new vendor risk management program, making it Third-Party Risk. It contains no specific facts, domain terms, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business finances through materiality assessments (stating no past material impact and potential future risks), fitting 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 describes the company's data handling and general threat environment but does not answer any substantive cybersecurity question about governance, management, processes, incidents, or business impact, so it is classified as None/Other. It contains no specific facts (e.g., no quantified data, named roles, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily states a conclusion about the materiality of cybersecurity incidents, which directly answers the Strategy Integration question per Rule 5; specificity is Generic Boilerplate because it contains no verifiable, firm-specific, or domain-expertise facts—it is a standard boilerplate statement with no specific cybersecurity details.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through vendor vetting and oversight processes, fitting the Third-Party Risk category; it contains no domain-specific terms, firm-unique details, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph focuses on managing third-party cyber risks through risk assessments and contractual terms, directly answering the Third-Party Risk question. It contains no firm-specific or verifiable facts, making it generic boilerplate for specificity.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing reviewing and drilling on the plan, which is a risk management activity, so category is RMP. No specific facts (e.g., dates, numbers, verifiable claims) are present, making it generic boilerplate for specificity.


reasoning: The paragraph is a cross-reference to risk factors and a general disclaimer, answering none of the substantive questions like governance or incidents, so content_category is None/Other. It contains no specific facts (e.g., named roles, tools, dates, or verifiable claims), so specificity is Level 1 Generic Boilerplate.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through a TPRM program, fitting the Third-Party Risk category. 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 addresses the business impact and materiality of cybersecurity, including negative assertions and potential effects, which aligns with Strategy Integration. It contains no specific facts that elevate specificity above generic boilerplate, as all statements are speculative or lack verifiable details.


reasoning: The paragraph primarily states a materiality assessment about cybersecurity's business impact, directly answering the Strategy Integration question. Specificity is Generic Boilerplate because it contains no verifiable claims, firm-specific details, or domain-expertise terms that pass the ERM test.


reasoning: The paragraph primarily answers how cybersecurity affects business by stating a materiality assessment about incidents, fitting Strategy Integration under Rule 5. It contains no specific facts that elevate above generic boilerplate, as the date reference is not a cybersecurity-specific verifiable claim and no domain terms or firm-specific details are present.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a backward-looking materiality assessment (no material incidents to date), 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 Generic Boilerplate.


reasoning: The paragraph primarily addresses how the company manages third-party cyber risks through assessments and requirements, making it Third-Party Risk; it contains only generic process descriptions with no specific facts, firm-specific details, or verifiable claims, so specificity is 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, which under Rule 5 is classified as Strategy Integration. For specificity, the paragraph contains no specific facts that elevate it above Level 1—no verifiable claims, firm-unique details, or domain expertise demonstrations—making it Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through assessments, categorizing it as Third-Party Risk. It lacks any specific facts (e.g., named roles, tools, or verifiable claims), resulting in generic boilerplate specificity.


reasoning: The paragraph primarily answers how cybersecurity risks could materially affect the business through materiality assessments and a negative incident assertion, fitting Strategy Integration. It contains no specific facts—only generic references and unverifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by discussing materiality assertions and potential financial impacts, aligning 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 addresses how third-party cybersecurity risks are managed through pre-onboarding risk assessments, directly answering the Third-Party Risk question. For specificity, the language is generic with no domain-specific terms, firm-unique details, or verifiable claims, so it is Level 1 Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business finances through materiality assessments (backward-looking conclusion and forward-looking speculation), fitting Strategy Integration; it contains no specific facts, practices, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality assertions (e.g., 'have not materially affected' and 'will materially affect'), fitting Strategy Integration. It contains no specific cybersecurity facts, so specificity is Generic Boilerplate.


reasoning: The paragraph is a general statement about the importance of cybersecurity governance without answering a specific question about board oversight, management roles, risk processes, or other substantive categories, so it falls under None/Other; it contains no specific facts that elevate specificity above Level 1, making it generic boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity by listing oversight activities like reviewing examination reports and monitoring emerging risks, aligning with 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 answers how cybersecurity affects the business by stating a backward-looking conclusion of no material impact, which aligns with Strategy Integration under Rule 5; it contains no specific facts, domain terms, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph discusses general cyber risks and threats without addressing company-specific governance, management, processes, or incidents, so it falls under None/Other; no specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph primarily describes the establishment and purpose of the cybersecurity risk management program, answering 'What does the cybersecurity program do?' which aligns with Risk Management Process; no specific facts are present to elevate specificity above Level 1, as the language is generic and lacks domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily answers the question of business impact by stating a negative materiality assertion about cybersecurity incidents, 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 Generic Boilerplate.


reasoning: The paragraph primarily addresses how cybersecurity risk is integrated into enterprise risk management, which is a risk management process aspect. It contains no specific facts that elevate specificity above Level 1, as it uses generic risk management language without cybersecurity domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing implemented policies and procedures to address risks, aligning with Risk Management Process; it contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating material effects on operations and finances, fitting Strategy Integration; it contains no specific facts (e.g., no quantified data, named entities, or domain terms), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality assessments and forward-looking risk statements, fitting Strategy Integration. It contains no specific facts, domain terms, or verifiable claims, making it Generic Boilerplate for specificity.


reasoning: The paragraph primarily discusses general cybersecurity risks and the absence of material incidents without describing governance, management roles, risk processes, or other substantive categories, fitting None/Other; it contains no specific facts that elevate specificity above Level 1, as all language is generic and boilerplate.


reasoning: The paragraph primarily answers what the cybersecurity program does in response to incidents (Risk Management Process), and it contains no specific facts that elevate specificity above generic boilerplate, as it uses standard process language without domain-specific details, firm-unique claims, or verifiable assertions.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through vendor assessments and contractual requirements, directly answering the Third-Party Risk question. It contains no domain-adapted terms, firm-specific details, or verifiable claims, making it generic boilerplate with no facts elevating specificity above Level 1.


reasoning: The paragraph is a general statement about cybersecurity risks and potential business impacts without describing specific processes, roles, incidents, or assessments, so it does not fit any substantive category and is classified as None/Other. It contains no domain terms, firm-specific facts, or verifiable claims, resulting in Generic Boilerplate specificity.


fact: CSO role

fact: phishing tests

reasoning: The paragraph primarily answers what the cybersecurity program does by describing team activities, tools, trainings, and incident response, fitting Risk Management Process; specificity is driven by the firm-specific 'CSO' role and domain-term 'phishing tests', with the CSO being a cybersecurity leadership role that distinguishes the company.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a backward-looking materiality conclusion (no material incidents to date) and referencing risk factors, which aligns with Strategy Integration. For specificity, it contains no domain terms, firm-specific facts, or verifiable claims—only generic risk language and cross-references—so it is Level 1.


reasoning: The paragraph directly answers how third-party cyber risks are managed through contractual requirements, making it Third-Party Risk. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so specificity is generic boilerplate.


content_category: Management Role

fact: Identity and access management, cyber defense operations, security engineering, and IT governance, risk and compliance professionals

fact: Executive Vice President/ Chief Information Security Officer with over 25 years' experience in cybersecurity risk management

fact: Chief Information Officer with over 27 years' experience in technology risk management

fact: Reporting lines: CISO and CIO report to Senior Executive Vice President / Chief Operating Officer, who reports to CEO and Board of Directors

fact: Engages third parties for penetration testing, incident response, threat intelligence, education, and managed security services

reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing leadership roles, qualifications, and reporting lines, fitting Management Role; specificity is Level 4 due to verifiable claims like specific years of experience for executives.


