content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities and reporting structure, making Board Governance the primary category. It is classified as Firm-Specific because it names specific internal committees and roles (Audit Committee, ERM Committee, CIO, VP Infrastructure).

provider: google


content_category: Strategy Integration

reasoning: The paragraph discusses general cybersecurity risks and concludes with a standalone materiality statement regarding the impact of these risks on the company's business and financial condition.


reasoning: The paragraph focuses primarily on the Board's oversight responsibilities and its interaction with specific executive roles (President and CEO, General Counsel) regarding cybersecurity risk management.


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal information security programs and risk management approach, specifically citing alignment with industry-standard frameworks (ISO and NIST).


reasoning: The paragraph primarily describes the company's internal risk management program and its integration into the broader ERM framework. While it mentions specific roles and frameworks, the central topic is the operational process of managing cybersecurity risk.


reasoning: The paragraph describes the company's internal risk management structure, specifically identifying the departments (Legal, Compliance, Finance) that comprise their cybersecurity team.


reasoning: The paragraph explicitly details the oversight responsibilities of the Audit Committee and the Board of Directors regarding cybersecurity, making it a clear Board Governance disclosure.


content_category: None/Other

reasoning: The paragraph is a cross-reference to another section of the filing (Item 1A) and does not contain substantive cybersecurity disclosure.


content_category: Management Role

reasoning: The paragraph focuses on the reporting lines and responsibilities of specific management roles (VP, IT Data Security; CTO) and internal committees, which aligns best with the Management Role category.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, including integration into enterprise risk management. It contains no specific names, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk management processes, including the use of specific frameworks and internal policies to assess and manage threats. It is classified as Firm-Specific because it references the company's specific 'Information Security Policy'.


reasoning: The paragraph identifies a specific management role (Health, Safety, and Environmental Director) and details their reporting line to the Board and their tenure, which is the primary focus of the Management Role category.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as incident response planning, risk assessments, and mitigation strategies, without naming specific frameworks, roles, or unique entities.


reasoning: The paragraph describes the company's internal process for managing third-party risk as a component of their broader risk management framework, rather than focusing on specific vendor oversight or contractual standards as a standalone topic. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk management framework (ERM and ERA) and how cybersecurity is integrated into that process. It is classified as Firm-Specific because it names the company's specific internal programs (ERM and ERA) and provides a specific count of risk categories.


reasoning: The paragraph focuses on the identification, reporting lines, and qualifications of the Information Security Officer, which is the primary subject of the text.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and mitigating cybersecurity risks, with the 'InfoSec team' serving as the central subject.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents, which falls under Strategy Integration. It contains no specific facts, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the oversight responsibilities of the Audit Committee and the Board, making it a clear Board Governance disclosure. It is Firm-Specific because it names the Audit Committee and specifies a quarterly reporting cadence.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats, which falls under Strategy Integration. It uses industry-specific terminology (CROs, CMOs) relevant to the pharmaceutical sector, qualifying it as Sector-Adapted.


reasoning: The paragraph details the company's internal incident response and escalation procedures, including specific committees and roles involved in the process. It qualifies as Quantified-Verifiable because it includes multiple named committees/roles and a specific time-bound requirement (24 hours).


reasoning: The paragraph focuses on the board's oversight responsibilities and the specific committee and management roles responsible for reporting cybersecurity risks to the board.


reasoning: The paragraph focuses primarily on the oversight responsibilities of the board and the audit committee, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it explicitly names the specific roles (CISO, CLO, CFO) involved in the risk management process.


reasoning: The paragraph describes the company's internal cybersecurity program, incident response plan, and risk management processes. It is classified as Firm-Specific because it explicitly names the Audit Committee and Board of Directors as part of the escalation path, which goes beyond generic boilerplate.


reasoning: The paragraph describes internal processes like incident response planning, tabletop exercises, and security training, which falls under Risk Management Process. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for risk assessment and control implementation, citing specific industry frameworks like CIS and PCI DSS.


reasoning: The paragraph primarily describes the board's oversight responsibility for risk, which is the defining characteristic of Board Governance. While it mentions consultants and past incidents, these are secondary to the description of the board's role and the general risk posture.


reasoning: The paragraph explicitly identifies the Audit Committee as the body responsible for cybersecurity oversight, which places it in Board Governance. It is Firm-Specific because it names the specific committee (Audit Committee) and the framework used (NIST CSF).


reasoning: The paragraph explicitly details the qualifications, reporting structure, and committee interactions of the company's CISO/CDIO, which is the core definition of the Management Role category.


reasoning: The paragraph focuses on the oversight responsibilities of the Board and the Audit Committee, specifically detailing the formation and composition of a dedicated Cybersecurity Risk Subcommittee.


reasoning: The paragraph describes the company's internal processes for incident identification, response, and testing, which falls squarely under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity protocols, training, and assessment procedures, which falls squarely under Risk Management Process. It contains no specific frameworks, named vendors, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the specific roles and responsibilities of the CIO, CEO, and various committees (Audit and ERM) in managing cybersecurity risks and incident response, making 'Management Role' the most appropriate category.


reasoning: The paragraph focuses on the oversight responsibilities of the Board and its committees, specifically detailing the delegation of duties to a named subcommittee.


content_category: Third-Party Risk

reasoning: The paragraph focuses entirely on the company's oversight and requirements for third-party vendors, which is the central topic. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident detection and response processes and aligns them with the NIST Cybersecurity Framework.


reasoning: The paragraph describes the company's internal incident response process, specifically identifying the roles involved in conducting assessments. While it mentions potential material impact, the core of the paragraph is about the operational procedure for handling incidents.


reasoning: The paragraph describes the company's internal cybersecurity program, tools, and processes, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it explicitly references specific industry frameworks (NIST, GDPR, ISO 27001) without providing firm-specific details like named roles or committees.


reasoning: The paragraph focuses on the qualifications, responsibilities, and background of the CISO, which is the primary subject of the text. While it contains specific details about the individual's background, it does not meet the threshold for Quantified-Verifiable as it lacks multiple hard metrics like dates, dollar amounts, or named third-party firms.


reasoning: The paragraph describes the company's internal training and risk management processes, specifically detailing their 'Company-wide Information Security training program' and associated exercises.


reasoning: The paragraph explicitly discusses the Board's delegation of cybersecurity oversight responsibilities to the Audit Committee, making Board Governance the primary topic.


reasoning: The paragraph focuses on the composition and leadership of the Information Security Council and the qualifications of the CISO, which falls squarely under Management Role.


reasoning: The paragraph primarily details the organizational structure, specific job titles responsible for cybersecurity, and their reporting lines to executive management and the Board.


reasoning: The paragraph describes the internal risk management process and the role of the ERM committee in overseeing cybersecurity considerations, making it a Risk Management Process disclosure. It is Firm-Specific because it names the specific committee (ERM) and specific roles (CISO, CDO) involved in the process.


reasoning: The paragraph contains a standalone materiality conclusion regarding cybersecurity risks for the fiscal year, which falls under Strategy Integration. It is classified as Firm-Specific because it explicitly references 'fiscal 2025', which is a specific time period unique to this filing.


