reasoning: This describes generic incident remediation/eradication steps (remove malware, identify root cause, prevent recurrence) without referencing any company-specific program, framework, roles, or incident details.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company’s own cybersecurity program and links it to its enterprise risk management (assessment/identification/management of risks). It contains no named roles, frameworks, tools, dates, or firm-specific details beyond generic statements.

provider: openai


content_category: Third-Party Risk

specificity_confidence: medium

reasoning: The paragraph is centrally about oversight of third-party IT service providers and uses third-party security-related data (Security Scorecard) to review and monitor them, which fits Third-Party Risk.


content_category: Strategy Integration

reasoning: The paragraph provides a financial/materiality-style conclusion about the absence of significant cybersecurity breaches and related expenses/penalties for defined reporting periods, without describing an incident narrative or internal risk-management processes.


content_category: Management Role

reasoning: The paragraph centers on a named internal security role (“internal cybersecurity coordinator”), describing its responsibilities and reporting line to the CEO, which is characteristic of a management-role disclosure rather than risk-process or incident content.


content_category: Board Governance

reasoning: The paragraph describes the Board receiving updates from committees/teams (Audit Committee and Cybersecurity team) on cyber risk indicators, testing, remediation, and threat management, which is board-level governance of cybersecurity.


reasoning: The paragraph is centered on which management role performs cybersecurity functions (the CFO acting as CISO) and how that CISO manages cybersecurity risks, making it primarily a management-role disclosure rather than an incident or process description.


category_confidence: medium

reasoning: The paragraph describes the company’s own cybersecurity program elements (threat-intelligence, control assessment, and testing), with external experts used to support those internal processes rather than focusing on vendor oversight as the central topic.


reasoning: The paragraph discusses the company’s own incident response plan being reviewed and updated as part of ongoing improvement. It contains no incident description, named personnel/tools, dates, or recognized standards, so it is generic risk-management language rather than incident disclosure or strategy.


reasoning: The paragraph is centered on board/committee oversight and reporting cadence to the Board and Audit Committee, with management providing updates. However, it uses standard committee names and generic “regular/as necessary” language without company-specific or verifiable details, making it boilerplate-level rather than firm-specific.


reasoning: This paragraph makes a standalone materiality/impact assessment regarding the absence of material cybersecurity incidents and immaterial expenses/penalties, without describing any incident narrative or specific internal processes or oversight.


reasoning: The paragraph describes the company’s internal cybersecurity incident monitoring/prevention and remediation process. While it mentions service providers/ISP personnel, these are supporting inputs to management monitoring rather than a vendor oversight program as the central topic.


reasoning: The paragraph describes internal security training and phishing simulation activities as part of the company’s cybersecurity practices. It contains no named frameworks, roles, dates, tools, or firm-specific identifiers, making it generic boilerplate.


reasoning: The paragraph centers on management roles (CIO and VP of Information Security) and assigns them primary responsibility and supervision over cybersecurity risk management.


reasoning: The focus is on the CSO/CISO (management cybersecurity roles) and how they stay informed and communicate updates. While it references board/audit reporting, the paragraph’s main subject is management roles and their internal reporting flow.


reasoning: The paragraph provides a materiality conclusion about whether any cybersecurity incidents occurred, without describing an actual incident narrative. This fits strategy/materiality integration rather than incident disclosure or risk process.


reasoning: The paragraph describes the company’s internal processes to identify, assess, and manage cybersecurity risk, including systems and data. It contains no named frameworks, roles, dates, tools, or other firm-specific details.


reasoning: The paragraph describes the company’s internal approach to assessing and managing cybersecurity material risks (monitoring and user training) as part of its risk management process, without board/management roles or an actual incident.


category_confidence: low

reasoning: The paragraph describes general responsibilities for cybersecurity professionals (an internal risk management function) but contains no named roles, programs, frameworks, dates, systems, or other firm-specific details.


reasoning: The paragraph is explicitly about the Board’s oversight of the cybersecurity program and how it is briefed. The mention of quarterly/annual updates and ERM integration is generic without any company-specific facts, dates, named committees/roles, or frameworks.


reasoning: The paragraph assigns cybersecurity responsibilities to specific management roles (CFO/COO/CEO), making management role attribution the central topic.


reasoning: The paragraph discusses cyber insurance coverage and mitigation of potential financial losses, with no incident narrative, named roles, processes, vendors, or verifiable firm-specific details.


reasoning: The paragraph describes general cybersecurity risk management importance and safeguarding critical data, but contains no company-specific details, frameworks, roles, incidents, or other verifiable specifics.


reasoning: The paragraph describes Thermon’s internal cybersecurity risk management system and its functions (identify, assess, mitigate) and CIA protection goals, which is internal process-focused rather than board oversight, roles, third-party oversight, or an incident narrative.


reasoning: The paragraph describes an internal cybersecurity-focused program/team and its responsibilities (awareness, learning, training), which is part of the company’s own risk management process rather than an incident or third-party oversight.


content_category: None/Other

reasoning: This paragraph describes generic cybersecurity training and policy communication without naming any specific roles, frameworks, dates, systems, or verifiable firm-specific details.


reasoning: The paragraph’s focus is the company’s risk management process for critical third-party service providers, suppliers, and vendors, including due diligence and periodic monitoring for adherence to cybersecurity standards.


reasoning: The paragraph describes the company’s own incident response process (IRP) and its testing via tabletop exercises, which is internal risk management. No named roles, dates, tools, frameworks, or other firm-specific identifiers are provided.


reasoning: The paragraph describes intended cybersecurity risk identification/assessment/management integrated into broader risk management processes, but it contains no firm-specific details, named frameworks, roles, systems, dates, or measurable facts.


reasoning: The paragraph describes the company’s own multi-layered cybersecurity program and how management is informed via incident response planning, but contains no firm-specific entities, dates, tools, or named standards or quantified facts.


reasoning: The paragraph is explicitly about who performs day-to-day cybersecurity management (IT staff) and the company’s consideration of enhancing or outsourcing that role, making it a Management Role disclosure.


reasoning: The paragraph describes general cybersecurity objectives (business continuity, protecting technology and data) but provides no company-specific, framework-specific, roles, vendors, incidents, or measurable details.


reasoning: The paragraph describes the company’s own cybersecurity program components (policies, procedures, assessments, monitoring, response plans, testing), which aligns with risk management process. However, it contains no specific frameworks, tools, roles, dates, or other firm-unique facts, making it largely boilerplate.


reasoning: The paragraph provides a materiality conclusion about cybersecurity threats’ impact on business/financial condition and includes a cross-reference to Risk Factors, but it does not describe any incident or internal processes.


reasoning: The paragraph attributes responsibility for cybersecurity risk assessment and management to named management roles (Senior Director of IT and CFO/Treasurer), making it primarily about management roles rather than the internal process itself.


reasoning: The paragraph is purely a materiality conclusion about whether an incident could materially impact financial condition/results, with no incident description or named entities, dates, or systems.


reasoning: This paragraph is solely boilerplate materiality language stating the incident is not reasonably likely to materially impact financial condition or business results, without describing what occurred.


reasoning: The paragraph discusses insurance reimbursement for costs related to a cyber incident, but it provides no incident narrative, scope, or verifiable quantities. It focuses on expected reimbursement timing/amount (unknown), which is primarily a financial/strategy integration disclosure.


content_category: Incident Disclosure

reasoning: This paragraph describes ongoing response activities typical of a cybersecurity incident (restoring systems, working with law enforcement, and retaining experts) but contains no named incident details, dates, systems, scope, or specific expert/regulatory entities.


reasoning: The paragraph references an ongoing cybersecurity incident (continuing forensic investigation and potential material financial impact), which is incident-related disclosure, but it provides no incident specifics (dates, systems, scope).


reasoning: The paragraph discusses post-incident business/financial impact (no material disruption, potential revenue loss and higher expenses) rather than describing the incident itself or internal risk processes. It contains some firm-specific statements about Coupang’s operational and financial impacts, but no concrete quantified metrics or named external entities.


reasoning: The paragraph discusses materiality conclusions about the incident’s impact on operations and financial condition/results, without providing incident specifics (what happened, affected systems, dates, or scope). It is therefore primarily a materiality/impact assessment rather than incident narrative.


reasoning: The paragraph is a materiality/financial impact statement about an incident (no material impact; not reasonably likely to materially affect financial condition/results) without describing what happened.


reasoning: The paragraph describes operational impact from an actual disruption (networks/transactional services not accessible) and provides an incident update link, indicating incident disclosure.


reasoning: This is forward-looking risk-related discussion referencing financial/insurance impacts, but it does not describe the incident or include any cyber-specific internal process details.


reasoning: The paragraph is focused on cybersecurity insurance coverage and how it relates to potential incident-related costs, which is a strategy/financial protection disclosure rather than an actual incident narrative. It includes company-specific posture (“Lee maintains...”) and detailed coverage categories, but no verifiable dollar amounts, dates, or named vendors/tools.


reasoning: This paragraph is general compliance/notification boilerplate referencing legal counsel, law enforcement, and regulators, but it does not describe a specific cybersecurity incident, systems/data impact, or any company-specific facts or frameworks.


