reasoning: The paragraph details the company's internal cybersecurity risk management processes, such as specific policies, audits, and operational controls like red/blue team exercises and a managed SOC.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal processes for managing cybersecurity risk, including vendor assessments and incident response planning, which places it squarely in Risk Management Process. While it mentions third-party risk, it does so as a component of the company's broader internal review and approval framework.

provider: google


reasoning: The paragraph primarily describes the company's internal risk management processes, including how they assess threats, manage third-party risks, and conduct vulnerability assessments. While it mentions the CIO, the core focus is on the operational processes for cybersecurity, and it includes specific details like the requirement for SOC 2 reports.


content_category: None/Other

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


content_category: Incident Disclosure

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


reasoning: The paragraph describes a specific cybersecurity incident (website defacement), the timeline of events, and the company's response actions, which clearly falls under Incident Disclosure.


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


reasoning: The paragraph describes a specific cybersecurity incident, including the date of the threat actor's communication, the nature of the data involved, and the company's specific response actions.


reasoning: The paragraph describes the company's current state regarding cybersecurity risk management processes (or lack thereof), which falls under the Risk Management Process category. It contains no specific names, dates, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the company's internal process for auditing and reviewing cybersecurity risks, including specific roles and committees involved in the oversight and remediation workflow.


content_category: Strategy Integration

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


reasoning: The paragraph consists of general statements about the importance of cybersecurity and a list of common cyber threats, without describing the company's specific internal processes, governance, or strategy.


content_category: Board Governance

reasoning: The paragraph describes the interaction between management and the Board regarding risk appetite, which falls under Board Governance. It contains no specific roles, committees, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the oversight responsibilities of the Board and the Audit Committee, specifically detailing their interaction with the CTO and the Advisor regarding cybersecurity risk management.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment activities, and general monitoring practices, which falls squarely under Risk Management Process. It contains no specific frameworks, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes specific details of a cybersecurity incident, including dates, scope of impact, and financial remediation efforts, which clearly falls under Incident Disclosure.


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


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents and discusses insurance coverage, which falls under Strategy Integration. It is classified as Firm-Specific because it references the company's specific experience during the year 2023.


reasoning: The paragraph describes the company's internal process of utilizing third-party service providers as part of their risk management strategy, rather than focusing on the oversight of specific vendors or contractual standards. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


content_category: Management Role

reasoning: The paragraph focuses on the qualifications and experience of specific management roles (CISO and VP of Information Security), which falls under Management Role.


reasoning: The paragraph describes the company's internal risk management procedures and policies, including a specific named internal policy, which qualifies as a firm-specific detail.


content_category: Third-Party Risk

reasoning: The paragraph focuses exclusively on the company's oversight of third-party service providers and the processes used to manage those risks, fitting the Third-Party Risk category. The language is generic and lacks specific names, dates, or frameworks.


reasoning: The paragraph primarily details the specific reporting lines and organizational structure of the CISO, CIO, and CTO, which falls under Management Role. While it mentions the Board, the core substance describes the management hierarchy.


reasoning: The paragraph focuses on the oversight responsibilities of the board-level Risk Committee and its interactions with management, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it names the specific committee ('Risk Committee'), a specific role ('Chief Risk Officer'), and a specific internal document ('Cybersecurity Incident Response Plan').


reasoning: The paragraph describes the company's internal cybersecurity safeguards, vulnerability assessments, and incident response planning, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it specifies an 'annual basis' for testing the incident response plan, which is a verifiable operational detail.


reasoning: The paragraph consists of high-level corporate mission statements and general assertions about the importance of safety and cybersecurity without describing specific processes, governance structures, or incidents.


reasoning: The paragraph describes the company's internal risk management processes and the specific organizational teams involved in overseeing new projects and vendor onboarding.


reasoning: The paragraph describes the company's internal procedures for responding to cybersecurity threats, including the role of the ISC (Information Security Committee), which is a firm-specific entity.


reasoning: The paragraph explains the company's business model (blank check company) as the reason for its lack of cybersecurity risk and processes, which constitutes a materiality/strategy assessment regarding their risk profile.


reasoning: The paragraph explicitly discusses the company's internal risk management processes (or lack thereof), which falls squarely under Risk Management Process. It contains no specific names, dates, or frameworks, making it generic boilerplate.


reasoning: The paragraph explicitly details the oversight responsibilities of the Audit Committee regarding cybersecurity risks and incident communication, which is the primary focus of Board Governance.


reasoning: The paragraph focuses on the board of directors' oversight activities and their interaction with management regarding cybersecurity risks, making 'Board Governance' the primary category. It contains no specific names, dates, or unique identifiers, rendering it generic boilerplate.


reasoning: The paragraph describes internal security training and awareness programs, which are standard components of a company's 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 risk management objectives and processes, including the oversight by a specific internal team and role.


reasoning: The paragraph focuses entirely on the Board of Directors' oversight responsibilities regarding cybersecurity and data privacy. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes management's general responsibilities and the IT department's role, but lacks specific named roles (like a CISO or CTO), committees, or unique programs that would elevate it beyond boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents and references risk factors, 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 cybersecurity program and ERM framework, making 'Risk Management Process' the most appropriate category. It is classified as 'Firm-Specific' because it names specific internal committees (TRCC, ERC) and roles (CRO, CISO) unique to the organization.


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


reasoning: The paragraph explicitly identifies specific management roles and their responsibilities regarding cybersecurity oversight, fitting the Management Role category.


reasoning: The paragraph describes the internal organizational structure and roles responsible for the cybersecurity risk management program, which falls under Risk Management Process. It is Firm-Specific because it names specific roles and internal groups unique to the company's structure.


reasoning: The paragraph describes the company's internal organizational structure for managing cybersecurity, specifically detailing the roles and responsibilities of the Cybersecurity Executive Council and the Cybersecurity Compliance Committee.


reasoning: The paragraph describes the company's internal incident response plan and the specific role (CEO) involved in the oversight process, which falls under Risk Management Process.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and directs the reader to the Risk Factors section, which fits the Strategy Integration category.


reasoning: The paragraph discusses the company's general approach to security controls and the inherent limitations of those controls, which falls under internal risk management processes. It contains no specific frameworks, roles, or unique company details, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk assessment, monitoring, and training procedures, which are central to its risk management process. It is classified as Sector-Adapted because it references specific industry frameworks and regulations (CIS, FERPA) without providing firm-specific details like named roles or committees.


reasoning: The paragraph explicitly identifies specific management roles (CIO, CTO, ISO) and their accountability for the company's information security program, fitting the Management Role category.


reasoning: The paragraph focuses on the reporting lines and communication flow to the Board and Audit Committee regarding cybersecurity incidents, making Board Governance the primary category. It is classified as Firm-Specific because it identifies specific roles (Head of Cybersecurity, CFO, General Counsel) and committees (Audit Committee, Board of Directors) involved in this governance structure.


reasoning: The paragraph describes the company's general approach to security controls and the inherent limitations of their risk management processes, without referencing specific frameworks, roles, or unique company details.


reasoning: The paragraph describes the company's internal process of using third parties for program evaluation and exercises, which is a component of their broader risk management strategy rather than a standalone third-party risk oversight disclosure. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for monitoring its information security program, including audits, regulatory exams, and testing procedures. It is classified as Firm-Specific because it references specific regulatory bodies (OCC) and specific service models (SOC as a Service) unique to their operational context.


reasoning: The paragraph primarily describes the company's internal incident response and vulnerability management processes, which falls under Risk Management Process. It is classified as Firm-Specific because it names a unique corporate role, 'Vice President of Operational Engineering'.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment methodology, and operational controls (segmentation, access, monitoring, patching), which falls squarely under Risk Management Process. Despite the detailed list of activities, no specific frameworks, named roles, or unique company identifiers are mentioned, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for vulnerability testing and vendor oversight, which falls under Risk Management Process. It mentions 'service organizational controls reports' (SOC reports), which is an industry-standard term, making it Sector-Adapted.


reasoning: The paragraph describes the company's internal enterprise risk management (ERM) process and how it identifies and monitors cybersecurity risks, which falls squarely under Risk Management Process. It is Firm-Specific because it explicitly names the company's 'ERM' process, which is a specific internal program.


reasoning: The paragraph describes the company's internal processes for risk management and security controls. While it mentions a third-party security program, it is framed as a component of the company's overall risk management approach rather than a standalone discussion of vendor oversight.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as vulnerability management and incident response planning, which falls squarely under Risk Management Process. It contains no specific names, dates, or frameworks, making it generic.


reasoning: The paragraph explicitly identifies specific management roles (SVP/IT Manager and ISO) and their qualifications, making it a clear Management Role disclosure.


reasoning: The paragraph focuses on the specific due diligence and contractual security requirements imposed on vendors, which is the central topic of the text.


reasoning: The paragraph describes general internal security measures (firewalls, anti-malware) without naming specific products, vendors, or unique organizational processes, making it a standard description of risk management activities.


reasoning: The paragraph describes general internal risk management activities like penetration testing and incident response planning without naming specific frameworks, vendors, or roles.


reasoning: The paragraph explicitly defines the oversight responsibilities of the Audit Committee and mentions specific roles (CISO) and internal plans (Cybersecurity Incident Response Plan), making it a clear example of Board Governance with firm-specific details.


reasoning: The paragraph focuses on the company's reliance on third-party service providers and the associated risks of cyber-attacks on those entities, which is the central topic of Third-Party Risk. It contains no specific names, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the roles and responsibilities of the CCO and CISO, specifically identifying their reporting lines and reliance on Fidelity's internal organization.


