content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is a cross-reference directing readers to Item 1A for discussion of whether cybersecurity risks may materially affect the company, rather than providing substantive cybersecurity governance, management, process, third-party, incident, or strategy disclosure itself. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, its specificity is Generic Boilerplate.

provider: openai

stage: benchmark


content_category: Third-Party Risk

reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party service providers, so Third-Party Risk is the best fit. It does not include domain-specific cyber terminology, firm-unique organizational details, or verifiable facts; the described practices are generic vendor-risk oversight measures.


fact: Information Technology Automated Solutions (ITAS) contract owners validate vendor certifications throughout the life of the agreement

specificity_confidence: medium

reasoning: The paragraph is primarily about how the company manages cybersecurity risks from third-party service providers, including pre-engagement assessments, contractual requirements, and ongoing audits, so Third-Party Risk is the best fit. Its specificity rises above boilerplate because it names a firm-specific internal group, Information Technology Automated Solutions (ITAS), but it does not include externally verifiable dates, numbers, or named outside firms.


fact: System and Organization Controls (SOC) 2

type: framework

fact: information security posture assessments for third-party vendors

fact: reviews of third-party hosted applications focused on sensitive data shared with third parties

reasoning: The paragraph is primarily about how the company manages cybersecurity risk arising from vendors and other service providers, so Third-Party Risk is the best fit. Its specificity is elevated by cybersecurity-specific third-party assessment details and named standards (SOC 2 and ISO 27001), but it does not include firm-unique roles/committees or externally verifiable claims.


content_category: Board Governance

fact: The CISO provides cybersecurity updates and briefings to the Audit and Risk Committee and the Board of Directors

reasoning: This paragraph primarily describes how cybersecurity information flows to the board and its committee, which is board oversight rather than management organization or program operations. Specificity rises to Firm-Specific because it identifies the CISO as the reporting role; the remaining details are mostly generic briefing cadences and oversight topics.


content_category: Management Role

reasoning: The paragraph primarily describes which management personnel are responsible for cybersecurity-related duties and approvals, so it is about management organization and responsibilities rather than board oversight or program activities. It does not contain qualifying domain-specific terminology beyond generic cyber-risk language, nor any firm-specific or externally verifiable facts under the stated rules.


category_confidence: medium

reasoning: The paragraph primarily answers how the board oversees cybersecurity by stating that the Board is actively involved in oversight and that cybersecurity is part of the company’s overall risk management approach. Its wording is high-level and generic, with no qualifying domain-specific technical terms, firm-specific structures, or externally verifiable facts that would raise specificity above boilerplate.


reasoning: The paragraph is primarily about how the company evaluates and manages cybersecurity risk from vendors and other external providers, so Third-Party Risk is the best fit. It remains Generic Boilerplate because it describes common vendor-risk practices in general terms without using cybersecurity-specific technical terminology, firm-unique structures, or verifiable facts.


reasoning: The paragraph primarily describes how the Audit Committee and Board oversee cybersecurity, including management reporting and escalation, which makes Board Governance the best fit. It does not include qualifying domain-specific technical terminology, firm-specific cybersecurity roles/committees that count under the rules, or externally verifiable facts, so specificity remains Generic Boilerplate.


content_category: Strategy Integration

reasoning: The paragraph primarily states management’s conclusion that cybersecurity threats are not currently reasonably likely to materially affect results of operations or financial condition, which is a materiality/business-impact assessment. Its statements about no breaches and no current material risk are negative self-assertions and general cautionary language, which do not add qualifying domain-specific, firm-specific, or externally verifiable facts.


fact: The Company's Chief Information Security Officer (CISO) reports to the Audit Committee or provides reports through representatives regarding cybersecurity risks

reasoning: This paragraph primarily describes how the board, through the Audit Committee, oversees cybersecurity risk and receives information from management, which makes it Board Governance. Specificity rises to Firm-Specific because it includes the named cybersecurity leadership role of Chief Information Security Officer (CISO), while the rest of the language is otherwise largely generic oversight description.