reasoning: This paragraph describes an actual cybersecurity incident (threat actor access and data exfiltration) and indicates what type of data was involved (limited data including PII) plus ongoing notifications to affected parties and regulators.


reasoning: This is a forward-looking materiality determination about whether an incident would materially impact financial condition/results, without describing what the incident was or any other cyber process details.


reasoning: This paragraph provides a materiality conclusion (no material operational or financial impact) about a cybersecurity incident, without describing incident details; it fits strategy/materiality integration rather than incident narrative or internal risk processes.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation/forensic analysis and notes evidence status, which is incident-specific disclosure even though it contains no concrete event details (dates, systems, scope).


reasoning: The paragraph provides a materiality/financial impact conclusion about a cybersecurity incident (no material impact; not reasonably likely to materially impact financial condition/results) without describing what happened. It is therefore strategy/financial-materiality integration rather than incident narrative or a risk management process.


reasoning: This is a standard legal/contract clarification about waiver scope under a Credit Agreement and Lease Agreement, with no cybersecurity or incident-related governance, risk process, or impact disclosure.


reasoning: The paragraph describes actions taken in response to an unspecified “matter” (notifying law enforcement and regulators), but it contains no incident-specific facts such as what happened, scope, dates, affected systems/data, or impact.


reasoning: This paragraph provides a materiality/financial impact conclusion about a cybersecurity incident being not reasonably likely to be material, without describing what happened. It is therefore strategy/impact integration rather than incident narrative or governance/process.


reasoning: The paragraph references an already-described cybersecurity incident and states there has been no material disruption, along with ongoing evaluation of potential impacts and remediation costs. However, it provides no concrete incident details (systems/data/date) or quantifiable impact.


reasoning: The paragraph discusses financial/cost treatment of a disclosed cybersecurity incident via expected insurance reimbursements, without describing what occurred or providing incident scope details.


reasoning: The paragraph describes the status of an ongoing cybersecurity incident (contained it and restored core IT environment), which is incident-related narrative, but it contains no named parties, dates, systems, scope, or other verifiable specifics.


reasoning: The paragraph describes a real cybersecurity incident, including notification and confirmation dates, and states that some customer information was exposed, which constitutes incident disclosure.


reasoning: This paragraph discusses material financial impact and ongoing assessment of that impact, without describing what systems/data were affected or incident details. It contains only generic disclosure language typical of SEC filings and no named tools, dates, amounts, or other firm-unique facts.


reasoning: The paragraph’s grammatical focus is a management role change, naming the interim chief executive officer and the individual’s existing titles. It describes an internal leadership succession detail specific to the company and its Korean subsidiary.


reasoning: This paragraph describes an ongoing cybersecurity incident investigation with indeterminate data scope and includes response-related actions (working with a cyber insurance provider for investigation/remediation/claims), which aligns most closely with incident disclosure.


reasoning: The paragraph describes an ongoing cybersecurity incident response (containing the incident, restoring access, and resuming operations), but it provides no incident specifics such as dates, affected systems/data scope, or named parties.


reasoning: The paragraph’s core disclosed substance is the identification of the chief technology officer and senior director of cybersecurity and compliance and their reporting line to the Audit Committee. Although it also mentions maintaining a cybersecurity risk management program, the management-role disclosure is the clearest primary focus.


reasoning: The paragraph refers to an ongoing cybersecurity incident investigation and describes response actions (engaging experts and notifying law enforcement) plus a materiality conclusion about financial impact, which fits incident disclosure.


reasoning: This paragraph provides a materiality/financial impact conclusion about an incident (no material operational or financial effect) without describing what happened or affected systems. The focus is on the company’s assessment of material impact rather than incident narrative or internal risk processes.


reasoning: This paragraph is a materiality assessment disclaimer about whether a cybersecurity incident could affect financial condition/results, with no incident narrative or specific company facts.


reasoning: The paragraph provides a materiality/financial-impact conclusion about an incident without describing what happened or affected systems. This is primarily about whether the incident could materially impact financial condition/results, which fits Strategy Integration rather than Incident Disclosure.


reasoning: The paragraph references an existing cybersecurity incident (“this incident”), describes a specific response action (closing off the unlawful access point), and indicates impact via notice to impacted customers.


reasoning: This sentence references an investigation and mailing notification letters, which is consistent with incident handling/disclosure. However, it provides no incident details (no date, scope, affected systems, or impacts), making it too generic to confirm a specific incident narrative.


reasoning: This paragraph discusses assessing potential material financial impact of the incident, but provides no incident details, no dates, and no firm-specific facts beyond generic materiality language.


specificity_confidence: low

reasoning: The paragraph describes an ongoing cybersecurity incident investigation focused on whether threat actors took personally identifiable information, and it notes a forthcoming definitive answer. It lacks firm-unique details (no dates, systems, or named parties), making the content largely generic.


reasoning: This paragraph narrates a cybersecurity incident by describing suspected attacker actions (access, data exfiltration, and encryption) and the current investigation status.


reasoning: The paragraph describes an actual operational disruption affecting online ordering (a real business impact) and notes the status of deliveries. While it lacks the usual technical incident details, the content goes beyond generic cybersecurity boilerplate by stating current disruption and its scope.


reasoning: The paragraph describes the status/outcome of an actual cyber incident (restoration of impacted systems/data, minor operational impacts, and that authorities closed the investigation without identifying a source), which is central incident disclosure.


reasoning: The paragraph describes a specific, real cybersecurity event (a system outage) with a date and states the company activated an incident response team, including external experts, which is central incident narrative content.


reasoning: The paragraph describes an actual event (systems outage due to a cybersecurity attack) and the company’s response actions (activating its incident response team). It includes a specific date, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation and references assessment of personal information in exfiltrated data, along with planned notifications to affected parties and regulators—hallmarks of incident disclosure. However, it contains no concrete dates, amounts, systems, tools, or named entities, making it generic in specificity.


reasoning: The paragraph references an ongoing cybersecurity incident and states the Company will continue to monitor its timing and materiality, which is incident-related disclosure. However, it provides no concrete incident details, dates, systems, or quantified impact, making it largely generic.


reasoning: The paragraph describes operational impact (primary website inaccessibility during the disruption) and provides incident communications details, including a specific URL.


reasoning: The paragraph discusses a specific previously referenced cyber incident and describes the claimed impact components (website rebuilding, new server/hosting platform, security protocol enhancements), which fits incident disclosure rather than generic risk management.


reasoning: This paragraph provides a materiality/financial-impact assessment of a cybersecurity incident (expecting material impact on Q4 2023 results but not on overall financial condition or ongoing operations) without describing what happened or operational scope, so it fits Strategy Integration.


reasoning: The paragraph refers to an ongoing cybersecurity incident and whether it has had/material impact and financial implications, which is consistent with incident-disclosure language, but it provides no concrete incident details (no dates, systems, or scope).


reasoning: This paragraph describes a real cybersecurity incident and its operational impact, including which systems were affected and the duration of the disruption.


reasoning: The paragraph is focused on materiality/financial impact conclusions about an incident (no material impact on operations and no material impact on financial condition/results), without describing what the incident was or response details. It is generic materiality language rather than a framework, tool, or named governance/management/process detail.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized third-party access) and provides a specific awareness date, fitting Incident Disclosure.


reasoning: The paragraph describes an actual cybersecurity incident’s operational impact (shipping/receiving, manufacturing processes, back office functions) and restoration/temporary measures, which is core incident disclosure content.


reasoning: This paragraph discusses materiality of an incident to financial condition/results of operations, but provides no incident details or measurable facts. It is therefore best classified as strategy/materiality integration rather than incident disclosure or internal risk process.


reasoning: The paragraph describes an actual incident, including when it was detected and what activity occurred (fraudulent attempts to obtain funds), which squarely fits incident disclosure. It is also anchored by a specific date and a named company.


reasoning: The paragraph references an actual cybersecurity issue (“unauthorized access to information”) and describes response actions involving regulators and law enforcement, which is characteristic of incident disclosure.


reasoning: The paragraph describes an actual cybersecurity incident trigger (a compromised fourth-party vendor) and states the company activated its response process, which are core incident-disclosure elements.


reasoning: This paragraph describes an actual incident notification and the Company’s response actions (investigate, contain, remediate) with a specific date, which fits Incident Disclosure.


reasoning: The paragraph describes incident-response/operational mitigation actions (temporary measures, manual transaction processing, alternative distribution channels) tied to restoring systems, which is characteristic of an incident disclosure. It does not provide incident scope or dates, so confidence is medium.


reasoning: The paragraph describes an actual cybersecurity incident (threat actor access) and states that notifications to affected parties and regulators will be provided, including affected data context (sensitive personal information). No firm-unique details, dates, systems, tools, or third parties are specified, making it generic.


reasoning: This paragraph ties to an incident-related disclosure by referencing an expected restoration timeline and interim measures for Change Healthcare systems, with a specific dated press release. However, it does not provide incident details itself, so incident disclosure is inferred via the cross-reference.


reasoning: This paragraph is generalized risk/disclaimer language about cybersecurity threats and potential impacts, with no named roles, internal programs, specific frameworks, third parties, or any described incident.


