reasoning: The paragraph primarily describes the company's internal processes for managing cybersecurity risks, including vendor reviews and incident response planning. While it mentions third parties, the focus is on the company's own internal review and approval processes, making 'Risk Management Process' the most appropriate category.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal risk management processes, including specific programs like the 'ICSIRP', which qualifies as a firm-specific fact.

provider: google


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and oversight without naming specific frameworks, roles, or unique programs. It uses standard boilerplate language regarding board/management oversight and risk mitigation.


content_category: Management Role

reasoning: The paragraph focuses on identifying the specific management roles (CISO, CCO) and the Information Security Team, detailing their responsibilities and professional qualifications.


reasoning: The paragraph describes the company's internal security programs, incident escalation procedures, and the roles involved in managing these processes, which falls squarely under Risk Management Process. It is Firm-Specific because it identifies specific cybersecurity-related roles (CISO, CIO) involved in the company's unique governance structure.


reasoning: The paragraph describes the company's internal incident response plan and escalation procedures, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it identifies a named internal program ('incident response ("IR") plan'), which distinguishes it from generic boilerplate.


reasoning: The paragraph details the company's internal incident response plan and the specific roles responsible for executing it, alongside their engagement with specific frameworks and government entities for risk management.


content_category: Board Governance

reasoning: The paragraph focuses primarily on the Board's oversight responsibilities and the reporting structure of management to the Board, making 'Board Governance' the primary category. While management roles and frameworks are mentioned, they are presented in the context of the Board's oversight activities.


content_category: Third-Party Risk

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


reasoning: The paragraph describes the company's internal security measures and risk management processes. Despite the long list of activities, all items mentioned (e.g., incident response plan, red/blue team exercises, vendor risk management) are generic security practices without unique identifiers, specific dates, or named tools/firms.


reasoning: The paragraph describes the company's internal risk management processes, including the use of the NIST framework, the existence of a SOC, and oversight by specific management roles (CIO and CISO).


reasoning: The paragraph identifies specific management personnel responsible for cybersecurity oversight and details their professional qualifications and history. It contains numerous verifiable facts, including named companies and specific employment dates, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses on the Board's delegation of cybersecurity oversight to the Audit Committee and the committee's specific responsibilities, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies the specific committee (Audit Committee) and a specific role (CTO) involved in the oversight process.


content_category: Strategy Integration

reasoning: The paragraph provides a materiality assessment regarding cybersecurity risks and incidents, which falls under Strategy Integration. It is classified as Firm-Specific because it includes a specific reference to the year 2023 in the context of the company's incident history.


content_category: None/Other

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


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident, including the nature of the unauthorized access, the exfiltration of files, and the operational impact, which clearly falls under Incident Disclosure. It is Firm-Specific because it includes a specific date (July 25, 2024) related to the incident determination, but it does not meet the threshold for Quantified-Verifiable as it lacks a second hard fact (e.g., a named firm, dollar amount, or second date).


reasoning: The paragraph describes the company's internal incident response and risk management processes, specifically referencing internal programs and teams like the Disaster Recovery Plan and the Crisis Management Team.


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 facts, dates, or named entities, making it generic boilerplate.


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


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


reasoning: The paragraph begins by explicitly defining the responsibilities and qualifications of the CIO, which makes 'Management Role' the primary focus despite the subsequent discussion of risk management processes.


reasoning: The paragraph describes the ongoing response and impact of a specific cybersecurity incident, including the scope of affected data and financial compensation details, clearly falling under Incident Disclosure.


reasoning: The paragraph describes the responsibilities of 'senior management' regarding risk appetite, which falls squarely under Management Role. It contains no specific roles, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal procedures for investigating and responding to cybersecurity threats, which falls under Risk Management Process. It is classified as Firm-Specific because it references a specific internal body, the 'ISC' (Information Security Committee or similar), which is a unique identifier.


reasoning: The paragraph is a general introductory statement about cybersecurity risks and the company's recognition of them, lacking any specific details about internal processes, governance, or incidents.


reasoning: The paragraph focuses primarily on the reporting lines and responsibilities of specific management roles (CISO, CIO, CTO) and their interaction with the CEO, which aligns with the Management Role category.


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


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the unauthorized access, and the company's response actions, which qualifies it as an Incident Disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks without referencing any specific incidents, which falls under Strategy Integration.


reasoning: The paragraph describes a standard internal security training process, which falls under Risk Management Process. It contains no specific dates, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes standard internal security measures like firewalls, intrusion detection, and incident response planning without naming specific tools, frameworks, or unique identifiers.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including the nature of the attack, the company's response, and the operational impact, which fits the Incident Disclosure category. It contains multiple verifiable facts, including specific dates and the name of the affected website, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal process of utilizing third-party service providers as part of their risk management strategy. It does not name specific vendors or unique programs, making it a generic description of risk management activities.


reasoning: The paragraph focuses on the qualifications and experience of specific management roles (CISO and VP of Information Security). It qualifies as Quantified-Verifiable because it provides two distinct quantified metrics regarding the years of experience for these specific roles.


reasoning: The paragraph focuses on the oversight responsibilities of the board-level Risk Committee, 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 program (Cybersecurity Incident Response Plan).


reasoning: The paragraph consists of high-level corporate mission statements and general safety philosophy without describing specific governance, management, risk processes, or incidents.


reasoning: The paragraph focuses exclusively on the company's oversight of third-party service providers, including assessments and contractual obligations, which fits the Third-Party Risk category. It contains no unique identifiers, named frameworks, or specific verifiable facts, making it generic boilerplate.


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 fact.


reasoning: The paragraph focuses on the responsibilities of management and the IT department. While it mentions a 'Software Engineer', this is not a cybersecurity-specific role as defined by the guidelines, and the rest of the text describes generic management functions.


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


reasoning: The paragraph explicitly addresses the company's internal risk management processes (or lack thereof), which falls squarely under the Risk Management Process category.


reasoning: The paragraph describes the company's internal risk management processes and the specific internal teams involved in oversight, rather than focusing on board governance or a specific incident.


reasoning: The paragraph explains that the company is a blank check company with no operations and thus no cybersecurity risk, which effectively places it in the 'None/Other' category as it describes the absence of cybersecurity activity rather than a governance, management, or risk process.


reasoning: The paragraph describes internal security practices like training, phishing simulations, and insurance, which are standard components of a risk management process. None of the mentioned activities are unique identifiers or named frameworks, and the mention of insurance is generic without specific details.


reasoning: The paragraph focuses on the board of directors' oversight role and their interaction with management regarding cybersecurity risks. It contains no specific facts, named committees, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph identifies specific management roles responsible for cybersecurity oversight, which is the primary focus of the Management Role category.


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


reasoning: The paragraph describes internal security practices like vulnerability management and incident response planning, which falls under Risk Management Process. It contains no specific frameworks, roles, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph consists of standard boilerplate disclaimers regarding the absence of material incidents and cross-references to risk factors, containing no substantive disclosure about governance, management, or specific processes.


reasoning: The paragraph describes the company's internal cybersecurity program, governance structure, and risk management framework. While it touches on governance and third-party risk, these are presented as components of the company's overarching internal risk management process.


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


reasoning: The paragraph describes the company's general approach to risk management and the inherent limitations of its security controls, which is a standard discussion of internal risk management processes.


reasoning: The paragraph describes the company's internal risk management objectives and identifies specific internal entities (Technology Leadership Centre and the Chief Technology Officer) responsible for overseeing these processes.


reasoning: The paragraph focuses on the oversight responsibilities of the Audit Committee, which is the grammatical subject throughout, fitting the Board Governance category. It contains no unique identifiers, named frameworks, or specific roles beyond the standard Audit Committee, making it generic boilerplate.