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


reasoning: The paragraph focuses on the company's approach to third-party procurement and due diligence, which falls under Third-Party Risk. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident response plan and the specific roles involved in managing and escalating cybersecurity incidents, which falls under Risk Management Process. It is classified as Firm-Specific because it lists specific internal roles and committees responsible for these processes.


reasoning: The paragraph describes the responsibilities of 'executive management' regarding cybersecurity oversight, which falls under Management Role. It contains no specific names, roles, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management, including policies, controls, and monitoring, which fits the Risk Management Process category. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the qualifications, reporting lines, and responsibilities of the CISO and COO, which falls squarely under Management Role. It is Firm-Specific because it identifies specific roles (CISO, COO) and a specific committee (Risk Committee) unique to the company's organizational structure.


reasoning: The paragraph details the reporting structure and oversight cadence involving specific roles and the Audit Committee, which falls under Board Governance.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including assessment frequency and specific operational components like training and penetration testing. It is classified as Sector-Adapted because it explicitly references the NIST framework.


reasoning: The paragraph focuses on the composition, leadership, and operational cadence of the 'Cybersecurity Council,' which is a management-level body. It contains numerous specific roles and verifiable facts regarding the council's structure and meeting frequency.


reasoning: The paragraph explicitly identifies a specific management role (VP of IT and Facilities) and outlines their cybersecurity responsibilities, which fits the Management Role category.


reasoning: The paragraph discusses the company's internal approach (or lack thereof) to risk assessment and management processes, fitting the Risk Management Process category. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph explicitly identifies the Audit Committee and the Board of Directors as the entities responsible for cybersecurity oversight, which places it squarely in Board Governance.


reasoning: The paragraph explicitly identifies the reporting structure of the CIO and the existence of an Information Security Department, which are specific management roles and organizational structures.


reasoning: The paragraph describes internal security training and policy review processes, 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 oversight responsibilities and meeting cadence of a specific board-level committee (the Technology Committee) at PNC.


reasoning: The paragraph describes the company's internal processes for monitoring and testing cybersecurity, including the operation of a specific 'dedicated cyber security center' and participation in 'national transmission grid security exercises', which are firm-specific operational details.


reasoning: The paragraph describes the company's internal incident response procedures and the specific cross-functional leadership team involved in significant incidents, which falls under Risk Management Process.


reasoning: The paragraph describes the company's internal cybersecurity monitoring and risk mitigation activities, which falls squarely under Risk Management Process. It contains no specific names, dates, or frameworks, making it generic boilerplate.


reasoning: The paragraph focuses on the CISO's reporting lines, interactions with a specific committee (IOC), and the composition of their internal team, which are core management role disclosures.


reasoning: The paragraph outlines the company's internal security procedures, such as monitoring, backup protocols, and risk assessment processes. It is classified as Risk Management Process because these activities describe the company's own internal security operations.


reasoning: The paragraph describes the company's internal incident response and escalation workflow, specifically detailing the committee and executive roles involved in the assessment process.


reasoning: The paragraph describes the company's internal cybersecurity program, assessment processes, and the specific frameworks used to manage risk, which falls squarely under Risk Management Process.


reasoning: This paragraph is generalized risk/disclaimer language about cybersecurity threats, dependencies on technology, and potential financial impact, with no board/management/process description and no incident narrative or firm-unique details.

provider: openai


reasoning: The paragraph is standalone materiality/disclosure language stating cybersecurity risks have not materially affected the company, with a cross-reference to risk factors. It does not describe an incident or internal process details, so it fits Strategy Integration materiality disclosure.


reasoning: The paragraph is explicitly about the Audit Committee’s oversight responsibilities and reporting cadence for cybersecurity risk, including quarterly and annual reporting mechanisms. It also names the ERM Committee and specific management roles (CIO/VP Infrastructure), making it firm-specific governance disclosure.


category_confidence: medium

reasoning: The paragraph primarily describes the company’s own risk assessment and safeguard processes (including how third parties support monitoring/testing) rather than making vendor oversight the central topic. It also includes a standalone materiality-style statement about lack of material impairment.


specificity_confidence: low

reasoning: The paragraph is explicitly about the Board’s oversight and cadence for receiving cybersecurity updates and incident materiality information, and it names Board interactions with the CEO and General Counsel. It does not include any firm-unique programs, systems, dates, or quantified metrics beyond generic governance language.


specificity_confidence: medium

reasoning: The paragraph centers on the ISO’s reporting line to the CRO and describes the ISO’s responsibilities and qualifications, which is management-role disclosure rather than board oversight, a risk process description, or an incident narrative.


reasoning: The paragraph describes the company’s internal risk identification/assessment approach (team, monitoring, scanning, reviews, periodic assessments) and related IT investment, which is an internal risk management process. While it mentions third-party IT providers, they are not the central focus; they are one input to the company’s overall risk management.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment and management approach and how it is intended to be integrated into its enterprise risk management. It does not narrate an incident and the discussion of third parties is one component of broader internal risk processes rather than vendor oversight being the central topic.


reasoning: The paragraph describes Emergent BioSolutions’ internal cybersecurity integration into its ERM, including its annual ERA, quarterly reviews, and risk handling approach (accept vs mitigate/avoid). While it uses general risk-management language, it includes firm-specific details like ERM structure (12 categories) and the named ERM/ERA processes.


reasoning: This paragraph is a cross-reference to Item 1A risk factors and contains generalized materiality language without describing any company-specific cybersecurity governance, management roles, internal processes, third-party controls, or an incident.


reasoning: The paragraph describes the company’s own information security programs and how they assess, identify, and manage risks to the confidentiality, integrity, and availability of its IT systems and data, which is internal risk management process content.


reasoning: The paragraph primarily describes Stellar Bancorp’s internal cybersecurity/ERM integration and risk management processes (identification/mitigation, ERM integration, periodic review, and reporting lines). It includes firm-specific role/reporting information (CISO→CRO) and the FFIEC-based framework reference, but lacks two+ fully verifiable external facts like dates, dollar amounts, or named vendors.


reasoning: The paragraph describes the company’s own cybersecurity program, including an incident response plan, routine testing/training, mitigation measures, ongoing monitoring by the IT team, risk assessments, and activities like threat modeling and vulnerability scanning/penetration testing. It contains no firm-unique named roles, dates, systems, tools, or quantified metrics.


reasoning: The paragraph is explicitly about the Board of Directors’ responsibilities, assessments, and oversight cadence regarding cybersecurity risks and programs. It includes firm-unique facts such as the named Health, Safety, and Environmental Director oversight and the individual’s employment tenure with Heat Waves.


reasoning: The paragraph describes board and Audit Committee oversight of cybersecurity risk, including delegated responsibilities and reporting cadence from specific technology leadership roles.


reasoning: The paragraph is centered on the Audit Committee’s and Board’s oversight responsibilities and cadence for cybersecurity risk management, including annual review and reporting. It is firm-specific because it names the Audit Committee and explicitly references management roles (CIO and CISO), though it contains no uniquely verifiable external metrics (e.g., dates beyond “at least annually” or named systems/tools).


reasoning: The paragraph is primarily about board-level responsibility for overseeing cybersecurity risk within the company’s enterprise risk management framework.


reasoning: The paragraph describes the company’s internal risk identification and assessment activities (via its dedicated InfoSec team), including monitoring threat intelligence and selecting controls. Although third-party sources/providers are mentioned, they are part of the company’s own risk management process rather than vendor oversight as the central topic.


reasoning: The paragraph describes Alternus’s internal cybersecurity risk management activities (multilayer defenses, monitoring, assessments, and integration into its Information Security Policy and quarterly ERM-level reviews). While it mentions external security firms, they are part of the company’s risk assessment process rather than the central topic of vendor oversight.


