content_category: Risk Management Process

category_confidence: high

specificity_confidence: medium

reasoning: The paragraph's grammatical subjects are Cheniere's internal processes—assessments, audits, exercises, training—making Risk Management Process correct. For specificity, 'Cyber Incident Response Plan' is a named internal program with a unique identifier (✓ IS list), which elevates this above Generic Boilerplate despite the otherwise generic language. I disagree with Annotator A's dismissal of this identifier; the capitalization and specific naming distinguishes it from generic 'incident response plan.' However, this is only one firm-specific fact, so it remains Firm-Specific rather than Quantified-Verifiable. I agree with Annotator B's conclusion on specificity level, though their reasoning was underdeveloped—they correctly identified the specific plan name but didn't articulate why it matters under the codebook.

provider: moonshotai


content_category: Board Governance

specificity_confidence: high

reasoning: The paragraph describes the board's oversight of cybersecurity risks and the cadence of management reporting (periodic presentations, updates when material). While 'management' appears as the grammatical subject in two sentences, the content focuses on the board's oversight process and briefing mechanisms, not on identifying specific cybersecurity management roles (CISO/CTO/CIO) or their qualifications. The Management Role category requires specific role identification, not generic references to 'management.' The paragraph contains no specific facts, named committees beyond the standard board of directors, dates, or frameworks, making it generic boilerplate.


content_category: Management Role

reasoning: The paragraph's grammatical subject is the CDIO (a technology/cybersecurity management role), and the content focuses entirely on this individual's responsibilities, qualifications, and tenure, fitting the 'Management Role' definition perfectly. For specificity, the disclosure contains two hard, independently verifiable facts that meet the Quantified-Verifiable threshold: (1) a specific date (January 2022) when the CDIO assumed the role, and (2) a specific quantified duration (over 20 years of experience). I agree with Annotator A that this reaches Quantified-Verifiable because these are concrete, externalizable data points (date + number), not merely organizational details. Annotators B and C appear to have treated the date and experience as merely 'firm-specific' details, but per the codebook calibration example ('The CISO has 17 years of experience...'), specific year counts are hard facts that count toward the QV threshold when paired with a specific date.


reasoning: The grammatical subject is the 'Audit and Risk Committee,' a board committee with oversight responsibility for cybersecurity risk, which squarely fits the Board Governance definition. For specificity, the paragraph contains zero hard verifiable facts (no dates, dollar amounts, headcounts, percentages, or named third-party firms/products). While the committee is named 'Audit and Risk Committee' rather than simply 'Audit Committee,' the codebook explicitly lists 'Audit Committee' as generic governance that does not qualify as firm-specific. An 'Audit and Risk Committee' is a standard governance variant (combining the mandatory audit function with risk oversight) rather than a specialized non-generic committee like a 'Technology Committee' or 'Cybersecurity Committee' (which the codebook lists as specific). The phrases 'comprised fully of independent directors' and 'regularly reviews' are standard governance boilerplate. Therefore, I agree with Annotators A and B that this is Generic Boilerplate, and disagree with Annotator C's classification of the committee name as a specific fact.


reasoning: The paragraph describes Garmin's internal cybersecurity risk management program, including risk assessment, alignment with frameworks, and integration with internal teams. This fits the Risk Management Process definition (company's own internal processes as the topic). All three annotators correctly identified this category. For specificity, the paragraph names the NIST Cybersecurity Framework (a recognized standard) but lacks any firm-specific facts from the IS list: there are no specific dates, named roles (e.g., CISO), named third-party firms (only unnamed 'third-party providers'), specific numbers, or unique internal program identifiers. References to 'in-house cybersecurity experts' and 'product development and technology management teams' are generic organizational descriptors, not specific facts per the codebook's exclusion criteria. Therefore, the paragraph is Sector-Adapted.


reasoning: The paragraph describes the company's internal risk assessment and system stratification process using the MLPS framework. While it mentions that a third party performs the assessment, the central topic is the company's own internal process and oversight structure, not vendor risk management. Regarding specificity, the disclosure names the Multi-Level Protection Scheme (MLPS), which is a recognized cybersecurity standard (the Chinese equivalent to NIST or ISO frameworks), but contains no firm-specific facts from the IS list. 'JiuGe Technology' is a corporate self-reference (subsidiary), 'IT Manager' is a generic role not on the cybersecurity-specific titles list, and the third party is unnamed. Therefore, Sector-Adapted is the correct specificity level, as the paragraph names a recognized standard but lacks unique identifying details about this specific company's implementation.