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 identifies specific cybersecurity-related roles (Chief Information Officer, Director of IT) rather than just generic management.


reasoning: The paragraph describes the company's internal organizational structure for managing cybersecurity, specifically detailing the roles and responsibilities of internal committees and leadership teams. While it mentions the Board, the primary focus is on the internal management and risk assessment processes.


reasoning: This paragraph is a standard forward-looking disclaimer regarding cybersecurity risks and contains a cross-reference to the Risk Factors section, which falls under the None/Other category.


reasoning: The paragraph focuses on the responsibilities of specific management roles (Head of Cybersecurity, CFO, General Counsel) regarding incident reporting and oversight, making Management Role the primary category.


reasoning: The paragraph describes the company's internal incident response and vulnerability management procedures, making Risk Management Process the most appropriate category. It is classified as Firm-Specific because it identifies a specific role (Vice President of Operational Engineering) involved in the escalation process.


reasoning: The paragraph describes the company's internal monitoring and testing processes, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies a specific regulator (OCC) that oversees the company's audits, which is a unique fact.


reasoning: The paragraph explicitly identifies specific management roles (CIO, CTO, Information Security Officer) and their responsibilities, which is the defining characteristic of the Management Role category.


reasoning: The paragraph describes the company's internal approach to security controls and risk mitigation, which constitutes a description of their risk management process, but it lacks any specific details or unique identifiers.


reasoning: The paragraph describes internal security practices like penetration testing and vendor review processes, which are standard components of a risk management program. It contains no specific dates, named tools, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes general internal processes for evaluating cybersecurity effectiveness using third-party providers and tabletop exercises, which are standard security practices. It does not name specific vendors, frameworks, or unique programs, making it generic.


reasoning: The paragraph describes the company's internal risk assessment, monitoring, and policy frameworks, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it references specific standards (CIS and FERPA) without providing unique, firm-specific operational details or multiple hard verifiable facts.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities regarding cybersecurity, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies the CISO role and a specific internal program ('Cybersecurity Incident Response Plan'), which are unique identifiers, though they do not meet the threshold for 'Quantified-Verifiable' per the provided instructions.


reasoning: The paragraph describes the company's internal risk management processes and security program in broad, generic terms without naming specific frameworks, roles, or unique identifiers.


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


reasoning: The paragraph describes general security practices like penetration testing and information sharing, which are standard components of a company's internal risk management process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks without describing any specific incident or internal process, which falls under Strategy Integration.


reasoning: The paragraph describes the company's internal cybersecurity program, including specific operational controls like network segmentation, access controls, and patch management, which falls under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes general internal security measures (firewalls, anti-malware) which falls under Risk Management Process, but contains no specific identifiers, frameworks, or unique facts.


reasoning: The paragraph describes the company's internal enterprise risk management (ERM) process and how it identifies and monitors cybersecurity risks, which is the core definition of the Risk Management Process category.


reasoning: The paragraph focuses entirely on the risks associated with third-party service providers and the potential impact of cyber-attacks on those entities. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph focuses on the identification and reporting lines of the CIO, which is a management role.


reasoning: The paragraph focuses on the responsibilities and qualifications of specific management roles (CCO and CISO) regarding cybersecurity oversight. It qualifies as Quantified-Verifiable because it contains multiple hard facts, including specific dates (May 2024) and quantified durations of experience (three years, sixteen years).


reasoning: The paragraph describes the company's internal cybersecurity program and risk management processes. It is classified as Firm-Specific because it cites specific certifications (HITRUST and SOC 2 Type II) held by the company, which goes beyond merely naming frameworks.


reasoning: The paragraph details the company's internal incident response procedures, escalation paths, and materiality assessment workflows, which are core components of a risk management process. It is classified as Firm-Specific because it identifies unique internal roles (e.g., Cybersecurity Incident Manager) and specific departmental structures (Global Information Security Team) involved in these processes.


reasoning: The paragraph focuses on the reporting structure and oversight cadence regarding cybersecurity, with the Audit Committee (a board-level entity) being a primary subject of the oversight process.


reasoning: The paragraph focuses on the reporting lines and responsibilities of the CISO, which falls under Management Role. It is Firm-Specific because it identifies a specific role (CISO) and a specific reporting date/committee structure.


reasoning: The paragraph focuses primarily on the company's vendor due diligence and contractual security requirements, which falls squarely under Third-Party Risk. The mention of 'PSCM' (the management entity) makes it firm-specific.


reasoning: The paragraph focuses on the composition, leadership, and reporting structure of the 'Cybersecurity Council,' which is a management-level body. While it mentions the Board, the primary subject is the management council's role and membership.


reasoning: The paragraph details the company's internal incident response and assessment procedures, specifically identifying the composition and function of the Cyber Security Subcommittee.


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 primarily details the qualifications, reporting structure, and responsibilities of the CISO, which is a management role.


reasoning: The paragraph describes the oversight responsibilities of the Technology Committee, which is a board-level committee, placing it squarely in Board Governance. It is Firm-Specific because it identifies a named committee unique to the company's governance structure.


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


reasoning: The paragraph discusses the company's internal approach (or lack thereof) to risk assessment processes, which falls under Risk Management Process. It contains no specific facts, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and processes, which falls under 'Risk Management Process'. It is classified as 'Sector-Adapted' because it references the NIST framework but lacks firm-specific details such as named roles, unique programs, or verifiable metrics.


reasoning: The paragraph focuses on the oversight responsibilities of the Audit Committee and the Board of Directors. It is classified as Generic Boilerplate because 'Audit Committee' and 'Board of Directors' are standard governance structures, and the language regarding periodic updates is generic.


reasoning: The paragraph describes internal security activities like monitoring, threat awareness, and testing, which falls under Risk Management Process. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph is a standard forward-looking disclaimer regarding potential cybersecurity risks and impacts, which falls under the 'None/Other' category as per the instructions.


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


reasoning: The paragraph focuses on the CISO's reporting lines and interactions with a specific committee (IOC), which falls squarely under Management Role.


reasoning: The paragraph describes general internal security activities and processes without naming specific tools, frameworks, or unique organizational structures.


reasoning: The paragraph describes internal security training, policy review, and control testing processes, which are standard risk management activities. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal security procedures and risk management activities, specifically identifying the IT security department as the entity responsible for evaluating third-party services.


reasoning: The paragraph is general forward-looking cybersecurity risk language and includes a materiality/consequence statement (“have not materially affected us...”) rather than describing an incident or internal risk management actions.

provider: openai


reasoning: The paragraph is generic materiality language and a cross-reference to Item 1A risk factors. It does not describe an incident or a company-specific cyber governance/process; it only points to another section for details.


specificity_confidence: medium

reasoning: The paragraph is explicitly focused on the Audit Committee’s role and reporting/oversight structure for cybersecurity risk, including quarterly reporting and annual enterprise risk assessment.


reasoning: The paragraph centers on requirements and oversight of third-party service providers’ cybersecurity measures (certification and breach reporting), which is the central topic. It also includes a firm-specific statement about no material impairment to operations or financial standing.


reasoning: The paragraph describes Emergent’s internal cybersecurity program integration with its ERM, including risk assessment, acceptance vs mitigation, monitoring cadence, and reporting within the organization—core risk management process content rather than incident disclosure or third-party oversight.


reasoning: The paragraph describes Stellar Bancorp's internal risk management and cybersecurity integration into its ERM, including ongoing processes like identification/mitigation and periodic review. It does not narrate a specific incident, so it is best categorized as the company's risk management process.


reasoning: This paragraph centers on the Information Security Officer’s reporting line to the Chief Risk Officer and describes the ISO’s responsibilities and qualifications. It is management-role focused rather than primarily describing governance, an incident, or a risk-management process.


reasoning: This paragraph is a cross-reference to the risk factors section and includes generic examples of potential impacts, without describing any company-specific cyber governance, processes, roles, or an incident.


reasoning: The paragraph is primarily framed around the Board’s oversight, briefing/presentation cadence, and reporting/materiality handling with specific named senior roles (President/CEO and General Counsel). It contains company-specific descriptions of how incident reporting and yearly board discussions are conducted, even though no hard dates, tools, or dollar amounts are provided.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment/management processes and their integration into enterprise risk management, including asset/threat/control identification. Although third-party providers are mentioned, they are part of the internal risk management process rather than a standalone vendor oversight topic.


reasoning: The paragraph describes the company’s internal risk assessment/monitoring approach (threat identification, evaluation methods, and ongoing IT investments) and names internal departments and a multi-stakeholder structure, which is central to the risk management process rather than a standalone incident or third-party requirement.


reasoning: The paragraph describes the company’s own information security programs and how they assess and manage risks across confidentiality, integrity, and availability, indicating an internal risk management process. It is sector-adapted because it names recognized frameworks/standards (ISO, NIST) and related concepts without company-unique details.


reasoning: The paragraph is centered on the Board of Directors’ oversight responsibilities, assessment activities, and review/discussion of cybersecurity and related processes. It also identifies a specific management role (HSE Director) as the overseer of the cybersecurity program, reinforcing board-governance focus.


reasoning: The paragraph is explicitly about the Audit Committee/Board oversight of cybersecurity risk management and how it reports to the Board, with management (CIO/CISO) involved in those reviews. It includes firm-specific governance details beyond generic cybersecurity statements (Audit Committee charter/annual review/reporting cadence and specified topics).