reasoning: The paragraph describes the company’s internal cybersecurity incident evaluation criteria, escalation approach, and its Incident Response Program and Business Continuity Plan—i.e., its risk management/IR processes. While it mentions third-party managed/hosted systems, the central topic is S&T’s own processes (not third-party oversight alone).


reasoning: The paragraph is primarily about Wendy’s own cybersecurity risk management strategy and the specific components used to identify, assess, and manage threats (governance-linked processes, controls, infrastructure, training, and dedicated teams), not a standalone incident or primarily vendor oversight.


reasoning: The paragraph primarily describes the company’s internal risk-management activities (monitoring, exercises/assessments, controls, and quarterly/annual briefings) as part of its process for informing the Audit Committee.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment and management processes (threat assessment, layered security, training, tooling, penetration testing, reporting, and third-party assessments). Although vendors are mentioned, the central topic is internal risk management, not vendor security oversight alone.


reasoning: The paragraph primarily describes Bel’s own cybersecurity and related governance processes (monitoring, training, penetration testing, asset protection, and access review/controls). While it includes vendor requirements (SOC 1/SOC 2 and access limitations), these are presented as part of Bel’s internal risk management and control procedures rather than vendor oversight being the central topic.


reasoning: The paragraph describes the company’s internal cybersecurity program elements (governance/IRM coordination, incident response planning, technical safeguards, training) and how risks are identified and managed. Third-party risk is discussed as part of the company’s overall risk management approach rather than as a standalone vendor oversight program.


reasoning: The paragraph describes the company’s approach to cybersecurity risk management (policies, standards, processes, investment) but provides no incident narrative or named roles/frameworks/tools. References to generic regulatory bodies are not specific enough to qualify as firm-specific facts under the decision test.


reasoning: This paragraph is general cybersecurity risk and dependency boilerplate (describing potential threats and impacts) without describing the company’s own incident, specific controls, governance, roles, or any named frameworks/tools/dates.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach (controls, awareness, monitoring, IR/BC/DR, and continuous improvement) and how it integrates with risk management. While it mentions third parties, vendor oversight is described as a component of the company’s overall risk management process rather than being the central focus.


reasoning: The paragraph focuses on Oracle-specific cybersecurity risk discussion and internal assessment about material effects in fiscal 2024, with mitigation/impact framed in terms of the company’s risk posture rather than a standalone incident. While it mentions vendors, it is not vendor oversight as the central topic, so it fits risk management/risk factor framing more than third-party risk.


reasoning: The paragraph describes the company’s internal Cybersecurity Program, including risk-assessment processes and an embedded Cyber Incident Response Plan and how it is administered and overseen. This is primarily an internal risk management/cyber governance process description rather than an actual incident disclosure or third-party vendor oversight as the central topic.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach, including who owns risk assessment/mitigation and how monitoring and incident escalation are handled. While it mentions the Audit Committee, the focus is on the company’s own processes and roles (not a central third-party-vendor oversight topic).


reasoning: This paragraph is general, forward-looking risk-factor boilerplate about potential cyber threats and impacts, with no board/management/process described and no actual incident or named frameworks, roles, dates, or tools.


reasoning: The paragraph focuses on the Board and specifically the Risk Committee’s responsibilities and reporting/meeting cadence for cybersecurity risk within the company’s ERM program, which is characteristic of Board Governance.


reasoning: The paragraph describes the company’s internal cybersecurity risk management strategy and processes (identification/escalation, technical safeguards, incident response and recovery planning, third-party risk management as part of internal oversight, and training). It does not describe a specific incident or include firm-unique identifiers, named frameworks/standards, dates, dollar amounts, or external named firms/tools, making it generic.


reasoning: The paragraph describes Spyre Therapeutics’ own cybersecurity risk and security processes (implemented NIST framework, dedicated IT team, testing/audits, monitoring, training, and due diligence) rather than an actual incident. Although it mentions vendors, vendor oversight is part of the company’s overall risk management process, not the central topic.


reasoning: The paragraph discusses general capabilities (detecting viruses/malware) and generic potential consequences, but it does not describe a company-specific process, framework, named role/system, or any real incident with effects. It also largely provides forward-looking risk-factor cross-reference language.


reasoning: The paragraph centers on the company’s Chief Information Officer and details his responsibilities, qualifications (including CISSP/CISA), and review/reporting cadence, which is the core focus. Although it mentions Board/Audit Committee interactions, the grammatical subject and main content are the CIO’s management role in cyber risk.


reasoning: The paragraph describes the company’s own cybersecurity risk management approach (monitoring, vulnerability/threat processes, policies, training, and supplier risk controls), rather than a board role, a specific incident, or standalone material/strategy impacts. It includes firm-specific procedural details like ISAC involvement, simulated phishing, and specific supplier-control mechanics.


reasoning: The paragraph is primarily about outsourcing cybersecurity governance/responsibility to a third-party IT and cybersecurity firm (including the vCISO and the team’s role in overseeing controls and risk management). It includes multiple firm-specific details such as vCISO, named roles, and the “over 30 years” experience plus specific certification names.


reasoning: The paragraph describes the Company’s internal cybersecurity controls, incident response/recovery planning, technical safeguards, employee training, and a risk-based approach to third-party risks as part of its overall risk management processes. There is no incident narrative or board/management role, and no named frameworks, tools, dates, or verifiable firm-specific details.


reasoning: The paragraph primarily describes the company’s internal cybersecurity and risk-management processes (training, monitoring, incident response tools, supplier risk process, escalation), with board and committee oversight serving as supporting governance detail. It includes firm-specific internal reporting lines and named committee/role elements (Audit Committee; head of information security department reporting to CFO; CISSP mention).


reasoning: This paragraph describes ADAMAS TRUST’s own cybersecurity risk identification, protective controls, monitoring, insurance, incident response/continuity planning, and enterprise risk assessment processes. It contains named frameworks and multiple firm-specific program/control descriptions, though no external firms, tool names, or hard quantified outcomes beyond "annual".


reasoning: The paragraph’s primary grammatical subject is the Board of Directors and the Audit Committee overseeing and reviewing cybersecurity risks. It contains only generic governance and forward-looking risk-language with no firm-unique details, named frameworks, roles beyond standard governance, or verifiable metrics.


reasoning: The paragraph describes AGM’s internal cybersecurity program elements (governance, processes, technical safeguards, incident response/recovery, training, and third-party risk management) as part of its ERM approach, which is primarily an internal risk management/process disclosure. It is not an incident narrative and is not centered on contractual third-party requirements alone.


reasoning: The paragraph describes the company’s own internal incident preparedness/response structure (Agility Plan, CMT) and ongoing controls (audits, assessments, training), which is characteristic of risk management processes rather than incident disclosure or pure third-party risk.


reasoning: This paragraph is general, forward-looking cybersecurity risk boilerplate and does not describe any actual incident, named roles, frameworks, or firm-specific systems/tools. It also contains a statement that no material cybersecurity threats occurred, but without any event narrative or verifiable specifics beyond generic language.


reasoning: The paragraph describes general types of potential cybersecurity incidents and mentions using an IRP, but it does not provide an actual incident narrative, named tools, dates, or firm-specific operational details. While it references IRP and directed attacks, the disclosure is largely generic and framed as risk/response capability rather than a specific incident or a named governance/management function.


reasoning: The paragraph describes Bowman’s own cybersecurity monitoring, incident response planning, and vulnerability/threat activities, i.e., internal risk management processes. While it mentions third parties, they are described as inputs to these internal processes rather than the central subject of third-party risk oversight.


reasoning: The paragraph describes Riot’s internal cybersecurity monitoring, detection tooling (EDR/SIEM), network protections, and incident/notification processes, which are core risk management activities. While it mentions third-party services, they are not the central topic; the focus is Riot’s own internal controls and response procedures.


reasoning: The paragraph describes CoreCivic’s own cybersecurity risk assessment and management program (how risks are identified and managed, and how systems are kept secure), including monitoring/impact language, but it does not provide named roles, dates, tools, frameworks, or incident-specific details.


reasoning: The paragraph describes the company’s internal cybersecurity and risk-management practices (monitoring, encryption, access controls, training, disaster recovery, vulnerability scanning, and a third-party risk register) rather than a board role or a disclosed incident. It contains no named external firms, products/tools, standards, or specific verifiable dates/amounts unique to Guardant Health.


reasoning: The paragraph describes the company’s internal governance and processes for assessing/managing cybersecurity risk and includes an internal Security and Privacy Governance Committee and a Cybersecurity Incident Response Plan. While it includes the CTO, the focus is on the company’s own risk-management structures and incident response plan rather than solely on a management-role description.


reasoning: The paragraph describes Schwab’s internal cybersecurity and enterprise risk management activities (information security program, monitoring, authentication controls, training, and policies). Although board oversight and the Risk Committee are mentioned, the dominant subject is Schwab’s own risk management and security processes.


reasoning: The paragraph centers on named management security roles (CISO, Information Security Team, CCO) and their responsibilities/qualifications for cybersecurity risk assessment and management, not on incident disclosure or a specific risk-control process.


reasoning: The paragraph is centered on who within management oversees and leads cybersecurity (named leaders, CISO, team structure) and their qualifications and responsibilities. This is primarily a Management Role description rather than an incident, governance body, or risk-control process.