reasoning: The paragraph primarily answers the question of how cybersecurity affects business outcomes through a materiality assessment (stating no breaches materially affected the business), fitting Strategy Integration. It contains no specific facts that elevate specificity above Level 1, as it is a negative assertion without verifiable details, domain expertise, or firm-specific information.


reasoning: The paragraph describes the Trust's operational characteristics (grantor trust, no operations, no customers, no personal data) and a vague tailored approach to cybersecurity, but does not answer any of the six substantive questions about cybersecurity governance, management, risk, incidents, or strategy, making it None/Other. With no specific cybersecurity facts or domain expertise shown, and for None/Other paragraphs, it is Generic Boilerplate.


fact: 30 years of information technology experience

fact: 17 years focused specifically on information security and risk management

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the CISO's responsibilities and qualifications, fitting Management Role. Specificity is driven by verifiable facts like 30 years IT experience and 17 years in info security, which are externally checkable claims.


reasoning: The paragraph primarily addresses the material impact of cybersecurity on business outcomes through negative assertions and hypothetical scenarios, aligning with Strategy Integration. It contains no specific facts, domain terms, or verifiable claims, so specificity is Level 1 (Generic Boilerplate).


reasoning: The paragraph primarily answers how cybersecurity could affect the business by stating a materiality assessment ('reasonably likely to materially affect'), which aligns with Strategy Integration per Rule 5. It contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims), so specificity is Level 1.


reasoning: The paragraph primarily addresses how cybersecurity affects business outcomes through materiality assessments and investments, aligning with Strategy Integration. No specific facts are present—statements are generic or speculative—so specificity is Level 1.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor selection, oversight, and contractual obligations, making Third-Party Risk the direct category. It contains no specific facts—only generic process descriptions—so it is Level 1 Generic Boilerplate.


reasoning: The paragraph primarily addresses board oversight of cybersecurity risks, fitting Board Governance as it describes the Audit Committee's role in overseeing policies and strategies. It contains no specific facts—only generic oversight language—so specificity is Level 1.


reasoning: The paragraph primarily addresses how cybersecurity affects business outcomes and finances, including materiality assessments and investments, fitting Strategy Integration. It contains no specific facts (e.g., no verifiable claims, firm-specific details, or domain terms that demonstrate expertise beyond generic risk language), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through evaluations and committee reviews, central to Third-Party Risk; specificity is Generic Boilerplate as it contains no domain-specific terms, firm-unique details, or verifiable claims, using only generic risk management language.


reasoning: The paragraph focuses on managing IT vendor and third-party risks through policies, assessments, and remediation tracking, which directly answers the Third-Party Risk question. It contains no specific facts (e.g., named programs, quantified data, or domain-specific terms that pass the ERM test), so it is Generic Boilerplate.


reasoning: The paragraph primarily answers the question of how cybersecurity affects the business by stating a negative materiality conclusion about impacts on strategy, finances, and operations, which aligns with Strategy Integration under Rule 5. For specificity, it contains no domain terms, firm-specific facts, or verifiable claims—only generic boilerplate language about materiality and cross-references, so it is Level 1.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through committee roles (Audit Committee and Risk Committee), fitting Board Governance. It contains no specific facts that elevate specificity above generic boilerplate, as it uses common governance language without firm-specific or verifiable details.


reasoning: The paragraph is a cross-reference to another section of the filing, answering no substantive cybersecurity question about governance, management, risks, incidents, or strategy, so it falls under None/Other. No specific facts are present—no domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes engaging external assessors as part of the cybersecurity program, which aligns with Risk Management Process under Rule 3 (third parties hired to serve the company). It contains no specific facts—such as named roles, quantified data, or verifiable claims—so it is Generic Boilerplate.


reasoning: The paragraph primarily addresses how the company manages third-party cyber risks through vendor due diligence and oversight, making it Third-Party Risk; specificity is Generic Boilerplate because it contains no firm-specific or verifiable facts, using only generic vendor management language.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor oversight and assessments, central to Third-Party Risk. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by describing its design, components, and activities, fitting Risk Management Process. It contains no specific facts (e.g., named roles, quantified data, or verifiable claims), so specificity is Generic Boilerplate.


category_confidence: medium

reasoning: The paragraph primarily answers how cybersecurity affects business through materiality assessments and a conclusion of no material effects, which is Strategy Integration; it contains no specific facts (e.g., no named roles, dates, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph is a general introductory statement about cybersecurity importance without addressing any specific questions about governance, management, risks, incidents, or business impact, so it falls under None/Other; it contains no domain terms, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how the company manages third-party cyber risks through a vendor due diligence process, making it Third-Party Risk; it contains no specific facts, dates, numbers, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business through materiality assessments (stating no material adverse effects and future risks), and contains no specific facts—such as domain terms, firm-specific details, or verifiable claims—that elevate specificity above generic boilerplate.


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


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality assessments (stating no material incidents and forward-looking risk likelihood), fitting Strategy Integration per Rule 5. No specific facts are present—only generic assertions and cross-references—so specificity is Level 1.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a backward-looking materiality assessment (no risks materially affected the company), which is Strategy Integration per Rule 5. No specific facts are present—such as domain terms, firm-specific details, or verifiable claims—to elevate specificity above Level 1, as the date and negative assertion are not cybersecurity-specific facts.


reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by describing implemented processes and controls, aligning with Risk Management Process. It contains no specific facts (e.g., named tools, dates, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers speculative and forward-looking questions about policy effectiveness and future risks, with cross-references to other sections, fitting None/Other; no specific cybersecurity facts, domain terms, or verifiable claims are present, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through due diligence, security assessments, and monitoring, making it Third-Party Risk. It contains no specific facts, firm-specific details, or verifiable claims, as the language is generic and could apply to any company's vendor risk process, so specificity is Level 1.


reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor oversight through assessments and monitoring, which directly aligns with the Third-Party Risk category. It contains no specific facts that elevate specificity above Level 1, as it describes standard cybersecurity practices without any firm-specific details, verifiable claims, or domain-adapted terminology that would demonstrate expertise beyond generic boilerplate.


reasoning: The paragraph primarily describes the board and audit committee's oversight of cybersecurity risks, fitting Board Governance. It contains no specific facts that demonstrate domain expertise, firm-specific details, or verifiable claims, so it remains at Generic Boilerplate specificity.


reasoning: The paragraph primarily addresses materiality assessments of cybersecurity incidents and their potential business impact, which aligns with Strategy Integration. It contains no specific facts, domain terms, or verifiable claims, making it generic boilerplate for specificity.


fact: CISO role

fact: Core Cybersecurity Management Team (CCMT)

fact: Teradata's CIRP program

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, describing the CCMT composition and responsibilities, which is Management Role. It contains firm-specific facts like the CISO role, named CCMT team, and Teradata's CIRP program, elevating specificity to Level 3.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's role in overseeing the ERM risk assessment, making it Board Governance. It contains no specific facts that elevate specificity above generic boilerplate, as all terms (e.g., ERM process, Audit Committee) are common in enterprise risk management without demonstrating cybersecurity domain expertise or firm-specific details.


