content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph discusses the company's general risk posture and concludes with a statement regarding the lack of material impact from cybersecurity threats to date, which aligns with Strategy Integration.

provider: google


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal process for managing third-party involvement in their cybersecurity program, rather than focusing on vendor oversight as a standalone risk management strategy. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


content_category: Board Governance

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


reasoning: The paragraph describes the company's internal risk management framework and assessment processes, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it names unique internal programs (ERM and ERA) and provides a specific count of risk categories.


reasoning: The paragraph describes the company's internal risk management structure and processes, specifically identifying the departments involved in their cybersecurity team.


reasoning: The paragraph describes the company's internal approach to managing cybersecurity risks and information security programs, fitting the Risk Management Process category. It is classified as Sector-Adapted because it explicitly names recognized frameworks (ISO and NIST) without providing firm-specific details.


reasoning: The paragraph describes the company's internal risk management processes and their integration into the broader enterprise risk management system, which is the core definition of the Risk Management Process category. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


content_category: Management Role

reasoning: While the paragraph mentions Board oversight, the central focus is the identification, qualifications, and reporting line of the specific management role (HSE Director) responsible for the cybersecurity program.


reasoning: The paragraph focuses primarily on the Board's oversight responsibilities and reporting structure. The roles mentioned (President, Chief Executive Officer, General Counsel) are classified as generic C-suite titles and do not constitute firm-specific facts.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and directs the reader to other sections of the filing, which fits the Strategy Integration category.


reasoning: The paragraph focuses on the Board's oversight responsibilities, specifically detailing the Audit Committee's role and its interaction with management roles like the CIO and CISO.


reasoning: While the paragraph mentions the Board, the primary focus and the majority of the text detail specific management roles (VP, IT Data Security; CTO) and internal committees (Cybersecurity Committee) responsible for cybersecurity, making Management Role the most applicable category.


content_category: None/Other

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


reasoning: The paragraph describes internal cybersecurity processes such as incident response planning, training, and risk assessment. It contains no specific dates, named frameworks, unique program identifiers, or specific roles, making it generic boilerplate.


reasoning: The paragraph consists entirely of forward-looking disclaimers and a cross-reference to a risk factor, with no substantive disclosure regarding governance, management, or specific processes.


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


reasoning: The paragraph describes the company's internal risk management processes, including the use of frameworks and cross-functional collaboration to assess threats. It is classified as Sector-Adapted because it explicitly names the NIST framework but lacks sufficient firm-specific facts (like named roles or unique programs) to reach the Firm-Specific level.


reasoning: The paragraph focuses primarily on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity, making Board Governance the most appropriate category. It is classified as Firm-Specific because it identifies unique management roles (Vice President of Operation & Information Technology and Head of Information Technology) that report to the committee.


reasoning: The paragraph describes the company's internal incident response and escalation procedures, which is the core definition of Risk Management Process. It is classified as Firm-Specific because it names unique internal committees (Technology Risk Management Committee, Materiality Committee) and a specific role (Senior Director of Information Security).


reasoning: The paragraph details the company's internal risk management and monitoring processes, with the 'InfoSec team' serving as a specific internal entity, making it firm-specific.


reasoning: The paragraph primarily describes the company's integration of cybersecurity into its enterprise risk management (ERM) program and the reporting structure of its security leadership. While it mentions the Board and frameworks, the focus is on the internal risk management processes and the specific roles of the CISO and CRO.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risk, including risk assessments and control implementation. It is classified as Sector-Adapted because it explicitly names recognized security frameworks (CIS and PCI DSS) without providing firm-specific details like unique program names or specific roles.


reasoning: The paragraph focuses primarily on the Audit Committee's oversight responsibilities regarding cybersecurity, which falls under Board Governance. While it mentions management roles, the primary grammatical subject and thematic focus is the board/committee's oversight function.


reasoning: The paragraph describes the company's internal cybersecurity processes, including vulnerability management and incident response planning, which falls under Risk Management Process. It is classified as Sector-Adapted because it explicitly references the NIST framework but lacks unique, firm-specific identifiers or multiple verifiable facts.


reasoning: The paragraph focuses on the board's oversight responsibility as the primary subject, with management/consultants mentioned only in relation to reporting to the board. The references to past incidents and materiality are generic boilerplate disclaimers without specific details.


reasoning: The paragraph describes internal security processes like incident response plans, tabletop exercises, and training, which are standard risk management activities. It contains no specific names, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the oversight responsibilities of the Audit Committee and the Board, which is a standard governance disclosure. It contains no unique identifiers, specific cybersecurity roles, or verifiable facts.


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


reasoning: The paragraph focuses on the responsibilities and reporting lines of the CIO and other senior leaders, making Management Role the primary category. It is Firm-Specific because it identifies specific roles (CIO, CEO) and specific committees (Audit Committee, ERM Committee) involved in the governance structure.


reasoning: The paragraph focuses on the Board's oversight structure, specifically detailing the delegation of responsibilities to a named committee (the Cybersecurity Subcommittee).


reasoning: The paragraph focuses on the identification, qualifications, and reporting lines of the company's cybersecurity leadership, fitting the Management Role category. It contains multiple verifiable facts, including specific dates and named external firms, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses primarily on the Board and Audit Committee's role in cybersecurity oversight, which aligns with the Board Governance category. It mentions the NIST Cybersecurity Framework, making it Sector-Adapted, but lacks sufficient firm-specific facts to reach the Firm-Specific level.


reasoning: The paragraph focuses on the specific roles (Director, IT Infrastructure & Security; VP of IT) and organizational structure responsible for cybersecurity, making 'Management Role' the primary category.


reasoning: The paragraph focuses primarily on the Board of Directors' oversight responsibilities and the reporting structure to the Board. It contains no specific facts, named cybersecurity roles, or unique identifiers, relying entirely on generic corporate governance language.


reasoning: The paragraph describes the company's internal security processes and tools in general terms without naming specific vendors, products, frameworks, or unique identifiers.


reasoning: The paragraph describes the company's internal incident response process, specifically identifying the roles involved in assessments (CEO, CFO, and MSP). While it mentions potential material impact, the core of the paragraph is about the internal process for handling incidents.


reasoning: The paragraph describes the company's internal cybersecurity policies, procedures, and risk management framework. It is classified as Firm-Specific because it identifies specific internal entities (OFS Advisor, IT Department) alongside the NIST framework.


reasoning: The paragraph details the board's oversight structure, specifically naming a unique 'Cybersecurity Risk Subcommittee' and providing the number of directors serving on it, which meets the threshold for quantified facts.