reasoning: The paragraph focuses on Jamf’s own cybersecurity risk management approach—policies, standards, processes, and practices for assessing and managing cyber threats—plus general statements about investing and oversight. It does not describe a specific incident or name a board/management role as the central subject, and it provides no verifiable dates, tools, standards, or external firms.


reasoning: The paragraph describes the company’s own processes to identify, assess, and manage cybersecurity-related risks and how they could affect operations and financial condition, without discussing an actual incident or board/management structure.


reasoning: The paragraph describes Cohen & Steers’ own internal cybersecurity program controls (monitoring, incident response plans, training, risk assessments, encryption, vendor risk management, and cyber insurance), which are risk management processes rather than a board function or an incident narrative.


reasoning: The paragraph describes USCF’s internal information security program, annual risk evaluation, and risk mitigation activities (including oversight of and due diligence on third parties) as part of the Trust’s/manager’s cybersecurity risk management process rather than a standalone board/incident disclosure.


reasoning: The paragraph is primarily about which management cybersecurity roles are responsible (CTO, CIO, CISO), their experience, and how they operate in managing cyber risks, which aligns most closely with Management Role despite also mentioning board reporting and SOC monitoring.


reasoning: The paragraph primarily describes Northern Trust’s internal cybersecurity and technology risk management program, policy, framework, and governance processes (including integration into enterprise risk management). Third-party vendors are mentioned only as part of the company’s internal third-party risk management controls, not as the central topic.


reasoning: The paragraph describes Embecta’s own cybersecurity risk management activities (monitoring, defense-in-depth, penetration testing, policy governance, and risk assessment frameworks). Third-party vendor assessment is included as part of the company’s risk management program rather than being the central standalone focus, so the best fit is Risk Management Process.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk management activities (policies/program, controls, monitoring, due diligence) rather than an actual incident. Third-party risk is included as part of the company’s own program, so the central topic is internal risk management process.


reasoning: The paragraph is primarily written from the perspective of board-level oversight, describing how the board delegates cybersecurity oversight to a specific board committee and how that committee is updated.


reasoning: The paragraph describes Ardent Health’s internal processes for assessing and managing third-party cyber risk (review/approval, cybersecurity team assessments, vendor risk analysis, FAIR model, incident response plan/escalation). Although it mentions third parties, they are not the central focus; the core topic is the company’s own risk management and incident response process.


reasoning: The paragraph primarily describes the company’s own cybersecurity risk management activities (incident management/response, monitoring, remediation, and integration into enterprise risk management). Although it also mentions diligence on third-party providers, that is a supporting component rather than the central focus.


reasoning: The paragraph centers on identifying specific management roles (President/CEO and General Counsel) and describing their responsibilities for cybersecurity risk management and incident reporting/coordination. It also includes multiple independently verifiable biographical timeline facts and quantified experience durations.


reasoning: The paragraph is largely generalized risk-management and forward-looking disclaimer language, including statements about continued investment and materiality (no material effect to date) without describing any specific incident or named frameworks, roles, dates, tools, or firm-unique details.


reasoning: The paragraph describes MEG’s own incident response plan and how it is executed, including escalation and roles, which is part of the company’s cybersecurity risk management process. It is not a central vendor/supplier oversight discussion or an incident narrative.


reasoning: The paragraph describes WTW’s internal cybersecurity risk management strategy and processes (incident response plan, technical safeguards, training, threat intelligence), including how third-party risk is managed as part of its overall internal program. No single third-party vendor oversight is central, and no actual incident narrative is provided.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach (identification, prioritization, mitigation, monitoring via SOC, and metrics). It also names specific roles (CIO, CISO) and a named internal function (SOC), making it more than generic boilerplate.


reasoning: The paragraph describes the company’s internal cybersecurity/security programs, monitoring, incident reporting/severity classification, and incident escalation and impact/materiality assessment processes. While it mentions roles (CISO, CIO, CFO, General Counsel, CEO), the subject is the firm’s risk management and incident response process.


reasoning: This paragraph is a standard forward-looking statements and safe harbor/disclaimer section, with no description of the actual incident or any specific cybersecurity actions, scope, systems, or measurable impacts.


reasoning: The central topic is oversight and controls over third-party providers (vendor management, audits, and imposing contractual cybersecurity obligations), which fits Third-Party Risk. The paragraph is specific to the company’s described vendor management approach, not just general security practices.


reasoning: The paragraph describes the company’s own incident/disaster recovery approach, escalation structure (CMT), and internal monitoring/assurance practices, which are internal risk management processes. While it mentions third-party consultants, they are not the central focus; the disclosure centers on the company’s internal processes and teams.


reasoning: The paragraph is primarily about Board delegation and Audit Committee oversight of the company’s cybersecurity program, including review cadence and discussions with the CTO and Advisor.


reasoning: The paragraph provides materiality conclusions about cybersecurity incidents and risks (none materially affecting in 2023) and discusses insurance coverage and potential business/financial impact, rather than describing an actual incident or internal risk controls.


reasoning: The paragraph is driven by board-level oversight—specifically the Audit Committee’s responsibilities and the communication/briefing structure from Kroger’s CIO/CISO to the Audit Committee and Board, including the Audit Committee’s oversight approach.


reasoning: The paragraph describes Grindr’s own cybersecurity risk management activities (e.g., incident response plan, vulnerability management, audits, access controls, training) and how it prioritizes risk. Although it mentions vendor risk management and a third-party managed SOC, these appear as components of the company’s internal risk process rather than vendor oversight being the central topic.


reasoning: The paragraph describes the company’s own incident response plan, escalation, testing cadence, and tabletop exercises, which are internal risk management processes. It includes firm-specific details like the IR plan escalation thresholds (moderate or higher business impact) and the coordination list for exercises.


reasoning: The paragraph primarily describes Alternus’s cybersecurity and risk management processes (assessment, monitoring/response/recovery, third-party risk evaluation) rather than board oversight or a stand-alone incident. Third-party vendors are discussed as part of the company’s overall internal cybersecurity risk management framework.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access and file exfiltration), the affected data type (potentially sensitive personal information/customer data), operational disruption, containment steps (shutting down systems/internet isolation), and restoration/ongoing assessment.


reasoning: The paragraph discusses the company’s internal cybersecurity posture (lack of formal policies/processes/training and no dedicated cybersecurity personnel), which fits risk management/process. However, it contains no firm-specific details, dates, named roles beyond generic descriptions, or recognized frameworks/standards.


reasoning: The paragraph is a generalized statement about not having identified material cybersecurity incidents and includes a generic risk-of-future-incidents and a cross-reference to Risk Factors, with no incident narrative or firm-specific details.


reasoning: The paragraph provides an incident narrative and updates (perpetrator identified, devices turned over) with concrete scope of access/data saved and detailed financial/operational impact via a compensation program (voucher amounts and timing).


reasoning: The paragraph discusses general risk assessment/management of cybersecurity-related material risks and potential impacts, but it provides no company-specific processes, roles, frameworks, or incident details.


reasoning: The paragraph describes a specific cybersecurity incident with a concrete date, unauthorized access/encryption, exfiltration, and operational impacts (financial/operating reporting systems), along with response actions and ongoing assessment—hallmarks of an Incident Disclosure.


reasoning: The paragraph is centered on governance/oversight by the Board of Directors and Audit Committee and describes reporting/escalation of cybersecurity matters to them, which is board/governance focused.


reasoning: The paragraph describes the company’s own cybersecurity program elements (safeguards, vulnerability assessments, threat intelligence) and its incident response plan/testing, which are internal risk management processes rather than an incident, governance, or third-party topic.


reasoning: The paragraph focuses on senior management’s role in producing cybersecurity risk appetite metrics for Board approval, which ties governance oversight to cyber risk. While management is mentioned, the approval/oversight by the Board is central, making Board Governance the best fit.


reasoning: The paragraph describes an actual cybersecurity incident (defaced website), actions taken (restoring/bringing down the site, temporary page, additional measures), and incident impacts including canceling a seminar and anticipated financial losses. The detailed narrative and operational/financial consequences align with Incident Disclosure.


reasoning: This paragraph describes internal information security training as part of the company’s security practices, but contains no named roles, dates, frameworks, tools, or other firm-specific details beyond generic training language.


reasoning: The paragraph describes a specific cybersecurity incident, including the threat actor’s email, claimed access to customer accounts and internal documentation, the company’s discovery/detection, termination and protective customer communications, and conclusions about a single campaign that took data.


reasoning: The paragraph describes the company’s own cybersecurity risk evaluation, prevention/detection/mitigation procedures and internal policies/training, including how it manages risks related to supplier/customer relationships as part of its risk processes. It is not an incident narrative and is not focused primarily on vendor requirements as the central topic.


reasoning: The paragraph describes the company’s own cybersecurity risk management program and related activities (assessments, testing, training, threat intelligence, and integration with enterprise risk management). Third parties are mentioned only as part of conducting assessments and as a scope consideration, not as the central topic of vendor oversight.


reasoning: The paragraph describes Sweetgreen’s internal risk identification/assessment/management activities, with third parties listed as supporting resources rather than third-party oversight being the central topic.


reasoning: The paragraph centers on who is responsible for cybersecurity (management led by the IT department, and a Software Engineer) and their duties, which is primarily a management-role description rather than incident disclosure or a distinct process framework.