reasoning: The paragraph is a speculative forward-looking statement about potential cybersecurity risks and business impacts, which does not address any substantive questions like governance, management, or processes, thus falling under None/Other. No specific facts are present, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business through materiality assessments (e.g., 'have not materially affected' and 'are reasonably likely to materially affect'), fitting Strategy Integration. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so it is Generic Boilerplate.


reasoning: The paragraph is a cross-reference to another section, so it does not answer any substantive cybersecurity question and falls under None/Other. It contains no specific facts about cybersecurity measures or processes, so specificity is Generic Boilerplate.


fact: CIO and Director of Cybersecurity both have over 20 years of cybersecurity oversight experience

fact: CIO previously served as CIO for a New York Stock Exchange listed manufacturing company

reasoning: The paragraph focuses on management roles, responsibilities, and qualifications in cybersecurity, directly answering how management is organized, which is Management Role. Specificity is Level 4 due to verifiable claims like 'over 20 years' (a lower bound) and specific career history that external parties could check.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Risk Committee's assurances, fitting Board Governance. It contains no specific facts (e.g., no firm-specific roles, verifiable claims, or domain terms that pass the ERM test), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing systems and programs to mitigate incidents, which aligns with Risk Management Process; it contains no specific facts, domain terms, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing a dedicated department for oversight, 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 how third-party cyber risks are managed, focusing on vendor oversight and contractual safeguards, which aligns with Third-Party Risk; it contains no specific facts (e.g., named roles, numbers, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how management is organized by describing the Chief Risk Officer's role in the ERM structure, fitting Management Role; for specificity, it contains no cybersecurity domain terms, firm-specific details, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business through a negative assertion about not experiencing material adverse events, which per Rule 5 is an assessment falling under Strategy Integration; specificity is Generic Boilerplate as no specific facts (e.g., names, dates, numbers, or verifiable claims) are present in the text.


reasoning: The paragraph is about a human resources officer's role and career history, which does not address any cybersecurity-related questions (e.g., board governance, management role in cybersecurity, risk management, etc.), so it is classified as None/Other. Since there are no cybersecurity-related facts in the paragraph, specificity is Generic Boilerplate (Level 1).


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through due diligence, contractual requirements, and oversight, making it Third-Party Risk; it contains no specific facts, so it is Generic Boilerplate.


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


reasoning: The paragraph describes an executive's career history and responsibilities without any mention of cybersecurity, so it does not answer any of the six substantive cybersecurity questions, hence None/Other. As per guidelines, None/Other paragraphs always receive Generic Boilerplate specificity with no specific facts.


reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor oversight processes, which aligns with the Third-Party Risk category. It contains no specific facts, dates, names, or verifiable claims, making it generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily describes the company's cybersecurity program processes and policies, answering 'what the program does,' which aligns with Risk Management Process. It contains no specific facts, firm-specific details, or verifiable claims, using only generic language, so specificity is Generic Boilerplate.


fact: more than 20 years of experience in cybersecurity and information technology

fact: holds a Certified Information Security Manager (CISM) certification

reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on the CISO's role, qualifications, and reporting lines, which fits Management Role. Specificity is Level 4 due to verifiable facts like the lower-bound experience claim and the CISM certification, which an external party could independently confirm.


reasoning: The paragraph is a general statement about data protection responsibility across the organization, not answering any specific cybersecurity question like governance, management, or processes; it contains no specific facts, making it generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a negative assertion about no material incidents and mentioning insurance, aligning with Strategy Integration per Rule 5. Specificity is Generic Boilerplate because the paragraph contains no verifiable, firm-specific, or domain-expertise facts; it uses generic risk language that any enterprise risk management professional could write.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by discussing materiality assessments and potential impacts, aligning with Strategy Integration. It contains no specific facts—only speculative or general statements—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity, detailing responsibility, lack of delegation, and management updates, which fits Board Governance. It contains no specific cybersecurity facts (e.g., domain terms, firm-specific details, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes how cybersecurity risks are integrated into the enterprise risk management process for audit planning, which aligns with Risk Management Process; no specific facts (e.g., named cybersecurity roles, verifiable claims) are present to elevate specificity beyond generic boilerplate.


content_category: Incident Disclosure

fact: AMCA (American Medical Collections Agency)

reasoning: The paragraph primarily answers what happened in a real cybersecurity incident (the AMCA Incident), fitting Incident Disclosure; specificity is driven by verifiable facts like the exact date and named third-party entity, which are externally confirmable.


reasoning: The paragraph primarily answers how cybersecurity affects the business through materiality assessments (stating no material incidents and no reasonable likelihood of material impact), fitting Strategy Integration; it contains no specific facts—no verifiable claims, domain-specific terms, or firm-unique details—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through contractual obligations for the Custodian and its vendors, fitting Third-Party Risk. It contains no specific facts that elevate specificity above Level 1, as it lacks verifiable claims, firm-specific details, or domain-adapted terminology beyond generic risk management language.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through a program requiring security controls and assessments, fitting Third-Party Risk; specificity is Generic Boilerplate because no specific facts, dates, numbers, or verifiable claims are provided, and all language is generic.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed in acquisitions, fitting Third-Party Risk as the central topic. It contains no specific facts—no domain terms that pass the ERM test, no firm-specific details, and no verifiable claims—so specificity is generic boilerplate.


reasoning: The paragraph primarily addresses how the company manages third-party cyber risks through vendor oversight and contractual requirements, fitting Third-Party Risk; no specific facts are present, as the language is generic and would be used in any enterprise risk management context, resulting in Level 1 specificity.


reasoning: The paragraph primarily discusses speculative cybersecurity risks and references Item 1A risk factors without describing governance, management, processes, or incidents, making it None/Other; as a None/Other paragraph, it is treated as Generic Boilerplate with no specific facts elevating specificity.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through vendor due diligence and contractual obligations, fitting the Third-Party Risk category. Specificity is Level 1 because the paragraph contains no specific facts, only generic boilerplate language that lacks domain expertise, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily answers how cybersecurity affects business finances through a materiality assessment (stating no material impact and no reasonable likelihood), fitting 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 the board oversees cybersecurity through reports and incident communication, fitting Board Governance. It contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims) that elevate specificity above generic boilerplate, as it uses common oversight language without demonstrating cybersecurity expertise or unique company details.


reasoning: This paragraph is a cross-reference to risk factors in Item 1A, which does not answer any substantive cybersecurity question and contains no specific facts, so it is classified as None/Other with Generic Boilerplate specificity.


reasoning: The paragraph primarily addresses board oversight of cybersecurity risk management, fitting Board Governance; it contains only generic governance language without domain-specific terms or verifiable facts, so specificity is Level 1.


fact: over 25 years of experience in information technology and information security

reasoning: The paragraph primarily answers how management is organized for cybersecurity by describing the Chief Security and Trust Officer's role, reporting line, and qualifications, fitting Management Role. Specificity is Level 4 due to the verifiable claim of over 25 years of experience, which is a hard lower-bound fact that can be externally checked.


reasoning: The paragraph primarily addresses how the company manages cybersecurity risks from third parties, such as vendors and service providers, making Third-Party Risk the central category. It contains no specific facts, dates, numbers, or verifiable claims, and the language is generic enough that a non-cybersecurity risk management professional could use it, so specificity is Level 1.