fact: The management team includes a Chief Information Officer with responsibility for assessing and managing cybersecurity risks

reasoning: The paragraph primarily describes who in management is responsible for cybersecurity and the CIO's role and qualifications, which makes it a Management Role disclosure rather than a program/process description. Specificity rises to Firm-Specific because it identifies a named senior role (Chief Information Officer), but it does not include hard verifiable facts since 'many years of experience' is not quantified.


content_category: Risk Management Process

fact: Requires service providers to provide System and Organizational Control (SOC) type reports

reasoning: The paragraph primarily describes what the cybersecurity program does—using standards, software, and internal audits to identify and mitigate threats—so Risk Management Process fits best, even though it briefly mentions service providers. Specificity is elevated by the cybersecurity-specific reference to SOC reports, which reflects domain knowledge, but there are no firm-unique roles, committees, dates, numbers, or other externally verifiable facts.


fact: The Director - Information Systems serves as the Company's chief information officer

reasoning: The paragraph primarily describes how the Board oversees cybersecurity risk, including support from a board committee and interaction with management, so Board Governance is the best fit. Specificity rises to Firm-Specific because it identifies a firm-specific management role in the governance chain—the Director - Information Systems as the Company's chief information officer—while the rest is largely generic oversight language.


fact: The board receives periodic updates from the Chief Information Officer

fact: The board receives periodic updates from the Executive Director of Information Security

fact: The paragraph references an ISMS (Information Security Management System)

reasoning: This paragraph primarily describes how the board and its committee oversee cybersecurity-related risk and how information flows up to the board, which makes Board Governance the best fit. Its specificity rises to Firm-Specific because it names firm-specific management roles involved in board reporting; the ISMS reference also adds cybersecurity domain terminology.


fact: Depending on the incident, representatives from specific company functions may be included on the investigation/response teams, including Legal/Compliance, Corporate Security, Internal Audit, Human Resources, Directors of Banking and Mortgage, and Corporate Communications.

reasoning: The paragraph primarily describes how management organizes incident/investigation response participation across company functions, which fits Management Role more than a process description. Specificity rises to Firm-Specific because it identifies a concrete cross-functional team composition by department, but it does not provide verifiable numbers, dates, or named external firms.


fact: 24/7 security operations center is utilized

fact: security operations center

fact: real-time situational awareness across the cyber-threat environment

fact: insider threat protection program

fact: cross-function information sharing to assess insider threat activity

fact: operational technology

reasoning: The paragraph primarily describes what the cybersecurity program does—monitoring, insider-threat detection, training, and preparedness—so it is best classified as Risk Management Process. Specificity reaches Firm-Specific because it includes the organizationally distinctive claim that the company utilizes a 24/7 security operations center, alongside several cybersecurity domain terms.


fact: Cybersecurity incidents may be detected through automated event-detection notifications or similar technologies

fact: These technologies are monitored by a security operations team

reasoning: The paragraph primarily describes how the company detects, investigates, and assesses cybersecurity incidents, which is a risk management process rather than governance or management organization. Its specificity rises above boilerplate because it references cybersecurity-specific detection mechanisms and security operations monitoring, but it does not provide firm-unique or externally verifiable details.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk from vendors and service providers, making Third-Party Risk the best fit. Its descriptions—due diligence, contractual review, review of new third parties, and ongoing monitoring—are generic vendor-risk activities and do not include qualifying domain-specific technical terms, firm-unique details, or externally verifiable facts.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk from business partners, making Third-Party Risk the best fit. Its language is high-level and generic, with no domain-specific cyber terminology that passes the ERM test and no firm-specific or verifiable facts.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk arising from vendors and service providers, making Third-Party Risk the best fit. Although it describes vendor oversight activities, it uses largely generic risk-management language without domain-specific technical terms, firm-unique structures, or externally verifiable facts, so specificity remains Generic Boilerplate.