reasoning: The paragraph is explicitly about board-level and Audit Committee oversight of cybersecurity risk, including delegated committee responsibility and reporting from specific cybersecurity-relevant management roles.


reasoning: The paragraph describes the company’s internal cybersecurity risk management activities (incident response plan lifecycle, routine testing/training, risk assessments, threat modeling, vulnerability scanning, penetration testing, monitoring, and reporting). It does not describe an actual incident or board/management structure, and contains no named frameworks, tools, dates, or external parties.


reasoning: The paragraph describes the Trustee’s own cyber risk management program and cybersecurity protocols (identification, assessment, mitigation, response) and an annual assessment of that program, which are internal risk management processes rather than governance, incident disclosure, or standalone strategy.


reasoning: The paragraph describes the company’s internal cybersecurity risk identification and assessment activities (InfoSec team, threat intelligence review, control evaluation, and mitigation processes). While third-party consultants/providers are mentioned, they are part of the company’s internal risk management process rather than the central topic of third-party risk oversight.


reasoning: The paragraph centers on oversight responsibilities of the Board for cybersecurity risk management and ties this to the enterprise risk management framework, with governance structures referenced (Cybersecurity Committee). The inclusion of named governance bodies and specific reporting lines makes the content firm-specific.


reasoning: This paragraph is generic forward-looking risk/assurance language and a cross-reference to a risk-factor title; it does not describe a specific internal process, named role, incident, framework, or other firm-verifiable details.


reasoning: The paragraph describes the Company’s internal cybersecurity readiness activities (incident response plan, tabletop exercises, business continuity/disaster recovery, risk-based selection of controls, and limitations of security controls). It does not disclose an actual incident or name specific frameworks, tools, roles, vendors, or dates.


reasoning: The paragraph describes the company’s internal cybersecurity workflow (notification, investigation, risk-level assignment, escalation, and reporting) as part of its risk management program, including a specific 24-hour reporting requirement. It is not an incident narrative, nor third-party/vendor oversight; instead it focuses on the company’s own processes and committees.


reasoning: The paragraph describes ABERCROMBIE & FITCH CO's internal cybersecurity policies, control development, recurring risk assessments, and how risks are prioritized and addressed—i.e., its risk management process. It also references specific named security frameworks (CIS Critical Security Controls and PCI DSS) but provides no firm-specific identifiers or quantified facts.


specificity_confidence: low

reasoning: This paragraph is centered on the Audit Committee’s and Board’s oversight responsibilities for cybersecurity and related reporting cadence, with no incident narrative or named firm-specific processes beyond generic governance language.


reasoning: The paragraph describes Alternus’s own cybersecurity risk management approach (controls, assessment processes, policy integration, and quarterly review), rather than an actual incident or vendor oversight as the central topic.


reasoning: The paragraph describes the company’s internal vulnerability/risk management and incident response planning activities (including processes, roles, and escalation), rather than a standalone incident narrative.


reasoning: The paragraph’s grammatical subject is the board/audit committee, describing their cybersecurity oversight responsibilities, meeting/reporting activities, and advising the full board. It also references management’s roles only in the context of supporting that board oversight, so the best single category is Board Governance.


reasoning: This paragraph centers on board and Audit Committee oversight responsibilities, including creation and charter requirements of a Cybersecurity Risk Subcommittee, making it Board Governance. It includes firm-unique governance structure details (a named subcommittee and two independent directors).


reasoning: The paragraph centers on the company’s named cybersecurity executive (CDIO/CISO), reporting line, tenure, and oversight responsibilities, which fits Management Role. It includes multiple firm-specific details (named roles/committee and prior employers) but lacks hard metrics/dates beyond “since 2021,” so it is not Quantified-Verifiable.


reasoning: The paragraph is centered on board/committee oversight and delegation of cybersecurity and privacy enterprise risk responsibilities, including the Audit Committee and a named Cybersecurity Subcommittee.


category_confidence: medium

reasoning: Although the Board/Audit Committee are mentioned, the paragraph’s substantive content centers on how the company’s cybersecurity program is structured and integrated into operations (risk management approach) and the standards it is based on (NIST CSF).


reasoning: The paragraph primarily describes the company’s internal cybersecurity review and monitoring processes (assessments, tabletop exercises, metrics, prevention/detection/mitigation/remediation, and an incident response/notification plan), which fits Risk Management Process more than governance or incident disclosure.


category_confidence: low

reasoning: The paragraph focuses primarily on governance and who is responsible for cybersecurity risk assessment/management, but it does not describe a concrete incident narrative or a named board committee/management role. Because it describes the company’s approach to managing cybersecurity risk (consultants reporting to the board) alongside generic forward-looking statements, Risk Management Process is the closest fit, though the board-oversight language makes category assignment somewhat ambiguous.


reasoning: The paragraph is centered on the company’s own IT Department cybersecurity risk management policies, processes, controls, and how they manage threats and allocate resources. Although it mentions third-party providers and audits, these are components of the internal risk management approach rather than standalone third-party risk oversight.


reasoning: The paragraph is centered on board/committee oversight (Board of Directors and Audit Committee) and describes the board’s reporting cadence and escalation path (quarterly reports and earlier reporting by CEO/CFO). It also includes a company-specific governance flow involving the outsourced managed service provider and the named executive reporting roles, making it firm-specific.


reasoning: The paragraph is centered on specific cybersecurity leadership (Director, IT Infrastructure & Security), reporting lines to named executive roles, and the structure for the cybersecurity program. Although it also mentions processes like the CIRP, the grammatical focus is on management roles and their oversight/reporting.


reasoning: The paragraph describes the company’s own incident detection and response program, including operational plans, reviews, and incident response exercises. It is not an incident disclosure of an actual event or a vendor oversight description.


reasoning: The paragraph centers on the CISO, describing responsibilities, qualifications, and oversight of cybersecurity programs and teams, which fits the Management Role category.


reasoning: The paragraph describes the company’s own cybersecurity education/training and testing activities (phishing simulations, tabletop exercises, preparedness/incident response readiness), which are internal risk management process elements. No firm-unique facts, named tools/products, or specific frameworks/standards are provided.


reasoning: The paragraph describes the company’s own cybersecurity incident identification/response processes, tools, and testing activities (internal monitoring, analytics, and penetration testing). Although it mentions engaging third-party experts, the central topic is VECTOR GROUP’s internal risk management process, not vendor security oversight.


reasoning: The paragraph is primarily a forward-looking limitation on the effectiveness of cybersecurity preventative measures and a general statement about encountering intrusions; it does not describe a specific incident or rely on internal named risk processes. The mention of “Cybersecurity Program” is generic here and the materiality statement is not tied to a specific event or firm-unique details.


reasoning: The paragraph describes the company’s own cybersecurity risk mitigation program (tools, controls, monitoring, incident response procedures, and access controls), which is internal risk management. It also includes firm-specific items like maintaining an ISO 27001 certification and using specific frameworks/standards (NIST, GDPR) to structure that program.


reasoning: The paragraph describes a real cybersecurity incident (user data accessed/downloaded from 23andMe.com accounts) and subsequent response/protective actions, which fits Incident Disclosure. It also includes multiple firm-specific operational details (e.g., password resets, two-factor verification, Security Operations enhancements) tied to the disclosed event.


reasoning: The paragraph focuses on the company’s Information Security team and explicitly identifies the CISO, reporting lines (CISO → CITO → CEO), and detailed qualifications/certifications. These are management/role descriptions rather than an incident or an internal risk process narrative.


reasoning: The paragraph describes governance/oversight via an internal information security council, including its leadership and meeting purpose. Although it centers on the CISO’s role and qualifications, the presence and function of a named information security council makes it closer to governance than purely management.


reasoning: The paragraph focuses on engaging third-party providers and imposing security terms on vendors (incident notification protocols, encryption, data disposal) and using third parties for assessments, which is central to third-party risk oversight.


reasoning: The paragraph is centered on Board-level oversight and specifically describes the Audit Committee’s role in overseeing cybersecurity risk and receiving incident updates, so it fits Board Governance. It does not include firm-unique identifiers, named frameworks, dates, amounts, tools, or external entities, making it effectively generic despite being cybersecurity-specific.


reasoning: The paragraph focuses on materiality/financial impact language (“material information security breaches,” “significant operating expenses”) and does not describe a specific past incident; it also frames incident assessment practices as part of ensuring disclosure if a material event occurs, aligning best with strategy/materiality integration.


reasoning: The paragraph centers on the company’s internal risk management structure (ERM) and describes how cybersecurity inputs (from the CISO/CDO) are incorporated into ongoing risk identification, monitoring, self-assessments, and remediation. This is an internal risk management process rather than incident disclosure or third-party oversight.