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access to 23andMe.com accounts) and the subsequent response actions taken by the company.


reasoning: The paragraph describes the company's internal cybersecurity policies, procedures, and frameworks, which is the definition of Risk Management Process. It is classified as Firm-Specific because it identifies the specific investment advisor (OFS Advisor) responsible for these strategies.


reasoning: The paragraph primarily describes the Board's oversight responsibilities and the reporting structure to the Board, which falls under Board Governance. The roles and committees mentioned are generic corporate titles and bodies, not specific to this company.


reasoning: The paragraph describes the internal cybersecurity risk management processes and identifies the specific internal teams (Longbridge's technology team and operational risk management group) responsible for these activities.


reasoning: While the paragraph mentions internal training, the core focus of the text is the detailed description of the company's oversight and assessment processes for third-party providers, including a specific named policy document.


reasoning: The paragraph primarily describes the company's internal risk management processes and alignment with a specific framework (NIST CSF), which places it squarely in Risk Management Process.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and the frameworks used to guide it, which falls squarely under Risk Management Process.


reasoning: The paragraph is a cross-reference to the Risk Factors section and contains standard, generic disclaimers about the limitations of cybersecurity controls, offering no substantive disclosure on governance, management, or specific processes.


reasoning: The paragraph details the specific qualifications, certifications, and reporting lines of the CISO and the Information Security team, which are central to the Management Role category.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the qualifications, reporting lines, and background of the CISO and CEO, which falls squarely under Management Role. It contains multiple verifiable facts including specific certifications, university names, and historical dates/roles.


reasoning: The paragraph describes the company's intended internal processes for managing cybersecurity risk, including specific activities like vulnerability management and penetration testing. It is classified as Firm-Specific because it explicitly notes the absence of an Audit Committee, which is a unique organizational fact about this company's governance structure.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access) and the company's immediate response actions, which falls squarely under Incident Disclosure. It is classified as Firm-Specific because it names the company and the specific date of the incident.


reasoning: The paragraph describes an ongoing cybersecurity incident, including the timeline and the nature of the threat actor, which falls squarely under Incident Disclosure.


reasoning: The paragraph is primarily a materiality conclusion regarding the impact of cybersecurity incidents on the company's financial condition and strategy, which fits the Strategy Integration category. It contains one specific fact (the date of a past incident), making it Firm-Specific.


reasoning: The paragraph focuses on the oversight responsibilities of the Board of Directors and the Audit Committee, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies specific roles (CSO) and committees (Audit Committee) involved in the governance structure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of determination and the company's response actions, which fits the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident, including dates of detection and remediation, making it a clear Incident Disclosure. It qualifies as Quantified-Verifiable because it contains multiple specific dates and the named entity.


reasoning: The paragraph describes the remediation and operational impact of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It is classified as Firm-Specific because it identifies unique business functions (billing and label making) impacted by the event.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence and the company's response actions, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes an ongoing cybersecurity incident, including the nature of the exfiltrated data and the extortion attempt, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the company's internal approach to using external experts and training employees as part of its broader risk management and security assessment processes. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the affected system, and the scope of the unauthorized access, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including dates of detection and occurrence, which qualifies it as an Incident Disclosure.


reasoning: The paragraph focuses on identifying specific management roles (VP of IT), reporting lines, and the composition of a named internal committee (IT Executive Steering Committee), which falls squarely under Management Role.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of determination and the company's response actions, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the specific scope and nature of data involved in a cybersecurity incident, which is the core of an incident disclosure.


reasoning: The paragraph describes the response actions and scope of a specific cybersecurity incident involving a third-party provider and the company's customers, which constitutes an incident disclosure.


reasoning: The paragraph describes the nature and impact of a cybersecurity incident, including unauthorized access and data exfiltration, which falls squarely under Incident Disclosure. It contains no specific dates, named systems, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident (website defacement), including the date of occurrence and the specific system affected, which qualifies as an incident disclosure.


reasoning: The paragraph discusses the materiality and financial impact of a specific incident, which falls under Incident Disclosure per the tiebreaker rules (Incident narrative + financial impact → Incident Disclosure). It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph is a standard legal disclaimer regarding forward-looking statements and safe harbor provisions, which does not provide substantive cybersecurity disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the scope of affected data and the number of accounts involved, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence and the nature of the impact, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the ongoing operational status and recovery progress related to a specific cybersecurity incident previously reported, which falls squarely under Incident Disclosure.


reasoning: The paragraph details the financial impact and estimated remediation costs of a specific cybersecurity incident, which is the primary focus of the text.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of notification, the threat actor involved, the affected system, and the timeline of the breach, clearly fitting the Incident Disclosure category.


reasoning: The paragraph describes the status, operational impact, and financial consequences of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It contains multiple verifiable facts, including a specific dollar amount and multiple dates, meeting the criteria for Quantified-Verifiable.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including the exact dates of occurrence and resolution, which qualifies as an Incident Disclosure.


reasoning: The paragraph focuses on the materiality assessment of the incident's impact on financial condition and the role of cybersecurity insurance, which falls under Strategy Integration. It is classified as Firm-Specific because it references the specific filing document (Form 8-K) in the context of the incident's materiality.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access/encryption) that occurred on a specific date, which is the definition of an Incident Disclosure.


reasoning: The paragraph focuses on the materiality assessment of an incident and financial guidance, which falls under Strategy Integration. It contains multiple specific dates, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the financial impact of a specific cybersecurity incident, including a materiality assessment and specific dates related to the incident's timeline, fitting the Incident Disclosure category.


reasoning: The paragraph describes the operational impact and remediation timeline of a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the ongoing investigation, scope, and response actions related to a specific cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named forensic firms, or other verifiable facts that would elevate it beyond generic boilerplate.


reasoning: The paragraph describes the financial impact and operational consequences of a specific cybersecurity incident, which falls under Incident Disclosure. It is classified as Firm-Specific because it references specific fiscal quarters (Q4 2023 and Q1 2024) related to the company's revenue recognition, though it lacks the two distinct verifiable facts required for Quantified-Verifiable (e.g., specific dollar amounts or named third-party firms).


reasoning: The paragraph describes the nature and impact of a specific cybersecurity incident involving a former executive officer, which qualifies as an incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the dates of detection and remediation, which constitutes an incident disclosure.


reasoning: The paragraph describes the financial and operational impact of a cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named forensic firms, or quantified dollar amounts, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident (ransomware) and the company's response to it, which falls squarely under Incident Disclosure. It contains multiple verifiable facts, including specific dates and the company name, meeting the criteria for Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident involving a named subsidiary, including the date of discovery and the response actions taken, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the event (unauthorized access/encryption), and the operational impact, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident involving a third-party vendor (CDK Global) and details the impact on specific internal systems (DMS, CRM), meeting the criteria for Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection and the entity involved, which qualifies as an incident disclosure. It reaches the Quantified-Verifiable level because it contains two verifiable facts: the specific company name and the specific date of the incident.


reasoning: The paragraph describes financial remediation actions taken specifically in response to a cybersecurity incident, which falls under Incident Disclosure. It contains multiple verifiable facts, including specific dollar amounts, dates, and named entities.


reasoning: The paragraph describes a specific cybersecurity incident involving a named third-party vendor (CDK Global) and details the impact on specific internal systems and the timeline of the disruption.


reasoning: The paragraph describes the ongoing remediation efforts and financial impact assessment related to a specific cybersecurity incident, which aligns with the Incident Disclosure category.


reasoning: The paragraph describes the company's internal approach to risk management and cybersecurity processes without naming specific frameworks, roles, or unique identifiers.


reasoning: The paragraph describes a specific cybersecurity incident, the company's response actions, and the operational impact, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the nature of the unauthorized access, and the company's response actions.


reasoning: The paragraph describes a specific cybersecurity incident, including the detection date and references to a prior filing, which qualifies as an incident disclosure. It contains two specific dates (July 5, 2024, and June 30, 2024), meeting the criteria for Quantified-Verifiable.