reasoning: The paragraph primarily describes what the company's cybersecurity program does—maintaining and testing incident response and recovery plans—so it fits Risk Management Process. However, it uses generic process language without cybersecurity-specific domain terms that pass the ERM test, firm-unique details, or externally verifiable facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily states management’s conclusion that cybersecurity has had no impact on results of operations or financial condition to date, which is a business-impact/materiality assessment. It contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts; the negative assertion about no incidents is not independently verifiable.


fact: assessments of the SOC reports of third-party providers

fact: implementing complementary controls

reasoning: The paragraph primarily explains how the company manages cybersecurity risk from vendors and service providers, so Third-Party Risk is the best fit. Its specificity rises above boilerplate because it uses cybersecurity-specific concepts like reviewing SOC reports and implementing complementary controls, but it does not provide firm-unique roles, committees, systems, or externally verifiable facts.


fact: The paragraph references protection of the confidentiality, integrity, and availability of critical systems and information

reasoning: The paragraph primarily describes what the company’s cybersecurity program is intended to do—manage cyber risk to protect systems and information—so it fits Risk Management Process. Its specificity rises above boilerplate because it uses the cybersecurity concept of confidentiality, integrity, and availability, but it provides no firm-specific roles, structures, numbers, or other verifiable details.


reasoning: The paragraph primarily describes the company’s cybersecurity program relying on external partners and consultants as part of its risk management approach, which fits Risk Management Process rather than Third-Party Risk because it is not about overseeing vendor cyber risk. It contains no qualifying domain-specific technical terms, firm-unique organizational details, or externally verifiable facts, so specificity is Generic Boilerplate.


fact: annual IT Security assessment based on the IASME Cyber Essentials framework

fact: IASME Cyber Essentials

fact: UK government Cyber Security NCSC approval is referenced for the framework

fact: NIST framework

reasoning: The paragraph primarily describes the company's cybersecurity program activities and assessment approach, so it is best classified as Risk Management Process. Its specificity is driven by named cybersecurity frameworks and standards—IAMSE Cyber Essentials, ISO 27001, and NIST—which show domain-specific cybersecurity knowledge, but it does not include firm-unique organizational facts or externally verifiable company-specific claims.


fact: The company references its ISIRP as including action plans for responding to third-party cybersecurity threats and incidents.

fact: The vendor management program uses System and Organization Control (SOC) reports for information security reviews.

reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from third-party providers, including due diligence, contractual protections, and ongoing vendor oversight, so Third-Party Risk is the best fit. Specificity rises to Firm-Specific because it names the company’s ISIRP, and it also contains domain-adapted detail through use of SOC reports.


reasoning: The paragraph primarily describes how management is organized to handle cybersecurity, centering on the Chief Executive Officer’s responsibility for leading cybersecurity risk assessment and management and reporting upward to the board. Its language is generic and does not include qualifying domain-specific terminology, firm-unique roles beyond excluded generic titles, or verifiable facts, so specificity remains Generic Boilerplate.


fact: The company has a capitalized internal program called the "Third Party Program"

reasoning: The paragraph is centrally about how the company manages cybersecurity risk arising from third parties, so Third-Party Risk is the best fit. Specificity rises above boilerplate because it references a company-specific internal program, the "Third Party Program," but otherwise the description is generic and contains no verifiable numbers, dates, or named external standards.


fact: Deutsche Bank's Chief Security Officer has served in information security roles for more than 20 years

type: quantified

fact: The company references a Chief Security Officer role

fact: The Chief Security Officer previously served as global Chief Information Security Officer / Chief Security Officer for three different large European financial institutions

reasoning: The paragraph primarily describes management organization and qualifications by focusing on the Chief Security Officer’s experience and support structure, which fits Management Role. Specificity reaches Quantified-Verifiable because it includes externally checkable numerical claims, including more than 20 years of experience and service at three different financial institutions.


fact: The CISO chairs the Cybersecurity Steering Committee.

fact: The company has a Cybersecurity Steering Committee.