reasoning: The paragraph discusses whether cybersecurity threats/incidents have caused material impacts and includes a forward-looking assessment of reasonable likelihood of material effect, without describing an actual incident or internal controls/processes in detail.


reasoning: This paragraph describes the Trustee’s internal cyber risk management program and cybersecurity protocols and how they are integrated into the overall risk management process. Although it mentions a third-party vendor for an annual assessment, the central focus is the company’s own program/process rather than vendor security oversight alone.


reasoning: The paragraph describes the company’s internal cyber threat/incident handling workflow (notification, investigation, risk rating, escalation, and reporting), which is an internal risk management process rather than an actual incident or third-party oversight.


reasoning: The paragraph describes the company’s internal cybersecurity program and incident response planning activities (vulnerability/risk management, monitoring, IR plan components), which are core risk management processes. It names the NIST framework, but provides no firm-unique systems, dates, or vendor/entity names beyond general roles.


reasoning: The paragraph describes the Company’s own incident response planning, tabletop exercises, business continuity/disaster recovery, and an internal risk-based approach to selecting security controls. It also includes generic limitations/forward-looking risk language without any Cinemark-specific named roles, dates, amounts, systems, or vendors.


reasoning: The paragraph centers on board/committee oversight (Audit Committee and full Board) of cybersecurity risk and reporting cadence (quarterly). However, it contains no firm-unique roles, named individuals/systems, dates, or externally verifiable details beyond generic governance practices.


reasoning: The paragraph’s main grammatical subject is the board of directors’ oversight responsibilities and the reporting relationship to the board.


reasoning: The paragraph describes ABERCROMBIE & FITCH’s internal cybersecurity and information risk management processes (controls, assessments, prioritization, and program updates). It references industry frameworks (CIS Critical Security Controls and PCI DSS) but does not provide firm-unique operational details beyond general internal processes.


reasoning: The paragraph centers on the Board and Audit Committee oversight responsibilities and the formation/requirements of a Cybersecurity Risk Subcommittee, which are board-governance details.


reasoning: The paragraph is centered on board and audit committee oversight responsibilities and reporting cadence regarding cybersecurity risks and incidents. It also names specific management roles (CISO, Chief Legal Officer, CFO) involved in the cyber risk programs, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph centers on a named management role (CDIO/CISO), reporting line, tenure, responsibilities, and briefings to a named committee (TCRC), which are clearly management/organizational details rather than a process or incident.


reasoning: The paragraph centers on board/committee oversight (Board, Audit Committee) and describes the Cybersecurity Subcommittee’s establishment and duties, including reporting cadence to the Audit Committee and Board. It includes company-specific committee details (Cybersecurity Subcommittee established in 2023 and comprised of independent directors).


reasoning: The paragraph describes reporting/escalation of cybersecurity information to the Audit Committee and ERM Committee and potential escalation to the Board, which places the board/committee oversight at the center of the disclosure. It is firm-specific because it names roles (CIO, CEO) and specific committees (Audit Committee, ERM Committee), though it does not include quantifiable or uniquely checkable external facts.


reasoning: The paragraph is primarily about the Board and its Audit Committee oversight and reporting cadence (quarterly) of cybersecurity risk and incident information, including escalation to the Board via the CEO/CFO.


reasoning: The paragraph describes the company’s own cybersecurity processes (identification, monitoring, testing, and engagement of penetration testing experts) rather than a board role, specific management role, or a disclosed incident event.


reasoning: The paragraph describes how the company’s cybersecurity program is integrated into operations and based on a cybersecurity framework to manage and respond to risks, which aligns most with internal risk management process. Although the Board/Audit Committee are mentioned, the dominant subject is the company’s approach to managing cybersecurity risks.


reasoning: The paragraph centers on controls imposed and oversight performed for external service providers/vendors (security standards, contractual security terms, required incident notification/encryption/disposal, and use of third-party penetration studies). While it also mentions incident monitoring, the dominant topic is third-party security risk management rather than internal risk processes or board/management oversight.


reasoning: The paragraph describes the company’s internal cybersecurity training and readiness activities (education, phishing simulations, exercises) as part of its own risk management processes. It contains no company-specific named roles, dates, systems, amounts, or external frameworks, so the content is generic.


reasoning: This paragraph describes Equifax’s internal incident detection and response processes (IR/ recovery planning, exercises, and preparedness testing). It is not an incident narrative or third-party oversight, and it frames the program using the NIST CSF.


reasoning: This paragraph identifies the CISO as the primary owner of cybersecurity risk activities and describes the CISO’s qualifications and responsibilities, which is management-role content rather than a process description.


reasoning: This paragraph focuses on OFS Advisor’s internal IT Department cybersecurity risk management policies and procedures (processes like assessments, vulnerability management, and oversight), with a stated use of the NIST Cybersecurity Framework. Vendor oversight is mentioned only as one element within the company’s internal risk process, not as a standalone third-party risk governance topic.


reasoning: The paragraph describes a real cybersecurity incident (user data accessed/downloaded) with a specific date (October 2023) and the affected source (23andMe.com accounts). It also details post-incident response/remediation actions such as password resets and requiring two-factor verification.


reasoning: The paragraph primarily describes the company’s internal cybersecurity organization and how it operates its Cyber Incident Response Plan and security controls, which are elements of the firm’s risk management processes. It also includes reporting lines and board updates, but the central focus is on managing/overseeing the cybersecurity program through CIRP and related procedures.


reasoning: The paragraph describes the company’s own cybersecurity program elements (tools, processes, monitoring, incident response policies, access controls, testing) and how they manage cyber risk internally. It includes named standards/frameworks (NIST Cybersecurity Framework, GDPR, ISO 27001), but no firm-unique roles, dates, amounts, or named vendors.


reasoning: The paragraph describes the company’s internal enterprise risk management committee processes (self-assessments, remediation action plans) and how cybersecurity inputs from CISO/CDO are incorporated into risk decision-making.


reasoning: The paragraph centers on management’s role and qualifications—specifically the CISO, reporting lines to the CITO and CEO, and named certifications/education. It provides multiple company-specific, verifiable facts about named roles and credentials.


reasoning: The paragraph centers on material impact and materiality implications ("potential to materially impact" and lack of material breaches/expenses) rather than describing a specific incident. It also includes named roles (CEO, CFO) and an MSP for incident assessments, which makes it more firm-specific than generic boilerplate.


reasoning: The paragraph centers on leadership responsibility through the CISO and the ISC that he/she leads, including tenure and specific cybersecurity certifications. While it also describes a council meeting cadence, the key substantive governance/structure is tied to the identified management role (CISO) and his/her qualifications.


reasoning: The paragraph is primarily about Board and committee oversight (Audit Committee) of cybersecurity risk, controls, and incident reporting, making Board Governance the best fit. It names a committee, but provides no firm-unique operational details beyond generic governance descriptions and no verifiable dates, amounts, systems, or named individuals, so it is treated as Generic Boilerplate.


reasoning: The paragraph discusses whether cybersecurity incidents materially affect business strategy, results of operations, or financial condition, including a prior incident and an overall materiality-style conclusion. It also cross-references the Item 1A risk factor section rather than describing internal risk management steps or a current incident narrative.


reasoning: The paragraph makes a standalone materiality conclusion for fiscal 2025 that cybersecurity risks did not materially affect (and are not reasonably anticipated to materially affect) strategy, operations, or financial condition, which fits Strategy Integration rather than an incident narrative.


reasoning: The paragraph provides a standalone materiality conclusion (no material incident/immaterial expenses/no known reasonably likely material cybersecurity risks) and forward-looking statements about potential future impact. It does not describe an actual incident narrative, nor internal processes or governance details.


reasoning: The paragraph describes the company’s own cybersecurity risk management program and how it is designed/assessed, including the use of specific frameworks.


reasoning: This paragraph is generic forward-looking risk-factor language with conditional statements and a cross-reference to Item 1A, without describing internal processes, board/management roles, specific frameworks, or any incident details.


reasoning: The paragraph describes the company’s (through Longbridge) ongoing internal cybersecurity assessments and maintenance activities—patch/vulnerability management, access controls, disaster recovery, monitoring, and technology deprecation—indicating an internal risk management process rather than an incident or board/management role.


reasoning: Although the paragraph mentions management and the Board, the primary subject is the Company’s internal cybersecurity measures and risk assessment approach (aligned to NIST CSF and integrated into its ERM program), making it best categorized as a Risk Management Process.


reasoning: The paragraph primarily describes Aptar’s internal security training and its own risk-management processes for managing third-party risk (assessments, ongoing monitoring by its Information Security Department). Although it references third-party providers, the central subject is Aptar’s internal process rather than vendor oversight requirements as the primary disclosure, and it also includes training and insurance as supporting elements.