reasoning: The paragraph describes the ongoing investigation and status of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It is Firm-Specific because it references the specific filing ('this Report') as the temporal anchor for the materiality assessment.


reasoning: The paragraph describes an ongoing cybersecurity incident, including the nature of the unauthorized access and the exfiltration of data, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the affected business unit (Canadian operations), and the company's response actions, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the ongoing response and impact of a specific, named cybersecurity incident (the cyberattack on Change Healthcare), which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the company's internal risk management processes, including the frequency of reviews and the specific roles involved in those processes.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the Chief Technology Officer, which is a management role. It is classified as Firm-Specific because it identifies specific roles (Chief Technology Officer, General Counsel) involved in the governance structure.


reasoning: The paragraph explicitly discusses the board of directors' oversight role and the specific delegation of cybersecurity risk review to the audit committee, making it a clear Board Governance disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents, which falls under Strategy Integration. It contains no specific facts, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity incidents over a specific timeframe, which falls under Strategy Integration. It is Firm-Specific because it references a specific timeframe ('last two fiscal years') unique to the company's reporting period.


reasoning: The paragraph explicitly identifies a specific individual (Mr. Gharib) and details his responsibilities regarding cybersecurity, which falls squarely under Management Role.


reasoning: The paragraph focuses on the Audit Committee's role in cybersecurity oversight and reporting lines to senior leadership, which falls squarely under Board Governance.


reasoning: The paragraph focuses on identifying specific management roles (CIO, Information Security Director) and their qualifications, which falls under Management Role. It reaches the Quantified-Verifiable level because it provides specific, verifiable metrics regarding the years of experience for these named roles.


reasoning: The paragraph explicitly identifies the Chief Financial Officer as the primary role responsible for cybersecurity risk management and defines the reporting line to the Nomination and Corporate Governance Committee.


reasoning: The paragraph focuses on the oversight responsibilities of the Board of Directors and a specific committee, making 'Board Governance' the correct category. It is 'Firm-Specific' because it names the 'Enterprise Risk Management Committee', which is a unique organizational entity.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence and the company's response actions, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the company's internal approach to identifying and managing cybersecurity threats and incidents, which falls squarely under Risk Management Process. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for incident response and escalation, specifically naming internal teams and committees responsible for these actions.


reasoning: The paragraph describes the company's internal cybersecurity program and organizational structure (CDRM and Global CISO), which falls under Risk Management Process. It is Firm-Specific because it names the specific internal organization (CDRM) and role (Global CISO) unique to the company.


reasoning: The paragraph describes the company's internal risk management processes and integration with other corporate programs, which is the definition of Risk Management Process. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph explicitly identifies the board of directors of the parent company (Apollo Global Management, Inc.) as the primary entity responsible for cybersecurity oversight, placing it squarely in Board Governance.


reasoning: The paragraph primarily discusses the lack of material impact on business strategy and financial condition, which falls under Strategy Integration. It contains no specific dates, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes internal risk management activities such as employee training, awareness updates, penetration testing, and cybersecurity assessments. It is classified as Firm-Specific because it identifies a specific internal entity, the 'Cybersecurity Team', which is unique to the company's organizational structure.


reasoning: The paragraph describes the company's internal risk management structure and the collaboration between specific internal teams and roles, which falls under Risk Management Process.


reasoning: The paragraph describes the company's internal risk assessment and mitigation processes without referencing any specific frameworks, roles, or unique identifiers.


reasoning: The paragraph explicitly details the qualifications, certifications, and tenure of the CISO and CTO, which are management roles.


reasoning: The paragraph details the company's internal cybersecurity risk management program, including specific committee structures and policy counts, which falls squarely under Risk Management Process.


reasoning: The paragraph explicitly identifies a specific individual (Jack Wang) and his role/responsibilities regarding cybersecurity, which falls squarely under Management Role.


reasoning: The paragraph describes the company's internal process of engaging third parties for risk management activities like audits and testing. It does not name specific vendors or frameworks, making it generic boilerplate.


reasoning: This paragraph is a cross-reference to another section of the filing and contains no substantive cybersecurity disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for the year 2023, which falls under Strategy Integration. It is classified as Firm-Specific because it explicitly references the year 2023, which is a specific, verifiable fact unique to this filing's reporting period.


reasoning: The paragraph describes the company's internal activities for managing cybersecurity risks and compliance, which fits the Risk Management Process category. It contains no specific names, dates, or frameworks, making it generic boilerplate.


reasoning: The paragraph explicitly names the Audit Committee as the body responsible for cybersecurity oversight, which places it squarely in Board Governance and makes it firm-specific.


reasoning: The paragraph details the formation of a board-level committee and provides specific, verifiable credentials of the committee chair, which is a core component of board governance and oversight.


reasoning: The paragraph describes the company's general approach to identifying and managing cybersecurity risks, which falls under Risk Management Process. It contains no specific details, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the reporting lines and responsibilities of specific management roles (CISO and CTO), which is the primary definition of the Management Role category.


reasoning: The paragraph describes the company's internal approach to identifying and addressing cybersecurity risks, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it references the 'CIA' triad, a standard industry framework, but lacks specific company-unique details.


reasoning: The paragraph provides a standalone conclusion regarding the materiality of cybersecurity incidents and expenses, which is classified as Strategy Integration.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents and mentions general resource expenditure, which falls under Strategy Integration.


reasoning: The paragraph describes the company's internal incident response plan and associated procedures, which falls squarely under Risk Management Process. It contains no specific names, dates, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk management activities, specifically the engagement of third-party firms for simulation exercises and ongoing monitoring. While it mentions third parties, the focus is on how the company integrates these services into its own internal security operations rather than vendor oversight policies.


reasoning: The paragraph focuses on the specific qualifications, tenure, and professional background of named management roles (VP of Information Systems and CFO) regarding cybersecurity oversight.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks for a specific fiscal year, which falls under Strategy Integration. It is Firm-Specific because it references a specific fiscal year end date unique to the company's reporting period.


reasoning: The paragraph focuses on the oversight responsibilities of the Audit Committee and the Board, as well as the reporting structure of specific executive roles to the Board.


reasoning: The paragraph describes the company's internal audit and risk assessment processes, which falls squarely under Risk Management Process. It contains no specific names of committees, roles, frameworks, or dates, making it generic boilerplate.


reasoning: The paragraph describes the company's internal process for testing controls (ethical hacks, penetration tests) and program reviews. It does not name specific vendors, frameworks, or unique internal teams, making it generic boilerplate.


reasoning: This paragraph is a cross-reference to another section of the filing and contains no substantive cybersecurity disclosure.


reasoning: The paragraph focuses exclusively on the company's approach to managing risks associated with third-party vendors and service providers, which aligns with the Third-Party Risk category. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph consists of generic statements about the importance of cybersecurity and common threats, without describing specific governance, management, processes, or incidents.


reasoning: The paragraph focuses on the Board's delegation of cybersecurity oversight to a specific committee (the audit committee), which is the primary subject of the text.


reasoning: The paragraph explicitly discusses the Board of Directors and the Audit Committee's role in overseeing cybersecurity risks, which fits the Board Governance category.


reasoning: The paragraph explicitly identifies the specific management role (Vice President of Operations) responsible for the cybersecurity program and defines the reporting line to the audit committee.


reasoning: The paragraph describes how the company integrates third-party risk assessment into its broader internal cybersecurity risk management processes, fitting the tiebreaker rule for Risk Management Process.