reasoning: The paragraph is framed around whether cybersecurity threats/incidents have materially impacted (and may in the future affect) business strategy, results of operations, and financial condition, making it primarily strategy/financial integration rather than process or incident details.


reasoning: The paragraph discusses materiality/financial impact of cybersecurity risks and states no material incident has occurred, along with a forward-looking caveat; it does not describe an actual incident narrative or internal risk process.


reasoning: The paragraph describes the company’s own cybersecurity risk management program and how it is designed/assessed, including named internal practices (risk management) and frameworks. Because it names recognized standards (NIST CSF) and Sarbanes-Oxley but contains no other company-unique facts, it is Sector-Adapted rather than Firm-Specific.


reasoning: The paragraph describes the company’s (via Longbridge) own internal cybersecurity assessments and ongoing practices such as patch/vulnerability management, access controls, DR/BC considerations, and threat monitoring—i.e., risk management processes rather than board oversight, a named role, a standalone incident, or third-party risk requirements.


reasoning: The paragraph focuses on Aptar’s internal risk management activities (training and its processes for assessing/monitoring third-party providers and using its Information Security Department), which is primarily an internal risk management process rather than a standalone incident or pure third-party-only governance requirement.


reasoning: This paragraph is general forward-looking risk-factor language with no substantive description of the company’s cyber governance, management roles, internal processes, third-party oversight, or any actual incident.


reasoning: The paragraph describes the company’s own cybersecurity risk management processes (assess, identify, and manage risks on its IT systems) rather than a specific incident, board oversight, or third-party controls. It contains no named frameworks, roles, dates, or other verifiable firm-specific details beyond generic references to industry standards.


reasoning: The paragraph describes the company’s internal information security evaluation, training, and refinement processes, with external experts mentioned as part of those internal activities. There is no named role, framework, date, or specific system/tool, and no central focus on vendor requirements.


reasoning: The paragraph describes the company’s internal cybersecurity risk assessment and management approach, including alignment to a named framework and integration into its ERM program. Board/management oversight is mentioned, but the substance focuses on the risk management processes and evaluation approach.


reasoning: The paragraph is explicitly about board/committee oversight of cybersecurity risks, including how often the Board and Audit Committee meet with the CSO and what they review.


reasoning: The paragraph describes a real cybersecurity incident, including unauthorized access by a third party, the company’s response actions (incident response/business continuity protocols and containment), and business disruption and ongoing investigation.


reasoning: The paragraph centers on named cybersecurity management roles (VP of IT/Information Security Officer), their specific responsibilities, reporting/updating relationships (to CFO and Audit Committee), and committee composition.


reasoning: The paragraph describes a real incident, including when it was detected, unauthorized access, the company’s response actions (investigate/contain/remediate, external experts, law enforcement), and specific affected systems (financial and operating reporting systems) with operational disruptions.


reasoning: The paragraph primarily describes the company’s own planned cybersecurity risk management program and processes (identification/assessment/treatment, monitoring, assessments, vulnerability management, and reviews), which fits Risk Management Process. Although it mentions Board oversight and the absence of an Audit Committee, the main subject is the company’s internal risk program rather than governance or a disclosed incident.


reasoning: The paragraph describes an actual cybersecurity incident (nation-state access and exfiltration beginning late November 2023) and adds ongoing investigation details plus impacts on employee email accounts, source code repositories, and internal systems.


reasoning: The paragraph describes an actual cybersecurity incident, including unauthorized access, containment actions, business disruption, and remediation status, anchored to a specific date.


reasoning: This paragraph describes a real cybersecurity incident, including when it was discovered, what systems were accessed, what data fields were targeted, and the company’s stated evidence-based limitations and continuing investigation.


reasoning: The paragraph describes a real cybersecurity incident (nation-state access and exfiltration from employee email accounts), includes key dates, describes response actions (removing access), and provides impact/materiality statements. The presence of specific dates (Jan 12 and Jan 13, 2024) plus additional verifiable incident facts supports Quantified-Verifiable specificity.


reasoning: The paragraph describes an actual cybersecurity incident (detected unauthorized access on May 6, 2024) and the company’s response actions, plus operational impact (disruptions and limited access to financial/operating reporting systems), which fits Incident Disclosure.


reasoning: The paragraph describes an actual cybersecurity/data incident (what a former employee obtained), provides scope of affected accounts (up to 33 million), states what was not obtained (banking/payment/login), and discusses investigation and regulator-initiated inquiries and inability to estimate penalty losses.


reasoning: This paragraph centers on the company’s Chief Information Security Officer (organizational placement, qualifications, and reporting/oversight lines), making it a management-role disclosure rather than an incident or process description.


reasoning: This paragraph describes the status and operational impact of an actual cybersecurity incident (restoration of access, stolen/destroyed data, and specific affected business functions like billing/label making), which fits Incident Disclosure.


reasoning: The paragraph describes a specific unauthorized access incident with dates, threat actor behavior, and exfiltration of client/PII and administrative/user data, including response actions (incident response process) and reporting.


reasoning: The paragraph discusses materiality and expected costs/impact of a cybersecurity incident on financial results, without providing an incident narrative, specific systems/data scope, or dates. It functions as a forward-looking material impact assessment rather than incident disclosure details.


reasoning: This paragraph is a standard forward-looking statements safe-harbor/disclaimer with no concrete description of an incident’s specifics, scope, timeline, affected systems, or financial impact details.


reasoning: This paragraph describes the scope and nature of the affected data (what it contains/does not contain and what records are included) in the context of an apparent cybersecurity incident, making it incident disclosure.


reasoning: The paragraph narrates an actual cybersecurity incident and describes response actions and scope (third-party environment), along with specific affected data elements (names, DOB, SSN/tax IDs) and customer notification outcomes.


reasoning: The paragraph describes a real cybersecurity incident (illegal access, production halts, data exfiltration) and associated operational/data impacts and follow-on notifications, which is characteristic of incident disclosure.


reasoning: The paragraph describes an actual cybersecurity incident (defaced website), provides incident timeline and actions taken (restoration attempts, taking the site down, temporary page) and specifies affected web address/web platform.


reasoning: The paragraph describes an ongoing investigation into a real cybersecurity event (data exfiltration) and provides impact-related details (exfiltrated clients’ files and personal information scope), along with response actions (expert evaluation, client notifications, assessment of public release).


reasoning: This paragraph describes a real cybersecurity incident with exfiltration details (video meeting/screen images), extortion threats, response actions, and potential operational and financial impact tied to a specific fiscal quarter.


reasoning: The paragraph describes a specific, real incident (system outage) tied to a cybersecurity attack, including what attackers did (accessed network, encrypted critical applications, exfiltrated files) and the operational impact (delayed billing/collections/payments) with restoration timing.


reasoning: The paragraph focuses on the Company’s preliminary financial estimate of incident-related expenses (remediation and customer reimbursements) and notes ongoing assessment, but it does not describe the underlying incident events or technical/operational scope. That aligns with financial/strategy impact disclosure (Strategy Integration) rather than incident narrative (Incident Disclosure).


reasoning: The paragraph describes a specific incident (date detection, unauthorized activity, encryption and data theft) and includes response actions and operational/fulfillment disruption, which is characteristic of an incident disclosure.


reasoning: This paragraph focuses on materiality conclusions and potential financial impacts (insurance coverage and possible uncovered costs), without describing what the cybersecurity incident actually did or its affected systems/data.


reasoning: The paragraph describes the effects of a cyber incident (system shutdown causing disrupted replenishment, order fulfillment delays, cancellations, reduced e-commerce demand, delayed wholesale shipments) and provides status updates on restoration and residual impacts.


reasoning: The paragraph describes a specific unauthorized-access incident (notification date, threat actor names, targeted system) and provides incident response actions plus data exfiltration scope and timeframe (May 2023).


reasoning: The paragraph describes the incident’s business/financial impact (materiality to results and earnings) and ties it to operational effects since specific dates, which is characteristic of disclosed cyber incidents rather than general risk processes.


reasoning: The paragraph narrates a real cybersecurity incident (unauthorized access to file systems) and describes response actions, containment, and operational interruption (temporary network business interruption). It includes a specific date and named subsidiary/entities, making it firm-specific rather than generic.


reasoning: This paragraph describes an ongoing investigation tied to a specific security incident and characterizes impacts (website offline, delayed IT communications) and data/scope outcomes (no apparent material impact to IP; no apparent access to customer/stakeholder proprietary information).


reasoning: The paragraph describes an actual incident’s operational impacts, containment/remediation status, and provides a specific cost estimate with a dated reference, indicating incident disclosure rather than general risk or strategy language.