fact: 429,252 Umpqua Bank customers whose information was involved in the Vendor Incident

reasoning: The paragraph primarily answers what happened in a cybersecurity incident by describing a specific event with dates, scope, and response actions, making it Incident Disclosure. The quantified fact of 429,252 affected customers is an externally verifiable claim, driving specificity to Level 4.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing incident response procedures, which falls under Risk Management Process. No specific facts are present to elevate specificity beyond generic boilerplate, as the language uses common risk management terms without domain-specific expertise or verifiable claims.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through Audit Committee reporting and management briefings, which is Board Governance; it contains no specific facts, making it generic boilerplate with no domain-adapted, firm-specific, or verifiable claims.


reasoning: The paragraph primarily answers how cybersecurity affects the business through materiality assessments and references to risk factors, which aligns with Strategy Integration under Rule 5 (negative assertion about no material incidents). It contains no specific facts—such as named roles, verifiable claims, or domain-specific processes—so specificity is generic boilerplate.


reasoning: The paragraph is a speculative disclaimer and cross-reference to risk factors, not answering any substantive cybersecurity question (e.g., governance, incidents, or processes), so it is None/Other. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses how the company manages cybersecurity risks from third-party providers, which directly answers the Third-Party Risk question. Specificity is Level 1 because the description is generic with no firm-specific or verifiable facts; the language on vendor management processes could apply to any business and does not demonstrate domain expertise or unique company details.


reasoning: The paragraph primarily answers how cybersecurity affects business finances through materiality assessments and insurance, fitting Strategy Integration; it contains no specific facts (e.g., verifiable claims, firm-specific details, or domain-expertise terms) that elevate specificity beyond generic boilerplate.


reasoning: The paragraph primarily answers how third-party cybersecurity risks are managed, focusing on the Adviser's approach to overseeing risks from vendors and external users, which aligns with Third-Party Risk. Specificity is Level 1 because the paragraph contains no specific facts, domain terms, firm-specific details, or verifiable claims; it uses generic boilerplate language that any business professional could write.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through vendor evaluation and contractual obligations, central to Third-Party Risk. It contains no specific facts, domain terms, firm-specific details, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph is an introductory statement recognizing cybersecurity importance without describing specific governance, management, processes, incidents, or business impact, so it answers none of the substantive questions and falls under None/Other. No specific facts are present—only generic boilerplate language—so specificity is Level 1.


reasoning: The paragraph primarily describes the cybersecurity risk assessment process, answering 'what the cybersecurity program does' for Risk Management Process. It contains no specific facts—only generic risk management language like 'periodic risk assessments' and 'identification of risks' that any enterprise risk professional could use, so specificity is Level 1.


reasoning: The paragraph is a boilerplate statement about general cybersecurity investment and a cross-reference to risk factors, which does not answer any substantive question like governance, management, or incidents, so it 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 primarily answers the question of how cybersecurity affects the business by stating a materiality assessment (negative assertion about no material impact), which aligns with Strategy Integration per Rule 5. No specific facts are present—such as domain terminology, firm-specific details, or verifiable claims—so specificity is Level 1 (Generic Boilerplate).


reasoning: The paragraph is a cross-reference to another section of the filing, which falls under 'None/Other' as it does not answer any substantive cybersecurity question about governance, management, processes, incidents, or strategy. No specific facts are present in the text, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses board oversight of cybersecurity by describing delegation to the audit committee, fitting Board Governance; it contains no specific facts, as all language is generic and common in corporate disclosures, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily states a conclusion about past cybersecurity incidents not affecting business outcomes and references risk factors, which directly answers the Strategy Integration question about materiality assessments. It contains no specific facts—such as domain terms, firm-specific details, or verifiable claims—that would elevate specificity beyond generic boilerplate language.


reasoning: The paragraph primarily answers how the board and audit committee oversee cybersecurity through reporting, which is a governance-chain structure, so Board Governance is assigned. No specific facts like named individuals, dates, or quantified data are present, making it generic boilerplate with no elevation above Level 1.


reasoning: The paragraph primarily answers how the board oversees risk management, which in the context of Item 1C cybersecurity disclosures aligns with Board Governance; it contains no specific facts, dates, numbers, or verifiable claims, making it generic boilerplate language.


reasoning: The paragraph directly describes a real cybersecurity incident detected in April 2023 and the response actions, answering 'what happened,' so it is Incident Disclosure; it contains no specific facts (e.g., verifiable dates, named experts, or firm-specific details) that elevate specificity above generic boilerplate language.


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. It contains no specific cybersecurity facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing requirements imposed on vendors, central to Third-Party Risk; it contains no specific facts, making it generic boilerplate with no domain-adapted, firm-specific, or verifiable claims.


reasoning: The paragraph primarily states the importance of an information security program and its integration without answering any substantive cybersecurity questions (e.g., governance, processes, incidents), so it is classified as None/Other; with no specific facts like named roles, tools, or verifiable claims, it is Generic Boilerplate.


reasoning: The paragraph primarily addresses board oversight of cybersecurity, fitting Board Governance, and contains no specific facts that elevate specificity beyond generic boilerplate language.


reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor assessments and contractual controls, so it is Third-Party Risk. It contains no specific facts—language is generic and could apply to any company, showing no domain expertise or verifiable claims, hence Generic Boilerplate.


reasoning: The paragraph is a general statement about technology reliance and associated risks, not answering any specific cybersecurity question, so it's classified as None/Other; with no specific facts present, it is Generic Boilerplate.


reasoning: The paragraph is a forward-looking risk statement without describing any cybersecurity governance, management, processes, or incidents, so it falls under None/Other; it contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims) that elevate specificity above generic boilerplate.


fact: firewalls

fact: intrusion prevention

fact: endpoint detection and response systems

fact: access controls

fact: vulnerability assessments

fact: cybersecurity threat intelligence

reasoning: The paragraph primarily answers what the cybersecurity program does by describing technical safeguards and processes like firewalls and vulnerability assessments, fitting Risk Management Process. Specificity is Domain-Adapted due to multiple cybersecurity-specific terms that demonstrate expertise, such as endpoint detection and response, which a non-security ERM professional would not naturally use.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through Audit Committee engagement and Board discussions, which is Board Governance. No specific facts are present—all language is generic and would apply to any public company, so specificity is Level 1.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through the company's dependence on the Investment Adviser and other service providers, making Third-Party Risk the central category. It contains no specific facts such as named entities, quantified data, or domain-specific terms, so specificity is Generic Boilerplate.


reasoning: The paragraph is a cross-reference to risk factors and contains no substantive cybersecurity disclosure, so it falls under None/Other. No specific facts are present in the text, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a materiality assessment, fitting Strategy Integration under Rule 5. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so it is generic boilerplate.


reasoning: The paragraph primarily answers how management is organized for incident response by describing team composition and roles, which aligns with Management Role; 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 addresses the materiality of cybersecurity's impact on business outcomes, with a backward-looking negative assertion about no material adverse effects, which aligns with Strategy Integration per Rule 5. It contains no specific facts, domain terms, or verifiable claims, making it generic boilerplate for specificity.


reasoning: The paragraph primarily describes the reporting flow from management to the audit committee and board, which answers how the board oversees cybersecurity (Board Governance). No specific facts are present—titles like 'Global Director of IT' lack security qualifiers and are not verifiable, and all language is generic oversight terminology, so specificity is Level 1.