reasoning: The paragraph describes internal risk management processes, specifically insurance oversight and business continuity planning. It is classified as Firm-Specific because it identifies a specific corporate role (Vice President of Finance and Treasurer) responsible for these tasks.


reasoning: The paragraph explicitly identifies the Chief Financial Officer as the leader responsible for cybersecurity risk management and describes the IT department's reporting line to the Audit Committee, placing it squarely in Management Role.


reasoning: The paragraph describes standard internal security practices, policies, and training programs common to most financial institutions, without referencing specific frameworks, named roles, or unique company programs.


reasoning: The paragraph discusses the potential financial impact of cybersecurity incidents and mentions insurance coverage, which falls under Strategy Integration. It contains no specific facts, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal approach to risk management and cybersecurity programs without referencing specific frameworks, roles, or unique identifiers.


reasoning: The paragraph describes the company's internal operational procedures for incident response and monitoring, which is the definition of Risk Management Process. It is classified as Firm-Specific because it identifies a specific management role ('Senior Vice President, IT Operations') unique to the company's organizational structure.


reasoning: The paragraph describes the company's internal risk management processes and oversight structure. It is classified as Firm-Specific because it explicitly names the 'Audit Committee', which is a specific governance body within the company.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the Director of Cybersecurity and the executive committee, which is the definition of Management Role. It is classified as Firm-Specific because it details the company's unique internal reporting structure and specific job titles.


reasoning: The paragraph describes the company's internal vulnerability assessment program and risk management procedures, which falls squarely under Risk Management Process. It contains no specific names, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident response and monitoring processes, specifically the role of their Security Operations Center, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies a specific internal team (Security Operations Center) responsible for these functions.


reasoning: The paragraph explicitly discusses the Board's oversight responsibilities and the delegation of cybersecurity oversight to the Audit Committee, which is the primary subject of the text.


reasoning: The paragraph describes the company's internal cybersecurity controls and processes, which falls under Risk Management Process. It contains no specific frameworks, roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph primarily focuses on a standalone materiality conclusion regarding cybersecurity risks, which falls under Strategy Integration. While it mentions third-party service providers, it does not detail specific oversight mechanisms or vendor standards, making the mention incidental to the broader materiality statement.


reasoning: The paragraph describes a specific cybersecurity incident, including the date the company took action to isolate systems, which qualifies as an incident disclosure.


reasoning: The paragraph describes the status and findings of an ongoing cybersecurity incident investigation, which falls squarely under Incident Disclosure. It contains no specific dates, named forensic firms, or unique identifiers, making it generic in specificity.


reasoning: The paragraph describes the company's adoption of a specific cybersecurity framework (NIST) as part of its internal risk management and compliance efforts.


reasoning: The paragraph discusses the financial and operational impact of a specific cybersecurity incident, which falls under Incident Disclosure. It is classified as Firm-Specific because it references specific time periods (quarter ended December 31, 2024, and full year 2024) unique to the company's reporting context.


reasoning: The paragraph describes the nature and scope of a specific cybersecurity incident (data exfiltration of PII) and the company's response actions, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the company's ongoing response to a cybersecurity incident and provides a materiality assessment, which aligns with the Incident Disclosure category. It contains no specific, verifiable facts or unique identifiers, rendering it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence and the company's response actions, which qualifies as an incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection and the entity involved, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the response to and impact of a specific cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named forensic firms, or other verifiable facts, making it generic in specificity.


reasoning: The paragraph describes the financial impact of a specific cybersecurity incident, including quantified earnings per share data, which falls under Incident Disclosure.


reasoning: The paragraph describes the details, timeline, and scope of a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity) and the company's immediate response actions, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the operational impact and response actions related to a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the status and impact of an ongoing cybersecurity incident, which falls under Incident Disclosure. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery and the company involved, which constitutes an incident disclosure.


reasoning: The paragraph describes the scope and findings of an ongoing cybersecurity incident investigation, specifically detailing the types of data exfiltrated and the affected business unit.


reasoning: The paragraph describes the ongoing status and potential impact of a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the operational impact and recovery status of a specific cybersecurity incident, including a precise date and a quantified financial impact metric.


reasoning: The paragraph describes the timeline and regulatory status of a specific cybersecurity incident, including dates and the involvement of a named government agency.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery and the nature of the event (unauthorized access and encryption), which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and controls, which is the core definition of the Risk Management Process category. It contains no specific frameworks, named roles, or unique company identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding the impact of a cybersecurity incident, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph is a standard legal disclaimer regarding forward-looking statements and contains no substantive cybersecurity disclosure.


reasoning: The paragraph discusses the financial impact and ongoing risks associated with a specific, previously disclosed incident, which falls under Incident Disclosure. While it contains a materiality statement, the context is tied directly to the incident narrative rather than a standalone strategy discussion.


reasoning: The paragraph describes the financial impact and response actions related to a specific cybersecurity incident, which falls under Incident Disclosure. It is classified as Firm-Specific because it references a specific timeframe ('first quarter') related to the incident's financial impact.


reasoning: The paragraph describes a specific cybersecurity incident (ransomware) that occurred on a specific date, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the company's response actions to a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the nature of the unauthorized access and the financial impact of a misdirected wire payment, which qualifies as an incident disclosure.


reasoning: The paragraph provides a standalone materiality assessment regarding the impact of a cybersecurity incident on the company's financial condition and operations, which falls under Strategy Integration.


reasoning: The paragraph describes the ongoing response to a specific cybersecurity incident, including the scope of the impact and the actions taken to address it, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence and the company involved, which qualifies as an incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of system isolation and the company's response actions, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of identification and the company involved, which qualifies as an incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the timeline of the event and the nature of the data accessed, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes an ongoing investigation into a cybersecurity incident, specifically mentioning file exfiltration and the assessment of sensitive information, which falls squarely under Incident Disclosure. It contains no specific dates, named systems, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the scope and impact of a specific cybersecurity incident, including the number of affected consumers and the types of data involved, which classifies it as an incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection and the date the threat actor was ejected, which clearly falls under Incident Disclosure.


reasoning: The paragraph details the specific financial and operational impacts resulting from a cybersecurity incident, which falls under Incident Disclosure. It contains multiple quantified financial figures and specific fiscal periods, meeting the criteria for Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery and the company name, which qualifies as an incident disclosure.


reasoning: The paragraph describes the scope of data exfiltrated during a cybersecurity incident, which falls squarely under Incident Disclosure. It contains multiple verifiable facts, including the specific fiscal year-end date and the specific SEC filing document.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity) and the company's immediate response actions, fitting the Incident Disclosure category. It is classified as Quantified-Verifiable because it contains both a specific date and the named company entity.


reasoning: The paragraph discusses the potential impact of a specific, ongoing incident, which falls under Incident Disclosure. It is classified as Firm-Specific because it references a specific financial reporting period (three months ended March 31, 2026) unique to the company's current filing context.


reasoning: The paragraph describes a specific cybersecurity incident, detailing the nature of the unauthorized access and the scope of the compromised data, which qualifies as an incident disclosure.


reasoning: The paragraph is a standard legal disclaimer regarding forward-looking statements, which does not contain substantive cybersecurity disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (data exfiltration) and includes the date of discovery and the company name, meeting the criteria for Incident Disclosure and Quantified-Verifiable specificity.


reasoning: The paragraph provides an update on a specific, named cybersecurity incident (Change Healthcare cyberattack) and references a specific date and exhibit, clearly falling under incident disclosure.