reasoning: The paragraph describes the company's internal incident detection and response processes and references the NIST Cybersecurity Framework (NIST CSF) as the basis for their program.


reasoning: The paragraph describes the company's internal risk management processes and security controls. It is classified as Firm-Specific because holding an ISO 27001 certification is a verifiable, unique fact about the company's security posture, which elevates it beyond Sector-Adapted.


reasoning: The paragraph describes internal training programs and risk assessment activities (simulations, tabletop exercises), which are standard components of a company's internal risk management process. All mentioned activities (phishing simulations, tabletop exercises, training) are explicitly listed as generic security practices in the instructions and do not constitute firm-specific facts.


reasoning: The paragraph contains a standalone materiality conclusion regarding cybersecurity threats for the fiscal year, which falls under Strategy Integration. It is Firm-Specific because it references a specific fiscal year (fiscal 2025).


reasoning: The paragraph focuses entirely on the qualifications, responsibilities, and background of the CISO, which falls squarely under Management Role.


content_category: Third-Party Risk

reasoning: The paragraph focuses primarily on the company's oversight, contractual requirements, and engagement of third-party vendors and consultants, making Third-Party Risk the most applicable category.


reasoning: The paragraph focuses on the Board's oversight structure and the delegation of cybersecurity risk responsibilities to the Audit Committee. While the Audit Committee is named, it is a standard governance structure and does not qualify as a firm-specific fact in this context, resulting in a Generic Boilerplate classification.


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident that occurred in October 2023 and details the subsequent response actions taken by the company.


reasoning: While the paragraph mentions internal training, the central focus of the text is the company's oversight of third-party providers, including specific references to their 'Sustainable Purchasing Charter' and the 'Information Security Department's' role in monitoring them.


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


reasoning: The paragraph focuses on the identification and qualifications of the CISO and the internal governance structure (ISC), which are management-related roles. It contains multiple verifiable facts, including specific professional certifications and tenure duration.


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


reasoning: The paragraph focuses on the materiality assessment of cybersecurity risks and incidents on the company's financial condition and business strategy, which is classified as Strategy Integration. It includes a specific date regarding a past incident, making it Firm-Specific.


reasoning: The paragraph primarily describes the company's internal risk management processes and framework adoption, specifically mentioning the NIST Cybersecurity Framework and integration into their ERM program.


reasoning: The paragraph details the specific management-level committee (ERM) and the reporting roles (CISO, CDO) responsible for cybersecurity risk oversight, fitting the Management Role category.


reasoning: The paragraph is a cross-reference to the Risk Factors section and contains standard forward-looking disclaimers about the limitations of cybersecurity controls, which does not constitute substantive disclosure.


reasoning: The paragraph focuses on the Board of Directors' oversight responsibilities and their interaction with the CSO and Audit Committee, making it a clear Board Governance disclosure. It is classified as Firm-Specific because it identifies the specific role (CSO) involved in these governance interactions.


reasoning: The paragraph describes the company's intended internal risk management processes and framework, making 'Risk Management Process' the most applicable category. It is classified as 'Firm-Specific' because it explicitly mentions the company's unique governance structure regarding the absence of an Audit Committee.


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


reasoning: The paragraph describes the company's internal cybersecurity assessment and monitoring processes, specifically identifying the 'operational risk management group' as a key internal entity responsible for these tasks.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risks without providing any specific details, frameworks, or unique identifiers.


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


reasoning: The paragraph describes the details, scope, and ongoing nature of a specific cybersecurity incident, which is the definition of Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the affected system, and the scope of the data accessed, which qualifies as an incident disclosure.


reasoning: The paragraph describes the company's internal processes for security testing, training, and management review without naming specific entities, frameworks, or unique programs.


reasoning: The paragraph focuses on the roles, reporting lines, and specific professional qualifications of the CISO and the Information Security team, which is the definition of Management Role.


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


reasoning: The paragraph describes a specific cybersecurity incident, including dates of detection and remediation, and the scope of the affected personnel, which falls squarely under Incident Disclosure.


reasoning: The paragraph focuses on the qualifications, reporting lines, and background of the CISO and CEO, which falls squarely under Management Role. It contains multiple verifiable facts, including specific certifications, degrees, and historical dates/roles, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses primarily on the identification, responsibilities, and qualifications of the VP of IT and the IT Executive Steering Committee, which falls squarely under Management Role. It qualifies as Quantified-Verifiable because it contains multiple hard facts, including specific tenure durations (three years, 25 years) and a list of specific named roles and committees.


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


reasoning: The paragraph describes the details, scope, and response actions related to a specific cybersecurity incident involving a third-party provider, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including dates of detection and occurrence, the nature of the threat actor, and the scope of the data exfiltration.


reasoning: The paragraph provides a detailed description of the scope and nature of data involved in a specific cybersecurity incident, which is the core definition of Incident Disclosure.


reasoning: The paragraph describes the details of an actual cybersecurity incident, including the nature of the exfiltrated data and the operational impact, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the scope and nature of an ongoing cybersecurity incident, including the exfiltration of data and the company's response actions, which fits the Incident Disclosure category. It contains no specific dates, named firms, or other verifiable facts, making it generic.


reasoning: The paragraph focuses on the materiality assessment and financial impact of an incident without describing the incident itself, which aligns with Strategy Integration. It contains no specific dates, dollar amounts, or named entities, making it generic boilerplate.


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


reasoning: The paragraph describes the financial impact and remediation estimates related to a specific cybersecurity incident. While it contains a dollar range, it only provides one hard verifiable fact (the dollar range), making it Firm-Specific rather than Quantified-Verifiable.


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


reasoning: The paragraph describes the nature, impact, and response actions related to a specific cybersecurity incident, which falls squarely under Incident Disclosure. It is classified as Firm-Specific because it references a specific prior filing ('Original Form 8-K') unique to this company's disclosure history.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the event (unauthorized access, encryption, data theft), and the company's response actions.


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


reasoning: The paragraph describes a specific cybersecurity incident, including the date of notification, the threat actor involved, and the timeline of the breach, which clearly falls under Incident Disclosure.