reasoning: The paragraph centers on the company's cybersecurity oversight processes for third-party service providers (annual third-party risk assessments and contractual obligations), which matches third-party risk. It contains firm-specific program elements and operational details rather than generic language.


reasoning: The paragraph describes the company’s internal process after receiving notice of a cybersecurity threat, including investigation, assessment by the ISC, and isolating affected systems. References to outside advisors are secondary to the internal risk-management/incident-assessment workflow.


reasoning: The paragraph centers on named management cybersecurity roles (CISO and VP of Information Security) and describes their qualifications and experience. It does not describe governance/board oversight or a company cybersecurity process, nor an incident.


reasoning: The paragraph describes JetBlue’s own cybersecurity strategy/process elements (detection, analysis, response, risk management, resilience), but contains no firm-specific details, named roles, frameworks, dates, or tools. Thus it is treated as generic boilerplate despite referencing internal activities.


reasoning: This is largely boilerplate about being a blank check company with no operations and claims of no adoption of cybersecurity risk management processes, without describing a specific incident, concrete governance/management role, or internal risk framework/process details.


reasoning: The paragraph’s grammatical subject is the board-level Risk Committee and it describes its oversight responsibilities, reporting cadence, and engagement with management and the cyber incident response plan. This is board governance rather than a description of the company’s internal cyber risk processes on their own.


reasoning: The paragraph describes internal process involvement by the Information Security/IT teams (early engagement in PMO routines and Vendor Management Office requirements) to onboard products/projects/vendors, which is primarily an internal risk management process rather than a standalone third-party risk program.


reasoning: The paragraph describes general cybersecurity activities (training, phishing testing, newsletters) and mentions cyber insurance, but it contains no named roles, dates, frameworks/standards, tools, or firm-specific details beyond common practices.


reasoning: The paragraph describes the company’s own internal incident response plan and how it guides immediate mitigation and long-term remediation. It contains no firm-specific identifiers (named programs/tools/roles beyond generic “chief executive officer”), dates, or verifiable metrics.


reasoning: The paragraph is a general statement about lacking specific cybersecurity risk processes and does not describe any internal approach, framework, named roles, third-party oversight, or incident/impact details. It reads as non-substantive boilerplate rather than a defined risk management disclosure.


reasoning: The paragraph centers on named cybersecurity and management roles (CISO and other executives) and describes who oversees and participates in cybersecurity risk management and related incident prevention/mitigation/detection/remediation.


reasoning: The paragraph describes the company’s own cybersecurity risk management objectives and improvement initiatives, including review of processes by a technology leadership function under the CTO. It is focused on internal processes rather than an incident or third-party vendor oversight.


reasoning: The paragraph discusses the company’s security controls, a risk-based approach to selecting controls, and limitations of monitoring/detection. It is not an incident narrative and provides no firm-unique program names, dates, frameworks, or quantified facts.


reasoning: The paragraph centers on the Board of Directors overseeing cybersecurity/data privacy risk and reviewing the cybersecurity program and response plan with management.


reasoning: The paragraph is primarily a forward-looking statement that no material cybersecurity incidents are currently known, includes generic risk-mitigation language, and cross-references Item 1A without describing any incident details or specific internal processes.


reasoning: The paragraph is centered on the board of directors’ oversight activities (reviews of the cybersecurity risk profile, using indicators, and management reporting), which is board governance rather than describing management’s role or the company’s own processes in detail.


reasoning: The paragraph describes the company’s own internal security and resilience processes (defense in depth, vulnerability remediation, and incident response/disaster recovery planning), which fits Risk Management Process. It contains no firm-unique identifiers, dates, named tools/frameworks, or external entities, making the disclosure largely generic.


reasoning: This is a forward-looking boilerplate statement of no known material cybersecurity impacts, with no incident narrative, named roles, frameworks, or specific facts.


reasoning: The paragraph is centered on the Audit Committee’s oversight duties for cybersecurity risk, its update cadence from management, and its role in forming/confirming mitigation and disclosure compliance for material incidents.


reasoning: This paragraph describes general limitations of implementing security controls and using a risk-based approach, but it does not provide company-specific processes, named roles, frameworks, vendors, or incident details.


reasoning: The paragraph describes Arrow’s internal cybersecurity risk management program and explicitly links multiple internal organizational units (Board, CIO, Director of IT, and the enterprise risk management group) to it, making it primarily about the company’s risk management processes rather than an incident or third-party oversight.


reasoning: The paragraph describes PERDOCEO’s internal cybersecurity risk assessment and mitigation activities (process, monitoring, assessments, IR planning-like activities, policy, and training) rather than governance or a specific incident. It includes recognized standards/laws (CIS, FERPA) but no firm-unique identifiers, dates, or external named entities/tools, leading to a Sector-Adapted specificity classification.


reasoning: The paragraph emphasizes oversight by the board’s Audit Committee, including quarterly review/cadence until remediation is complete. Management and external-auditor activities are described, but the governance/oversight mechanism is the core focus.


reasoning: The paragraph describes BlackRock’s own cybersecurity program and internal risk management processes (governance structure, safeguards, incident response/recovery planning, and third-party risk management as part of ERM). Third parties are discussed as an internal control component rather than a standalone vendor oversight requirement, so it fits best under Risk Management Process.


reasoning: The paragraph describes the company’s own incident response and vulnerability management escalation/coordination processes (who gets notified, and how they work with the incident response team). It is not an incident narrative or third-party oversight, so Risk Management Process is the best fit.


reasoning: This paragraph is forward-looking boilerplate about potential cybersecurity risk and includes a cross-reference to another risk factor (Item 1A). It does not describe a specific incident, internal program, named governance/management role, or any firm-specific cybersecurity framework or tools.


reasoning: The grammatical subject is specific management roles (CIO, CTO, and Information Security Officer) and it describes their accountability and responsibilities over the information security program.


reasoning: The paragraph describes EMCOR’s internal cybersecurity program and governance structures as part of its overall risk management process (policies, dedicated teams, monitoring prevention/detection/remediation, and incident response), which is central to the disclosure. It is not primarily an incident narrative or third-party/vendor oversight.


reasoning: The paragraph centers on PSCM’s contractual and due-diligence requirements imposed on vendors handling sensitive information, which is vendor oversight. It also includes a materiality statement about being unaware of material cyber risks, but the dominant topic is third-party risk controls.


reasoning: The grammatical focus is on governance/oversight—prompt board and Audit Committee notification of incidents, with specific responsible officers (CFO, General Counsel) and the Head of Cybersecurity feeding information to senior leadership. The paragraph also ties this to incident response processes, but the distinctive emphasis is on board-level notification responsibilities.


reasoning: The paragraph describes general internal technical safeguards (firewalls, anti-malware, monitoring agents) to protect information systems, but it contains no company-specific details, dates, frameworks, roles, or metrics.


reasoning: The paragraph primarily describes the company’s own internal risk management and security processes (assessment, controls, prevention/detection/mitigation). While it mentions a third-party security program, this is presented as one component of the overall internal risk management approach rather than vendor oversight being the central focus.


reasoning: The paragraph describes Western Digital’s internal enterprise risk management process and how it identifies, assesses, manages, reports, and monitors cybersecurity risk, including mitigation structures and response plans.


reasoning: The paragraph centers on the Audit Committee’s responsibilities and reporting/oversight duties for cybersecurity risks, including incident-related updates. It also names the CISO and the company’s Cybersecurity Incident Response Plan, making it firm-specific governance disclosure.


reasoning: The paragraph describes the company’s own cybersecurity monitoring and testing program (audits, exams, vulnerability/penetration testing, patching, and SOC log monitoring), making it a risk management process disclosure. Third-party vendors and SOC as a Service are supporting components rather than the central focus.


reasoning: The paragraph describes the company’s own internal security testing and control review workflow (including evaluating weaknesses and providing outputs to leadership), with vendor reports mentioned as an input to that internal process rather than the central focus.


reasoning: The paragraph primarily describes the company’s own cybersecurity risk management program and controls (identification of critical systems, segmentation, access controls, continuous monitoring, patch/vulnerability scanning, and related governance/process steps). Third-party audits/managed security services are supporting components rather than the central topic, so it fits Risk Management Process.


reasoning: The paragraph describes Teladoc’s own cybersecurity program, how it manages cybersecurity threats, and the frameworks/certifications it uses to adopt and assess controls. It is therefore an internal risk management process disclosure rather than an incident or third-party risk narrative.


reasoning: The paragraph describes internal cybersecurity program evaluation activities (including tabletop exercises) and mentions using third-party service providers as a means to do so, making the company’s own risk management process the central topic rather than third-party risk alone.


reasoning: The paragraph is forward-looking boilerplate stating the company is not aware of material cyber-attacks and references Item 1A, without describing any specific incident, systems affected, or firm-specific cyber processes.


reasoning: The paragraph centers on Berkshire’s reliance on third-party service providers and the potential impact of cyber-attacks at those providers, with monitoring as a response to that third-party dependency risk.


reasoning: The paragraph discusses due diligence and contractual provisions during third-party procurement, which is central to vendor risk oversight. However, it contains no named entities, dates, tools, frameworks, or firm-specific facts, making it largely generic.