reasoning: The paragraph describes the company's response actions to an ongoing incident, including communication with stakeholders and operational adjustments, which falls under Incident Disclosure. It is classified as Firm-Specific because it names the proprietary 'Halliburton Management System'.


reasoning: The paragraph describes the financial and operational consequences of a specific cybersecurity incident, including costs and duration, which aligns with the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident, including dates of occurrence and escalation, and the company's materiality determination, which fits the Incident Disclosure category.


reasoning: The paragraph describes the company's response to an incident (activating response plans, taking systems offline, notifying law enforcement), which falls squarely under Incident Disclosure. It contains no specific dates, named systems, or unique entities, making it generic boilerplate.


reasoning: The paragraph discusses the ongoing financial impact and materiality assessment of a cybersecurity incident, which falls under Incident Disclosure. It contains no specific facts, dates, or metrics, relying entirely on generic boilerplate language.


reasoning: The paragraph describes a specific cybersecurity incident (data exfiltration) and the company's response actions, which clearly falls under Incident Disclosure. It is Firm-Specific because it includes a specific date (February 21, 2024) related to the incident.


reasoning: The paragraph describes standard incident response actions such as containment, investigation, and notification without providing any specific details, dates, or named entities.


reasoning: The paragraph describes the status and remediation of a previously disclosed cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named systems, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding the financial impact of a cyber incident, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific document ('Original Report') unique to this filing's context.


reasoning: The paragraph describes the status of an ongoing incident and general remediation actions, which falls squarely under Incident Disclosure. It contains no specific dates, named forensic firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the immediate response actions taken following a specific cybersecurity incident, including notifying law enforcement in a specific jurisdiction (Singapore), which qualifies as an incident disclosure.


reasoning: This paragraph is a standard legal disclaimer regarding the filing status of the report and contains no substantive cybersecurity information.


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident, which falls under Strategy Integration according to the tiebreaker rules.


reasoning: The paragraph describes how cybersecurity risk management is integrated into the company's broader enterprise risk management framework, which is a core component of internal risk management processes.


reasoning: The paragraph describes the ongoing investigation and assessment of a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named systems, or unique entities, making it generic boilerplate.


reasoning: The paragraph describes the company's internal process for evaluating vendors as part of their broader risk management framework. While it mentions third-party vendors, it does not provide specific oversight details or contractual standards, making it a description of internal process rather than third-party risk management.


reasoning: The paragraph explicitly discusses the board of directors' oversight responsibilities and reporting cadence, placing it squarely in Board Governance. It is Firm-Specific because it identifies the 'audit committee' as the specific body responsible for reporting to the board.


reasoning: The paragraph describes the oversight relationship between the Committee and the Board regarding cybersecurity, which falls squarely under Board Governance. It contains no specific names of committees, roles, or dates, making it generic boilerplate.


reasoning: The paragraph consists entirely of forward-looking disclaimers and a cross-reference to another section of the filing, containing no substantive cybersecurity disclosure.


reasoning: The paragraph details the specific scope and impact of a cybersecurity incident, which is the core definition of an Incident Disclosure. It is classified as Firm-Specific because it provides a detailed, unique inventory of the specific data types compromised during this particular event.


reasoning: The paragraph explicitly discusses the board of directors and its audit committee's role in cybersecurity oversight, placing it squarely in Board Governance. It is Firm-Specific because it identifies the specific committee (Audit Committee) responsible for this oversight.


reasoning: The paragraph is a generic introductory statement about reliance on technology and third parties, lacking any specific details about the company's actual risk management processes or governance structures.


reasoning: The paragraph describes oversight responsibilities and explicitly names a specific internal body, the 'Cybersecurity Committee', which indicates board-level governance activities.


reasoning: The paragraph focuses on the qualifications and tenure of a specific management role (Group Head, Cybersecurity/Information Security Officer). It contains multiple verifiable facts, including the specific year of hire and the number of years of experience.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its integration with enterprise risk management, which falls squarely under Risk Management Process. It contains no specific frameworks, roles, dates, or unique identifiers, making it generic boilerplate.


reasoning: This paragraph describes the professional background of an individual (Mr. Tao) and does not discuss cybersecurity governance, risk management, or incidents.


reasoning: The paragraph describes general internal efforts to improve cybersecurity and controls without referencing specific frameworks, roles, or unique company programs.


reasoning: The paragraph describes the general purpose of the company's cybersecurity program, which falls under internal risk management processes, but contains no specific details, frameworks, or unique identifiers.


reasoning: The paragraph describes the impact of a specific cybersecurity incident on a named subsidiary (Targus) and provides a materiality assessment, which falls under Incident Disclosure.


reasoning: The paragraph describes the company's internal processes for incident response and recovery, specifically mentioning the frequency of testing, which falls under Risk Management Process.


reasoning: The paragraph focuses on the Board of Directors' oversight role and their interaction with specific management roles (CISO and CIO), placing it squarely in Board Governance.


reasoning: The paragraph identifies specific management roles (head of the ITS Department) responsible for cybersecurity risk management, which falls under Management Role.


reasoning: The paragraph provides a standalone materiality conclusion regarding the financial impact of a cybersecurity incident, which falls under Strategy Integration. It contains no specific facts, dates, or metrics, making it generic boilerplate.


reasoning: The paragraph describes the company's general approach to integrating cybersecurity into its enterprise risk management program without providing specific details, frameworks, or unique processes.


reasoning: The paragraph describes internal cybersecurity training and policy compliance procedures, which are core components of a company's risk management process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: This paragraph describes general cybersecurity threats and vulnerabilities common to any business, without detailing the company's specific risk management processes or governance structures.


reasoning: The paragraph describes the general oversight responsibilities of the board and executive officers without naming specific committees, roles, or processes, making it generic boilerplate.


reasoning: The paragraph discusses the qualifications of the internal IT team, which falls under Management Role, but it provides no specific names, roles, or verifiable details, making it generic boilerplate.


reasoning: This is a standalone materiality conclusion regarding cybersecurity incidents, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal approach to managing cybersecurity risks as part of its broader enterprise risk management, which is the definition of the Risk Management Process category. It contains no specific details, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the governance structure and reporting lines for cybersecurity, specifically naming the committees and roles involved in the oversight process.


reasoning: The paragraph describes a standard step in an incident response process, which falls under internal risk management procedures. It contains no company-specific details, frameworks, or verifiable facts.


reasoning: This paragraph describes general business tools (email, cloud storage) and makes a vague, boilerplate statement about relying on reputable providers, which does not constitute a substantive cybersecurity disclosure.


reasoning: This paragraph serves as a section header or introductory sentence for the cybersecurity disclosure and does not contain substantive information about the company's actual cybersecurity practices.


reasoning: The paragraph explicitly identifies a specific management role (internal cybersecurity coordinator) and their reporting line to the CEO, which falls under Management Role.


reasoning: The paragraph identifies specific management roles (CIO, Director of IT Security, Risk and Compliance) and their qualifications, which falls squarely under Management Role.


reasoning: The paragraph explicitly describes the oversight relationship between the audit committee and the board of directors regarding cybersecurity, which falls squarely under Board Governance.


reasoning: The paragraph provides a negative disclosure regarding cybersecurity incidents and financial impact for specific reporting periods, which falls under Strategy Integration. It is classified as Quantified-Verifiable because it cites two specific, verifiable time periods.