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


reasoning: The paragraph focuses on the materiality assessment of an incident and its financial impact, which falls under Strategy Integration. It is Firm-Specific because it references specific fiscal dates and a specific past press release date.


reasoning: The paragraph describes a specific cybersecurity incident involving a named subsidiary, including the date of discovery and the response actions taken, which qualifies as an incident disclosure.


reasoning: The paragraph focuses on the materiality assessment and financial impact of an incident rather than describing the incident itself, fitting the Strategy Integration category. It contains two specific dates, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including the timeline of the event and the specific cause, which qualifies as an Incident Disclosure.


reasoning: The paragraph provides a materiality assessment regarding the financial impact of an incident and mentions insurance coverage without describing the incident itself, which aligns with Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including detection and remediation timelines, which falls under Incident Disclosure. It contains two specific dates, meeting the threshold for Quantified-Verifiable.


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


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


reasoning: The paragraph describes a specific cybersecurity incident (ransomware) and the company's response to it, which falls squarely under Incident Disclosure. It is Firm-Specific because it references specific dates related to the incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence and the specific website affected, which constitutes an incident disclosure.


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


reasoning: The paragraph focuses on the financial and operational materiality of an incident without describing the incident itself, which aligns with Strategy Integration. It contains no specific dates, dollar amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph focuses on the financial impact and liquidity strategy resulting from a cybersecurity incident, rather than describing the incident itself or internal risk management processes.


reasoning: The paragraph describes a specific cybersecurity incident involving a third-party vendor (CDK Global), the date of the incident, and the operational impact on specific internal systems.


reasoning: The paragraph describes an ongoing cybersecurity incident, including specific dates of the event and the filing, and names the affected third-party provider and internal systems.


reasoning: The paragraph describes a specific cybersecurity incident, including the detection date and references to a prior filing, which qualifies it as an incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, the company's response actions, and the operational impact, which fits the Incident Disclosure category. It is Firm-Specific because it names the company involved, though it lacks the two hard verifiable facts required for Quantified-Verifiable.


reasoning: The paragraph describes the operational impact and remediation timeline of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It is classified as Firm-Specific because it identifies the specific geographic locations affected (domestic and Mexico) and a specific timeframe for restoration (mid-June), though it lacks the two hard verifiable facts required for Quantified-Verifiable.


reasoning: The paragraph describes the status and impact of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It is Firm-Specific because it references the filing date (via 'As of the date of this Report') and discusses the specific status of an ongoing investigation.


reasoning: The paragraph focuses on the financial impact (insurance recovery) and a materiality assessment of a previously disclosed incident, which falls under Strategy Integration. It contains no specific dates, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the nature of the intrusion, and the operational impact, which qualifies as an Incident Disclosure.


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


reasoning: The paragraph focuses on the responsibilities and reporting lines of the Chief Technology Officer, which is a specific management role.


reasoning: The paragraph focuses on the financial and operational impact of an incident, specifically revenue recognition delays and expenses, without describing the incident itself. It contains firm-specific details regarding the company's unique revenue recognition process and specific fiscal periods.


reasoning: The paragraph describes the scope and nature of an actual cybersecurity incident, including the type of data accessed and the affected business unit, which places it squarely in Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, response actions taken, and the operational impact, which clearly falls under Incident Disclosure.


reasoning: The paragraph focuses on identifying specific management roles (CIO, Information Security Director) and their qualifications, which is the primary subject of the text.


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


reasoning: The paragraph describes the board's oversight structure and delegation to the audit committee, which is standard governance language applicable to most public companies.


reasoning: The paragraph describes general internal activities related to risk management and compliance without naming specific frameworks, roles, or unique programs.


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


reasoning: The paragraph provides a materiality conclusion regarding past incidents and expenses, which falls under Strategy Integration. It is Firm-Specific because it references a specific timeframe ('last two fiscal years') regarding the company's own incident history.


reasoning: The paragraph focuses on the specific management role (CFO) responsible for cybersecurity oversight and their reporting line to a specific board committee, making it a Management Role disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents without describing any specific events or internal processes.


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


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


reasoning: The paragraph focuses on the Board of Directors' oversight responsibilities, including training, policy approval, and the delegation of duties to a specific committee.


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


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


reasoning: The paragraph primarily focuses on a materiality conclusion regarding cybersecurity risks and their impact on the business, which falls under Strategy Integration. It contains no specific dates, named roles, frameworks, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph focuses on the Audit Committee's role in overseeing cybersecurity risks, which places it squarely in Board Governance. All mentioned roles and committees are standard corporate governance structures and do not constitute firm-specific facts.


reasoning: The paragraph focuses on the roles and responsibilities of management (specifically the CSO and enterprise risk management team) in addressing cybersecurity risks, making 'Management Role' the most appropriate category.


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


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risk, specifically training, testing, and assessments. It is classified as Firm-Specific because it identifies a specific internal entity, the 'Cybersecurity Team', which distinguishes it from generic boilerplate.


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


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


reasoning: The paragraph focuses exclusively on the identification, qualifications, and tenure of the CISO and CTO, which falls squarely under Management Role.


reasoning: The paragraph details the company's internal incident response and escalation procedures, which is a core component of risk management. It is classified as firm-specific because it identifies unique internal organizational bodies such as the 'Incident Management Team' and 'Privacy and Security Subcommittee'.


reasoning: The paragraph discusses the materiality of cybersecurity risks and mentions expenditures on cyber insurance without describing a specific incident or internal process, fitting the Strategy Integration category.


reasoning: The paragraph describes the company's general approach to using third-party experts for risk management and testing, which falls under internal risk management processes. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for the year 2023, which falls under Strategy Integration. It is Firm-Specific because it references a specific fiscal year (2023) in the context of its materiality assessment.


reasoning: The paragraph focuses on identifying the specific individual responsible for cybersecurity risk management and their qualifications, which falls squarely under Management Role.


reasoning: The paragraph provides a materiality conclusion regarding past incidents and financial impact without describing a specific incident narrative, which aligns with the Strategy Integration category.


reasoning: The paragraph focuses on the Board's assignment of cybersecurity oversight to the Audit Committee, which is the primary subject of the text. While it mentions an 'IRP' (Incident Response Plan), the core governance structure is the main topic.