reasoning: The paragraph is a cross-reference to risk factors with no substantive cybersecurity disclosure, fitting None/Other; no specific facts are present, so specificity is Generic Boilerplate.


reasoning: The paragraph is a cross-reference to risk factors in another section, providing no substantive cybersecurity disclosure, so it fits None/Other; no specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through delegation to the Audit Committee, which is a governance-chain structure, so it is classified as Board Governance. It contains no specific facts—such as domain terminology, firm-unique details, or verifiable claims—beyond generic governance language, resulting in Generic Boilerplate specificity.


reasoning: The paragraph is a cross-reference to risk factors, which explicitly falls under None/Other as it contains no substantive cybersecurity disclosure; it has no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's role in risk oversight, fitting Board Governance. It contains no specific facts (e.g., named roles, quantified data, or domain-specific practices) that would elevate specificity beyond generic boilerplate, as the language is standard governance terminology any business professional could use.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality assessments (has not materially affected, reasonably likely to materially affect), fitting Strategy Integration. It contains no specific facts—only generic risk language and cross-references—so specificity is Generic Boilerplate.


reasoning: The paragraph is a cross-reference to risk factors in another section, answering none of the substantive cybersecurity questions and fitting 'None/Other'; it contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses how the company manages cybersecurity risks from third-party vendors through oversight procedures, fitting the Third-Party Risk category. It contains no specific facts—such as named vendors, tools, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor oversight, which is the central topic of Third-Party Risk. It contains no specific facts that elevate specificity above generic boilerplate, as it lacks domain-specific terminology, firm-unique details, or verifiable claims.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a materiality assessment conclusion (have not materially affected or are reasonably likely to materially affect), which aligns with Strategy Integration; specificity is Level 1 because the paragraph contains no verifiable, firm-specific, or domain-expertise facts—it is a generic boilerplate statement about materiality without specific details.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality assessments, aligning with Strategy Integration. It contains no specific facts (e.g., quantified data, verifiable claims, or domain-specific terms that pass the ERM test), so specificity is generic boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's role in reviewing risk and controls, with the CFO's management responsibilities as part of the governance chain; for specificity, no domain terms, firm-specific facts, or verifiable claims are present, making it generic boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Risk Committee and governance chain, fitting Board Governance. It contains no specific facts (e.g., named roles, dates, or verifiable claims), so specificity is Generic Boilerplate.


reasoning: The paragraph is a cross-reference to risk factors and does not answer any primary cybersecurity question, so it's classified as None/Other; with no specific facts provided, specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's role in reviewing risks and management reporting, fitting Board Governance. It contains no specific facts—such as named roles, dates, or verifiable claims—so it is generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, focusing on responsibilities and expertise, which aligns with Management Role. It contains no specific facts like named roles, quantifiable data, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers the Strategy Integration question by stating a materiality assessment about cybersecurity incidents affecting business outcomes. No specific facts are present—such as domain terms, firm-specific details, or verifiable claims—making the paragraph generic boilerplate with no elevated specificity.


reasoning: The paragraph primarily answers how the board oversees cybersecurity by mentioning support from the Board and Audit Committee, fitting Board Governance. 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 by describing the governance chain (Board → Audit Committee → General Counsel), so it is Board Governance. It contains no specific facts that elevate specificity above Level 1—no domain terms, firm-unique roles, or verifiable claims—making it generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a negative assertion about material effects, aligning with Strategy Integration. For specificity, it contains no verifiable, firm-specific, or domain-expertise facts—only generic statements and a cross-reference—so it is Level 1.


reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing board and Audit Committee responsibilities, which aligns with Board Governance. It contains no specific facts—such as named roles, verifiable claims, or domain-specific terminology—that would elevate specificity above generic boilerplate language.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a materiality assessment (no threats anticipated to have material effect), fitting 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 the board oversees cybersecurity, detailing updates, presentations, and engagement with experts, which aligns with Board Governance. It contains no specific facts such as named standards, dates, quantifiable data, or firm-specific roles that would elevate specificity above generic boilerplate.


reasoning: This paragraph is a definitional statement for regulatory terms, not answering any substantive cybersecurity questions like governance or risk management, so it is None/Other. It contains no specific facts about the company's cybersecurity practices, roles, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily addresses board oversight of cybersecurity, including expertise and resource allocation, fitting Board Governance; it contains no specific facts (e.g., named roles, verifiable claims, or domain-specific terms), so specificity is generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business finances by stating a materiality assessment (no risks likely to have material effects), fitting Strategy Integration. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so specificity is generic boilerplate.


fact: Vice President, Information Security and Privacy

fact: Senior Vice President, Chief Strategy and Digital Officer

reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee and management briefings, which is Board Governance. Specificity is Firm-Specific because the named management roles (VP-level and above with security-related portfolios) are unique to this company's cybersecurity organization.


reasoning: The paragraph primarily answers the question of business impact by stating a conclusion about the materiality of cybersecurity risks, 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 Generic Boilerplate.


reasoning: The paragraph primarily addresses the business and financial impact of cybersecurity, stating conclusions about materiality and costs, which aligns with Strategy Integration. It contains no specific facts that elevate specificity above generic boilerplate, as it lacks verifiable claims, firm-specific details, or domain-specific terminology demonstrating expertise.


reasoning: The paragraph primarily answers how management is organized for cybersecurity, describing responsibilities and qualifications, so it's Management Role. It contains no specific facts, domain terms, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's responsibilities and management's risk assessment updates, fitting Board Governance; no specific facts are present, so it's generic boilerplate with no domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily addresses materiality assessments and investment in cybersecurity, which directly answers how cybersecurity affects business finances, fitting Strategy Integration; no specific facts are present, as all language is generic and not verifiable, resulting in Level 1 specificity.


reasoning: This paragraph is a cross-reference to risk factors, not answering any substantive cybersecurity question, so it falls under None/Other. As a cross-reference with no specific facts, it is Generic Boilerplate.


reasoning: The paragraph directly answers how the board oversees cybersecurity through oversight structure and information flow, fitting 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 'What does the cybersecurity program do?' by describing incident response planning and evaluation processes, aligning with Risk Management Process; it lacks any domain-specific terminology, firm-specific details, or verifiable claims, making it generic boilerplate for specificity.


reasoning: This paragraph is a cross-reference to risk factors in another section and contains no substantive cybersecurity disclosure, so it falls under None/Other; it has no specific facts, so specificity is Generic Boilerplate.


category_confidence: low

reasoning: The paragraph generically describes the goal of implementing risk management strategies to minimize cybersecurity breach impact, which primarily answers what the cybersecurity program aims to do (Risk Management Process), but it lacks any specific details or measures. No facts elevate specificity above Level 1, as all language is forward-looking and generic without domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily describes what the cybersecurity program does with third-party assistance, such as assessment and monitoring, which aligns with Risk Management Process; it contains no specific facts, dates, names, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how management is organized for cybersecurity by describing roles and responsibilities of the Senior Director of IT and General Counsel, fitting Management Role. No specific facts are present—such as verifiable claims, firm-specific details, or domain expertise terms—so specificity is Generic Boilerplate.