reasoning: The paragraph describes the company's internal approach to cybersecurity, specifically its investment in threat intelligence and use of external experts to assess controls, which falls under Risk Management Process.


reasoning: The paragraph describes the company's internal process for monitoring cybersecurity incidents and managing information flow, which falls under Risk Management Process. It is Firm-Specific because it identifies the 'Investment Manager' as a specific entity involved in the process.


reasoning: The paragraph focuses on the oversight of third-party service providers and explicitly names a specific tool (Security Scorecard) used for this purpose, placing it squarely in Third-Party Risk.


reasoning: The paragraph explicitly identifies specific management roles (CIO and VP of Information Security) responsible for cybersecurity, which falls squarely under Management Role.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents and associated expenses, which falls under Strategy Integration.


reasoning: The paragraph focuses on the oversight role of the Board and Audit Committee regarding cybersecurity risks, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it explicitly names the 'Audit Committee', which is a specific governance body within the company.


reasoning: The paragraph describes the company's internal process for maintaining and updating its incident response plan, which is a core component of risk management.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents, which falls under Strategy Integration. It is classified as Quantified-Verifiable because it cites two specific, verifiable dates.


reasoning: The paragraph describes internal cybersecurity training and awareness processes, which falls under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph discusses cyber insurance as a financial mitigation strategy, which falls under Strategy Integration. It contains no specific details, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph describes an internal initiative and team (CyberSmart Defender Network) created to manage cybersecurity awareness and training, which falls under internal risk management processes.


reasoning: The paragraph describes internal risk management processes, including training and vendor oversight. While it mentions third-party providers, it frames them as a component of the company's internal risk management process rather than focusing on specific vendor oversight or contractual standards.


reasoning: The paragraph explicitly identifies the specific management role (CFO) that holds the CISO responsibility, making it a disclosure about management structure rather than general risk processes.


reasoning: The paragraph describes general functions of cybersecurity staff without naming specific roles, teams, or frameworks, making it a generic description of internal risk management processes.


reasoning: The paragraph focuses on the Board's oversight activities and the flow of information to the Board, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies the specific internal bodies (Audit Committee and Cybersecurity team) responsible for these updates.


reasoning: The paragraph explicitly identifies specific management roles (CFO, COO, CEO) and their respective responsibilities regarding cybersecurity oversight and decision-making.


reasoning: The paragraph explicitly discusses the management of cybersecurity and the qualifications of the personnel involved, fitting the Management Role category. It contains no specific names, roles, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident response planning and testing procedures, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies the specific mechanism (IRP) and the specific testing method (annual tabletop exercises) used by the company.


reasoning: The paragraph describes internal security training procedures, which falls under the company's risk management processes. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal approach to risk management (monitoring tools, training) without naming specific frameworks, roles, or unique systems.


reasoning: The paragraph describes the company's internal processes for identifying and managing cybersecurity risks, which falls squarely under Risk Management Process. It contains no specific frameworks, roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's intent to implement a risk management process for cybersecurity threats, which falls under Risk Management Process. It is classified as Firm-Specific because it references a unique, named system ('BDTP TM').


reasoning: The paragraph explicitly discusses the Board of Directors' role in overseeing the cybersecurity program, which falls squarely under Board Governance. It is classified as Firm-Specific because it identifies the specific oversight body (Board of Directors) and the cadence of their reporting (quarterly/annual).


reasoning: The paragraph describes the company's internal cybersecurity program components, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it explicitly names the entity 'Dime Community Bank'.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats, which falls under Strategy Integration. It is classified as Firm-Specific because it explicitly references the year 2024, which is a specific date unique to this reporting period.


reasoning: The paragraph focuses on the qualifications of a specific individual and the reporting lines of named management roles (CTO and Senior Director) to a specific committee, which falls under Management Role.


reasoning: The paragraph describes the company's internal risk management system in general terms without referencing specific frameworks, roles, or unique processes.


reasoning: The paragraph provides a standalone materiality conclusion regarding the impact of an incident, which falls under Strategy Integration according to the tiebreaker rules.


reasoning: The paragraph explicitly identifies specific management roles (Senior Director of IT, CFO, Treasurer) responsible for cybersecurity risk management, which falls squarely under Management Role.


reasoning: The paragraph discusses the financial strategy regarding the incident, specifically the pursuit of insurance reimbursement, which falls under Strategy Integration.


reasoning: The paragraph describes the company's response actions to an ongoing cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific facts (e.g., names of firms, dates, or specific systems), making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: This paragraph is a high-level, aspirational statement about cybersecurity goals that lacks any specific operational details, governance structures, or incident narratives.


reasoning: The paragraph discusses the potential material impact of an ongoing incident and the status of the investigation, which falls under Incident Disclosure. It contains no specific dates, named entities, or unique details, making it generic boilerplate.


reasoning: The paragraph discusses the potential financial and operational impact of an incident without describing the incident itself or specific internal processes, fitting the Strategy Integration category for materiality assessments.


reasoning: This is a standalone materiality conclusion regarding an incident, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph discusses cybersecurity insurance coverage and future assessment plans, which falls under financial/strategic impact rather than governance, process, or a specific incident narrative.


reasoning: The paragraph describes the nature of a cybersecurity incident (data exfiltration, PII) and the ongoing response (notifications), which falls squarely under Incident Disclosure. It contains no specific dates, named forensic firms, or unique identifiers, making it generic.


reasoning: The paragraph describes an ongoing cybersecurity incident and directs readers to a specific company-hosted URL for updates, which constitutes a firm-specific detail regarding the incident response.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph discusses the potential business and financial impacts (litigation, insurance costs, regulatory scrutiny) resulting from a cybersecurity incident, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or metrics, making it generic boilerplate.


reasoning: The paragraph describes standard incident response actions (notifying law enforcement and regulators) following an incident, which falls under Incident Disclosure. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: This paragraph describes executive leadership changes at a subsidiary, which is a corporate governance matter unrelated to cybersecurity risk management, incident disclosure, or strategy.


reasoning: The paragraph describes the company's internal cybersecurity program and incident response planning, which falls under Risk Management Process. It contains no specific frameworks, roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standard materiality assessment regarding a cybersecurity incident without describing the incident itself or providing specific details, fitting the definition of Strategy Integration.


reasoning: The paragraph describes ongoing incident response activities (forensic analysis) related to a previously mentioned incident, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standard materiality assessment regarding a cybersecurity incident without describing the incident itself or providing specific details, fitting the definition for Strategy Integration.


reasoning: The paragraph discusses the materiality of an incident and potential impacts without describing the incident itself or specific response actions, fitting the Strategy Integration category for materiality assessments.


reasoning: The paragraph describes standard incident response actions (notifying law enforcement and regulators) following an incident, which falls under Incident Disclosure. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph discusses the financial impact (insurance recovery) of a cybersecurity incident without providing specific details about the incident itself or specific financial figures, placing it squarely in Strategy Integration.


reasoning: The paragraph provides a standalone materiality assessment regarding an incident, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the status of an ongoing cybersecurity incident investigation and the involvement of an insurance provider, which falls squarely under incident disclosure. It contains no specific dates, named entities, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph discusses the materiality of an incident's financial impact, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph is a high-level introductory statement about the importance of cybersecurity, lacking any substantive details regarding specific processes, governance, or incidents.


reasoning: The paragraph describes specific response actions taken by the company in relation to a previously mentioned cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the status of an ongoing incident (containment and restoration), which falls squarely under Incident Disclosure. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph describes the operational impact of an ongoing cybersecurity incident, specifically noting disruptions to online ordering in the United States, which qualifies as an incident disclosure.