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


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


reasoning: The paragraph primarily describes the board of directors' oversight role regarding cybersecurity and risk management, making Board Governance the most applicable category. It is classified as Sector-Adapted because it references recognized frameworks (NIST and ISO) but lacks unique, firm-specific operational details.


reasoning: The paragraph describes the company's internal approach to risk management and incident response procedures, which falls squarely under Risk Management Process. It contains no specific roles, dates, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph details the company's internal cybersecurity risk management activities, including committee meetings and training programs, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies a specific internal 'Security Committee' and a specific role, 'head of Information Security'.


reasoning: The paragraph focuses on the Board's oversight activities and the reporting structure to the Board, making Board Governance the primary category. It is classified as Firm-Specific because it identifies specific cybersecurity-related roles (CIO, CISO, CIRO) within the organization.


reasoning: The paragraph focuses on the specific roles of the CISO and CTO, their reporting lines, and their responsibilities, which falls squarely under Management Role.


reasoning: While the paragraph mentions board oversight, the core substantive disclosure identifies a specific management role (Vice President of Operations) responsible for the cybersecurity program, which takes precedence under the tiebreaker rules.


reasoning: The paragraph describes the company's internal risk management activities, specifically the engagement of external entities for simulation exercises and ongoing monitoring, which falls under Risk Management Process. It is Firm-Specific because it cites a specific timeframe (fiscal 2024) and specific types of organizations (ISACs) used in their process.


reasoning: The paragraph focuses on the qualifications and professional background of specific management personnel (VP of Information Systems and CFO) in relation to cybersecurity oversight.


reasoning: The paragraph describes the establishment of a board-level Cybersecurity Committee and details the specific qualifications of its chair, which is a core component of board governance and oversight.


reasoning: The paragraph consists entirely of forward-looking disclaimers regarding potential risks and insurance limitations, which falls under the None/Other category.


reasoning: The paragraph focuses on the organizational structure and management oversight of cybersecurity, specifically identifying the IT department and the CFO's role. It is classified as Firm-Specific because it includes a unique, quantified claim about the team's collective experience, which distinguishes it from generic boilerplate.


reasoning: The paragraph provides a materiality assessment regarding cybersecurity risks and incidents, which falls under Strategy Integration. It is classified as Firm-Specific because it includes a specific fiscal year-end date, but lacks the two or more hard facts required for Quantified-Verifiable status.


reasoning: The paragraph describes internal security monitoring and assessment activities like penetration testing and program reviews, which are standard risk management processes, but it lacks any specific details, named frameworks, or unique identifiers.


reasoning: This paragraph is a cross-reference to the 'Risk Factors' section of the filing and does not contain substantive cybersecurity disclosure.


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


reasoning: The paragraph describes the company's internal process for assessing third-party risks, which falls under Risk Management Process. It contains no specific entities, dates, or frameworks, making it generic boilerplate.


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


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


reasoning: The paragraph consists of general, boilerplate risk disclosures regarding cybersecurity threats common to the industry and does not provide substantive details about the company's specific governance, management, or risk processes.


reasoning: The paragraph focuses entirely on the Board's oversight responsibilities and the delegation of cybersecurity risk to the audit committee, which is a standard governance disclosure.


reasoning: The paragraph focuses entirely on the Board of Directors and Audit Committee's oversight responsibilities, which fits the Board Governance category. It contains no unique identifiers, specific roles, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the Board's oversight responsibilities and the delegation of cybersecurity oversight to the Audit Committee. While 'Audit Committee' is a named committee, it is considered a standard governance structure at every public company and does not elevate the specificity beyond boilerplate in this context.


reasoning: The paragraph describes the company's internal security tools, policies, and testing procedures, which constitutes a description of their risk management process. It is classified as firm-specific because it names a specific internal policy program.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the Director of Cybersecurity, which is a specific management role. It is classified as Firm-Specific because it identifies unique internal roles and committee structures rather than just generic management titles.


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


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


reasoning: The paragraph describes the company's general approach to risk management and oversight, which is standard boilerplate language without specific details or unique identifiers.


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


reasoning: The paragraph describes the company's internal operational processes for incident detection and response, specifically referencing their Security Operations Center and incident severity matrix.


reasoning: The paragraph describes general internal security measures and processes without naming specific frameworks, roles, or unique identifiers, making it boilerplate.


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


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


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


reasoning: The paragraph describes the company's internal operational procedures for incident management, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies a specific management role (Senior Vice President, IT Operations) responsible for these processes.


reasoning: The paragraph describes the company's internal cybersecurity measures and processes, which is the definition of Risk Management Process. It contains only generic security practices without any specific frameworks, dates, or unique identifiers.


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


reasoning: The paragraph describes the scope and impact of a previously disclosed cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph describes the operational impact of a specific cybersecurity incident, including the scope of affected systems and the status of recovery, which falls squarely under Incident Disclosure. It contains two hard verifiable facts (a specific date and a percentage), meeting the threshold for Quantified-Verifiable.


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


reasoning: The paragraph describes the response actions and impact assessment of a specific cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named tools, or verifiable metrics, making it generic.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of discovery and the nature of the event, which falls under incident disclosure.


reasoning: The paragraph describes the timeline and scope of a specific cybersecurity incident, including the identification of affected systems and previous related activity, which clearly falls under Incident Disclosure.


reasoning: The paragraph focuses on the financial materiality and impact assessment of a previously disclosed incident without describing the incident narrative itself, which aligns with Strategy Integration.


reasoning: The paragraph focuses on the financial and operational materiality assessment of a cybersecurity incident rather than the incident narrative itself, placing it in Strategy Integration. It contains two specific date references, meeting the threshold for Quantified-Verifiable.


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


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


reasoning: The paragraph describes incident response actions (cooperating with law enforcement) and provides a materiality assessment regarding an ongoing incident, which aligns with the Incident Disclosure category.


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


reasoning: The paragraph describes the status and impact of a previously disclosed incident, which falls under Incident Disclosure. It contains no specific dates, named entities, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the materiality assessment of an incident and potential financial impacts, which falls under Strategy Integration. It contains no specific facts, dates, or metrics, making it generic boilerplate.


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


reasoning: The paragraph focuses on the financial impact (material non-recurring expenses) of an incident rather than describing the incident itself, fitting the Strategy Integration category. It is Firm-Specific because it references a specific timeframe ('first quarter') related to the company's financial reporting.


reasoning: This paragraph is a standard legal disclaimer regarding forward-looking statements and does not contain any substantive cybersecurity information.


reasoning: The paragraph describes the scope of data exfiltrated during a cybersecurity incident, which falls squarely under Incident Disclosure. It contains specific dates related to the company's fiscal year-end and expected filing timeline, making it firm-specific.


reasoning: The paragraph describes the financial impact of a specific cybersecurity incident, which falls under Incident Disclosure according to the tiebreaker rules (Incident narrative + financial impact). It contains multiple quantified financial figures and specific timeframes, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the status and response actions related to a specific cybersecurity incident, including law enforcement involvement and disclosure delays. It contains multiple verifiable facts, including two specific dates and a named government agency.


reasoning: The paragraph focuses on the materiality assessment of an incident rather than describing the incident itself, which aligns with the Strategy Integration category. It is Firm-Specific because it names a specific product/system ('Dropbox Sign') affected by the incident.