reasoning: The paragraph is classified as None/Other because it primarily discusses hypothetical cybersecurity risks and potential business impacts with speculative language ('could') and includes a cross-reference to risk factors, without answering any of the six substantive questions or describing specific cybersecurity measures. Specificity is Generic Boilerplate (Level 1) as there are no domain-specific, firm-specific, or verifiable facts in the paragraph, and for None/Other categories, it always defaults to Level 1.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee's oversight role, which is Board Governance. It contains no specific facts such as named individuals, dates, or verifiable claims, making it generic boilerplate language.


fact: penetration testing

fact: threat modeling

fact: vulnerability scanners

fact: intrusion prevention and detection systems

fact: anti-malware/endpoint protection

fact: identity and access management

fact: phishing email simulations

fact: tabletop exercises

fact: Incident Response Plan based on NIST, HITRUST, and SOC2 frameworks

reasoning: The paragraph primarily describes what the cybersecurity program does, listing specific activities and tools, so it fits Risk Management Process; for specificity, it contains multiple domain-specific terms like penetration testing and incident response plans that demonstrate cybersecurity expertise, elevating it to Level 2.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the Audit Committee and management reporting flow, which aligns with Board Governance. It contains no specific facts—such as verifiable claims, firm-specific roles, or domain expertise terms—that would elevate specificity above generic boilerplate, as all language is standard governance terminology any enterprise risk management professional would use.


reasoning: The paragraph primarily addresses managing third-party cyber risks through supplier assessments and due diligence, fitting Third-Party Risk. It contains no specific facts, domain terms, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through due diligence and monitoring, fitting the Third-Party Risk category. No specific facts are present—language is generic and applies to any company's vendor risk management, so specificity is Level 1.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a materiality assessment (no material incidents in three years), which aligns with Strategy Integration; it contains no specific facts that elevate specificity above Level 1, as the language is boilerplate and lacks domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph is a cross-reference to risk factors, explicitly pointing elsewhere for information, which aligns with None/Other per the rules; it contains no specific cybersecurity facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes board oversight of cybersecurity through reports and incident updates, fitting Board Governance; it contains no specific facts, making it Generic Boilerplate.


reasoning: The paragraph primarily states conclusions about whether cybersecurity has or will materially affect the business, which aligns with Strategy Integration per Rule 5; it contains no specific cybersecurity facts, making it generic boilerplate with no domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing requirements imposed on service providers, central to Third-Party Risk. It contains no specific facts, firm-specific details, or verifiable claims, making it Generic Boilerplate with no elevated specificity.


reasoning: The paragraph primarily answers the question of whether cybersecurity has materially affected or is likely to affect the business, which aligns with Strategy Integration per Rule 5 (negative assertion about material impact). For specificity, it contains no domain-specific terms, firm-specific details, or verifiable claims, so it is Generic Boilerplate.


reasoning: The paragraph is a general commitment statement about cybersecurity importance and measures, without addressing any specific governance, management, processes, incidents, or impacts, so it falls under None/Other; no specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes through materiality statements (no past effects and potential future effects), which aligns with Strategy Integration. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—making it generic boilerplate with Level 1 specificity.


reasoning: The paragraph directly addresses how third-party cyber risks are managed through vendor due diligence and contract requirements, making it Third-Party Risk. It contains no specific facts (e.g., named vendors, quantified data, or domain-specific practices) that would elevate specificity above generic boilerplate.


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, making it generic boilerplate with Level 1 specificity.


reasoning: The paragraph primarily addresses board oversight of cybersecurity risks through management reporting, fitting Board Governance; it contains no specific facts such as names, dates, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a materiality assessment (no material impact to date), fitting Strategy Integration; it contains no specific facts beyond generic risk statements, so specificity is Generic Boilerplate.


reasoning: The paragraph is a cross-reference to risk factors in another section and does not answer any substantive cybersecurity questions about governance, management, processes, or incidents, 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.


reasoning: The paragraph primarily addresses board oversight of cybersecurity through executive updates to the Board and audit committee, fitting Board Governance. No specific facts are present, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity by describing delegation to the Audit Committee, fitting Board Governance. It contains no firm-specific or verifiable facts, only generic governance language, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses how cybersecurity affects business operations and stakeholder trust, aligning with Strategy Integration; it contains no specific facts, domain terms, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph is a general commitment statement that does not answer any substantive cybersecurity questions (e.g., governance, management, processes), so it falls under None/Other. No specific facts are present—no domain terms, firm-specific details, or verifiable claims—so specificity is Level 1.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality assessment conclusion, 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 is a cross-reference to another section and does not describe any cybersecurity measures, governance, or incidents, so it falls under None/Other. It contains no specific facts, so specificity is Level 1.


reasoning: The paragraph primarily answers how third-party cyber risks are managed through vendor assessments and contractual obligations, directly fitting Third-Party Risk. It contains no specific facts, such as named providers, dates, numbers, or verifiable claims, so it is generic boilerplate with no elevated specificity.


reasoning: The paragraph provides general context on cybersecurity reliance and definition without answering any substantive questions like governance, management, or processes, and contains no specific facts (e.g., domain terms, firm-specific details, or verifiable claims) to elevate specificity above Level 1.


reasoning: The paragraph primarily addresses materiality assessments and insurance coverage regarding cybersecurity impacts, which aligns with Strategy Integration. It contains no specific facts, domain expertise vocabulary, or verifiable claims, making it generic boilerplate for specificity.


reasoning: The paragraph directly addresses materiality assessments of cybersecurity's impact on business outcomes, which is the core question for Strategy Integration. It contains no specific facts—no verifiable claims, domain terms, or firm-specific details—making it generic boilerplate for specificity.


fact: IT Security Steering Committee led by Chief Financial Officer

fact: Members include VP of Software Engineering and Director of Information Systems and Security

fact: Collectively have over 40 years of experience

reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing the committee structure, leadership roles, and team composition, which fits Management Role; specificity is driven by the verifiable claim of 'over 40 years' of collective experience, which is a hard lower-bound number that can be externally checked.


reasoning: The paragraph primarily answers how cybersecurity affects business through materiality assessments, stating conclusions about no material effects, which fits Strategy Integration; it contains no specific facts, making it generic boilerplate.


reasoning: The paragraph primarily addresses board oversight of cybersecurity risks, fitting Board Governance as it describes the Board and Audit Committee's role in reviewing risk management measures. It contains no specific facts—only generic governance language—so specificity is Level 1.


reasoning: The paragraph primarily answers how management is organized and responsible for cybersecurity risks, focusing on roles, qualifications, and monitoring, which aligns with Management Role; it contains no verifiable or firm-specific facts, only generic descriptions, so specificity is Level 1.


fact: over twenty years of experience in information technology, security, and cybersecurity

reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing roles and experience, which fits Management Role; specificity is driven by the verifiable claim of 'over twenty years of experience,' which is externally checkable.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through vendor assessments, fitting the Third-Party Risk category; no specific facts are present, so it is Generic Boilerplate with no domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality assessment (no incidents likely to materially affect operations), which aligns with Strategy Integration. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so it is generic boilerplate.


reasoning: The paragraph primarily addresses board oversight of cybersecurity, fitting Board Governance, and contains no specific facts (e.g., named roles, dates, or verifiable claims), making it generic boilerplate.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing the use of a third party for assessment, which is a risk management activity; it contains no specific facts, so specificity is Level 1.