reasoning: The paragraph's grammatical subjects are the 'audit committee' and 'Board of Directors,' and the primary focus is their oversight of the cybersecurity program, the reports they receive, and the escalation protocols to them. While management roles (ISO, CISO) are mentioned, they appear in the context of the reporting chain that ultimately informs the Board/committee, making Board Governance the appropriate category per the tiebreaker rule that assigns Board Governance when 'management mentioned briefly + board oversight as main focus.' The specificity is Firm-Specific because it identifies cybersecurity-specific roles (CISO and ISO), but lacks hard verifiable facts (dates, dollar amounts, named third-party firms/tools) required for Quantified-Verifiable. I agree with Annotator B: the paragraph centers on governance and oversight structures rather than internal risk management processes or management roles as the primary topic.


reasoning: The paragraph identifies a specific management role (Executive Vice President, Senior Operations Officer) as the grammatical subject and describes her qualifications, tenure, and cybersecurity oversight responsibilities, fitting the Management Role category definition. I agree with Annotators B and C that this reaches Quantified-Verifiable specificity because it contains two hard, independently verifiable facts: '35 years of experience' and '24 years' in the current role. These specific numbers meet the threshold for Quantified-Verifiable under the codebook's calibration examples (which treat specific years of experience as hard facts), distinguishing it from generic tenure descriptions.


reasoning: The paragraph's grammatical subject is the CIO, Jovan Kangrga, and the text focuses entirely on his identification, qualifications, tenure, team composition, and reporting lines to the CLO, CEO, and Board. This aligns precisely with the 'Management Role' definition covering CISO/CTO/CIO identification, qualifications, and reporting lines. While the paragraph contains multiple numerical claims (e.g., 'past four years,' 'over 13 years,' 'over 40 years of combined experience'), these are biographical experience metrics and durations, not the hard verifiable facts (specific dates, dollar amounts, headcounts, percentages, named third-party firms, or named tools/products) required for Quantified-Verifiable specificity. However, the disclosure includes the cybersecurity-specific title (CIO), the named individual (Jovan Kangrga), specific durations, and educational institutions, which clearly exceed generic boilerplate and satisfy the Firm-Specific threshold.


reasoning: The paragraph describes the company's internal processes for risk identification, assessment, monitoring, and mitigation, which aligns with the Risk Management Process category definition ('Risk assessment, framework adoption, vulnerability management, monitoring...'). While 'Management' is the grammatical subject, the content focuses on the processes themselves rather than on identifying specific cybersecurity roles (CISO/CTO/CIO), their qualifications, or reporting lines—which are the defining elements of the Management Role category. The paragraph contains no specific facts: 'Management' is a generic term (not a specific cybersecurity title like CISO), and there are no dates, named frameworks, dollar amounts, headcounts, or other unique identifiers. It is generic boilerplate that could apply to any company.


reasoning: The paragraph's grammatical subject is the 'VP of IT' (Vice President, Information Technology and Facilities), and the text focuses on this management role's operational oversight responsibilities, qualifications, and experience. This aligns with the 'Management Role' category definition. While the paragraph mentions assessing processes against frameworks (NIST, CIS, ISO 27001), this is secondary to the primary focus on the VP of IT's leadership and credentials.


reasoning: The paragraph describes the company's internal cybersecurity approach and monitoring processes, including the use of a third-party consultant as a component of its risk management program. This aligns with 'Risk Management Process' rather than 'Third-Party Risk' because the vendor is mentioned as a tool within the company's internal process, not as the central topic of vendor oversight. For specificity, the consultant is unnamed (falling under the 'NOT' list as an unnamed entity), security tools are unspecified, and 'over 30 years' is an approximate duration rather than an exact specific number. Because no exact durations, dates, dollar amounts, headcounts, percentages, named firms, or named tools are present, the paragraph lacks any facts from the ✓ IS list and is Generic Boilerplate. I agree with Annotator A: while '30 years' references a number, the modifier 'over' makes it an approximation, not an exact duration or specific verifiable fact required to elevate the paragraph to Firm-Specific status.