reasoning: The paragraph primarily describes the company’s internal information security evaluation/testing, training, and refinement process, with external experts referenced as a supporting element rather than vendors being the central topic. It contains no firm-unique names, dates, systems, or quantified/verifiable facts, and uses only generic cybersecurity concepts.


reasoning: The paragraph is explicitly about board and Audit Committee oversight cadence for cybersecurity, including meetings with the Company’s CSO and what topics are reviewed, which squarely fits Board Governance.


reasoning: This paragraph centers on identified security leadership (CISO) and reporting/oversight lines, plus qualifications of named executives. It describes the organization and roles of management rather than cyber risk processes or incidents.


reasoning: The paragraph describes a specific cybersecurity event (unauthorized third-party access) with a stated detection date and includes incident response actions (external experts, notifying law enforcement) and operational impacts on business/financial reporting systems.


reasoning: The paragraph centers on the VP of IT/Information Security Officer’s responsibilities, reporting relationships (including to the CFO and Audit Committee), and qualifications, plus the named IT Executive Steering Committee composition.


reasoning: The paragraph describes the company’s own cybersecurity risk management processes (assess/identify/manage risks and impacts on CIA). It does not name any specific frameworks, roles, systems, dates, or verifiable company-specific details, so it remains generic boilerplate.


reasoning: The paragraph focuses on the company’s intended internal cybersecurity risk management program and processes (identification, assessment, monitoring, reviews, and testing). It mentions a third-party consultant only as part of implementing that internal process, not as the central topic (so it is not third-party risk).


reasoning: The paragraph describes a real cybersecurity incident, including unauthorized access, detection-to-response actions (incident response/business continuity protocols), business disruption from containment, continued investigation, engagement of cybersecurity experts, and law enforcement notification, anchored by a specific determination date.


reasoning: The paragraph describes an actual cybersecurity incident, including the date it was determined, unauthorized access by a third party, containment actions, business disruption, and remediation status.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access) with a named system (Dropbox Sign/HelloSign), a specific date, threat-actor actions, and conclusions about scope and affected data, which is characteristic of Incident Disclosure.


reasoning: This paragraph describes an actual cybersecurity incident, including the detection date (May 6, 2024), unauthorized access, response actions (incident response procedure, external experts, and law enforcement notification), and impact (disruptions/limited access to financial and operating reporting systems).


reasoning: The paragraph describes an actual cyber incident (unlawful access and exfiltration), ransom/threat demands, specific response actions taken, offline impact, and expected insurance coverage with a stated financial impact window (Q1 fiscal 2026).


reasoning: The paragraph describes a real cybersecurity incident with specific detection/access dates, unauthorized access and exfiltration details, and response actions (incident response, reporting to law enforcement and regulators).


reasoning: This paragraph describes an actual, ongoing cybersecurity incident (initial compromise and exfiltration, subsequent attempts to access source code repositories/internal systems, and ongoing investigations). It includes a specific timeframe (“late November 2023”) and incident scope details tied to the company.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access by a former employee), includes scope (up to 33 million accounts) and what data was/was not obtained, and states response actions (ongoing investigation and engagement of external forensic experts) and regulator activity.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access and exfiltration), includes specific dates, scope details, and response actions (removal of access, law enforcement and regulatory notifications) along with materiality statements.


reasoning: The paragraph describes an actual incident, including investigation/notification actions, the types of personal information accessed, scope limitations, and customer notification and impact assessment.


reasoning: This paragraph is a generic safe-harbor and forward-looking statements disclaimer with no incident facts, dates, named parties, frameworks, or process details beyond general references.


reasoning: The paragraph describes what data elements were included/excluded in the company’s affected dataset and the nature of the records, which is part of explaining internal handling/impact of the data exposure within a risk/process context rather than a board/management role or a clearly described incident narrative with response actions.


reasoning: The paragraph narrates a real cybersecurity incident (defaced website), includes a specific date, a specific web address, and describes response actions taken (restoring from backups, taking the site down, placing a temporary page, reviewing the web platform).


reasoning: This paragraph discusses materiality and expected financial impact/costs of an incident rather than describing what happened; it is primarily materiality/financial effects language without incident specifics or identifiable firm-specific details.


reasoning: The paragraph describes the status of remediation/restoration and ongoing operational impact from an actual cybersecurity incident, including affected business functions and data outcomes.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access, temporary operational limitations/production halt, and data exfiltration) and notes response actions such as reviewing impacted data and issuing notifications.


reasoning: The paragraph describes an ongoing cybersecurity investigation with concrete incident details (data exfiltration by a threat actor, scope described, analysis steps, and client notifications). It does not include verifiable dates/amounts or named external vendors, so it is firm-specific rather than quantified-verifiable.


reasoning: The paragraph describes an ongoing investigation into unauthorized access in connection with an incident and notes observed effects (website offline, delayed communications), along with assessments of material impact. However, it provides no named systems, dates, or quantitative/identifiable details, making it largely boilerplate.


reasoning: The paragraph provides a financial/materiality impact assessment for an incident, including a preliminary expense range ($180M–$400M) and statements about operational impacts not having occurred yet. However, it does not describe the incident mechanics or specific response actions beyond investigation/assessing impact, so it aligns more with financial/materiality integration than incident narrative.


reasoning: The paragraph describes a specific real-world cybersecurity incident, including a concrete date, discovery of unauthorized access, ransomware-like encryption, data theft, operational impacts, and incident response actions (external experts, incident response plan, system shutdowns, and cooperation with federal law enforcement). It includes multiple verifiable details beyond generic incident-response language.


reasoning: The paragraph describes the real-world effects of a cyber incident (system shutdown, operational disruptions, cancellations/delays) and reports remediation progress since the Original Report.


reasoning: The paragraph discusses materiality/financial impact of the Incident (reasonably likely to affect earnings for Q2 ended June 30, 2024) and related expected business effects, without adding new incident narrative details.


reasoning: This paragraph is standalone materiality/financial impact language about whether the incident affects financial condition/results, and discusses cybersecurity insurance coverage and potential uninsured costs, without describing any specific incident facts or entities.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access), when it was discovered, who was affected (Targus), and specific response actions taken (incident response/business continuity, containment, remediation, recovery in process), which squarely fits Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (suspected actor, unauthorized access to HPE’s cloud email, investigation/contain/remediate actions) with a timeline (Dec 12, 2023 notification; exfiltration beginning May 2023) and scope details, which squarely fits Incident Disclosure.


reasoning: The paragraph describes a real cybersecurity-related outage incident (date, unauthorized access, encryption, exfiltration) and ongoing remediation/impact (restoration timeline and delayed billing/collections/payments). It is therefore best categorized as Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity/IT disruption incident with start and restoration dates, the impact to website/email communications, and concrete response actions (investigation, remediation, reinstatement, restoration). This is classic incident disclosure rather than risk-process or governance.


reasoning: The paragraph describes a realized cybersecurity incident, including containment/remediation status, operational impacts, revenue impact, and specific estimated costs with dates.


reasoning: The paragraph provides an explicit materiality expectation regarding the incident’s financial impact and discusses expected financial metrics for specific quarters, including guidance referenced to a dated press release—i.e., standalone financial/impact integration rather than incident narrative details.


reasoning: The paragraph describes a real cybersecurity incident, including detection and key actions taken (investigation, incident response plan, system shutdown) and an asserted ejection date, along with notification/cooperation with law enforcement and regulators.


reasoning: The paragraph describes a specific cybersecurity-related incident affecting access to systems, identifies the triggering event date (June 19, 2024), and includes incident impact and restoration/disruption details (through July, restoration of DMS and CRM).


reasoning: This paragraph focuses on financial impact of the incident (delayed revenue recognition to Q1 2024, revenue loss from moving transactions to other providers, and one-time expenses). It includes company-specific business mechanics (agent revenue recognition based on title policy issuance notices), but does not describe the incident itself beyond its effects.


reasoning: This paragraph describes concrete impacts from a cybersecurity incident (operational shutdown/restart durations, restoration timing) and remediation actions (new IT infrastructure and cyber security experts), including a statement about the threat actor no longer having access.


reasoning: This paragraph focuses on materiality/financial impact and cost expectations (including digital sales revenue loss and cybersecurity insurance) rather than describing the incident events themselves. It is therefore best categorized as strategy/impact integration, though it refers to an incident rather than being purely boilerplate materiality language.


reasoning: The paragraph focuses on the Company’s remediation actions—evaluating procedures/software to strengthen threat surveillance and improving backup systems—describing internal processes. Although it includes insurance and a materiality statement, there are no incident details beyond generic remediation and financial-impact language, so the primary subject is risk management remediation.