reasoning: The paragraph primarily describes how cybersecurity information flows to and is overseen by the Board, including Board updates, education, and director expertise, so Board Governance is the best fit. Its specificity is Firm-Specific because it includes company-distinct organizational details such as the CISO and the named Cybersecurity Steering Committee, but no externally verifiable hard facts.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from suppliers, service providers, and other business partners, so Third-Party Risk is the best fit. It stays at Generic Boilerplate because it describes common vendor diligence and contractual notice requirements without any domain-specific technical practices, firm-unique structures, or verifiable facts.


fact: Our CISO provides more in-depth reporting on cybersecurity risks to the Audit Committee and the Board

fact: threat landscape

reasoning: The paragraph primarily describes how the board and its Audit Committee oversee cybersecurity risk and receive reporting, which is board-level oversight. Specificity is elevated to Firm-Specific because it includes the named cybersecurity leadership role of the CISO; it also uses domain terminology such as 'threat landscape,' but no externally verifiable facts are provided.


fact: Chief Information Officer (CIO) oversees the Chief Information Security Officer (CISO)

fact: Information Security team

fact: Cyber Incident Response Teams under the CISO

fact: Cybersecurity posture

reasoning: The paragraph primarily describes how management is organized for cybersecurity, including reporting lines and role responsibilities, which makes it a Management Role disclosure. Specificity is Firm-Specific because it names company roles and internal teams such as the CIO, CISO, Information Security team, and Cyber Incident Response Teams, but it does not provide externally verifiable dates, numbers, or certifications.


reasoning: The paragraph primarily describes what the cybersecurity program is monitored for and what program activities are covered in updates—such as prevention, detection, mitigation, remediation, assessments, and policy review—so it is best categorized as Risk Management Process rather than management structure. Its language remains generic and does not include qualifying domain-specific technical terms, firm-unique roles/committees, or externally verifiable facts.


fact: Kroger's CDO leads technology and digital capabilities for the company, including the overall cybersecurity strategy

fact: Kroger's CDO reports to the CEO

fact: Kroger's CDO has over 20 years of experience leading and transforming technology, digital growth, and e-commerce in the retail and food industry

fact: Kroger's CDO earned a master's degree in business administration and management from Ecole Sup rieure de Commerce de Chamb ry, Rh ne-Alpes, France

fact: Kroger's interim CISO brings nearly 20 years of experience developing and leading security and risk programs

fact: The interim CISO's experience includes governance, information security, and threat management

fact: Kroger's interim CISO earned a bachelor's degree in management information systems and marketing from Miami University

reasoning: The paragraph is primarily about who in management is responsible for cybersecurity and their qualifications, reporting lines, and experience, which makes it a Management Role disclosure. Specificity is Quantified-Verifiable because it includes externally checkable facts such as named leadership roles, a quantified experience claim ('over 20 years'), and specific educational credentials from named universities.


fact: The Chief Technology Officer (CTO) is primarily responsible for assessing and managing material risks from cybersecurity threats

fact: The Chief Operating Officer (COO) is primarily responsible for assessing and managing material risks from cybersecurity threats

fact: The CTO has over 10 years of experience overseeing cybersecurity functions within technology-driven organizations

fact: The COO has over 5 years of experience overseeing cybersecurity and IT functions

reasoning: This paragraph primarily describes how the board oversees cybersecurity risk through delegation to the Audit Committee and reporting from management, so Board Governance is the best fit. Specificity reaches Quantified-Verifiable because it includes externally checkable experience claims for the CTO and COO, along with firm-specific named management roles.


reasoning: The paragraph primarily describes management responsibility and qualifications: a Director is responsible for the information security program, and management reviews cyber risks. It does not include qualifying domain-specific cybersecurity terminology beyond generic risk language, nor any firm-specific or externally verifiable facts that would elevate specificity.


fact: protect the confidentiality, integrity, and availability of its critical systems and information

reasoning: The paragraph primarily describes the company’s cybersecurity risk management program and its integration into a broader risk framework, which is a risk management process topic. Specificity rises above boilerplate because it uses the cybersecurity-specific CIA triad concept—confidentiality, integrity, and availability—but it includes no firm-specific roles, committees, dates, or verifiable claims.