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


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


reasoning: The paragraph provides specific details regarding the scope and impact of a cybersecurity incident, specifically the number of affected consumers, which classifies it as an incident disclosure.


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


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident without describing the incident itself or providing specific financial details, which falls under Strategy Integration.


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


reasoning: The paragraph describes the ongoing response to a specific cybersecurity incident, including the scope of the disruption and the company's remediation efforts. It identifies a specific business unit (Change Healthcare) affected by the incident.


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


reasoning: The paragraph focuses on the materiality assessment and potential financial impact of an incident without describing the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph describes a specific ransomware incident and the company's immediate response actions, which constitutes an Incident Disclosure. It contains a specific date, qualifying it as Firm-Specific.


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


reasoning: The paragraph focuses on the materiality assessment of an incident regarding financial results and operations, which falls under Strategy Integration. It is Firm-Specific because it references a specific fiscal period end date (March 31, 2026).


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


reasoning: The paragraph describes the narrative of a specific cybersecurity incident, including the date of the response action and the current status of operations, which falls under Incident Disclosure.


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


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity detected on a specific date) and the company's immediate response actions, which fits the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident (data exfiltration) and the company's immediate response actions, which falls squarely under Incident Disclosure. It contains one specific date, making it Firm-Specific rather than Generic Boilerplate, but lacks a second hard verifiable fact (like a named firm or specific dollar amount) required for Quantified-Verifiable.


reasoning: The paragraph provides an update on a specific, named cybersecurity incident (the Change Healthcare cyberattack) and references specific company actions taken in response, making it an incident disclosure.


reasoning: The paragraph describes the response actions taken in relation to a specific cybersecurity incident, which falls squarely under Incident Disclosure. It is Firm-Specific because it identifies a unique geographic location (Singapore) involved in the incident response, which is a verifiable fact about this specific event.


reasoning: The paragraph describes the status of an ongoing incident investigation and regulatory evaluation, which falls squarely under Incident Disclosure, but it contains no specific dates, named entities, or verifiable facts.


reasoning: The paragraph describes the company's response actions and ongoing operations in the context of a previously disclosed incident, making it an incident disclosure.


reasoning: This paragraph is a standard legal disclaimer regarding forward-looking statements and does not contain any substantive cybersecurity information.


reasoning: The paragraph provides a materiality assessment regarding an incident without describing the incident itself, its scope, or specific response actions, which aligns with the Strategy Integration category.


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


reasoning: The paragraph provides a detailed description of the scope and impact of a specific cybersecurity incident, which is the core definition of Incident Disclosure.


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


reasoning: The paragraph describes standard incident response and containment activities following an incident, which falls under Incident Disclosure. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph describes a specific cybersecurity incident (data exfiltration) and the company's response actions, which falls squarely under Incident Disclosure. It contains one specific date, making it Firm-Specific rather than Generic Boilerplate.


reasoning: This paragraph is a standard materiality disclaimer regarding a cybersecurity incident without providing any specific details about the incident itself or the company's internal processes.


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


reasoning: The paragraph describes the integration of cybersecurity risk management into broader enterprise risk management processes, which falls squarely under Risk Management Process. It contains no specific details, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph details the operational and financial impact of a specific cybersecurity incident, including specific costs and dates, which aligns with the definition of incident disclosure.


reasoning: The paragraph describes the status of an incident (contained) and ongoing response actions (remediation, working with experts), which falls under Incident Disclosure. It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or metrics, making it generic boilerplate.


reasoning: The paragraph describes the status of an ongoing investigation into a disclosed incident, specifically mentioning file exfiltration and the evaluation of notification requirements. It contains no specific dates, named entities, or unique identifiers, making it generic in specificity.


reasoning: The paragraph focuses on the board's oversight responsibilities and reporting structure. It is classified as Generic Boilerplate because 'the Board', 'audit committee', 'executive leadership team', and 'annual' are all standard, non-specific terms.


reasoning: The paragraph focuses on the oversight activities of a board committee and its reporting relationship to the full Board, which is the definition of Board Governance. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph serves as a section header ('Risk management and strategy') followed by generic boilerplate language about dependency on technology, which does not describe specific internal processes, governance, or incidents.


reasoning: The paragraph focuses on the board of directors and the audit committee's oversight role. It is classified as Generic Boilerplate because 'the Board' and 'Audit Committee' are standard governance structures at every public company and do not constitute firm-specific facts.


reasoning: The paragraph focuses on the materiality assessment of an incident's impact on the company's financial condition, which falls under Strategy Integration. It is Firm-Specific because it names a specific subsidiary (Targus) and a specific financial metric (Operating Adjusted EBITDA).


reasoning: The paragraph describes oversight responsibilities and the evaluation of a specific internal committee, which falls squarely under Board Governance. The mention of a 'Cybersecurity Committee' makes it firm-specific.


reasoning: This paragraph is a standard legal disclaimer regarding the filing status of the report under the Securities Exchange Act and Securities Act, which contains no cybersecurity-related information.


reasoning: The paragraph focuses on the qualifications and tenure of a specific cybersecurity management role, which falls squarely under Management Role.


reasoning: The paragraph provides a materiality assessment regarding a previously disclosed incident without describing the incident details or providing specific financial metrics, fitting the Strategy Integration category.


reasoning: The paragraph consists entirely of a forward-looking disclaimer and a cross-reference to another section of the filing, which falls under the 'None/Other' category.


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


reasoning: The paragraph identifies specific management roles (head of the ITS Department) responsible for cybersecurity risk management, which places it squarely in the Management Role category.


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


reasoning: The paragraph describes the company's internal process for evaluating vendors as part of its broader risk management framework. While it mentions third-party vendors, the focus is on the company's internal risk assessment methodology rather than specific vendor oversight or contractual standards.


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


reasoning: The paragraph focuses on the Board of Directors' oversight role and the reporting cadence from management, making it a clear Board Governance disclosure. It is Firm-Specific because it identifies specific cybersecurity-related roles (CISO and CIO) reporting to the Board.


reasoning: The paragraph describes the company's internal approach to integrating cybersecurity into their broader enterprise risk management program, which falls under Risk Management Process. It contains no specific frameworks, roles, dates, or verifiable metrics, making it generic boilerplate.