reasoning: The paragraph identifies the management roles responsible for cybersecurity responsibilities (SVP/IT Manager and ISO) and describes the ISO’s experience and training, focusing on qualifications and role coverage rather than incident or risk processes.


reasoning: The paragraph centers on named management roles (CCO and CISO) and describes their responsibilities and qualifications for cybersecurity risk assessment and management, with the CISO/CCO explicitly driving the oversight function.


reasoning: The paragraph centers on a named board subcommittee (Cyber Security Subcommittee) making initial assessments and triggering notifications to executive leadership, indicating board-level oversight of cybersecurity incident triage.


reasoning: The paragraph describes general security activities (penetration testing, aligning to industry frameworks, and using incident response/external counsel and industry collaboration) without focusing on vendor oversight as the central topic, so it fits internal risk management. It contains no named frameworks, tools, dates, roles, or other firm-unique specifics.


reasoning: The paragraph is centered on identifying the CISO, describing qualifications, reporting lines, and responsibilities, with only secondary mention of the COO’s board Risk Committee role.


reasoning: The paragraph’s grammatical subject is a management role (CIO) describing reporting lines and responsibilities for the company’s information security program, which fits Management Role. It includes firm-unique organizational details (Information Security Department led by CIO and specific reporting structure), making it Firm-Specific.


reasoning: The paragraph describes the company’s internal incident response plan and operating process (roles, escalation path, materiality assessment, and reporting/notification triggers), which is clearly an internal risk management process. It includes firm-specific role/team details (e.g., Global Information Security Team incident manager) rather than an actual incident narrative.


reasoning: The paragraph centers on oversight/reporting to the Audit Committee (and other top executives) regarding cyber threats and related internal control reviews, which is board/governance subject matter.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach (policies, programs, controls, monitoring, mitigation, training) rather than a board/management role or a specific disclosed incident.


reasoning: The paragraph contains generic forward-looking risk language (no cybersecurity attacks) and typical potential impacts, without describing any real incident details, named roles, frameworks, or other firm-specific facts.


reasoning: The paragraph centers on a named management role (“VP of IT and Facilities”) and describes its cybersecurity responsibilities, which fits the Management Role category.


reasoning: The paragraph describes the company’s own cybersecurity risk management program (risk assessments, controls, data loss prevention, training, and internal/third-party assessments) with NIST as a named standard. Although it mentions third-party risk management as part of the program, the central topic is the company’s internal risk management process.


reasoning: The paragraph centers on the Cybersecurity Council’s governance role (chaired by the CISO, briefing the Board/senior management, escalation, meeting cadence, and oversight materials like a scorecard). It contains multiple firm-specific internal governance details and named roles/teams for PSEG.


reasoning: The paragraph is primarily about the CISO’s role and how it interacts with the IOC (meetings/executive sessions) and is responsible for incident-related activities, which is management/oversight rather than internal process design. However, since the grammatical subject is the CISO and it involves oversight with an IOC, the closest category is Board Governance, though it could also fit Management Role.


reasoning: The paragraph is about the Audit Committee’s governance and oversight of cybersecurity risk (board-level update/notification mechanisms), with the board governance structure as the grammatical focus. It contains no firm-unique details beyond generic committee/board oversight language.


reasoning: The paragraph describes the company’s own proposed/expected risk assessment and safeguard process (identifying risks, likelihood/damage, and whether safeguards are sufficient), which fits risk management process rather than governance, incident disclosure, or third-party risk.


reasoning: The paragraph describes the company’s own cybersecurity activities (monitoring threats, using threat intelligence and tools, mitigating risks), which fits a risk management process description; however, it contains no named frameworks, roles, dates, tools, or other firm-specific verifiable facts.


reasoning: The paragraph is written around the Board-level Technology Committee and describes its oversight mandate and meeting cadence over technology, including cyber and related security risks.


reasoning: The paragraph primarily describes the company’s own cybersecurity preparedness activities and operations (cyber security center and monitoring/detection/response capabilities). Although third-party consultants and exercises are mentioned, they are components of the company’s internal risk management efforts rather than the central topic of vendor risk oversight.


reasoning: The paragraph describes the company’s planned internal cybersecurity program (awareness/training), policy updates, and testing/effectiveness of security controls, which are elements of its risk management process. It contains no uniquely identifiable company facts, named tools/frameworks, dates, or external entities.


reasoning: The paragraph states that executive management considers cybersecurity risk and has ultimate responsibility for overseeing the company’s cybersecurity strategy, indicating management-level oversight. However, it provides no named roles, dates, frameworks, tools, or incident details, making it generic.


reasoning: The paragraph describes the company’s own incident response procedure (policy, triage, escalation to a leadership team) and related internal processes, which fits Risk Management Process rather than incident narrative or third-party risk.


reasoning: The paragraph describes the company’s internal cybersecurity and security-risk processes (monitoring, flaw correction, backups, physical protection) and includes authorization/review steps by the IT security department. Although it mentions third-party/cloud services, that is presented as one part of the company’s internal risk-management controls rather than a standalone third-party risk program.


reasoning: The paragraph focuses on the Board's oversight of cybersecurity risks, including receiving presentations, incident updates, and annual discussions, making Board Governance the clear category as the Board is the grammatical subject. It contains no firm-specific facts, named frameworks, roles, dates, or quantifiable details, rendering it Generic Boilerplate.

provider: x-ai


reasoning: The paragraph describes the company's internal processes for assessing, identifying, and managing cybersecurity risks, including integration into enterprise risk management and handling third-party threats as a component, which fits Risk Management Process. No incident narrative, board/management roles, or vendor-centric focus is present.


reasoning: The paragraph describes the company's internal multi-stakeholder team and processes for identifying, assessing, and managing cybersecurity risks, including monitoring methods, with third parties as components rather than the central focus. The specific team composition qualifies as a firm-specific fact, making it Firm-Specific but lacking two or more hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk assessment processes, including engaging third parties to assist in designing, implementing, monitoring, and testing cybersecurity safeguards, with requirements imposed on those providers as a component of those processes. Vendor oversight is not the central standalone topic but integrated into the company's own risk management activities; the materiality statement is boilerplate.


reasoning: The paragraph outlines general cybersecurity risks, potential financial impacts, and a standalone materiality conclusion that threats have not materially affected the company to date, with no incident narrative or process details, aligning with Strategy Integration per tiebreakers.


reasoning: The paragraph centers on the identification, qualifications, reporting lines, and responsibilities of the Bank's Information Security Officer (ISO) and Chief Risk Officer (CRO), making 'Management Role' the most applicable category. It includes firm-specific elements like named cybersecurity roles and quantified experience, qualifying as Firm-Specific but lacking two or more hard verifiable facts (e.g., dates, dollars, named external firms) for Quantified-Verifiable.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risks, including receiving quarterly reports from the ERM Committee and directly from the CIO or VP Infrastructure, making the board committee the primary grammatical subject. Specific named committees and cybersecurity-related roles like CIO confirm Firm-Specific level without reaching Quantified-Verifiable threshold.


reasoning: Paragraph states no material cybersecurity impact to date (standalone materiality conclusion) and cross-references risk factors, fitting Strategy Integration per guidelines; no incident narrative or other category better matches. No named frameworks, roles, dates, metrics, or firm-specific facts present, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the company's own internal risk management processes, including ERM integration, framework adoption (FFIEC), program reviews, and cross-functional approach to cybersecurity, making Risk Management Process the best fit. Board oversight and CISO reporting are mentioned but are components of the broader internal processes rather than central topics.


reasoning: This paragraph is a cross-reference to the risk factors section (Item 1A) and quotes generic boilerplate language about potential cybersecurity risks and impacts, with no substantive disclosure on governance, processes, incidents, or strategy.


reasoning: The paragraph details the company's internal Enterprise Risk Management Program (ERM) and Enterprise Risk Assessment (ERA), including annual assessments, quarterly monitoring, and categorization of cybersecurity as one of 12 risk categories, which fits Risk Management Process as it covers risk assessment, monitoring, and ERM integration. Board reporting is mentioned briefly but is not the focus.


reasoning: The paragraph describes the company's own internal Information Security programs aligned to specific frameworks (ISO and NIST) for assessing, identifying, and managing cybersecurity risks, making 'Risk Management Process' the most applicable category. It names recognized frameworks but lacks any firm-specific facts like roles, dates, or unique programs, confirming Sector-Adapted specificity.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risk management, including reviews and discussions with the CIO and CISO, and reporting to the Board, which aligns with Board Governance as the board/committee is the grammatical subject. Mentions of CIO and CISO provide firm-specific details but do not shift the category to Management Role, per tiebreakers.


reasoning: The paragraph describes the company's internal cybersecurity processes including incident response planning, testing, training, risk assessments, threat modeling, vulnerability scanning, and penetration testing, making 'Risk Management Process' the most applicable category. No firm-specific facts, named frameworks, dates, roles, or quantifiable metrics are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centers on the board of directors and Audit Committee's oversight of cybersecurity risks, with them as the primary grammatical subjects, fitting Board Governance; mentions of specific IT leadership roles reporting to them support this without shifting focus to Management Role.