reasoning: The paragraph primarily addresses materiality assessments by stating conclusions about past incidents not having material impact and future risks not being likely to materially affect operations, which aligns with Strategy Integration; no specific facts are present to elevate specificity beyond generic boilerplate language.


reasoning: The paragraph primarily answers how cybersecurity affects the business through negative assertions about incidents and speculative material consequences, aligning with Strategy Integration per Rule 5. 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 a real cybersecurity incident (unauthorized activity, response, and impact), answering 'what happened,' so it is classified as Incident Disclosure. For specificity, it contains no externally verifiable or firm-specific facts—only generic incident description terms like 'incident response plan' and 'containment measures' that fail the ERM test for domain expertise, resulting in Generic Boilerplate.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing incident response processes and team formation, aligning with Risk Management Process; it contains no specific facts (e.g., no verifiable claims, firm-specific roles, or domain terms that pass the ERM test), so specificity is generic boilerplate.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed by relying on the Adviser's personnel for oversight, fitting the Third-Party Risk category; it contains no specific facts such as named entities, quantified data, or domain-specific terms that would elevate specificity beyond generic boilerplate.


reasoning: The paragraph primarily addresses how third-party cybersecurity risks are managed through consultants and processes, fitting the Third-Party Risk category. It contains no specific facts such as names, numbers, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes engaging third-party consultants for cybersecurity testing and advisory services, which answers what the cybersecurity program does (Risk Management Process), not third-party risk management as the central topic. No specific facts are present, such as named entities, quantifiable data, or domain-specific terms that pass the ERM test, so specificity is Generic Boilerplate.


reasoning: The paragraph directly states a conclusion about whether cybersecurity has or will materially affect the business, which aligns with Strategy Integration per Rule 5; it contains no specific facts, making it generic boilerplate for specificity.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through assessments and contractual provisions, fitting Third-Party Risk. It contains no specific facts like named programs, dates, numbers, or verifiable claims, so it is Generic Boilerplate.


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


reasoning: The paragraph focuses on managing third-party cybersecurity risks through assessments and contractual obligations, directly answering the Third-Party Risk question. It contains only generic process descriptions without any firm-specific or verifiable facts, so specificity is Level 1.


reasoning: The paragraph primarily addresses materiality assessments of cybersecurity risks on business outcomes, which aligns with Strategy Integration; it contains no specific facts (e.g., no firm-specific roles, verifiable claims, or domain terms beyond generic risk language), so specificity is Level 1.


reasoning: The paragraph primarily answers whether cybersecurity has affected business outcomes by stating no material incidents have occurred, which is a materiality assessment under Strategy Integration per Rule 5. It contains no specific facts—only generic negative assertions—so specificity is Level 1.


reasoning: The paragraph is from a blank check company with no operations and no cybersecurity program, which per Rule 6 (SPACs and no-operations companies with no program) falls under None/Other; no specific cybersecurity facts are present, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by describing activities like risk assessments, safeguards, monitoring, and training, fitting Risk Management Process. It contains no specific facts that elevate specificity above Level 1, as all language is generic and passes the ERM test for domain expertise.


reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by describing procedures for asset identification, assessment, monitoring, and classification, which aligns with Risk Management Process; it contains no specific facts (e.g., no firm-specific roles, verifiable claims, or domain terms that pass the ERM test), so specificity is Level 1.


reasoning: The paragraph primarily states a negative assertion about no material cybersecurity incidents, which under Rule 5 is classified as Strategy Integration as it addresses materiality assessments. No specific facts (domain terms, firm-specific details, or verifiable claims) are present, so specificity is Level 1 Generic Boilerplate.


reasoning: The paragraph is a cross-reference to Item 1A and does not answer any substantive cybersecurity question, falling 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 processes, making it Third-Party Risk. For specificity, it contains no firm-specific or verifiable facts, and the domain terms (e.g., 'security assessments') are generic practices that any enterprise risk management professional would use, so it's Level 1.


reasoning: The paragraph primarily addresses board oversight by describing the flow of cybersecurity updates from management to the board and audit committee, fitting Board Governance; it contains no specific facts (e.g., no domain terms, firm-specific details, or verifiable claims) that would elevate specificity above generic boilerplate.


reasoning: The paragraph directly addresses how third-party cyber risks are managed through vendor requirements and monitoring, making it Third-Party Risk. It contains no specific facts—only generic risk management language—so specificity is Level 1 (Generic Boilerplate).


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a materiality conclusion (no incidents materially affecting operations), which aligns with Strategy Integration. It contains no specific facts—only generic statements about awareness and proactive steps—so specificity is Level 1.


reasoning: The paragraph primarily answers the Strategy Integration question by stating a backward-looking materiality assessment about cybersecurity's impact on business outcomes, per Rule 5. It contains no specific facts—only a generic negative assertion that cannot be externally verified—so specificity is Level 1.


reasoning: The paragraph describes potential business impacts of cybersecurity risks in a speculative manner ('Could... Disrupt...'), which does not directly answer any of the six substantive questions (e.g., it is not an assessment under Strategy Integration per Rule 5) and lacks any specific facts, making it generic boilerplate.


reasoning: The paragraph primarily answers the question about business impact by stating a materiality conclusion that cybersecurity risks have not materially affected or are not likely to materially affect the company, which aligns with Strategy Integration per Rule 5. It contains no specific facts—no verifiable claims, firm-specific details, or domain terminology that passes the ERM test—so specificity is Generic Boilerplate.


reasoning: The paragraph is a forward-looking disclaimer and cross-reference to Risk Factors, answering none of the substantive cybersecurity questions, and contains no specific facts, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating conclusions about materiality, which aligns with Strategy Integration; 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 addresses BHE's reliance on third-party service providers and associated cyber risks, which is the central topic of Third-Party Risk. It contains no specific facts—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 risk assessment processes, fitting Risk Management Process; it contains no specific facts—using generic language like 'periodic risk assessments' and 'cybersecurity threats' that fail the ERM test for domain expertise and lack any firm-specific or verifiable claims, so specificity is Level 1.


reasoning: The paragraph primarily answers how the board oversees cybersecurity, focusing on oversight structure and delegation, which aligns with Board Governance. It contains no specific facts—no domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


fact: Deputy Chief Executive Officer and Chief Financial Officer role

fact: More than seven years of operational responsibility for IT

reasoning: The paragraph primarily addresses management organization for cybersecurity, detailing specific roles and verifiable experience, leading to Management Role category; the 'more than seven years' claim is a quantified-verifiable fact, driving specificity to Level 4.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a backward-looking materiality conclusion (no material impact to date), which aligns with Strategy Integration. It contains no specific facts—only generic risk language and a non-verifiable negative assertion—so specificity is Level 1.


reasoning: The paragraph primarily describes the cybersecurity program's activities, such as assessing risks and reviewing policies, which answers 'What does the program do?' fitting Risk Management Process. It contains no specific facts that elevate specificity above generic boilerplate, as it uses standard risk management language without domain expertise or verifiable claims.


reasoning: The paragraph focuses on managing third-party cybersecurity risks through processes and contract reviews, directly answering the Third-Party Risk question. It contains no specific facts, tools, or verifiable details, making it generic boilerplate for specificity.