reasoning: The paragraph describes ongoing incident response actions and provides a materiality conclusion regarding a specific incident, which falls under Incident Disclosure. It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the nature of an ongoing cybersecurity incident, including unauthorized access and data exfiltration, which falls squarely under Incident Disclosure. It contains no specific dates, named systems, or other verifiable facts, making it generic.


reasoning: This is a standalone materiality assessment statement regarding an incident, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the status of an ongoing investigation into a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named forensic firms, or other verifiable facts, making it generic.


reasoning: The paragraph describes the ongoing status of an incident investigation and the intent to notify parties, which is standard language for an incident disclosure. It contains no specific dates, named forensic firms, or unique identifiers.


reasoning: The paragraph discusses the ongoing status of an incident and the company's monitoring of its materiality, which is standard language for an incident disclosure update.


reasoning: The paragraph describes a specific response action (mailing notification letters) taken by the company in the context of an ongoing incident investigation.


reasoning: The paragraph describes a specific cybersecurity incident involving a third-party provider, including specific dates of notification and confirmation, which qualifies as an incident disclosure.


reasoning: The paragraph discusses the potential material impact of an incident on financial condition, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident (system outage) that occurred on a specific date, which constitutes an incident disclosure.


reasoning: This paragraph discusses legal waivers related to a Credit Agreement and Lease Agreement, which are standard legal boilerplate and do not pertain to cybersecurity governance, risk management, or incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access) and provides a specific date and company name, meeting the criteria for Incident Disclosure and Quantified-Verifiable specificity.


reasoning: The paragraph describes actions taken in response to an ongoing cybersecurity incident, specifically directing users to a company-created communication portal.


reasoning: The paragraph describes a specific cybersecurity incident (systems outage) and its date of occurrence, which clearly falls under Incident Disclosure. It contains two verifiable facts (a specific date and the company name), meeting the criteria for Quantified-Verifiable.


reasoning: The paragraph describes the company's response to an incident and identifies the source as a fourth-party vendor, which falls under incident disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic.


reasoning: The paragraph describes the impacts of a previously disclosed cyber incident, which falls under Incident Disclosure. It contains no specific dates, dollar amounts, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a materiality assessment regarding the financial impact of an incident, which falls under Strategy Integration. It is Firm-Specific because it references a specific time period (fourth quarter of 2023) unique to the company's reporting.


reasoning: The paragraph describes the status of an ongoing incident response (containment and restoration), which falls squarely under Incident Disclosure. It contains no specific dates, named systems, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph provides a standard materiality assessment regarding an incident, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the operational impact of a specific cybersecurity incident, which falls under Incident Disclosure. It is classified as Firm-Specific because it provides a specific duration of impact ('approximately six weeks'), though it lacks a second verifiable fact to reach the Quantified-Verifiable threshold.


reasoning: The paragraph discusses the materiality of an incident, which falls under Strategy Integration, but uses standard boilerplate language regarding financial impact assessment without providing any specific details or metrics.


reasoning: The paragraph describes a specific cybersecurity incident (attempted fraudulent fund acquisition) and includes two verifiable facts: the date of the incident and the name of the entity involved.


reasoning: The paragraph describes operational response actions taken during an ongoing incident (restoring systems), which falls under Incident Disclosure. It contains no specific dates, named systems, or verifiable metrics, making it generic.


reasoning: The paragraph describes the nature of a cybersecurity incident (unauthorized access to IT systems) and the company's response (notification plans), which falls squarely under Incident Disclosure. It contains no specific dates, named systems, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including specific training cadences and testing frequencies. It qualifies as Quantified-Verifiable because it contains multiple verifiable facts, such as the quarterly frequency of phishing tests and the annual frequency of penetration testing.


reasoning: The paragraph describes the remediation status and investigation outcome of a previously disclosed cybersecurity incident, which falls under Incident Disclosure. It is classified as Firm-Specific because it references the company's specific 'Original Report' filing.


reasoning: The paragraph describes the ongoing response and restoration efforts related to a specific cybersecurity incident (Change Healthcare) and references a specific date and exhibit, meeting the criteria for Incident Disclosure.


reasoning: The paragraph describes the company's general reliance on IT and standard risk management activities like monitoring and infrastructure development, without referencing specific frameworks, roles, or unique programs.


reasoning: The paragraph describes the company's internal processes for incident response, business continuity, and risk evaluation. It is classified as Firm-Specific because it names specific internal roles (Chief Security Officer) and internal programs (Incident Response Program, Business Continuity Plan).


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity) with a precise date and the company name, meeting the criteria for Incident Disclosure and Quantified-Verifiable specificity.


reasoning: The paragraph describes the operational impact and response to a cybersecurity incident, which falls under Incident Disclosure. It lacks specific dates, named systems, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph explicitly defines the composition of the company's internal 'Risk Management Team' by listing specific roles, which is the primary focus of the text.


reasoning: The paragraph describes specific response actions (notifying authorities, working with law enforcement) taken in relation to an unauthorized access event, which constitutes an incident disclosure.


reasoning: The paragraph primarily focuses on a standalone materiality conclusion regarding cybersecurity risks for the fiscal year, which falls under Strategy Integration.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including security controls, training, and monitoring, which aligns best with the Risk Management Process category.


reasoning: The paragraph focuses primarily on the oversight responsibilities of the Board and its Risk Committee, making Board Governance the most appropriate category. It is classified as Firm-Specific because it identifies a specific internal governance body (the Risk Committee) and a specific reporting cadence.


reasoning: The paragraph describes the company's internal cybersecurity risk management strategy, including specific frameworks adopted and the internal oversight bodies (Technology Committee and Internal Audit team) responsible for reviewing assessments.


reasoning: The paragraph focuses on the identification and qualifications of the personnel (both internal and outsourced) responsible for cybersecurity, which falls under Management Role. It reaches the Quantified-Verifiable level because it lists specific roles, certifications, and a specific number of years of experience.


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management and regulatory compliance, making it a Risk Management Process disclosure. It is classified as Firm-Specific because it names specific regulatory bodies relevant to the company's operations.


reasoning: This paragraph describes general operational reliance on IT systems and lists common cybersecurity threats, which constitutes standard risk factor boilerplate rather than a specific disclosure of governance, management, or internal processes.


reasoning: The paragraph describes the company's internal cybersecurity risk management strategy, including incident response, technical safeguards, and employee training. While it mentions third-party risk, it is presented as a component of the broader internal risk management program rather than a standalone vendor oversight discussion.


reasoning: This paragraph is a standard, generic risk factor disclosure describing potential cybersecurity threats and their consequences without referencing any specific internal processes, governance structures, or actual incidents.


reasoning: The paragraph focuses heavily on the qualifications, reporting lines, and specific professional history of the CISO and CTO, which places it squarely in the Management Role category. It qualifies as Quantified-Verifiable because it lists multiple specific, verifiable entities (OWASP, IBM, Axway, Security Shepherd) and roles.


reasoning: The paragraph focuses primarily on the responsibilities, qualifications, and reporting lines of the Chief Information Officer and the senior leadership team, which falls squarely under Management Role. It is classified as Firm-Specific because it names specific roles (CFO, General Counsel, etc.), committees (Audit Committee), and internal documents (Risk Report).


reasoning: The paragraph provides a comprehensive overview of the company's internal cybersecurity program and risk management processes, including specific organizational roles and committees involved.