reasoning: The paragraph describes a specific cybersecurity incident (systems disrupted/taken offline), the cause discovered, impacts to email communications, and the restoration/reinstatement timeline with dates.


reasoning: The paragraph discusses materiality and expected financial impacts (costs, revenue loss from digital sales during recovery, insurance offset, and lack of long-term impact) without describing what happened in the incident.


reasoning: The paragraph narrates a specific cybersecurity incident, including what happened (unauthorized occurrences), key response actions (containment/remediation, investigation, incident response plan, system shutdown), and an outcome/scope timing (threat actor ejected) with specific dates.


reasoning: The paragraph focuses on expected financial/materiality impact of the incident on specified reporting periods and references prior guidance from a dated press release, which is characteristic of Strategy Integration rather than incident narrative or governance/process details.


reasoning: The paragraph’s main decision point is the materiality conclusion (no material impact and not reasonably likely to have one) and the expectation of insurance reimbursement, without providing an incident narrative or operational scope. While it mentions remediation steps, the emphasized disclosure is financial/material impact and reimbursement terms, aligning best with Strategy Integration.


reasoning: The paragraph describes a real cybersecurity incident at CDK and the resulting operational impacts and remediation (access restored; disruptions during July) on specific Company systems/applications (DMS, CRM, customer lead/inventory integrations).


reasoning: This paragraph is about liquidity/capital obtained by waiving payments to fund remediation, with explicit dollar amount ($3.7M) and specific financing documents and dates, but it does not narrate what the cybersecurity incident did.


reasoning: The paragraph describes an actual incident (unauthorized occurrences), the attacker’s action (encrypting data files), containment/response steps (investigation, activating an incident response plan, shutting down systems), and operational/data-impact details (manufacturing facilities not operating, order fulfillment impacted, customer personal information not believed compromised).


reasoning: The paragraph focuses on financial/operational impact of an incident (delayed revenue recognition, loss of revenue due to provider changes, and one-time expenses) rather than describing what happened in the incident itself. It primarily addresses timing and revenue/expense effects, fitting Strategy Integration.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access), the company’s response steps, and includes the incident detection date, making it incident disclosure rather than general risk management. It also references prior disclosure tied to a specific filing date.


reasoning: This paragraph describes a specific ransomware incident, including when it occurred and its cause, and summarizes recovery/investigation and whether additional actions are needed—core elements of incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident with a detection date, response actions (incident response/business continuity, isolating network), and resulting operational/business-process disruption, along with notifications to regulators and law enforcement.


reasoning: This paragraph describes an actual cybersecurity incident (unauthorized third-party access), containment/response actions (IR plan activation, taking systems offline), notifications (federal law enforcement), and operational impact (temporary halt and restarting production). It is therefore incident disclosure rather than a general risk-management or boilerplate statement.


reasoning: The paragraph narrates a specific ongoing incident with dates (disruptions since June 19, 2024), identifies affected systems (DMS, CRM), and describes restoration/offline status, which are core incident-disclosure elements.


reasoning: The paragraph describes operational impact from a cybersecurity incident (shutdowns, disruption duration, restoration) and specific remediation actions taken, and it includes statements about the unauthorized party’s access.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation, identifies the access/exfiltration scope and what data was involved (customer/employee PII), and states notification and law enforcement actions—hallmarks of Incident Disclosure.


reasoning: The paragraph describes ongoing investigation of a specific cybersecurity incident, includes findings about whether customer/client data was accessed, and provides impact/materiality statements on operations and financial condition.


reasoning: The paragraph is centered on the company’s Chief Technology Officer and their responsibilities and reporting relationships regarding cybersecurity risk management, which fits Management Role. It also includes a firm-specific quantified experience detail (over 15 years) and named internal roles (CTO, General Counsel).


reasoning: This paragraph describes a specific cybersecurity incident with a dated discovery (October 15, 2025), includes response actions (IR activation, law enforcement notification, external experts), and states impact to business applications/IT access and remedial containment efforts.


reasoning: The paragraph is materiality/risk framing language about whether cybersecurity risks have materially affected the company and includes a cross-reference to Item 1A, but it does not describe a specific incident or internal risk-management process.


reasoning: The paragraph describes a real cybersecurity incident, including when it was detected (May 6, 2024), what was accessed, the response actions taken, and the operational impact (disruptions/limited access to financial and operating reporting systems).


reasoning: This paragraph is a cross-reference to the Risk Factors section and contains no substantive cybersecurity process, governance, incident, or strategy information.


reasoning: The paragraph describes the company’s internal cybersecurity risk management being integrated into enterprise risk management, including review frequency and mitigation processes, with specific management roles (CISO/CIO) involved.


reasoning: The paragraph describes an ongoing real-world cyberattack, specifies impacted services (pharmacy, medical claims, payment services), and includes investigation of impacted data and restoration of services, which is characteristic of Incident Disclosure.


reasoning: The paragraph centers on identified management/security leadership roles (CIO, Information Security Director) and their responsibilities and experience, making it a management-role disclosure rather than governance or incident/process description.


reasoning: The paragraph describes internal activities to manage cybersecurity threats (protect, respond to incidents) and to comply with data protection laws, but it does not identify any named roles, tools, dates, frameworks, or company-specific programs.


reasoning: The paragraph states the company has not experienced material cybersecurity incidents and that related expenses were immaterial, with a general note about contracting an investigation firm. There is no described real incident narrative or governance/management/process being detailed with firm-specific identifiers.


reasoning: The paragraph describes the company’s (Adviser’s) internal cybersecurity controls and procedures for identifying, classifying, escalating, and managing incidents. It does not provide specific frameworks, roles, dates, or verifiable firm-specific facts, making it generic boilerplate.


reasoning: The paragraph describes a real cybersecurity incident (detection, containment/remediation actions) and includes operational impact (service delays in Canada, recovery timing). The presence of a specific incident date and incident scope makes it firm-specific, though it lacks two hard independently-verifiable quantitative facts.


reasoning: The paragraph describes the company’s own cybersecurity risk management program (identify/assess/manage/mitigate) and how policies/controls are designed and integrated, including use of the NIST framework. Although it names a Global CISO and CDRM organization, the core subject is the internal risk management process.


reasoning: The paragraph’s grammatical subject is the chief financial officer and describes cybersecurity responsibilities and reporting. It also names the Nomination and Corporate Governance Committee as the board-related recipient, making this primarily a management/cyber governance role disclosure rather than an internal risk process or third-party risk.


reasoning: The paragraph is centered on the Audit Committee’s role in overseeing cybersecurity risk, with board/committee oversight as the grammatical subject. While it mentions specific parties (Audit Committee, CFO, senior IT leadership), it does not provide firm-unique details, named tools/frameworks, or quantified/verifiable facts beyond standard governance language.


reasoning: The paragraph is explicitly about board-level oversight, including delegation to a named board committee and reporting/approval cadence for cybersecurity governance.


reasoning: The paragraph is centered on a named individual (Mr. Gharib) describing his management responsibilities for cybersecurity and risk strategy integration, budgeting, incident preparation, and review of security reporting.


reasoning: The paragraph is explicitly about board and audit committee oversight of cybersecurity risk management. However, it contains no company-specific roles, dates, tools, frameworks, or quantified facts, making it effectively boilerplate despite mentioning “audit committee.”


reasoning: The paragraph primarily describes Apollo's internal cybersecurity risk management integration into its ERM framework and cites NIST/ISO-based standards, which is an internal process topic. Although the AGM board is mentioned, it is used as part of describing oversight of the risk management program rather than focusing on board governance mechanics alone.


reasoning: The paragraph describes the company’s internal incident response policy, incident handling procedures, escalation process, and mitigation/remediation activities. It also names internal governance structures (Incident Management Team, disclosure committee, Privacy and Security Subcommittee), making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes the company’s own internal cybersecurity risk assessment and mitigation approach (assessments, risk measurement/prioritization, and incident response plans) without referencing a board/committee, a specific management role, a named framework, or an actual incident.


reasoning: The paragraph centers on materiality/financial impact conclusions and discusses updates to the Bank’s information security strategy as part of overall business/financial considerations, without describing a specific incident event narrative.


reasoning: The paragraph focuses on named cybersecurity and technology leadership roles (CISO and CTO) and describes qualifications, tenure, and experience, which is management role disclosure rather than governance or process.


reasoning: The paragraph describes how material cybersecurity risks are managed through the company’s enterprise risk management process and decision-making, including coordination with a named cybersecurity role (CSO).