reasoning: The paragraph describes a liquidity/financing arrangement tied to the cybersecurity incident’s remediation and quantifies additional capital ($3.7M) via waived interest/lease payments under specific agreements and dates, which is strategy/financial integration rather than an incident narrative.


reasoning: The paragraph describes a specific ransomware incident, when it occurred, its origin, and the company’s investigation/recovery actions, which is direct incident disclosure rather than a general risk process.


reasoning: The paragraph describes a specific cybersecurity incident with a defined detection date, the company’s response actions, operational impact, ongoing investigation, and notifications to regulators/law enforcement—meeting the incident disclosure criteria.


reasoning: The paragraph describes a specific real incident (unauthorized occurrences, threat actor encryption), includes response actions (incident response plan, investigation, system shutdown), and provides concrete operational impacts (manufacturing facilities not operating, order fulfillment impacted) tied to a specific date.


reasoning: The paragraph describes a real cybersecurity-related disruption, including what systems were affected (DMS/CRM), the date disruptions began (June 19, 2024), restoration status, and ongoing investigation/testing.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized third-party access) along with concrete response actions (activating an incident response plan, taking systems offline, notifying law enforcement, halting and restarting production). It is therefore an incident disclosure rather than a general risk/process description.


reasoning: The paragraph describes an actual incident’s scope (limited access and exfiltration), the types of data involved (customer/employee information and PII), and response actions (notifications and law enforcement), which is characteristic of Incident Disclosure.


reasoning: The paragraph describes the status of an ongoing cybersecurity incident investigation and includes incident-specific actions (reporting to law enforcement, notifying regulators) and impact/materiality assessments.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access), the detection date, and response actions including investigation with external experts, which fits incident disclosure. It includes firm-specific dates and the company name, but lacks details like scope, systems, or quantified impact to reach the quantified-verifiable threshold.


reasoning: This paragraph describes a real cybersecurity incident, including the date discovered, unauthorized access details, third-party behavior, operational impacts, and specific response actions (containment, law enforcement notification, external experts, systems taken offline, remediation). The presence of verifiable specifics like a discovery date and concrete technical characteristics supports Quantified-Verifiable.


reasoning: The paragraph identifies a specific management role (Chief Technology Officer), describes responsibilities tied to cybersecurity risk management, and states reporting/meeting cadence with General Counsel.


reasoning: This paragraph only provides a cross-reference to the risk factors section for cybersecurity risk descriptions and does not disclose any specific cyber program, incident, or incident response details.


reasoning: The paragraph provides a standalone materiality statement about whether known cybersecurity threats (including prior incidents) have materially affected the company, plus a generic forward-looking risk disclosure. It is not an incident narrative or a description of internal cyber/risk processes.


reasoning: The paragraph describes a real cybersecurity incident with a specific detection date, external experts and law enforcement notification, and the operational impact on financial and operating reporting systems.


reasoning: The paragraph describes a real cybersecurity incident timeline (detection date), actions taken (incident response, isolation, engaging forensics), and operational/customer impact (service delays in Canada, recovery estimated in the coming week), which fits Incident Disclosure.


reasoning: The paragraph describes the company’s internal cybersecurity risk management process and its integration into enterprise risk management, including review cadence and who participates.


reasoning: This paragraph is explicitly about board and audit committee oversight and reporting cadence for cybersecurity risk, making Board Governance the correct category. It contains no firm-unique details (e.g., specific roles, dates, frameworks, or processes) beyond generic committee oversight language.


reasoning: The paragraph describes internal activities for managing cybersecurity-related material risks (e.g., protecting against/responding to incidents and maintaining compliance), which fits the company’s own risk management process. However, it contains no named roles, dates, systems, frameworks, or other firm-specific verifiable details.


reasoning: The paragraph centers on specific management roles (CIO and Information Security Director) and describes their responsibilities and experience, which is management-role disclosure rather than a company-wide risk process or incident narrative.


reasoning: The paragraph describes the company’s internal cybersecurity program and processes (assessing, identifying, managing incidents; controls and escalation for management visibility and disclosure). It contains no firm-specific entities, roles, dates, frameworks, or other verifiable details.


reasoning: The paragraph centers on the company’s CFO responsibilities and reporting line to the Nomination and Corporate Governance Committee, which is management/role governance over cybersecurity.


reasoning: The paragraph addresses the absence of material cybersecurity incidents and describes intended/ongoing response actions (contracting a forensic investigation firm and concluding no evidence of malware/persistence concerns), which is incident-related disclosure rather than board or general risk management.


reasoning: The paragraph centers on a named individual (Mr. Gharib) describing his responsibilities for cybersecurity risk integration, budgeting, incident preparedness, and approval/review of security activities.


reasoning: The paragraph describes an actual cyberattack and the company’s response (restoring services, investigating impacted data with law enforcement) and provides scope/impact details tied to Change Healthcare, which fits Incident Disclosure.


reasoning: The paragraph states that the Audit Committee (a board committee) is responsible for overseeing cybersecurity risks, and that senior IT leadership informs it. It also names a specific role (CFO), but does not include any uniquely verifiable external details beyond those governance roles.


reasoning: The paragraph describes HPE’s internal cybersecurity risk management program and how it identifies, assesses, manages, and mitigates cyber risks, including framework guidance (NIST). It is not primarily about board oversight, a management role reporting line, or a specific third-party/vendor relationship.


reasoning: This paragraph is explicitly about board/committee oversight: training, annual review/approval cadence, and delegation to the Enterprise Risk Management Committee with quarterly reporting to the full Board.


reasoning: The paragraph focuses on materiality/financial impact of cybersecurity threats and incidents, and mentions updating an information security strategy; however, it contains no firm-specific roles, dates, systems, frameworks, or quantified/verifiable details beyond generic statements.


reasoning: The paragraph describes the company’s internal processes for assessing threats/vulnerabilities, measuring/prioritizing cyber risk, and planning mitigation and incident response. It is generic and contains no firm-specific roles, dates, systems, or named frameworks/tools.


reasoning: The paragraph describes the company’s internal cybersecurity incident response policy, escalation process, and the roles/committees involved (management Incident Management Team, disclosure committee, Privacy and Security Subcommittee), which is an internal risk management process rather than an actual incident disclosure or third-party oversight.


reasoning: The paragraph describes the company’s internal cybersecurity and how it is integrated into its risk-management and related programs (ERM, business continuity/crisis, compliance). Third-party risk is mentioned as part of internal risk management rather than as a vendor-oversight focus.


reasoning: The paragraph describes the company’s internal risk management approach (embedding risk management into business processes and using an enterprise risk management team working with CSO and IT risk management to evaluate/mitigate cybersecurity risks). It is not a board topic, an incident, or standalone strategy/materiality language.


reasoning: The paragraph is primarily a materiality/strategy impact statement about cybersecurity risks (no material incidents experienced; resources spent including cyber insurance costs) with a cross-reference to risk factors, not an incident narrative or detailed internal risk process.


reasoning: The paragraph primarily describes how the company's cybersecurity policies/practices are integrated into its ERM and based on NIST/ISO frameworks, which is an internal risk management process. Although the AGM board is mentioned as overseeing, the main disclosure centers on integration of cybersecurity into ERM rather than board governance mechanics.


reasoning: The paragraph describes management roles (CISO and CTO) and their oversight responsibilities, reporting credentials, and experience, with multiple firm-specific and verifiable details (join dates and quantified experience plus named certifications).


reasoning: The paragraph’s grammatical subject is the Board/Cybersecurity Committee and describes governance actions and how the chair contributes to oversight of cybersecurity risk. It also includes multiple firm-unique, externally verifiable details (the 2023 establishment, named committee, and named certificate/program affiliations).


reasoning: The paragraph contains a standalone materiality-style conclusion regarding cybersecurity threats' lack of material impact on business strategy and financial condition, with generic forward-looking risk language and no incident narrative.


reasoning: The paragraph’s central topic is the company’s use of external third parties (assessors/consultants/auditors) for evaluating/testing its cybersecurity risk management, making it third-party risk-focused rather than an internal process description.


reasoning: The paragraph provides a standalone materiality/incidence statement (no material incidents; immaterial expenses; no penalties/settlements) and cross-references the Risk Factors section, without describing any actual incident narrative or internal processes.


reasoning: The paragraph centers on a named individual (Jack Wang) and his assigned responsibilities and reporting chain to executive officers and the Board, which is management-role governance over cyber risk.


category_confidence: low

reasoning: The paragraph describes general, ongoing risk identification and the existence of company processes for assessing and managing cybersecurity risks, but it does not name any framework, role, system, date, or other verifiable company-specific detail.


reasoning: The paragraph describes the company’s internal cybersecurity risk management activities (training, awareness updates, employee testing, penetration testing, and assessments). It is not focused on a board/management role identification or a third-party/vendor control, and it does not describe a specific incident event.