fact: The company has a dedicated incident management team responsible for coordinating cybersecurity incident response efforts

fact: Cybersecurity incidents meeting certain thresholds are escalated to the executive incident team

fact: The company maintains a cybersecurity and incident response program

fact: The program includes standard processes for reporting and escalating cybersecurity incidents to the executive incident team

fact: The company conducts at least one incident response test exercise annually using a simulated incident scenario

reasoning: This paragraph primarily describes how the company’s cybersecurity incident response process operates—coordination, escalation, tracking, reporting, and testing—so it fits Risk Management Process rather than Management Role. Specificity rises to Firm-Specific because it identifies internal teams such as the incident management team and executive incident team, even though most of the operational language is otherwise fairly standard.


fact: vulnerability management policy

fact: encryption of data

fact: incident detection and response policies and procedures

reasoning: The paragraph primarily describes the company’s cybersecurity program measures and controls—i.e., what it does to manage cyber risk—so it fits Risk Management Process. Its specificity rises above boilerplate because it includes cybersecurity-specific practices such as vulnerability management, incident detection/response, and encryption, but it does not provide firm-unique or externally verifiable details.


fact: identity management and access control safeguards

fact: encryption of data in transit and at rest

fact: system and network security monitoring

reasoning: The paragraph primarily describes protective cybersecurity measures the company has implemented, which is a description of the cybersecurity program's activities rather than governance or management structure. Specificity is elevated by cybersecurity-domain terms such as identity and access controls, encryption in transit and at rest, and system/network monitoring, but it contains no firm-unique or externally verifiable facts.


reasoning: The paragraph primarily explains how the company manages cybersecurity exposure arising from external service providers, especially its third-party accounting firm, so Third-Party Risk is the best fit. It does not include qualifying domain-specific security terminology, named firms, named roles/committees, certifications, dates, or other verifiable cybersecurity facts, so the specificity remains Generic Boilerplate.


fact: Chief Information Officer supervises the information security team

fact: Information Security Officer coordinates with compliance and human resources to conduct information security awareness training

fact: The Chief Information Officer and Information Security Officer have combined over 35 years of IT management experience

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity, focusing on the CIO and Information Security Officer’s responsibilities, reporting structure, and qualifications, even though it also mentions third-party risk activities. Specificity reaches Quantified-Verifiable because it includes a checkable numerical claim: the CIO and Information Security Officer have combined over 35 years of IT management experience.


reasoning: The paragraph is primarily about how the board oversees cybersecurity risk, including board expertise, reporting, and updates, so Board Governance is the best fit. Its language remains generic: it names only the Board and uses broad oversight phrasing without qualifying domain-specific terms, firm-unique structures, or verifiable details.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party service providers and supply-chain relationships, so Third-Party Risk is the best fit. Its language remains high-level and generic—describing vendor risk processes and audit rights without naming any specific framework, technology, internal program, team, or verifiable fact—so specificity is Generic Boilerplate.


fact: The company’s CISO provides cybersecurity updates to the Audit Committee and the Board

fact: The company’s Chief Information Officer provides cybersecurity and information technology updates to the Audit Committee and the Board

reasoning: This paragraph primarily describes how the board oversees cybersecurity risk, including delegation to the Audit Committee and reporting/escalation to the board, so it is Board Governance. Its specificity rises to Firm-Specific because it identifies firm-level cybersecurity leadership roles—specifically the CISO and Chief Information Officer—even though the rest of the language is largely generic governance boilerplate.


fact: The Director of Information Technology has over 20 years of experience in information security, risk management, and compliance.

reasoning: This paragraph primarily describes the oversight chain for cybersecurity risk management—board audit committee oversight flowing through management to the DIT—so Board Governance is the best fit. Its specificity is Quantified-Verifiable because it includes a concrete, externally checkable claim that the DIT has over 20 years of relevant experience.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk from vendors and service providers, making Third-Party Risk the best fit. Although it gives examples of provider types and describes a vendor management process, it uses largely generic ERM-style language (risk assessments, questionnaires, reviews, contractual obligations) without qualifying domain-specific terms, firm-unique governance details, or externally verifiable facts.