reasoning: I agree with Annotator B's category choice. While the CEO is indeed a generic C-suite role, the paragraph's grammatical subject is the CEO's oversight function, making this a management role description rather than a process description. The cross-functional team composition with 'mining operations' (specific to this biomed/mining company), 'software engineering,' 'compliance,' 'legal,' 'contractors,' and 'partners' constitutes a firm-specific departmental composition that goes beyond generic boilerplate. However, I disagree with Annotator B's specificity rating of 3 (Quantified-Verifiable) — there are no hard verifiable facts like dates, dollar amounts, headcounts, percentages, or named third-party firms. The team composition is specific but organizational, not quantified-verifiable. Annotator C incorrectly dismisses the team composition as generic; 'mining operations' in a biomed company and the specific multi-department list is clearly firm-specific. Annotator A misapplies the category: while incident response planning is mentioned, the paragraph describes WHO does it (CEO leads, specific team composition), not HOW the process works.


content_category: Strategy Integration

reasoning: The paragraph contains a brief, non-specific mention of past cybersecurity incidents ('we have, from time-to-time experienced cybersecurity incidents') combined with a materiality assessment ('such risks have not materially affected our business...'). Per the codebook tiebreaker rule, 'Brief mention of a past incident + materiality conclusion as the main point → Strategy Integration.' While the paragraph includes hypothetical risk language and ends with a cross-reference, the substantive disclosure of incident history and materiality prevents classification as None/Other. For specificity, the paragraph contains no named entities, dates, frameworks, roles, or quantifiable facts—only generic references to 'IT systems,' 'business,' and vague temporal markers ('from time-to-time')—making it Generic Boilerplate.


reasoning: The paragraph's grammatical subject is the company's own cybersecurity program (assessments, penetration testing, vulnerability scanning, framework adoption), making Risk Management Process correct. For specificity, Harley-Davidson as a named contractual counterparty and the Master Services Agreement are firm-specific facts, but these are organizational/structural details, not hard externally verifiable facts like dates, dollar amounts, or percentages. The NIST framework alone would make it Sector-Adapted, but the named Harley-Davidson relationship pushes it to Firm-Specific. No second hard verifiable fact exists to reach Quantified-Verifiable.


reasoning: The paragraph's grammatical subject is the Audit Committee and its oversight activities, which squarely fits the Board Governance category. Regarding specificity, while 'Audit Committee,' 'annual/quarterly' cadences, and 'executive leadership team' are generic per the codebook's exclusion list, the disclosure of a specific reporting structure involving a 'cybersecurity and data privacy leadership team' constitutes a specific team/department composition (analogous to the calibration example citing 'Legal, Compliance, and Finance'). This organizational detail is not universal and identifies something unique to this company's disclosure structure, elevating the paragraph from Generic Boilerplate to Firm-Specific.


reasoning: The paragraph's grammatical subject is the Chief Executive Officer (a management role), who is described as playing a pivotal role in informing the Audit Committee on cybersecurity risks. Per the codebook instructions, the category should be assigned based on the grammatical subject, and the tiebreaker rule states that when 'board oversight [is] mentioned briefly + management roles [are the] main focus,' the correct category is Management Role. While the Audit Committee appears as the recipient of briefings, the focus is on the CEO's reporting line and briefing responsibilities, not on the committee's oversight processes per se. The CEO is explicitly listed as 'generic C-suite' in the codebook, and 'once per year' constitutes a generic cadence without specific dates, resulting in no firm-specific facts.


reasoning: The paragraph describes the company's internal cybersecurity posture, specifically its lack of dedicated personnel and processes, reliance on third-party technologies as a substitute for internal capabilities, and basic incident response protocols. While third parties are mentioned, they are discussed as a component of the company's own risk management deficiencies rather than as the central topic of vendor oversight or contractual requirements, which aligns with Risk Management Process rather than Third-Party Risk. The reference to Management reporting to the Board describes a process, not a management role definition or board governance structure.