reasoning: The paragraph describes Mr. Tao's general professional experience in business consultation and marketing without any cybersecurity context, so it does not answer any of the six substantive cybersecurity questions. As a None/Other paragraph with no cybersecurity-specific facts, it is classified as Generic Boilerplate (Level 1).


reasoning: The paragraph is a generic statement about the importance of cybersecurity without detailing specific processes, roles, or impacts, so it falls under None/Other. No specific facts are present, as the language is high-level and could apply to any company, resulting in Level 1 Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a conclusion that no material risks have been identified that affected or are likely to affect business outcomes, which aligns with Strategy Integration per Rule 5; for specificity, no domain terms, firm-specific facts, or verifiable claims are present—only generic assertions and cross-references—so it is Level 1 boilerplate.


reasoning: The paragraph primarily answers whether cybersecurity risks have or will affect business outcomes, stating a materiality conclusion, which aligns with Strategy Integration; 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 whether cybersecurity has materially affected the business through a negative assertion, which is classified as Strategy Integration per Rule 5. It contains no specific facts—only a cross-reference and a generic statement—so specificity is Level 1.


reasoning: The paragraph primarily answers how cybersecurity incidents affect the business through a materiality assessment (stating no material impact in 2024 and referencing future impacts), fitting Strategy Integration. It contains no specific facts that elevate specificity above Level 1, as it uses general statements and negative assertions without verifiable details, firm-specific information, or domain expertise terms.


reasoning: The paragraph is a standard forward-looking statements disclaimer with no cybersecurity content, so it answers none of the substantive cybersecurity questions, leading to None/Other. No specific facts related to cybersecurity or the company's posture are present, so specificity is Generic Boilerplate.


fact: CIO has over 25 years of IT Risk Management experience

fact: Cybersecurity team has more than 30 years of collective information and product security experience

reasoning: The paragraph primarily addresses management's organization and roles in cybersecurity, with verifiable claims about the CIO's and team's experience, which are externally checkable facts driving specificity to Level 4.


reasoning: The paragraph primarily addresses regulatory requirements and cross-references, not answering any of the six substantive cybersecurity questions, so it falls under None/Other. As per rule, None/Other paragraphs always get Generic Boilerplate specificity, with no specific facts elevating it above Level 1.


reasoning: The paragraph primarily answers general questions about cybersecurity risks and threats without detailing governance, management, processes, or incidents, making it None/Other. It contains no firm-specific or verifiable facts, as all content is generic risk description, leading to Generic Boilerplate specificity.


reasoning: The paragraph primarily addresses the board's oversight responsibilities for cybersecurity risks, fitting Board Governance. It contains no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily addresses regulatory context and cross-references without describing the company's own cybersecurity practices, fitting None/Other; as per instruction, None/Other paragraphs always receive Generic Boilerplate specificity regardless of any factual elements present.


fact: Chief Privacy Officer has over 13 years previously serving as the Company's Chief Financial Officer

fact: Chief Information Security Officer has over 20 years of work experience in cybersecurity at financial institutions

reasoning: The paragraph primarily answers how management is organized for cybersecurity, focusing on roles, responsibilities, and qualifications, which aligns with Management Role; specificity is driven by verifiable claims about years of experience for key officers, elevating it to Level 4.


reasoning: The paragraph primarily answers how cybersecurity may affect the business by stating a forward-looking assessment of potential material effects, fitting Strategy Integration. It contains no specific facts (e.g., no verifiable claims, firm-specific details, or domain expertise terms), so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by listing roles and responsibilities of specific management members, fitting Management Role; it contains no specific facts (e.g., domain terms, firm-specific titles, or verifiable claims) that elevate specificity above generic boilerplate, as all language is high-level and applicable to any risk management context.


reasoning: The paragraph primarily answers what the cybersecurity program does by describing incident response plans and employee training, fitting Risk Management Process; it lacks any specific details, tools, or verifiable claims, making it generic boilerplate with no facts elevating specificity above Level 1.


reasoning: The paragraph primarily addresses board oversight of cybersecurity through communication with the Audit Committee, fitting Board Governance; it contains no specific facts, making it generic boilerplate with no domain terms, firm-specific details, or verifiable claims.


fact: 27 years of technology leadership experience for Vice President and Chief Information Officer

fact: Doctor of Business Administration for Vice President and Chief Information Officer

fact: 27 years of experience in infrastructure and security operations for Director of Information Security

fact: degree in Information Technology Management for Director of Information Security

reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing roles, qualifications, and committee structures, which aligns with Management Role. It contains verifiable facts like specific years of experience and degrees, driving Quantified-Verifiable specificity.


reasoning: The paragraph primarily discusses speculative business impacts and cross-references Item 1A without describing any specific cybersecurity measures or assessments, so it falls under None/Other per Rule 5. No specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a negative conclusion about material incidents, aligning with Strategy Integration per Rule 5; specificity is Level 1 because the paragraph contains no domain-adapted, firm-specific, or verifiable facts—it is a generic assertion about incident absence.


reasoning: The paragraph describes general cybersecurity risks and threats without addressing specific governance, management, processes, or incidents, fitting None/Other. As a None/Other paragraph, it has no specific facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity through the audit committee's reporting and responsibilities, which is Board Governance. It contains no specific facts—only generic oversight language that any enterprise risk management professional could use—so specificity is Level 1.


reasoning: The paragraph primarily answers how the company manages third-party cyber risks through vendor oversight and assessments, central to Third-Party Risk. It contains no specific facts—no named vendors, quantified data, or verifiable claims—making it generic boilerplate with no domain-specific terminology that passes the ERM test.


fact: assessment criteria for third-party cybersecurity risks based on access to network, data, and information systems

specificity_confidence: medium

reasoning: The paragraph directly addresses how third-party cyber risks are managed through assessment and contracting processes, fitting the Third-Party Risk category. Specificity is Level 2 because it includes domain-specific criteria (e.g., access to network, data, and information systems) that demonstrate cybersecurity expertise, passing the ERM test.


reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a materiality assessment (no past material effects), 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.


reasoning: The paragraph primarily answers how cybersecurity affects the business by stating a conclusion about material impact, which aligns with Strategy Integration per Rule 5. It contains no specific facts—such as domain terms, firm-specific details, or verifiable claims—so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes how management informs the Board of Directors on cybersecurity risks and the Board's oversight activities, answering the board governance question; it contains no specific facts that elevate specificity above Level 1, as it uses generic governance language without verifiable claims or firm-unique details.


reasoning: The paragraph primarily addresses how third-party cyber risks are managed through due diligence and contractual requirements, fitting the Third-Party Risk category. It contains no specific facts such as names, numbers, or verifiable claims, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes the company's use of external experts and technology for cybersecurity evaluations, which answers what the cybersecurity program does (Risk Management Process). It contains no specific facts that elevate specificity above Level 1, as it lacks domain-adapted terminology, firm-specific details, or verifiable claims, making it generic boilerplate.


reasoning: The paragraph primarily addresses how the company manages third-party cybersecurity risks through vendor reports and oversight, which is central to Third-Party Risk. For specificity, it contains no firm-specific or verifiable facts—such as named roles, specific processes, or quantifiable claims—so it is classified as Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity by listing oversight and promotion activities, fitting Board Governance; it contains no specific facts, making it generic boilerplate with no domain-adapted, firm-specific, or verifiable claims.