reasoning: The paragraph’s subject is the Board of Directors and its assignment of responsibility to the Audit Committee for cybersecurity governance and the reporting cadence.


reasoning: The paragraph is explicitly about governance: the Audit Committee and full Board receive cybersecurity-related reporting and briefings, and board continuing education is provided by named executive security roles (CIO/CISO/CIRO).


reasoning: The paragraph describes the company’s internal cybersecurity approach (stakeholder cross-functional process, incident controls, escalation procedures). It does not provide incident details, named roles/committees, frameworks, or company-specific facts beyond generic descriptions.


reasoning: The paragraph’s grammatical focus is the Chief Information Security Officer and Chief Technology Officer, including their reporting lines and responsibilities for the cybersecurity organization and implementation of strategy.


reasoning: This paragraph is standalone materiality/risk impact language and does not describe any incident or specific internal process. It references generally that cybersecurity threats could be reasonably likely to materially affect the company, including via the Risk Factors section.


reasoning: This paragraph describes the Company’s internal cybersecurity risk management program activities (governance cadence, training, and security policies), which fits Risk Management Process rather than an incident narrative or standalone materiality statement. It contains firm-unique operational details such as “over two dozen” policies and specific training/briefing activities.


reasoning: The paragraph identifies specific management roles (Vice President of Information Systems and CFO) and describes their tenure, responsibilities, and relevant qualifications, which is characteristic of a management role disclosure.


reasoning: The paragraph describes the company’s internal process for assessing, monitoring, and managing cybersecurity risks and incident-related prevention/mitigation/detection/remediation, including reporting within that process to the Audit Committee.


reasoning: The paragraph centers on board oversight and specifies reporting of significant incidents to the audit committee and then the board, which is Board Governance language. It also names specific roles/committees (Vice President of Operations and the audit committee), making it firm-specific, though it lacks verifiable external facts like dates or named systems to reach quantified-verifiable.


reasoning: This is a cross-reference to another section for general risk discussion and does not describe company-specific cybersecurity governance, incidents, or internal risk management details.


reasoning: The paragraph describes the company’s own incident response plan and its internal activities (triage, severity assessment, investigation, escalation, containment, remediation). Mentions of third-party security service providers are part of coordinating the internal plan rather than being the central topic of vendor oversight.


reasoning: The paragraph provides general statements about cybersecurity importance, threat examples (ransomware/denial-of-service), and a generic materiality impact possibility without describing internal risk management activities, specific roles, dates, or incidents.


reasoning: The paragraph contains only generic risk/insurance/materiality language without describing any internal processes, incident details, or named roles/frameworks. It addresses potential business/financial impact (material adverse effect) and cyber insurance, fitting Strategy Integration more than other categories.


reasoning: The paragraph is centered on the company’s third-party risk management activities and how it evaluates and mitigates risks arising from third parties and third-party incidents, which aligns best with Third-Party Risk.


reasoning: The paragraph centers on the Board and specifically the audit committee’s oversight of cybersecurity risk, including delegated responsibilities and reporting cadence.


reasoning: The paragraph focuses on how the company manages cybersecurity risks arising from third-party service providers, including selection/oversight and due diligence for parties with access to systems and facilities. While it also states these are included in broader risk management processes, vendor oversight is the central topic described.


reasoning: The paragraph describes the company’s internal cybersecurity practices and processes (tools, DR/tabletop exercises, security training, phishing testing, and penetration testing as part of its program). It is not focused on vendor oversight as the central topic, but rather on the company’s risk management activities.


reasoning: The paragraph is explicitly about board/committee oversight and briefing cadence for cybersecurity risk, making Board Governance the best fit. However, aside from generic committee/board descriptions, it lacks firm-unique roles, dates, frameworks, or measurable metrics, so it is treated as boilerplate-level specificity.


reasoning: The paragraph describes the company’s cybersecurity testing/review practices as part of its risk management program (ethical hacks, penetration tests, program reviews), but it does not identify specific systems, dates, roles, or named third parties, making it largely boilerplate.


reasoning: The paragraph describes internal cybersecurity preparedness activities (simulation exercise) and strengthening monitoring/incident response/detection/forensics, with vendors referenced as enablers rather than the central subject of the disclosure. It includes a specific time reference (fiscal 2024) and describes a specific cybersecurity exercise and augmentation areas.


reasoning: The paragraph describes the company’s internal processes for integrating cybersecurity into its Enterprise Risk Management and implementing a cybersecurity risk management program, which is central to risk management.


reasoning: The paragraph describes the company’s own risk assessment and evaluation activities (internal audit program, cybersecurity risk included in annual business risk assessment, and reporting of cybersecurity posture to business team leaders). However, it contains no firm-unique identifiers, dates, amounts, tools, or frameworks that would make it more than generic boilerplate.


reasoning: The paragraph is centered on the duties and reporting of a specific management role (“Director of Cybersecurity”) and describes its reporting/updating chain to named executives and an executive committee.


reasoning: The paragraph places grammatical emphasis on board/committee oversight (“board of directors and the Audit Committee”), but it also describes the company’s cyber risk management approach. The oversight language makes Board Governance the best match, while the process description remains non-firm-specific.


reasoning: The paragraph describes the company’s internal cybersecurity measures (incident response, disaster recovery/business continuity, risk assessments, encryption, network/access controls, monitoring, and training) as part of its risk management processes, without board/management role focus, vendor oversight, or incident narrative.


reasoning: The paragraph is explicitly about board/committee oversight of cybersecurity risk, with the Audit Committee identified as the body reviewing enterprise risk management and cybersecurity policies.


reasoning: The paragraph describes the company’s own vulnerability assessment/vulnerability management program, how often it is reviewed, and how it supports its cybersecurity risk management processes. It does not name any specific roles, systems, dates, frameworks by name, or third parties beyond generic internal/external environments.


reasoning: The paragraph describes the company’s internal cybersecurity risk protections, including cyber insurance ownership/review and the existence and testing of business continuity and disaster recovery/incident response readiness, which are internal risk management processes.


reasoning: The paragraph describes the company’s internal cybersecurity implementation efforts (adopting the NIST framework and aligning internal policies to legal/regulatory guidance), which fits a risk management process. It includes a named framework but no firm-unique roles, dates, systems, or quantified details.


reasoning: The paragraph describes general internal processes to oversee cybersecurity risks and provides generic future materiality/impact statements. Although it mentions third-party service providers, the central topic is the company’s risk oversight, and there are no named entities, dates, frameworks, or incident facts.


reasoning: The paragraph discusses an ongoing cybersecurity incident and states material business impact until recovery, but provides no incident specifics (no dates, systems, or quantifiable figures), making it largely boilerplate.


reasoning: The paragraph describes the company’s internal cybersecurity monitoring, severity assessment, and escalation steps within its incident response plan, which is a risk management process. It also specifies a named management role (Senior Vice President, IT Operations) directing the information security team.


reasoning: The paragraph describes the company’s internal incident-handling and monitoring processes (SOC operations, severity matrix, notification/escalation, triage). While specific to the company, it does not include unique named roles/organizations beyond the SOC and lacks externally verifiable details like dates, amounts, or vendor/tool names.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized activity) and specific response actions, including isolating systems from the Internet on December 20, 2023 and engaging law enforcement/regulators.


reasoning: This paragraph discusses financial/business impact and materiality expectations (material impact during a specific quarter, no material impact for full-year results) rather than describing incident events or controls.


reasoning: This paragraph describes an actual cybersecurity incident (unauthorized access and encryption) and the company’s response actions, which squarely fits Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident with a date and details of actions taken in response (investigation with external experts, incident response plan, shutting down systems, and notifying law enforcement), which fits Incident Disclosure.


reasoning: The paragraph describes the company’s own cybersecurity risk controls (e.g., incident detection/response, vulnerability management, DR/BC, encryption, monitoring, and vendor risk management processes), which is characteristic of its internal risk management process rather than an incident or board/management role.


reasoning: The paragraph describes the status/results of an ongoing cybersecurity incident investigation (no evidence of malware/ransomware/data destruction and whether the threat actor has access) and continues investigation of scope/impact, which is substantive incident disclosure.


reasoning: The paragraph describes incident response actions (notification/cooperation with law enforcement, assessing regulatory notifications) and provides materiality conclusions tied to the incident as of the filing date.


reasoning: The paragraph describes a real cybersecurity incident, including detection date, response actions (incident response/business continuity, disrupting activity), use of a cybersecurity firm, and notifications to regulators and law enforcement.


reasoning: The paragraph is a generic forward-looking statements disclaimer and does not describe any cybersecurity governance, management role, risk process, third-party risk, incident details, or materiality conclusions.