reasoning: The paragraph describes how Liberty Broadband organizes its cybersecurity risk management activities—specifically, that it participates in Liberty's (the parent entity) risk assessment and management processes via a services agreement, while subsidiary GCI maintains its own function. This describes the company's internal risk management structure and processes, not vendor oversight of an external third party. While a services agreement is mentioned, Liberty is a related entity (parent company), not an external vendor, and the focus is on the internal process for managing threats rather than third-party risk management.


reasoning: The paragraph primarily describes the company's internal processes for mitigating cybersecurity risks, including application design, backup systems, monitoring, detection activities, anti-malware use, employee training, quality audits, and response team structures. While the Head of IT department and reporting lines are mentioned, they appear as components of the 'communication and reporting structures' within the broader risk management framework rather than as the central focus. Per the tiebreaker rules, when management roles are mentioned briefly as part of a larger process description, the category remains Risk Management Process rather than Management Role.


reasoning: The paragraph describes the company's internal processes for prevention, detection, and response (firewalls, patching, backups, internal cloud). While it mentions third parties to note the avoidance of external dependence, vendor oversight is not the central topic. The description lacks named frameworks (NIST, ISO), specific dates, headcounts, dollar amounts, named third-party firms (e.g., Mandiant, Deloitte), or named products/tools (e.g., Splunk, CrowdStrike). Terms like 'Layer 7 firewall solutions' refer to a generic technical category (OSI application layer), not a specific product or unique system identifier. Cadences like 'daily' and 'monthly' are generic without specific dates. Therefore, the content is Generic Boilerplate.


reasoning: The paragraph describes the company's internal enterprise risk management (ERM) program and how it integrates cybersecurity risks, which aligns with Risk Management Process. While it mentions reporting to the Board, the grammatical subject and primary focus is the ERM program itself, not board oversight. I agree with Annotator A's specificity assessment: although the paragraph references 'Atleos' ERM programs,' company self-references do not count as firm-specific facts per the codebook. The disclosure lists generic ERM objectives (framework establishment, role definition, oversight, reporting, training) without naming specific frameworks (NIST, ISO), cybersecurity-specific roles (CISO), dates, numbers, or unique program identifiers. Unlike the calibration example that cites '12 risk categories with quarterly reviews' (which qualifies as Firm-Specific due to specific organizational details), this paragraph contains only universal, boilerplate descriptions of risk management processes applicable to any company.


reasoning: The paragraph describes the company's internal processes for monitoring, vulnerability management, training, and access controls, which clearly fits 'Risk Management Process.' While the text mentions the 'Information Systems Security department,' this is a generic functional designation for a security department rather than a cybersecurity-specific role (like CISO), a unique team composition (e.g., 'Legal, Compliance, and Finance'), or a named program. The paragraph contains no named standards (NIST, ISO), dates, headcounts, named third-party firms, or specific tools/products. Therefore, it is Generic Boilerplate.


content_category: None/Other

reasoning: The paragraph provides generic contextual background about the types of data the company handles (IP, PII, clinical trial data) and states that IT security is important to operations, but it does not describe any specific risk management processes (e.g., assessment methodologies, frameworks, monitoring activities, or incident response planning). It lacks substantive disclosure regarding governance, management roles, or specific strategic integration beyond boilerplate statements about criticality. Annotator A correctly identified that this is introductory context without specific process description.


reasoning: The paragraph's grammatical subject is the company's risk management program and how it is implemented through its Manager and IT Service Provider. While third parties are mentioned, they are described as components of the internal risk management process, not as the central topic of vendor oversight requirements. The paragraph includes multiple firm-specific facts: the company has no employees, is externally managed by its Manager, and the IT Service Provider provides SOC 2 reports as part of annual reviews. These organizational specifics about how the REIT structure operates make this Firm-Specific, not merely Sector-Adapted.


reasoning: The grammatical subject of the main clause is 'Our approach to cybersecurity risk management,' which describes the company's internal process for integrating cybersecurity into its broader risk management framework. While the Board of Directors is mentioned, it appears as the agent in a passive construction ('overseen by') rather than as the grammatical subject. Per the codebook, Board Governance requires the board or committee to be the grammatical subject. The disclosure contains no specific facts—no named frameworks, cybersecurity-specific roles, dates, or committee names beyond the generic 'Board of Directors'—making it Generic Boilerplate.