reasoning: The paragraph primarily describes the company's internal risk management processes, including the use of specific frameworks (NIST) and internal plans (IRP, BCP, Disaster Recovery Plan) to identify and mitigate risks.


reasoning: The paragraph describes the company's internal cybersecurity team structure, internal security measures like penetration testing, and vendor oversight processes, which collectively define their risk management framework.


reasoning: The paragraph details the company's internal cybersecurity risk management framework, including monitoring, training, and policy development. While it mentions third-party engagement, it is framed as a component of the broader internal risk management process rather than a standalone vendor oversight section.


reasoning: The paragraph focuses primarily on identifying the specific management roles responsible for cybersecurity, their reporting structure, and their professional qualifications and tenure.


reasoning: The paragraph discusses the potential business and financial impact of cybersecurity risks and includes a standalone materiality conclusion regarding the lack of material impact to date, which aligns with Strategy Integration.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including the adoption of the NIST framework and the specific management roles responsible for oversight.


reasoning: The paragraph outlines the company's internal cybersecurity program structure and processes, including specific roles (AGM's CISO, AHL's CISO) and internal teams, which places it squarely in Risk Management Process.


reasoning: The paragraph describes the company's internal incident response framework and management structure (Agility Plan, CMT, CIO), which falls squarely under Risk Management Process. It is Firm-Specific because it names internal programs and teams unique to the company.


reasoning: The paragraph focuses on identifying specific management roles (CISO, SVP/CDO, SVP/CIO) and their qualifications, which is the primary definition of the Management Role category. It reaches the Quantified-Verifiable level because it contains multiple verifiable facts, including named individuals, specific job titles, and named industry/regulatory bodies (Edison Electric Institute, PUCT).


reasoning: The paragraph describes the company's internal processes for monitoring, incident response planning, and engagement with external experts, which falls squarely under Risk Management Process. It contains no specific names of frameworks, roles, committees, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph contains a standalone materiality conclusion regarding cybersecurity incidents for the fiscal year, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year-end date.


reasoning: The paragraph explicitly identifies the 'Risk Committee of the Board of Directors' as the body responsible for cybersecurity oversight, which places it squarely in Board Governance and makes it firm-specific.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as incident response planning, technical safeguards, and risk management, without naming specific frameworks, roles, or unique company details.


reasoning: The paragraph primarily discusses the materiality of past incidents and the potential for future material impact, which aligns with Strategy Integration. While it mentions an 'IRP', this is a standard internal process reference, but the core of the paragraph is a materiality assessment.


reasoning: The paragraph details the company's internal cybersecurity measures, processes, and safeguards, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it explicitly names the company, Cohen & Steers, throughout the text.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, policies, and governance structure, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it names specific internal policies and committees (e.g., Business Risk Committee) unique to the organization.


reasoning: The paragraph describes the internal risk management processes of the managing entity (USCF) regarding cybersecurity and third-party oversight. It is classified as Firm-Specific because it names the specific entities (USCF, USCI, CPER) involved in the management structure.


reasoning: The paragraph details the company's internal security tools (EDR, SIEM, firewalls) and specific operational procedures (incident reporting timeline), which falls under Risk Management Process. It is Firm-Specific because it includes a specific internal policy requirement (24-hour notification) and a specific strategic timeline (2025).


reasoning: The paragraph focuses on the qualifications and responsibilities of the Chief Technology Officer and the composition of the internal Security and Privacy Governance Committee, which are core elements of management oversight and role definition.


reasoning: The paragraph provides a comprehensive overview of the company's cybersecurity program, including risk management processes, board oversight, and management reporting lines. It is classified as Risk Management Process because it describes the internal mechanisms for managing cyber risk, with specific details about the reporting structure and certifications.


reasoning: The paragraph focuses on identifying the specific management roles (CISO, CCO) responsible for cybersecurity and details their specific professional qualifications and tenure.


reasoning: The paragraph consists entirely of definitions and cross-references to other sections of the filing, rather than describing specific governance, management, or risk processes.


reasoning: The paragraph serves as an introductory overview of the company's general approach to cybersecurity risk management and strategy, lacking specific details about the actual processes, named committees, or specific frameworks.


reasoning: The paragraph primarily describes the company's internal processes for risk assessment, incident management, and monitoring, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies specific roles (Senior Director of IT, CFO) and a specific committee (audit committee) involved in these processes.


reasoning: The paragraph primarily describes the company's internal risk management processes, including monitoring, framework adoption, and vendor assessment. It is classified as Firm-Specific because it names a specific internal committee (Information Security Risk Committee) and a specific internal team (global Security Operations Center).


reasoning: The paragraph details the company's internal incident response plan, escalation procedures, and risk management processes. It reaches the Quantified-Verifiable level because it cites multiple specific, verifiable entities and frameworks (NIST RMF, CMMC, U.S. Department of Defense) alongside specific internal roles.


reasoning: The paragraph describes the company's internal risk assessment program and general cybersecurity threats, which falls under Risk Management Process. It contains no specific frameworks, roles, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph primarily details the company's internal processes for managing cybersecurity, such as their Information Security Program, committee structure, and multi-layered controls. While it mentions third-party risk management, it is presented as a component of their broader internal risk management framework.


reasoning: The paragraph focuses on identifying specific management personnel (CEO, General Counsel) responsible for cybersecurity oversight and details their qualifications, which falls squarely under Management Role.


reasoning: The paragraph primarily details the oversight responsibilities of the Audit Committee and the Board of Directors regarding cybersecurity, which falls under Board Governance. While it includes a materiality disclaimer, the governance description is the substantive focus.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment approach, and monitoring functions, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it names specific internal roles (CIO, CISO) and the internal SOC team, alongside the NIST framework.


reasoning: The paragraph describes the company's internal security controls, monitoring, and risk management procedures. While it lists many security measures, they are standard industry practices and lack any company-specific identifiers, frameworks, or verifiable facts.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and oversight without naming specific committees, roles, frameworks, or unique programs. It relies on generic language regarding board and management oversight and standard risk management practices.


reasoning: The paragraph primarily focuses on the delegation of cybersecurity oversight from the board to the Audit Committee and the reporting structure between management and that committee.


reasoning: The paragraph focuses primarily on identifying specific management roles (CTO, CIO, CISO) and their qualifications, which aligns with the Management Role category. It reaches the Quantified-Verifiable level because it provides specific years of experience for three distinct roles and mentions a specific operational service (24/7 SOC Managed Service).


reasoning: The paragraph details the company's internal cybersecurity strategy, including specific internal programs like the 'ICSIRP', which falls squarely under Risk Management Process.


reasoning: The paragraph describes the company's internal incident response and risk management processes, specifically referencing the Disaster Recovery Plan and the Crisis Management Team. It is categorized as Risk Management Process because these are internal operational procedures rather than board governance or incident disclosure.


reasoning: The paragraph details the company's internal security programs, incident reporting structures, and the specific roles involved in risk management and incident escalation, which falls squarely under Risk Management Process.


reasoning: The paragraph describes the company's internal incident response plan, escalation procedures, and testing methodologies (tabletop exercises), which falls squarely under Risk Management Process. It is Firm-Specific because it details the specific composition of the teams involved in these exercises (internal cybersecurity team, retained consultants, outside counsel, etc.).


reasoning: The paragraph focuses on the company's reliance on third-party service providers and their vendor management program, which is the central topic. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses primarily on the oversight responsibilities of the Audit Committee and the Board, including the reporting structure of the CIO and CISO to these bodies. While it mentions management roles and frameworks, the central theme is the governance structure.