reasoning: This paragraph describes an actual cybersecurity incident (unauthorized activity) and specific response actions, including a dated containment step (isolating systems from the Internet on December 20, 2023).


reasoning: This paragraph describes an actual cybersecurity incident’s material business/earnings impact for a specific quarter and provides quantified GAAP EPS figures and an estimated EPS reduction attributable to the incident.


reasoning: The paragraph provides ongoing-incident materiality/financial impact conclusions using generic phrasing without describing concrete incident events, dates, systems, or named actors; this aligns most with materiality/impact integration rather than incident disclosure.


reasoning: This paragraph describes the status and impact of an actual cybersecurity incident (containment/remediation, whether systems were compromised, unauthorized transactions, and transfers). The details are framed in general terms without firm-unique identifiers or dates, so it is treated as generic incident-disclosure language.


reasoning: The paragraph describes a real cybersecurity event (unauthorized access and exfiltration) and associated response actions (providing notifications to affected parties and regulators). However, it does not include firm-unique or externally verifiable details such as dates, dollar amounts, specific systems, or named third parties, making it largely boilerplate.


reasoning: The paragraph describes the realized impact of a cybersecurity incident (temporary operational disruption), indicates evidence of data exfiltration (“files were taken”), and outlines incident-response actions (reviewing files and notifying individuals/regulators).


reasoning: The paragraph describes an actual cybersecurity incident, including the date it was discovered, the actions taken (containment, assessment, remediation), and the observed effect (unauthorized access and encryption). It contains company-specific incident details, but no quantified metrics or named external vendors/tools to reach Quantified-Verifiable.


reasoning: This paragraph describes the cybersecurity incident’s relationship to earlier threat-actor activity, including the timing (May 2023 and June 2023), affected system (SharePoint files), and response actions (investigation, containment, remediation) plus a materiality conclusion.


reasoning: This paragraph is standalone materiality/impact language about the incident’s financial effects and general post-incident risks, without describing what happened or naming any roles, systems, dates, amounts, or frameworks.


reasoning: This paragraph provides a standalone materiality conclusion about the cybersecurity incident’s lack of material impact on business operations and financial condition/results, without describing any incident facts, dates, scope, or response actions.


reasoning: This paragraph describes the real impact of a cybersecurity incident on distribution, billing/collections, online operations, and payments, including operational restoration status and recovery timing. It also provides verifiable specifics (February 12, 2025 status and a five-percent revenue figure).


reasoning: The paragraph reports an ongoing cybersecurity investigation and provides estimates about what personal data was stolen, including a specific quantity (35.5 million consumers) and related findings about passwords and types of payment/identity data.


reasoning: The paragraph describes incident-related disclosure timing directed by the U.S. Department of Justice and includes response status (working with law enforcement, at least one person apprehended, and whether data is publicly available), which is characteristic of an incident disclosure narrative.


reasoning: The paragraph quantifies financial impact ($2.3 million additional expenses and ~$15 million of unfulfilled revenue) and discusses expected fulfillment timing, which is standalone business/financial impact tied to the incident rather than describing incident mechanics.


reasoning: The paragraph describes consequences of an actual cybersecurity event (non-recurring expenses accrued in the first quarter) and includes incident-response actions (notification to federal law enforcement) rather than describing general risk management.


reasoning: The paragraph describes an actual cybersecurity incident (additional data exfiltration) and provides details about the confirmed contents of the exfiltrated data (PII and PHI) and the Company’s review completion status.


reasoning: This paragraph describes an actual cybersecurity incident and its specific impacts/actions (unauthorized access, deletion of emails, misdirected wire payment) including a dollar amount and non-recovery status, which squarely fits Incident Disclosure.


reasoning: This paragraph provides boilerplate expense and materiality language about the incident’s potential financial impact, without describing incident details, processes, or naming specific roles, systems, dates, or frameworks.


reasoning: The paragraph describes a real cybersecurity event (a ransomware incident) with timing, scope (internal IT systems), and response actions (containment, experts, investigation, notifications), which fits Incident Disclosure.


reasoning: The paragraph discusses actual data exfiltration and what type of data was exfiltrated, along with concrete timing for the related Form 10-K release. These details fit an incident disclosure context rather than generic risk-process language.


reasoning: The paragraph describes actions taken after becoming aware of a cybersecurity incident (launching an investigation, working with law enforcement, notifying users/regulators) and references unauthorized access to personal information, which is characteristic of incident disclosure.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access) with a specific discovery date and includes incident response activation, which fits Incident Disclosure.


reasoning: The paragraph describes a real cybersecurity-related operational disruption (unauthorized access by a threat actor) and the company’s response actions and recovery timeline, plus materiality to operations.


reasoning: This paragraph describes a real cybersecurity incident (unauthorized activity), includes specific response actions, and provides a specific date for isolating systems from the Internet.


reasoning: The paragraph describes a specific cybersecurity event with dates, alleged unauthorized access/exfiltration, affected data types, and related response actions (incident response activation and hiring external experts), which fits incident disclosure.


reasoning: The paragraph describes an ongoing cybersecurity incident involving exfiltration and unauthorized access, along with investigation scope and potential legal/regulatory notifications. It contains multiple incident-specific statements, though it does not provide firm-unique identifiers beyond the company reference.


reasoning: This paragraph focuses on materiality/financial impact conclusions and business implications rather than describing what happened in the incident. The only incident-specific detail provided is its limitation to the Dropbox Sign infrastructure, supporting a Strategy Integration classification.


reasoning: This paragraph describes active disruption and response actions (restoring systems, retaining security experts, working with law enforcement, notifying parties) and identifies the affected system as Change Healthcare.


reasoning: The paragraph provides an incident-related materiality expectation and timing (no material disruption; no expected material impact for the three months ended March 31, 2026), which is substantive incident disclosure rather than general boilerplate.


reasoning: The paragraph describes ongoing expenses tied to a cybersecurity incident and provides financial impact details (external experts cost, lost production duration, affected operations, and timing/materiality during a specific quarter ending June 29, 2024).


reasoning: The paragraph describes a real cybersecurity incident with a specific detection/ejection date (July 10, 2024) and includes incident response actions (external specialists, activating the incident response plan, shutting down systems).


reasoning: The paragraph is a standard forward-looking statements disclaimer with no cybersecurity substance, incident description, governance/process details, or named entities beyond generic phrasing.


reasoning: This paragraph provides a standalone materiality/impact assessment using generic language (“not had a material impact,” “not reasonably likely to materially impact”) without describing incident details or naming entities, dates, or systems.


reasoning: The paragraph describes an actual cybersecurity incident (date of awareness, unauthorized third-party access) and the Company’s response actions (investigation with experts/counsel, notifying law enforcement, containment, preserving system integrity). It includes a company-specific incident narrative with a specific date, but no named tools/vendors beyond generic “cybersecurity experts” and “external counsel.”


reasoning: The paragraph describes actions taken in response to a cybersecurity incident (containment, enhanced monitoring/access controls, engaging forensic experts, and notifying regulatory/law enforcement), which is incident-response narrative rather than a standalone risk process or strategy statement.


reasoning: The paragraph provides an update about a specific real-world cybersecurity event (the Change Healthcare cyberattack) and describes ongoing response activities (data assessment, impacted-individual/provid- customer support, service restoration) along with a verifiable date and exhibit reference.


reasoning: This paragraph describes a real cybersecurity matter detected on a specific date and details incident response actions (assess/contain/remediate, isolating systems, and investigating with external cybersecurity advisors).


reasoning: This paragraph provides a standalone materiality conclusion about the incident’s financial impact, with no incident narrative or operational details, and no named entities, dates, or metrics.


reasoning: This paragraph describes actions taken after discovering a cybersecurity incident (containment, investigation with third-party professionals, notification to law enforcement, restoration, monitoring, and notifying affected parties). It provides real incident response details, but no firm-specific names, dates, amounts, or uniquely identifiable systems/tools.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized third-party access) and provides incident specifics, including an affected user count (~8.4 million) and what types of data were or were not compromised.


reasoning: The paragraph describes a real cybersecurity event (unauthorized data exfiltration) with a specific date and includes incident response actions (containment and investigation with law enforcement/cybersecurity experts/external counsel).


reasoning: The paragraph describes a real cybersecurity incident (ransomware, encryption, and later unauthorized disclosure) with specific dates and escalation details, which is characteristic of an Item 1.05 incident disclosure.


reasoning: The paragraph provides a standalone materiality conclusion about the cyber incident’s financial impact, with no incident narrative details or governance/management process descriptions.


reasoning: This paragraph is a standard legal disclaimer about whether information is deemed filed or incorporated by reference; it contains no cybersecurity substance, processes, governance, roles, or incident details.