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


reasoning: The paragraph describes internal security policies and training procedures, which are core components of a company's risk management process. The content is generic, as it describes standard practices without naming specific programs, tools, or unique identifiers.


reasoning: The paragraph focuses on the board of directors and the audit committee's oversight role regarding cybersecurity. It is classified as Generic Boilerplate because 'Audit Committee' and 'Board of Directors' are standard governance structures and no unique identifiers or specific details are provided.


reasoning: The paragraph describes general internal efforts to improve cybersecurity and controls without referencing specific frameworks, roles, or unique programs, making it a standard description of risk management processes.


reasoning: This paragraph is a standard, generic disclaimer about common cybersecurity threats and vulnerabilities that could apply to any company, containing no specific details about the company's actual risk management processes or unique environment.


reasoning: The paragraph focuses on identifying specific management roles (CIO, Director of IT Security) and their qualifications, which falls under Management Role. It is Quantified-Verifiable because it contains both specific named roles and a quantified metric (20 years of experience).


reasoning: The paragraph describes the company's internal processes for incident response and testing, which falls under Risk Management Process. It is classified as Firm-Specific because it specifies a unique testing cadence ('twice yearly'), which is a verifiable fact about their internal operations.


reasoning: The paragraph discusses the qualifications of the internal IT team, which falls under Management Role. It contains no specific names, dates, roles, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes generic corporate governance and management responsibilities without referencing cybersecurity-specific oversight, roles, or processes.


reasoning: The paragraph focuses on the oversight of third-party service providers and explicitly names a specific tool (Security Scorecard) used for monitoring them, which places it firmly in the Third-Party Risk category.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents without describing any specific incident, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph focuses on the roles of the CSO and CISO and their reporting structure, making 'Management Role' the primary category. It is 'Firm-Specific' because it names specific internal roles (CSO, CISO) and a specific internal committee (Global Security Steering Committee).


reasoning: The paragraph describes a generic step in an incident response process without referencing a specific incident, unique program name, or company-specific detail.


reasoning: The paragraph focuses on the responsibilities and reporting lines of a specific management role (internal cybersecurity coordinator), which falls squarely under Management Role.


reasoning: This paragraph describes generic business services (email and cloud storage) and makes a vague, boilerplate statement about third-party providers without naming any specific vendors, frameworks, or internal processes.


reasoning: The paragraph explicitly addresses the occurrence (or lack thereof) of cybersecurity incidents and associated financial impacts for specific time periods, which falls under Incident Disclosure.


reasoning: The paragraph focuses on the Board's oversight activities and the reporting structure, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies the specific internal entities (Audit Committee and Cybersecurity team) involved in the reporting process.


reasoning: The paragraph describes the company's internal approach to cybersecurity, including threat intelligence and control assessments, which falls under Risk Management Process. It is Firm-Specific because it explicitly names the company (Invesco) as the entity performing these actions.


reasoning: The paragraph explicitly identifies the specific management roles (CFO and CISO) responsible for cybersecurity oversight, making 'Management Role' the primary focus.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight role regarding cybersecurity risks. Per the instructions, 'Audit Committee' alone is considered generic, and 'the Board' is generic, making this boilerplate.


reasoning: The paragraph serves as an introductory sentence for the company's cybersecurity program and risk management approach, which is a standard framing for the Risk Management Process category.


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


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity incidents and costs without describing a specific incident, which aligns with the Strategy Integration category.


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity incidents, which falls under Strategy Integration. It is Firm-Specific because it cites specific fiscal year-end dates.


reasoning: The paragraph describes standard internal security practices like phishing simulations and employee training, which fall under the company's internal risk management processes. These activities are common security practices and do not contain any unique identifiers, named frameworks, or verifiable facts.


reasoning: The paragraph explicitly identifies specific management roles (CIO and VP of Information Security) responsible for cybersecurity, which aligns with the Management Role category.


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


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


reasoning: The paragraph explicitly identifies specific management roles (CFO, COO, CEO) and their responsibilities regarding cybersecurity, which falls squarely under Management Role.


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


reasoning: The paragraph describes the company's internal process for reviewing and updating their incident response plan, which falls under Risk Management Process. It contains no specific dates, roles, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the Board of Directors' oversight role. It is classified as Generic Boilerplate because 'Board of Directors', 'periodic updates', and 'quarterly' are considered generic governance language and cadences, lacking specific identifiers or unique committee names.


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


reasoning: The paragraph describes internal risk management processes, including training and vendor oversight, without naming specific programs, frameworks, or unique entities.


reasoning: The paragraph describes an internal cybersecurity program and team ('CyberSmart Defender Network'), which falls under the company's internal risk management processes.


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


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


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


reasoning: This paragraph is a generic statement of purpose or goal regarding cybersecurity and does not describe specific governance, management, processes, or incidents.


reasoning: The paragraph describes internal cybersecurity processes (IRP and tabletop exercises), which falls under Risk Management Process. It is considered Generic Boilerplate because 'IRP' and 'tabletop exercises' are standard, non-unique security practices and no specific identifiers, dates, or frameworks are provided.


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


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


reasoning: The paragraph describes the company's internal approach to identifying and managing cybersecurity risks, which falls under Risk Management Process. It is classified as Firm-Specific because it references a unique internal system, 'BDTP TM'.


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


reasoning: The paragraph identifies specific management roles responsible for cybersecurity risk management, making 'Management Role' the primary focus.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for a specific fiscal year, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year (2024), which is a unique fact, but it does not meet the threshold for Quantified-Verifiable (only one hard fact).


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration.


reasoning: The paragraph discusses the financial strategy regarding cybersecurity insurance and potential reimbursement, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: This paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


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


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


reasoning: The paragraph discusses the potential financial and operational impact of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, amounts, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the qualifications of a specific individual and the reporting lines of key management roles (CTO and Senior Director of Cybersecurity and Compliance), which places it squarely in Management Role.


reasoning: The paragraph discusses cybersecurity insurance coverage and future financial guidance, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident without describing the incident itself or providing specific financial details.


reasoning: The paragraph discusses the potential material impact of an incident without providing a narrative of the incident itself, which aligns with the Strategy Integration category.


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


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph discusses the potential financial and business impacts (litigation, insurance costs) of a cybersecurity incident without describing the incident itself or providing specific details, which aligns with Strategy Integration.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph describes an active incident and provides specific, verifiable resources (a unique URL and the named system affected) for stakeholders to track the event.