reasoning: The paragraph states no material past cybersecurity incidents or effects and assesses future risks as reasonably likely to be material, which is a standalone materiality conclusion without incident narrative, fitting Strategy Integration. It includes forward-looking disclaimers and a risk factor cross-reference, with no substantive disclosure on governance, processes, or roles.


reasoning: The paragraph primarily details management roles, reporting lines (VP IT Data Security reports to CTO), and the Cybersecurity Committee composed of executives, with board oversight mentioned only briefly at the start; per tiebreakers, this fits Management Role. Multiple cybersecurity-specific roles and named committee make it Firm-Specific, with no hard verifiable facts (dates, dollars, etc.) reaching Quantified-Verifiable.


reasoning: The paragraph details the company's own internal processes for risk identification, threat assessment, monitoring, control evaluation, and mitigation, including a process for third-party risks as a minor component, making Risk Management Process the best fit. The mention of a 'dedicated InfoSec team' qualifies as a firm-specific cybersecurity team, elevating specificity to Firm-Specific with no hard verifiable facts reaching Quantified-Verifiable.


reasoning: The paragraph focuses on the Audit Committee's and full Board's oversight of cybersecurity risks, including monitoring via reports from management and quarterly reporting to the Board, with the board/committee as the grammatical subject. No firm-specific facts, named frameworks, roles, dates, or quantifiable details are present, matching generic boilerplate governance language.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including framework adoption (NIST), team assessments, monitoring, third-party assistance as a component, departmental integration, policy incorporation, and quarterly reviews, making Risk Management Process the best fit. It includes firm-specific elements like the dedicated cybersecurity team, specific departmental compositions, and named Information Security Policy, exceeding Sector-Adapted (NIST alone) but lacking two hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph details the Trustee's internal cyber risk management program, protocols, training, and annual third-party assessment, focusing on the company's own processes for identifying, assessing, and mitigating cybersecurity threats, integrated into overall risk management, which matches Risk Management Process. No named frameworks, roles, dates, vendors, or other specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph primarily describes the Board of Directors' oversight responsibilities, assessments, and interactions regarding cybersecurity risks, with the board as the repeated grammatical subject; the HSE Director is mentioned as part of this oversight structure but not as the central focus.


reasoning: The paragraph describes the company's internal cybersecurity processes including vulnerability management, monitoring via a service provider, and an incident response plan aligned with NIST, which fits Risk Management Process. Board and Audit Committee are mentioned only briefly as escalation points, not as the main focus.


reasoning: The paragraph details the company's internal escalation and response processes for cybersecurity threats and incidents, including notifications, risk assessment, and reporting requirements, making 'Risk Management Process' the best fit. It contains multiple firm-specific elements like named roles and committees, but lacks two or more hard verifiable facts (e.g., dates, dollars, external firms) required for Quantified-Verifiable.


reasoning: The paragraph centers on the CDIO/CISO's identification, qualifications, reporting structure, experience, team oversight, and interactions with the TCRC, making 'Management Role' the clear fit as the management role is the primary grammatical subject. Multiple hard verifiable facts (specific date and several named external firms) exceed the threshold for Quantified-Verifiable.


reasoning: Paragraph describes the company's internal risk assessment processes, control development based on frameworks, and ongoing assessments, fitting Risk Management Process; third-party involvement is a minor component, not central. Named frameworks qualify as Sector-Adapted with no firm-specific facts like roles, dates, or unique programs.


reasoning: The paragraph describes the company's internal processes including incident response planning, tabletop exercises, business continuity plans, employee training, and risk-based security controls, which fits Risk Management Process as the company's own processes are the central topic. No named frameworks, roles, dates, metrics, or unique firm-specific details are present, making it Generic Boilerplate.


reasoning: The paragraph details the company's own internal processes and procedures for protecting data/systems, monitoring via tools like SIEM with behavioral analytics, and conducting periodic penetration testing, fitting Risk Management Process as the central topic. It contains no named frameworks, roles, dates, metrics, or other firm-specific facts, qualifying as Generic Boilerplate.


reasoning: The paragraph describes the Board's primary responsibility for cybersecurity oversight, the Audit Committee's review role, and the formation of a Cybersecurity Risk Subcommittee with specific expertise requirements, centering on board/committee oversight.


reasoning: The paragraph focuses on the Board of Directors and Audit Committee overseeing cybersecurity risks, receiving quarterly reports, and the flow of incident information to the Board, making Board Governance the primary category as the board/committee is the grammatical subject. No firm-specific facts, named frameworks, or verifiable metrics are present; all elements like 'Audit Committee,' 'quarterly reports,' and generic C-suite roles are boilerplate.


reasoning: The paragraph centers on the CIO and senior leaders as the grammatical subjects reviewing cybersecurity metrics and leading the response plan, with reporting lines to committees, fitting Management Role; brief mentions of committees do not shift focus to Board Governance per tiebreakers.


reasoning: The paragraph primarily describes the board of directors and audit committee's oversight responsibilities for cybersecurity risks and incidents, with management roles mentioned secondarily as part of that oversight structure. Tiebreaker notes board/committee as grammatical subjects for oversight, despite naming specific management leaders.


reasoning: Paragraph focuses on materiality conclusions regarding past vague incidents ('experienced cybersecurity incidents, from time to time' with no material impact) and no reasonably likely future risks, fitting Strategy Integration per tiebreakers for brief incident mention + materiality as main point; board oversight is briefly mentioned but generic and not central.


reasoning: The paragraph focuses on the Board, Audit Committee, and Cybersecurity Subcommittee's oversight responsibilities for cybersecurity risks, making Board Governance the clear fit as board/committees are the grammatical subjects. It contains firm-specific elements like the named Cybersecurity Subcommittee and its 2023 establishment, qualifying as Firm-Specific but lacking two hard verifiable facts (e.g., only one date, no dollars/headcounts/external firms) for Quantified-Verifiable.


reasoning: The Board and Audit Committee are the grammatical subjects actively involved in oversight of the cybersecurity program, aligning with Board Governance; brief mentions of internal processes and NIST framework introduce some overlap with Risk Management Process but do not override the board focus.


reasoning: Paragraph details the company's internal cybersecurity risk management processes, including policies like vulnerability management, training, and third-party due diligence as one element, with NIST framework adoption. OFS Advisor is a firm-specific entity, elevating beyond Sector-Adapted.


reasoning: The paragraph centers on identifying and describing specific management roles (e.g., Director of IT Infrastructure & Security, VP of IT), their qualifications, expertise, and reporting lines, which aligns with Management Role; board reporting is mentioned briefly but not the focus per tiebreakers.


reasoning: The paragraph centrally describes oversight of third-party providers, vendors, and consultants, including security assessments, contractual requirements, and penetration studies, making Third-Party Risk the most applicable category rather than a component of internal Risk Management Process.


reasoning: The paragraph focuses on the CISO as the primary subject, detailing their qualifications, experience, responsibilities, and team oversight, which aligns with 'Management Role' criteria for management roles like CISO identification and qualifications.


reasoning: The paragraph details the company's own internal cybersecurity processes, including adoption of the NIST CSF framework, incident detection/response processes, operational plans, and regular exercises, fitting Risk Management Process. It lacks references to board oversight, specific roles, incidents, third-parties, or strategy elements.


reasoning: The paragraph provides a standalone materiality assessment stating no material breaches or significant expenses to date and acknowledges potential future impacts on business and finances, with a cross-reference to risk factors, fitting Strategy Integration. No named frameworks, roles, dates, metrics, or other firm-specific facts are present; CEO/CFO are generic C-suite titles and MSP is vague/unnamed.


reasoning: The paragraph describes the company's internal training programs, simulations, and exercises for cybersecurity awareness and incident response preparedness, which falls under own internal risk management processes. No specific facts, named frameworks, roles, dates, or quantifiable elements are present, making it generic boilerplate.


reasoning: The paragraph describes a specific past cybersecurity incident including what happened (unauthorized access and download of user information from 23andMe.com accounts), when (October 2023), and response actions (system enhancements, password resets, two-factor verification), fitting Incident Disclosure perfectly. It contains at least two hard verifiable facts (specific date and named system), qualifying as Quantified-Verifiable.


reasoning: The paragraph provides a materiality assessment stating no cybersecurity threats materially affected or are anticipated to affect business strategy, results of operations, or financial condition in fiscal 2025, with only brief generic mentions of past intrusions, aligning with Strategy Integration per tiebreakers for brief incident mentions + materiality conclusion. It includes cross-references but substantive disclosure on financial/business impact.


reasoning: The paragraph describes the Board's overall responsibility for enterprise risk management, delegation to the Audit Committee for cybersecurity oversight, and reporting cadences from management, making the board/committees the grammatical subjects. This clearly fits Board Governance; Audit Committee is standard and not firm-specific, with no unique facts, dates, or named elements.


reasoning: The paragraph centers on the Information Security team, CISO, CITO, and CEO's roles, qualifications, experience, education, certifications, and reporting lines, making 'Management Role' the clear fit per guidelines. Multiple firm-specific elements like named cybersecurity roles (CISO), quantified experience, and specific certifications elevate it to Firm-Specific, with no two hard verifiable facts (e.g., dates, dollars) for Quantified-Verifiable.