reasoning: The paragraph describes an actual cybersecurity incident being contained and ongoing remediation/response actions (reinforcement of systems, monitoring, prevention), which is characteristic of incident disclosure rather than general risk management.


reasoning: The paragraph describes a real cybersecurity incident (data exfiltration) with a specific disclosure date and includes response actions (containment) and who assisted the investigation.


reasoning: The paragraph focuses on how the Company is managing operations in light of an incident—following internal safety standards under its Halliburton Management System and identifying the incident’s effects—rather than describing the incident itself.


reasoning: The paragraph describes an actual cybersecurity incident (file exfiltration and ongoing investigation) and discusses evaluating/issuing regulatory and legal notifications based on findings, which fits Incident Disclosure.


reasoning: The paragraph provides a standalone materiality conclusion about financial condition/results of operations with no incident narrative details, dates, scope, or operational particulars.


reasoning: The paragraph describes how cybersecurity operating procedures are integrated into the company’s enterprise risk management (ERM) programs, focusing on internal risk management processes. It does not provide firm-specific names, dates, roles, or frameworks.


reasoning: The paragraph describes an actual cybersecurity matter (“unauthorized activity”) and specific response steps taken (activating a cybersecurity response plan, internal investigation with external advisors, taking systems offline, notifying law enforcement, restoring systems, and assessing impacted data). However, it contains no company-specific identifiers, dates, systems, or named parties, so it is not firm-specific or verifiable beyond standard incident-response language.


reasoning: The paragraph provides a materiality conclusion about financial impact and EBITDA contribution context, not a new incident narrative or internal risk process. It focuses on how the incident affects (or does not affect) financial results and operations.


reasoning: This paragraph is a forward-looking disclaimer about the possibility of cybersecurity incidents and includes a cross-reference to Item 1A Risk Factors, with no substantive cyber governance/process details, incident narrative, or firm-specific facts.


reasoning: The paragraph describes outcomes of an ongoing/previous cybersecurity incident (removal of an external party from IT systems, restoration of access, and confirmation of data completeness/integrity), which is incident-specific response language.


reasoning: The paragraph is centered on the Committee’s oversight and reporting cadence/activities, but it uses generic terms (“the Committee,” “management,” “cybersecurity risks/incidents”) without naming specific roles, dates, or entities.


reasoning: The paragraph describes the company’s own cybersecurity risk management process for assessing vendors (risk-based evaluation using vendor criticality/size), without a vendor oversight program being the central topic. It is not incident-specific and contains no named roles, dates, systems, or frameworks.


reasoning: The paragraph centers on the board’s oversight responsibilities and how the audit committee and executive leadership inform the board. However, it contains no company-specific names, systems, dates, or detailed metrics beyond generic cadence, making it largely boilerplate.


reasoning: This paragraph describes an actual cybersecurity incident’s impact (what was and was not compromised, whether customer funds were accessible) and the categories of data believed affected. However, it contains no company-specific identifiers, dates, dollar amounts, named systems, or external parties, so it does not meet the criteria for Firm-Specific or Quantified-Verifiable specificity.


reasoning: The paragraph describes board-level oversight of data privacy/cybersecurity compliance and annual evaluation of a Cybersecurity Committee, with no company-specific named roles, dates, or concrete details.


reasoning: The paragraph discusses general cyber dependency on internal systems and third parties, but it does not describe any specific company program/process, named framework, roles, or incidents, making it largely boilerplate and not central to a particular category.


reasoning: The paragraph describes ongoing internal investment in cybersecurity and internal controls/processes, but it provides no incident details, named roles, dates, frameworks, or firm-specific elements.


reasoning: The paragraph describes the company’s internal cyber risk management and how it is integrated with enterprise risk management for its IT environment. It is framed generically without naming specific roles, dates, systems, frameworks, or external standards.


reasoning: The paragraph identifies a specific management role (Group Head, Cybersecurity/Information Security Officer) and provides company-specific tenure and quantified experience details, making it a management-role description rather than a risk process or incident narrative.


reasoning: The paragraph describes the company’s own cybersecurity program as part of its enterprise risk management process (assessing, identifying, and managing cyber risks). It contains no firm-specific details, named roles, dates, frameworks, or measurable facts.


reasoning: The paragraph describes board and Audit Committee oversight of cybersecurity risk management, including audit committee responsibilities. It does not identify a unique role/person or specific time, but it does name the Audit Committee and ties oversight to the committee charter, making it more than generic boilerplate.


reasoning: The paragraph describes the purpose of the company’s cybersecurity program (protecting against unauthorized access and disruption), which is an internal risk management/process statement rather than an incident or board/management role.


reasoning: The paragraph identifies a specific internal management subject (head of the ITS Department) and executive management as responsible for assessing and managing cybersecurity material risks. While it doesn’t name a person, it is still a firm-specific organizational role in the company.


reasoning: The paragraph describes the background of an identified individual (Mr. Tao), which is management-related information rather than a cyber risk process or incident disclosure.


reasoning: The paragraph describes CrowdStrike’s cybersecurity risk management being integrated into its enterprise risk management program, which is internal process-focused. It contains no named roles, dates, frameworks, or other firm-unique verifiable details beyond generic statements.


reasoning: The paragraph describes general cybersecurity vulnerabilities and risk types (malware, ransomware, phishing) but provides no company-specific controls, processes, dates, roles, frameworks, or verifiable details.


reasoning: The paragraph is explicitly about Board of Directors oversight and reporting cadence, with the Board receiving quarterly reports from named management roles (CISO and CIO) regarding cybersecurity threats and processes.


reasoning: This paragraph is generic governance language describing board and executive oversight without naming any cyber-specific process, committee, role, dates, or frameworks, and provides no substantive cybersecurity disclosure.


reasoning: This is a standalone materiality statement about no cybersecurity incident materially affecting business strategy, results of operations, or financial position, with no incident narrative or firm-specific details.


reasoning: The paragraph describes the company’s internal cybersecurity risk controls (PII policy, employee training, quarterly testing/re-training). It is not an incident narrative or a vendor-focused disclosure, though it mentions vendors as information recipients.


reasoning: The paragraph contains only generic statements about IT team qualifications and participation in unspecified programs, without naming roles, committees, frameworks, dates, systems, or other verifiable firm-specific facts.


reasoning: The paragraph’s subject is board and committee oversight (audit committee reporting and board briefings), which squarely fits board governance. However, it contains no firm-specific names, dates, roles, or detailed program facts beyond generic descriptions, making it boilerplate.


reasoning: The paragraph is centered on the individuals that comprise the company’s ISC, identifying the CIO and Director of IT Security, Risk and Compliance and describing their qualifications and experience. This is governance/operations role identification rather than incident disclosure or a distinct risk-process description.


reasoning: The paragraph centers on how Mercer oversees the cybersecurity of third-party IT service providers, including use of Security Scorecard for review and monitoring.


reasoning: The paragraph is a general description of using reputable third-party e-mail and cloud storage providers with cybersecurity protections, without describing the company’s specific internal risk processes or governance details.


reasoning: The paragraph describes how the company’s cybersecurity program fits within its overall risk management approach and previews key areas, but it contains no named frameworks, roles, dates, or other company-specific details.


reasoning: The paragraph describes the company’s own incident response and recovery testing practices (simulations/tabletop exercises and frequency), which is an internal risk management process rather than an incident disclosure or third-party oversight.


reasoning: The paragraph describes internal incident remediation and prevention steps (eradication/root-cause identification) rather than board oversight or a specific disclosed incident. It contains no company-specific entities, dates, systems, or measurable facts, making it generic guidance.


reasoning: This paragraph provides a materiality-style statement about whether a significant breach occurred and reports the absence of related expenses/penalties/settlements over specific periods, which fits Strategy Integration rather than incident narrative or internal process.


reasoning: The paragraph identifies a specific management role (CFO) and states it serves as the CISO, describing how that role manages cybersecurity risks.


reasoning: The paragraph describes the company’s own cybersecurity-related program activities (threat-intelligence, forums, external experts, testing controls), which is central to its risk management process rather than a board/management role or a discrete incident.


reasoning: The paragraph describes the company’s own incident response plan being reviewed and updated as part of an internal process. It does not name any specific roles, dates, systems, frameworks, or other firm-unique details.


reasoning: The paragraph describes internal monitoring activities for preventing, detecting, mitigating, and remediating cybersecurity incidents, including receipt of notifications and communications. No named roles, dates, systems, or verifiable firm-specific details are provided, and the vendor/service-provider mention is only ancillary to the company’s internal monitoring process.


reasoning: The paragraph’s subject is governance oversight: the Global Security Steering Committee reports quarterly to the Board of Directors and the Audit Committee, indicating board/committee cyber-risk briefing and cadence.