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


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


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


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


reasoning: The paragraph provides a materiality assessment regarding an incident without describing the incident narrative or providing specific financial details, which aligns with the Strategy Integration category.


reasoning: The paragraph discusses the materiality of an incident and potential financial/operational impacts without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, named entities, or verifiable metrics, making it generic boilerplate.


reasoning: This paragraph describes executive leadership changes at a subsidiary, which is corporate governance/personnel information and does not pertain to cybersecurity risk management, board oversight of cyber, or incident disclosure.


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


reasoning: The paragraph provides a standalone materiality assessment regarding an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes specific response actions taken in relation to a disclosed incident, which falls under Incident Disclosure. It contains no specific dates, named tools, or other verifiable facts, making it generic.


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


reasoning: The paragraph discusses the financial impact (insurance recovery) of a cybersecurity incident without describing the incident itself or providing specific financial details, which aligns with the Strategy Integration category.


reasoning: The paragraph discusses the materiality of an incident without describing the incident itself or providing specific financial details, which aligns with the Strategy Integration category for standalone materiality assessments.


reasoning: The paragraph describes the status of an ongoing incident investigation and notification plans, which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or unique identifiers, making it generic boilerplate.


reasoning: This paragraph is a standard legal disclaimer regarding the scope of a waiver under existing agreements and contains no substantive cybersecurity disclosure.


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


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


reasoning: The paragraph describes ongoing incident response actions (investigation, engaging experts, notifying law enforcement) and provides a materiality conclusion regarding an incident, which falls under Incident Disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the operational impact of an ongoing cybersecurity incident, specifically detailing which systems are disrupted and which are functioning, which qualifies as incident disclosure.


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


reasoning: The paragraph discusses the ongoing monitoring of materiality regarding an incident without describing the incident itself or providing specific details, which aligns with the Strategy Integration category for materiality assessments.


reasoning: The paragraph describes the nature of an ongoing cybersecurity incident, specifically mentioning unauthorized access, data exfiltration, and encryption, which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph discusses the potential financial impact and materiality of an incident without describing the incident itself or providing specific financial data, which aligns with the Strategy Integration category.


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


reasoning: The paragraph describes a specific cybersecurity incident (system outage) and the immediate response actions taken, which falls squarely under Incident Disclosure.


reasoning: The paragraph provides a standalone materiality assessment regarding a potential incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it Generic Boilerplate.


reasoning: The paragraph describes a response action (notification) related to an incident, which falls under Incident Disclosure. It contains no specific dates, named entities, or verifiable metrics, making it generic.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access) and provides a specific date, which qualifies as an incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (systems outage) and the company's immediate response actions, which falls squarely under Incident Disclosure. It contains one specific date, making it Firm-Specific rather than Generic Boilerplate, but lacks a second hard verifiable fact required for Quantified-Verifiable.


reasoning: The paragraph describes actions taken in response to an ongoing cybersecurity incident, specifically the creation of a dedicated communication channel, which falls under incident disclosure.


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


reasoning: The paragraph discusses the financial/operational impact of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, dollar amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph focuses on the materiality assessment of an incident's financial impact rather than describing the incident itself, which aligns with Strategy Integration. It is Firm-Specific because it references a specific fiscal period (fourth quarter of 2023).


reasoning: The paragraph describes the operational impact of a cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named systems, or verifiable metrics, making it generic boilerplate.


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


reasoning: The paragraph describes the operational impact of a specific cybersecurity incident, which falls under Incident Disclosure. It is Firm-Specific because it quantifies the duration of the operational disruption, though it does not meet the threshold for Quantified-Verifiable as it lacks a second independent hard fact.


reasoning: The paragraph discusses the materiality of an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or metrics, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident (attempted fraudulent fund acquisition) and provides a specific date, clearly falling under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity on IT systems) and provides a specific date, clearly falling under Incident Disclosure.


reasoning: The paragraph provides a standalone materiality assessment regarding an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it Generic Boilerplate.


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


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including threat assessment, training, and third-party oversight. It is classified as Firm-Specific because it references specific oversight bodies (Audit Committee and Board) in the context of their internal assessment reporting structure, which goes beyond just naming frameworks.


reasoning: The paragraph describes the company's internal processes for incident evaluation, escalation, and response, including specific named internal programs and the role of the CSO.


reasoning: The paragraph describes general cybersecurity risks and the company's high-level approach to monitoring and mitigating them, which falls under internal risk management processes. It contains no specific frameworks, roles, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the composition and responsibilities of the internal management team (the 'Risk Management Team') and their reporting lines to the Audit Committee, making 'Management Role' the primary category.


reasoning: The paragraph provides a standalone materiality assessment regarding an incident without describing the incident itself, which falls under Strategy Integration.


reasoning: The paragraph describes specific response actions taken by a named entity (Targus) in relation to an unauthorized access incident, which falls under Incident Disclosure.


reasoning: The paragraph details the company's internal cybersecurity risk management strategy, including specific frameworks used and internal governance structures like the Technology Committee and ERM program.


reasoning: The paragraph focuses primarily on identifying the specific management roles (CISO and CTO) responsible for cybersecurity, their reporting lines, and their professional qualifications. It qualifies as Quantified-Verifiable because it contains multiple hard facts, including specific years of experience and named external organizations/projects.


reasoning: While the paragraph mentions management roles and internal processes, the central and most detailed portion of the disclosure focuses on the specific requirements imposed on third-party vendors (SOC reports, access limitations), making Third-Party Risk the most applicable category.


reasoning: The paragraph provides an update on the restoration of systems following a cybersecurity incident, referencing specific dates and documents related to the event.


reasoning: The paragraph describes the company's internal cybersecurity program and risk management processes. It is classified as Firm-Specific because it identifies specific management roles (CIO, Global Head of IT Security) involved in these processes.


reasoning: The paragraph provides a materiality assessment regarding cybersecurity threats for a specific fiscal year, which falls under Strategy Integration. It is Firm-Specific because it references a specific fiscal year ('fiscal 2024').


reasoning: The paragraph describes the company's internal risk management processes, including security controls, training, and monitoring. It is classified as Sector-Adapted because it explicitly references the NIST CSF framework but lacks firm-specific details like named tools, specific dates, or unique internal program names.


reasoning: The paragraph describes general reliance on IT infrastructure and lists common cybersecurity threats, but it does not describe specific internal risk management processes, governance, or incidents. It functions as a standard risk factor disclosure.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and strategy. It contains no specific dates, named roles, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management and regulatory compliance, which falls under Risk Management Process. It is Firm-Specific because it names the specific regulatory bodies the company is subject to.


reasoning: The paragraph focuses on the identification, qualifications, and roles of the cybersecurity team (both internal and outsourced), which aligns with the Management Role category. It is Firm-Specific because it details the specific roles (vCISO, etc.) and certifications held by the team members.


reasoning: The paragraph primarily describes the company's internal cybersecurity program, incident response planning, and the specific organizational structure and oversight committees responsible for managing these risks. While it mentions management roles, the focus is on the operational processes and governance structure of the program itself.


reasoning: The paragraph focuses primarily on the Board of Directors and the Risk Committee's oversight responsibilities regarding cybersecurity, making Board Governance the clear category. It is classified as Firm-Specific because it identifies a specific named committee (Risk Committee) responsible for these duties, rather than relying solely on generic terms like 'the Board' or 'Audit Committee'.