reasoning: The paragraph describes the company’s own cybersecurity risk management activities (training, awareness, testing, penetration testing, and assessments) rather than an incident narrative or board-level oversight. The presence of the named internal “Cybersecurity Team” makes it firm-specific compared with generic disclosure.


reasoning: The paragraph focuses on the company’s internal cybersecurity program integration into its own risk management and related programs (ERM, business continuity/crisis management, third-party risk management, insurance risk management, and employee compliance). While it mentions third-party risk, the central topic is how the company integrates and operates its internal processes, not vendor oversight as the primary subject.


reasoning: The paragraph is focused on risk of cybersecurity threats and whether any incidents have materially impacted the business, including mention of spending on cyber insurance costs, without describing an actual incident or internal risk-management processes.


reasoning: The paragraph provides a materiality-style conclusion about whether cybersecurity threats could affect strategy/results/financial condition and contains general risk caveats, without describing incidents or identifiable firm-specific security practices.


reasoning: The paragraph’s central focus is the Company engaging external experts/third parties to evaluate and test its cybersecurity risk management activities, including audits and threat assessments. It describes vendor-type oversight as the main topic rather than internal risk management alone.


reasoning: The paragraph describes the company’s own cybersecurity risk management program activities (committee briefings, employee training, and security policy coverage). It is not an incident narrative or a standalone strategy/materiality statement, and third-party/vendor oversight is only mentioned as a policy topic within the internal program.


reasoning: The paragraph provides materiality conclusions (no material cybersecurity incidents; incident expenses/penalties/settlements immaterial; none occurred) and cross-references Risk Factors, but contains no incident narrative or named frameworks/roles/processes.


reasoning: The paragraph describes the company’s internal processes for assessing/identifying/managing cybersecurity risk, but contains no named roles, frameworks, standards, dates, or other firm-specific details beyond generic statements and cross-references.


reasoning: The paragraph centers on a specific individual (Jack Wang) and his responsibilities, qualifications, and reporting lines for cybersecurity risk and incident reporting, which is management-role disclosure rather than incident narrative or risk-process detail.


reasoning: The paragraph’s primary subject is the Board/Audit Committee oversight process for cybersecurity, including board briefings and continuing education. It is specifically tied to board governance functions and names OMNICOM’s CIO/CISO/CIRO presenters.


reasoning: The paragraph’s grammatical subject is the Board of Directors/Audit Committee and it describes their responsibilities and briefing cadence regarding cybersecurity oversight. It is not centered on management roles or internal risk processes as the primary subject.


reasoning: The paragraph describes FutureFuel Corp.’s own incident response plan and the internal processes it includes (triage, severity assessment, investigation, escalation, containment, remediation), which is central to its risk management approach.


reasoning: The paragraph describes the company’s internal cross-functional process for identifying, preventing, mitigating, and escalating cybersecurity incidents, and references incident controls/procedures. It does not provide incident details, material financial impact, named roles, or specific frameworks/tools beyond generic concepts.


reasoning: The paragraph centers on specific management roles (Vice President of Information Systems and Chief Financial Officer) and describes their tenure, oversight responsibilities, and related cybersecurity risk qualifications/certifications.


reasoning: The paragraph provides a materiality conclusion about cybersecurity risk (no known threats materially affected the company) and refers to risk factors elsewhere, without describing any incident or internal risk management processes.


reasoning: The paragraph centers on responsibility and reporting structure for the IT department directed by the Chief Financial Officer and reporting cadence to the Audit Committee, with management roles being the grammatical focus.


reasoning: The paragraph is primarily focused on specific cybersecurity and technology leadership roles (CISO/CTO) and their reporting and responsibilities. While it mentions third-party consultants, the central topic is management role assignment and oversight rather than third-party risk management.


reasoning: The paragraph’s primary grammatical subject is the board of directors, describing its oversight role over the cybersecurity risk management program and incident reporting to the audit committee.


reasoning: This paragraph is a cross-reference to a risk-factor section and does not provide substantive cybersecurity process details, governance, incident facts, or strategy/materiality conclusions.


reasoning: The paragraph is centered on the Board establishing and leveraging a standing Cybersecurity Committee for oversight of cybersecurity risk, including details about the committee chair.


reasoning: The paragraph describes the company’s own internal audit program and an annual risk assessment that includes evaluation of cybersecurity risks and reporting to business-team leaders. It contains no named frameworks, tools, external firms, specific dates, dollar figures, or unique program identifiers.


reasoning: The paragraph describes the company’s own internal cybersecurity testing/review activities (how it manages control effectiveness), with third parties as an implementation component rather than as the central subject of vendor oversight. No named vendors, tools, standards, or specific dates are provided, making it non-firm-specific.


reasoning: The paragraph primarily describes the company’s internal cybersecurity preparedness activities (crisis simulation and augmenting monitoring/detection/IR/forensics), which are part of its risk management process. Third parties are mentioned but mainly as enablers of the company’s own cyber program rather than as a standalone vendor-risk governance topic.


reasoning: This paragraph is general forward-looking boilerplate about cybersecurity limitations and insurance, with no board/management/process details, no incident narrative, and no named facts beyond a cross-reference to Item 1A.


reasoning: The paragraph’s primary focus is the company’s third-party risk management, including evaluating risks from vendors/suppliers and handling third-party cybersecurity compromise incidents. It does not name any specific frameworks, dates, roles, tools, systems, or external firms.


reasoning: The paragraph is general forward-looking risk framing about the importance of cybersecurity and potential impact, without describing internal processes, governance actions, named roles, or any actual incident.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach and its integration into its Enterprise Risk Management process, focusing on identifying and managing cyber risk. It contains no named roles, frameworks, dates, or other verifiable company-specific details.


reasoning: The paragraph is centered on the Board and its delegated oversight to the audit committee, including review responsibilities and reporting cadence for cybersecurity risk.


reasoning: The paragraph is explicitly about Board and Audit Committee oversight of cybersecurity risk (board/committee described as the grammatical subject). It contains no uniquely identifying company facts beyond generic governance structure and does not name specific roles (e.g., CISO), tools, dates, or quantified details.


reasoning: The paragraph is about board and Audit Committee oversight of cybersecurity risks, briefing cadence, and reporting, making it Board Governance.


reasoning: The paragraph describes the company’s own risk management processes (assessing and incorporating third-party-related cyber threat risks) rather than making vendor oversight the central topic. It contains firm-specific process descriptions tied to the company’s third-party provider selection/oversight.


reasoning: The paragraph describes the company’s internal cybersecurity risk management processes and their integration into overall risk management, but it does not provide any firm-specific details beyond generic governance and process descriptions.


reasoning: The paragraph describes the company’s internal cybersecurity measures and processes (e.g., incident response planning, disaster recovery/business continuity, risk assessments, encryption, monitoring, and training) without focusing on a board role or a disclosed incident.


reasoning: The paragraph describes the company’s internal cybersecurity incident prevention/detection/mitigation processes (monitoring, severity assessment, and escalation within its incident response plan). While “Board” and “Committee” are generic, the presence of a named management role (Senior Vice President, IT Operations) and an embedded incident response plan makes it firm-specific.


reasoning: The paragraph describes the company’s internal cybersecurity risk controls (cyber insurance coverage review and continuity/DR and incident response readiness testing), which are part of its risk management process rather than an incident or third-party vendor oversight.


reasoning: The grammatical focus is on the specific cybersecurity leader (Director of Cybersecurity), including responsibilities, experience, reporting/update flows, and named internal stakeholders, which aligns most directly with a management-role description.


reasoning: The paragraph describes general internal processes related to overseeing cybersecurity risks associated with third-party services, but it does not provide incident details, named roles/tools/frameworks, or any firm-specific verifiable facts. The forward-looking statements and lack of incident narrative indicate boilerplate risk-management language rather than an incident or board/management-specific disclosure.


reasoning: The paragraph focuses on the company’s own cyber risk management approach—implementing a named framework and adopting internal policies to align with regulatory guidance.


reasoning: The paragraph describes the status and materiality-related impact of a cybersecurity incident (scope unknown, ongoing material impact on business operations), even though it does not provide incident specifics. No named entities, dates, tools, frameworks, or quantified impacts are included.


reasoning: The paragraph describes Western Digital’s internal processes for handling incidents, including its Security Operations Center, severity matrix/tier approach, triage, and notification/escalation—i.e., the company’s risk management operations.


reasoning: The paragraph describes a real cybersecurity incident (illegal access and encryption of data) and includes response actions taken (containment, remediation, internal investigation, engaging specialists, restricting IT access). It also provides a specific incident date, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes a real cybersecurity incident (detection on May 1, 2024) and includes response actions such as investigation with external cybersecurity experts, activating an incident response plan, shutting down portions of IT systems, and notifying law enforcement.