reasoning: The paragraph details the company's internal cybersecurity program, including framework adoption (NIST, GDPR, ISO 27001 certification), security controls, monitoring, incident response, and assessments, which aligns with Risk Management Process as the central topic of own processes. ISO 27001 certification is a firm-specific fact elevating beyond Sector-Adapted, with no hard verifiable facts (dates, amounts, named firms/tools) reaching Quantified-Verifiable.


reasoning: The paragraph details the company's internal processes for cybersecurity assessments, vulnerability management, monitoring, and related activities performed by specific teams, fitting Risk Management Process; third-party mention is incidental, not central. Named internal teams and services provide firm-specific details without named frameworks or two+ verifiable hard facts (no dates, amounts, or named external firms).


reasoning: Paragraph briefly mentions a past cybersecurity incident in August 2020 but focuses on materiality conclusion (no material impact) and forward-looking disclaimer, fitting Strategy Integration per tiebreaker for brief incident mention + materiality as main point.


reasoning: The paragraph focuses on the CISO's role, leadership of the ISC, qualifications, experience, and certifications, making 'Management Role' the most applicable category as the CISO is the grammatical subject with detailed personal specifics. No board oversight or internal processes dominate; ISC supports but centers on CISO.


reasoning: The paragraph details the company's own cybersecurity risk management program, including framework adoption for identifying, assessing, and managing risks, which aligns with Risk Management Process. It names specific recognized frameworks (NIST CSF and SOX) but lacks any firm-specific facts like roles, dates, or unique programs, making it Sector-Adapted.


reasoning: The paragraph describes the company's internal risk management processes through the ERM committee's quarterly meetings, risk assessments, action plans, and remediation, with cybersecurity integrated via inputs from the CISO and CDO. This fits 'Risk Management Process' as the central topic on own internal processes, not primarily focused on specific management roles or board oversight.


reasoning: This paragraph assesses the material impact of cybersecurity risks, stating no material past incidents, immaterial expenses, and no known risks likely to materially affect the business, which aligns with Strategy Integration for materiality conclusions without incident narrative. It includes forward-looking statements and a cross-reference to Risk Factors, reinforcing the financial/business impact focus.


reasoning: The paragraph focuses centrally on vendor/supplier oversight processes, including assessments, monitoring, and a named charter, which matches Third-Party Risk criteria over general Risk Management Process. It includes firm-specific facts like the named Sustainable Purchasing Charter and Information Security Department, but lacks two or more hard verifiable facts for higher specificity.


reasoning: This paragraph consists of forward-looking disclaimers about the increasing sophistication of cybersecurity threats and the potential insufficiency of controls, with a cross-reference to Risk Factors, providing no substantive disclosure on governance, processes, incidents, or strategy.


reasoning: The paragraph focuses on the company's own internal processes for assessing, identifying, and managing cybersecurity risks through IT systems, aligning with the Risk Management Process category. It lacks any named frameworks, roles, dates, or other specific facts, making it generic boilerplate.


reasoning: The paragraph details the company's internal processes for evaluating and testing information security using external experts, conducting training, and refining policies based on results, which aligns with Risk Management Process as these are components of their own risk assessment and monitoring. External experts are mentioned as tools within internal processes, not as the central topic of vendor oversight. No specific facts, frameworks, or named entities are present, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for risk assessment, framework adoption (NIST), ERM integration, and team coordination for reviewing risks, making Risk Management Process the best fit; board/management mention is brief and introductory, not the focus.


reasoning: This paragraph provides a detailed narrative of a specific cybersecurity incident, including the date it occurred, the affected system (Dropbox Sign), scope of unauthorized access to user data, response actions taken, and limitations of impact, directly matching Incident Disclosure criteria.


reasoning: The paragraph focuses on the Board of Directors and Audit Committee's oversight of cybersecurity risks, including meeting cadences with the CSO, making board/committee the grammatical subject which aligns with Board Governance. CSO is a cybersecurity-specific role, qualifying as a firm-specific fact, but no hard verifiable facts like dates or named firms reach Quantified-Verifiable.


reasoning: This paragraph provides a narrative of a real cybersecurity incident, including the determination date, unauthorized access by a third party, response actions like incident protocols and containment, and scope of disruption, directly matching Incident Disclosure criteria.


reasoning: This paragraph describes a real cybersecurity incident with detection date, response actions (activated procedure, external experts, law enforcement), scope of affected systems (IT systems, business applications for operations, financial and operating reporting), and ongoing impact, clearly fitting Incident Disclosure. It includes one hard verifiable fact (specific date), making it Firm-Specific but not Quantified-Verifiable (needs two).


reasoning: The paragraph focuses on the CISO's identification, qualifications, certifications, reporting lines, and the CEO's relevant experience, making 'Management Role' the clear fit as management roles are the grammatical subjects. Board oversight is mentioned briefly but not central. Multiple firm-specific facts like the named CISO role, specific university, certifications held, and dated experience exceed Generic/Sector-Adapted but lack 2+ hard verifiable facts (only one clear date range) for Quantified-Verifiable.


reasoning: The paragraph focuses on the VP of IT's role, responsibilities, qualifications, reporting lines to CFO and Audit Committee, and the composition of the IT Executive Steering Committee and security team, making management roles the grammatical subject. Brief mention of Audit Committee updates does not shift to Board Governance per tiebreakers.


reasoning: Paragraph describes a real cybersecurity incident with date, unauthorized access details, response actions, containment, business disruption, and remediation status, directly matching Incident Disclosure criteria. Contains one hard verifiable fact (specific date), meeting Firm-Specific threshold but not Quantified-Verifiable (needs two).


reasoning: This paragraph provides a detailed narrative of a specific cybersecurity incident, including timeline, scope (small percentage of employee emails including senior leadership and key functions), threat actor, response actions (access removal, investigation, notifications), and initial impact assessment, fitting Incident Disclosure per guidelines and tiebreakers. Multiple specific dates (late November 2023, January 12/13, 2024) qualify as two or more hard verifiable facts, making it Quantified-Verifiable.


reasoning: This paragraph provides a detailed narrative of a specific cybersecurity incident, including detection and access dates, threat actor description, data exfiltration scope (client PII, administrative data, employee/contractor accounts), and response actions like incident response activation and law enforcement notification, clearly fitting Incident Disclosure. Two specific dates qualify it as Quantified-Verifiable.


reasoning: This paragraph provides a narrative of a specific cybersecurity incident, including detection date, response actions (activating incident response procedure, engaging experts, notifying law enforcement), and scope/impact on systems and operations, directly matching Incident Disclosure. It includes one hard verifiable fact (specific date), qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second verifiable fact like a named firm or tool.


reasoning: The paragraph primarily describes the company's planned internal cybersecurity risk management processes, including systematic identification, assessment, management of risks, integration into overall ERM, use of technologies, third-party consultant support (as a component), and specific activities like vulnerability management and penetration testing. Board oversight is mentioned briefly at the start but is not the main focus; third-party is not central.


reasoning: Paragraph describes a specific cybersecurity incident with timeline (late November 2023), scope (small percentage of emails from senior leadership, cybersecurity, legal functions), actor activities (exfiltration, access to source code repos), and ongoing response, directly matching Incident Disclosure. Contains one hard verifiable fact (date) and firm-specific elements (named teams/functions, source code repositories), but not two+ hard facts for Quantified-Verifiable.


reasoning: Paragraph details the scope (impacted IT systems, billing/label making functions), response actions (contingency plans, data backups), and operational impact (operations continued) of a specific cybersecurity incident, directly matching Incident Disclosure criteria. No named roles, dates, frameworks, third-parties, tools, or quantifiable metrics present, making it entirely generic boilerplate.


reasoning: This paragraph details a specific cybersecurity incident involving a former employee accessing customer data from up to 33 million accounts, including scope of data, response actions, and regulatory involvement, fitting Incident Disclosure. It contains one hard quantifiable fact (33 million accounts) and other firm-unique incident details, making it Firm-Specific but not Quantified-Verifiable due to lacking a second verifiable fact like a date or named firm.


reasoning: The paragraph describes a specific cybersecurity incident, including what happened (website defacement by a bad actor), when (August 25, 2025), scope (website at wytecintl.com defaced twice), and response actions (restored from backups, took site down, reviewed platform), clearly fitting Incident Disclosure. It includes two hard verifiable facts: a specific date and a named system (wytecintl.com).


reasoning: This is a standard forward-looking statement disclaimer and safe harbor provision with vague references to 'the Incident' but no substantive cybersecurity disclosure, cross-references, or details, fitting 'None/Other'.


reasoning: This paragraph describes an actual cybersecurity incident including unauthorized access, data exfiltration (specific details on images of video meetings and screens), threat actor demands, response actions, and operational/financial impacts, fitting Incident Disclosure per guidelines and tiebreakers. It contains one firm-specific fact (fiscal quarter reference), making it Firm-Specific but not Quantified-Verifiable due to lacking a second hard verifiable fact.


reasoning: The paragraph assesses the financial and operational impact and materiality of a specific incident without providing any incident narrative, response details, or scope, fitting Strategy Integration per tiebreakers for financial impact assessment without describing what happened. No specific dates, amounts, named entities, frameworks, or other verifiable facts are present, making it Generic Boilerplate.