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


reasoning: The paragraph primarily describes the company's internal risk management processes, including specific internal programs like the IRP, BCP, and Disaster Recovery Plan, which elevates it beyond sector-adapted or generic boilerplate.


reasoning: The paragraph focuses on the potential business and financial impact of cybersecurity risks and includes a standalone materiality conclusion regarding past incidents, which aligns with Strategy Integration. It contains no specific facts, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including monitoring, training, and policy frameworks. While it mentions third-party risk, it is presented as a component of the broader internal risk management strategy rather than the central topic.


reasoning: The paragraph details the company's internal cybersecurity tools, operational processes, and specific incident reporting timelines, which falls squarely under Risk Management Process. It qualifies as Quantified-Verifiable because it includes a specific year (2025) and a precise, verifiable reporting timeframe (24 hours).


reasoning: The paragraph primarily describes the company's internal risk management processes, including oversight, reporting lines, and specific security practices. While it mentions the Board and Audit Committee, the core focus is on the operational structure and processes of the cybersecurity program, and it includes specific roles like the head of information security and the CFO.


reasoning: The paragraph focuses primarily on the qualifications, responsibilities, and reporting lines of the Chief Information Officer and the senior leadership team's role in the risk management process. While it mentions risk management processes, the central theme is the specific management roles and their involvement in the 'Risk Report' process.


reasoning: The paragraph describes the company's internal cybersecurity program and risk management processes, including specific roles like the AGM and AHL CISOs and the cross-functional departments involved.


reasoning: The paragraph describes the company's internal cybersecurity processes (incident response, technical safeguards, risk management) in general terms without naming specific frameworks, tools, or unique identifiers.


reasoning: The paragraph describes the company's internal incident response processes, specifically naming their internal 'Agility Preparedness Plan' and 'Crisis Management Team', which qualifies as a Risk Management Process.


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


reasoning: The paragraph describes the company's internal processes for monitoring, incident response, and engagement with external experts, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it names a specific internal program, the 'Cybersecurity Incident Response Plan'.


reasoning: The paragraph focuses primarily on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity. The mention of the Audit Committee is considered generic in this context as it is a standard governance structure, and the rest of the text describes standard oversight functions without unique identifiers or specific details.


reasoning: The paragraph focuses on identifying specific management roles (CISO, SVP/CDO, SVP/CIO) and their qualifications, which aligns with the Management Role category.


reasoning: The paragraph primarily discusses the potential financial and operational impact of cybersecurity risks and includes a materiality conclusion regarding the past fiscal year, which aligns with Strategy Integration. It is classified as Firm-Specific because it includes a specific fiscal year-end date, which is a unique fact.


reasoning: The paragraph primarily focuses on the Board of Directors and the Risk Committee's oversight responsibilities regarding cybersecurity, which aligns with the Board Governance category. The mention of the 'Risk Committee' makes it Firm-Specific, as it is a named committee beyond the generic 'Audit Committee'.


reasoning: The paragraph describes general cybersecurity risks and potential impacts using boilerplate language, and includes a cross-reference to the Risk Factors section, which falls under the None/Other category.


reasoning: The paragraph describes the company's internal cybersecurity measures and processes, such as monitoring, incident response, and training. Despite the long list of activities, all items listed are standard, generic security practices (e.g., 'data encryption', 'tabletop exercises', 'vulnerability scans') without naming specific tools, frameworks, or unique identifiers.


reasoning: The paragraph describes the company's internal security controls, processes, and risk management activities. It contains no specific dates, named tools, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk assessment program and cybersecurity risk management processes. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph describes the company's internal cybersecurity risk management program, policies, and frameworks, making it a clear Risk Management Process disclosure. It is Firm-Specific because it names unique internal programs and policies (e.g., 'Cyber and Technology Risk Management Policy', 'Third-Party Risk Management Program') and specific internal committees.


reasoning: The paragraph serves as an introductory overview of the company's general approach to cybersecurity risk management and oversight, lacking specific details, named frameworks, or unique identifiers.


reasoning: The paragraph describes the internal information security program and risk assessment procedures implemented by the manager (USCF), which falls under Risk Management Process. It is Firm-Specific because it names the specific manager (USCF) and the specific funds (USCI, CPER) involved in the disclosure.


reasoning: The paragraph consists entirely of definitions of cybersecurity terms and a cross-reference to another section of the filing, containing no substantive disclosure about the company's specific governance, management, or processes.


reasoning: The paragraph describes the company's internal processes for risk assessment, incident response, and vendor oversight, making 'Risk Management Process' the primary category. It is classified as 'Firm-Specific' because it identifies specific roles (Senior Director of Information Technology and Chief Financial Officer) involved in the risk management governance structure.


reasoning: The paragraph is primarily focused on identifying specific management roles (CTO, CIO, CISO) and detailing their qualifications, which aligns with the Management Role category. It qualifies as Quantified-Verifiable because it contains multiple specific metrics regarding years of experience and the 24/7 nature of the SOC service.


reasoning: The paragraph focuses heavily on the qualifications and leadership of the Chief Technology Officer, which is the primary subject, while also detailing specific internal committees and programs.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity, including the implementation of an 'Information Security Program' and specific risk management activities like third-party due diligence and multi-layered controls. While it mentions third-party risk, it is framed as a component of their overall internal risk management process.


reasoning: The paragraph focuses primarily on the Board's oversight structure and delegation to the Audit Committee, which defines the Board Governance category. It is classified as Firm-Specific because it identifies a specific management role (Director of IT) responsible for the cybersecurity program.