reasoning: The paragraph describes the company’s internal cybersecurity measures and processes (e.g., detection/response, vulnerability management, DR/BC, risk assessments) to manage cybersecurity risk. Vendor risk management is mentioned only as one element within the broader internal risk-management discussion rather than as the central focus.


reasoning: This paragraph discusses findings from an ongoing investigation into a cybersecurity incident (e.g., whether malware/ransomware/data alteration occurred and whether the threat actor has access) and describes continued investigation into scope/impact.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized activity) and the Company’s response actions, including a specific containment step with a date (isolating systems from the Internet on December 20, 2023).


reasoning: This paragraph discusses the expected business/operational and financial materiality of the incident (quarter ended December 31, 2024; no material impact on full year 2024 results) without describing what happened or incident scope, which fits Strategy Integration.


reasoning: This paragraph discusses an ongoing cybersecurity incident’s status (material impact and likelihood of financial impact) and response actions (cooperation with law enforcement and regulatory notification assessment), which fits incident disclosure despite lacking incident narrative details.


reasoning: The paragraph describes the company’s own vulnerability assessment and vulnerability management processes (review cadence, internal/external environment evaluation, preventative measures). It contains no named frameworks, tools, roles, dates, or other firm-unique facts, so it is generic boilerplate.


reasoning: The paragraph describes the Company’s internal cybersecurity practices and operating processes (tools, disaster recovery/tabletop exercises, training, phishing testing, and penetration testing activities). No board/management roles, third-party oversight as the central focus, or any actual incident narrative is described.


reasoning: This paragraph describes an actual cybersecurity incident (threat actor access and exfiltration) and includes incident-related scope (limited data including PII) plus ongoing notification actions.


reasoning: This paragraph describes incident response actions (“contain and remediate”) and provides incident scope/impact outcomes (no compromise of systems, no unauthorized transactions, no funds transferred, and continued member transactions), which is characteristic of incident disclosure.


reasoning: This paragraph is a standard forward-looking statements disclaimer with no cybersecurity substance, governance/process details, incidents, or named roles/frameworks/tools.


reasoning: The paragraph describes an actual cybersecurity incident, including detection date, response actions taken (incident response/business continuity, disrupting activity, investigation), and notifications/regulatory and law enforcement engagement, along with a statement that the impact has been contained.


reasoning: This paragraph describes an actual cybersecurity incident’s operational impacts (distribution delays, partial online limitations) and provides incident-related scope (core vs. weekly/ancillary products) with a specific date and a quantified revenue percentage.


reasoning: The paragraph describes an actual cybersecurity incident, including unauthorized access and encryption of data files, along with response actions taken by the Company, anchored to a specific date.


reasoning: The paragraph discusses an active cybersecurity incident and provides materiality-style statements about operational and financial impact, which is incident-related disclosure. However, it contains no named systems, dates, or quantified impacts beyond generic materiality language, making it boilerplate-level specific.


reasoning: This paragraph describes an actual cybersecurity incident and its operational impact (shipping/receiving/manufacturing support), along with preliminary findings that files were taken and related response actions.


reasoning: This paragraph ties a specific disclosed Incident to a material business/operations impact and provides quantified financial effects on GAAP diluted EPS for Q2 ended June 30, 2024.


reasoning: The paragraph describes ongoing results of an investigation into an exfiltration event, including what additional data was exfiltrated and the types of data (PII/PHI) impacted, which is characteristic of incident disclosure.


reasoning: This paragraph does not describe what happened in the incident; it only states that expenses may be incurred and that the Company believes the incident will not have a material financial impact, along with generic risk consequences.


reasoning: The paragraph focuses on financial/materiality impacts and related expenses from an incident event (i.e., costs, notification-related accruals) rather than describing what systems/data were affected or the incident narrative.


reasoning: The paragraph provides a materiality conclusion about the cybersecurity incident’s lack of material impact on business operations and financial condition/results, without describing what occurred or any technical/process details.


reasoning: The paragraph describes the scope/subject matter of exfiltrated data as part of an apparent cybersecurity incident disclosure and ties it to the company’s 10-K reporting timeline.


reasoning: The paragraph describes a reported cybersecurity incident’s alleged data theft based on a preliminary investigation and provides specific scope/details of potentially affected data (including a quantified consumer count and which data types were not involved).


reasoning: This paragraph describes an incident’s timeline and scope (unauthorized access and exfiltration of SharePoint files) and the Company’s response actions (investigation, containment, remediation) along with a materiality conclusion about impact.


reasoning: This paragraph describes a specific, actual cybersecurity event (a ransomware incident) including key response actions and subsequent planned notifications, which is characteristic of incident disclosure.


reasoning: This paragraph describes an actual cybersecurity event (unauthorized activity) and the company’s response actions (contain, assess, remediate, and isolating systems). It also includes a specific incident-related date (December 20, 2023), making it incident disclosure rather than a general risk-process description.


reasoning: This paragraph discusses an ongoing cybersecurity incident and its (non-)materiality, including operational and financial impact statements, which is incident-focused even though it provides no incident specifics beyond that it is limited to the Dropbox Sign infrastructure.


reasoning: This paragraph describes ongoing response to a real cybersecurity-related disruption (network interruption), including restoration efforts and scope (Change Healthcare systems affected; other systems operational), which is characteristic of incident disclosure.


reasoning: This paragraph references an already-described incident and includes materiality/financial-impact assessment language, but provides no incident specifics (no dates, systems/data, scope, or measurable impact), making it largely boilerplate. It is categorized as Incident Disclosure because it is explicitly tied to the Incident and the company’s materiality conclusion.


reasoning: This paragraph describes actions taken after becoming aware of a cybersecurity incident (investigation, mitigation, and notifications) and references unauthorized access to personal information, which constitutes incident disclosure. It contains no uniquely verifiable company-specific facts (no dates, tools, systems, or named firms).


reasoning: The paragraph describes an incident disclosure context with DOJ findings about delayed public disclosure, ongoing law-enforcement efforts, an apprehension outcome, and the status of whether data is publicly available.


reasoning: This paragraph narrates a real cybersecurity/operational incident (date, unauthorized access by a threat actor), describes incident response actions (activated a cybersecurity response plan with external experts, contained/assessed/remediated), and includes operational impact (restored within days/hours and no material impact).


reasoning: The paragraph provides financial impact (additional expenses and lost/undeliverable revenue) attributed to a cybersecurity incident but does not describe the incident’s events, timeline, or affected systems/scope. That makes it best categorized as strategy/financial integration rather than incident disclosure.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access) and includes incident response actions (activating the incident response plan) with a specific discovery date, so it fits Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity), the response actions taken (contain/assess/remediate, isolate from the Internet), and the status (contained/resumed operations), including a specific incident date.


reasoning: This paragraph describes a specific cybersecurity incident (unlawful access and exfiltration of call/text logs), including what was accessed/exfiltrated and the relevant timeframes, which fits Incident Disclosure.


reasoning: The paragraph describes an ongoing cybersecurity incident, including exfiltration of certain files, investigation into whether personal information was exfiltrated, and consideration of legal/regulatory notifications tied to the incident.


reasoning: The paragraph is tied to a disclosed cybersecurity incident and includes impact/materiality statements about financial results and operational disruption, which is incident-focused disclosure rather than generic boilerplate.


reasoning: This paragraph describes an actual cybersecurity incident, including unauthorized access, deleted emails, and operational/financially relevant details about a misdirected wire payment that was not recovered.


reasoning: This paragraph is a standard forward-looking statements disclaimer with no cybersecurity substance, governance/process details, incidents, or named frameworks/roles.


reasoning: This paragraph describes an actual cybersecurity incident (unauthorized third-party access) and specifies affected data types and the approximate number of users impacted, along with stated findings about what was not compromised.


reasoning: The paragraph narrates an actual cybersecurity incident, including detection date, response actions (containment, investigation, incident response plan activation, system shutdown), and an asserted outcome (threat actor ejected on July 10, 2024).


reasoning: The paragraph describes a real cybersecurity incident (unauthorized access) and includes response actions (investigation, law enforcement notification) plus asserted impact/scope (core financial and operational systems). It also provides a specific incident awareness date.


reasoning: This paragraph describes a real cybersecurity event (data exfiltration) and the company’s incident response actions (containment and investigation). It also states potential scope of impact by noting the data may contain personal information.


reasoning: This paragraph explicitly updates information about a disclosed cybersecurity incident (the Change Healthcare cyberattack) and references the Company’s press release describing data assessment, notifications/support, and service restoration progress, which are incident-related response details. It also includes a specific date (April 22, 2024) and a named exhibit attachment.


reasoning: This is a forward-looking materiality assessment stating the incident has not had (and is not reasonably likely to have) a material impact on financial condition and results of operations, without describing incident details or response actions.


reasoning: The paragraph describes the financial and operational impact of a specific cybersecurity incident (expenses, lost production duration, and materiality timing/scope), which is characteristic of incident disclosure rather than general risk management.


reasoning: This paragraph describes a real cybersecurity event (detection on/around February 14, 2026) and related response actions (assess/contain/remediate, isolating systems, investigating with external advisors), which fits Incident Disclosure.


reasoning: This paragraph describes actions taken after discovering an actual cybersecurity incident (activation of response protocols, containment by taking the network offline, investigation, restoration/monitoring, and notification steps), which constitutes incident disclosure. It also includes a specific jurisdictional detail (Singapore).


reasoning: The paragraph describes response actions taken in response to a cybersecurity incident (contain the threat, enhance security posture, increase monitoring, review access controls, engage experts, and notify authorities), which is characteristic of incident disclosure even though it lacks firm-specific details.


reasoning: The paragraph describes response actions to unauthorized activity (activating a cybersecurity response plan, taking systems offline, notifying law enforcement, restoring systems, and assessing impacted data), which is substantive incident disclosure.


reasoning: The paragraph focuses on the company’s internal operating/process approach (Halliburton Management System and process-based safety standards) while noting work to identify incident effects, but it does not narrate the incident (what happened, scope, or impact details) required for Incident Disclosure.


reasoning: The paragraph provides a materiality/financial impact assessment (no material impact; not reasonably likely to materially affect financial condition or results) without describing what happened or operational scope of an actual incident.


reasoning: The paragraph narrates a real cybersecurity incident (ransomware, file encryption, and later unauthorized disclosure) with dates and describes management’s evolving materiality conclusion, which squarely fits incident disclosure.


reasoning: The paragraph describes post-incident remediation outcomes (third party removal, restoration of access, and confirmation of data integrity), indicating an actual cybersecurity event and response status.


reasoning: This paragraph describes the cybersecurity incident’s impact and states what data types were affected (and what was not compromised), which is characteristic of incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (data exfiltration) with a concrete date and notes containment actions and an investigation, which squarely fits incident disclosure requirements.


reasoning: This paragraph discusses remediation and ongoing efforts to prevent further unauthorized activity, but it does not describe a concrete incident narrative or provide incident scope/impact details. It is focused on the company’s response/remediation process rather than board oversight, a named management role, or vendor requirements.


reasoning: This paragraph is a legal/filing disclaimer about whether the information is considered filed or incorporated by reference. It contains no cybersecurity substance, incident details, governance, or risk process information.


reasoning: The paragraph provides a materiality conclusion about the cyber incident’s impact on financial condition and results of operations, without describing incident facts or response steps. That aligns best with Strategy Integration materiality framing (though it references an ongoing investigation).


reasoning: The paragraph describes internal cybersecurity risk management procedures being integrated into the company’s enterprise risk management program, but it provides no named frameworks, roles, dates, systems, or other firm-specific details.


reasoning: This paragraph is a forward-looking disclaimer about potential cybersecurity incidents and directs the reader to another section for risk factor discussion. It contains no company-specific cyber details, named roles, frameworks, dates, incidents, or measurable facts.


reasoning: The paragraph’s grammatical subject is the board and its audit committee/executive leadership updates regarding cybersecurity risk oversight, which is classic board governance language. It contains no firm-unique identifiers, named tools/standards, or verifiable metrics beyond generic cadence and roles.


reasoning: The paragraph describes the company’s internal cybersecurity risk management process for evaluating vendors (how they evaluate), not vendor oversight as the central topic. It includes firm-specific description of their vendor evaluation criteria (criticality and size) and mentions external partner review.


reasoning: The paragraph discusses general dependence on software and infrastructure, including contractors and vendors, but does not describe a specific cyber risk management program, framework, or vendor security requirements as a central topic.


reasoning: This paragraph describes oversight and reporting flows between a board committee, management, and the full Board concerning cybersecurity risks and incidents, which is board-governance subject matter. It does not name any cybersecurity-specific roles/committees, dates, frameworks, or other firm-unique details beyond generic governance language.


reasoning: The paragraph ties an ongoing incident involving Targus to operational disruption and includes a materiality conclusion regarding financial impact and which parts of the business were affected, which fits Incident Disclosure.


reasoning: The paragraph identifies a cybersecurity-specific management role (Group Head, Cybersecurity/Information Security Officer) and describes qualifications/reporting scope. It is firm-specific due to Envestnet onboarding timing and explicit experience tenure.


reasoning: The paragraph is explicitly about board/committee oversight of cybersecurity risk management and internal controls, making it Board Governance. It contains no firm-unique entities, dates, tools, or other verifiable specifics beyond standard governance language, so specificity is treated as generic.


reasoning: The paragraph describes general internal cybersecurity and resiliency controls/processes but provides no incident details, named roles, frameworks, dates, or other firm-specific facts.


reasoning: The paragraph describes the company’s own cyber risk management program and how it is integrated with enterprise risk management processes to manage cybersecurity threats, without referencing any named roles, tools, standards, or specific events.


reasoning: The paragraph is written from a board/committee oversight perspective (“provide oversight,” “oversee compliance”) and specifically references evaluating the “Cybersecurity Committee,” making it board-governance content.


reasoning: The paragraph describes the purpose of the company’s cybersecurity program (protecting systems from common threats), which fits a risk management process topic, but it contains no specific framework, named roles, dates, or firm-unique details.


reasoning: The grammatical subject is management (head of the ITS Department and executive management) describing responsibility for assessing and managing cybersecurity-related material risks.


reasoning: The paragraph provides a materiality/financial-impact conclusion about a cybersecurity incident but does not describe the incident’s details or affected systems. This fits strategy integration (materiality assessment) rather than incident disclosure.


reasoning: The paragraph centers on qualifications/experience of a named individual (Mr. Tao), which is management-role related content rather than a cyber risk process or incident disclosure.


reasoning: The paragraph describes the company’s own incident response and recovery planning activities (frameworks, testing cadence, simulations/tabletop exercises), which is an internal risk management process.


reasoning: The paragraph describes an ongoing cybersecurity incident (files reportedly exfiltrated), ongoing investigation into sensitive/personal information in accessed systems, and evaluation of regulatory/legal notification requirements based on findings.


reasoning: The paragraph is about general board oversight and executive management of risks, with no cybersecurity-specific roles, incidents, frameworks, or firm-specific details.


reasoning: The paragraph discusses general cybersecurity vulnerabilities and types of threats, but it does not describe Beyond Air’s internal processes, named controls/frameworks, or a specific incident or governance role.


reasoning: The paragraph is explicitly about the Board of Directors’ oversight and reporting cadence for cybersecurity matters, with the Board described as the grammatical subject. It includes named cybersecurity roles (CISO, CIO) and firm context (NetScout), making it more than generic boilerplate even though it lacks quantified or external verifiable facts.


reasoning: The paragraph describes the company’s internal cybersecurity practices (PII policy, employee training, testing and retraining) rather than board oversight, management role, third-party controls, or a disclosed incident.


reasoning: The paragraph is centered on board and audit committee oversight/briefings about cybersecurity, with the board being the grammatical subject. It lacks firm-unique details (no named roles, dates, tools, or specific program identifiers), so it is treated as generic.


reasoning: The paragraph provides a materiality conclusion stating no cybersecurity incident has affected business strategy, results of operations, or financial position, without describing an incident or internal risk process.


reasoning: The paragraph focuses on the composition of the company’s ISC and specifically names the CIO and Director of IT Security, Risk and Compliance, including their qualifications. The presence of a quantified combined experience of 20 years makes it Quantified-Verifiable.


reasoning: This is generic, forward-looking style language about using reputable third-party e-mail and cloud storage providers, with no incident narrative and no specific internal process, role, framework, or firm-specific detail.


reasoning: The paragraph discusses qualifications of the company’s information technology team, which is closest to a management-role description, but it contains no named roles, committees, dates, tools, standards, or other firm-specific details.


reasoning: The paragraph describes that cybersecurity risk management is integrated into enterprise risk management, but it contains no firm-specific details, named roles, frameworks, dates, tools, or measurable facts.


reasoning: The paragraph describes the company’s cybersecurity program as part of its overall risk management approach, but it lists no concrete internal controls, named frameworks, roles, dates, or metrics.