reasoning: Paragraph describes management's implementation of risk processes with CFO serving as CISO as the central subject. While risk management processes are mentioned, the main focus is on the management role (CFO/CISO) and their responsibilities. The dual role of CFO as CISO is a firm-specific organizational structure choice.


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is a general statement about IT team qualifications with no substantive cybersecurity disclosure. It does not discuss board oversight, management roles, risk processes, third-party risks, incidents, or business strategy. It contains only vague references to 'professional experience' and programs from 'leading institutions' - no specific names, dates, or verifiable facts.

provider: minimax

stage: benchmark


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal processes for assessing, identifying, and managing cybersecurity risks, including traffic monitoring tools and user training — these are internal risk management activities.


reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks across their systems and data — this is a core risk management process disclosure, not board governance or third-party risk as the primary focus.


content_category: Management Role

reasoning: The grammatical subjects are the CSO and CISO (cybersecurity-specific roles), with the board and audit committee mentioned only as recipients of reporting, making Management Role the primary category per tiebreaker rules. The paragraph is Firm-Specific because it names the Global Security Steering Committee (a named internal committee, not a generic 'committee'), going beyond generic boilerplate.


content_category: Strategy Integration

specificity_confidence: medium

reasoning: This is a standalone materiality conclusion stating no cybersecurity incidents have materially impacted (or are reasonably likely to materially impact) the company. It contains no incident narrative, making it Strategy Integration rather than Incident Disclosure.


reasoning: This paragraph describes generic incident response steps (eradication) without referencing a specific incident, dates, systems, or scope. It reads as boilerplate language describing standard response procedures rather than a substantive disclosure about a particular cybersecurity event.


reasoning: This paragraph describes the company's internal employee and contractor training program for cybersecurity awareness, which is a component of the company's risk management process. The language is entirely generic boilerplate with no specific facts, frameworks, or firm-unique details.


reasoning: The paragraph describes internal cybersecurity processes (threat intelligence, control assessment, capability testing) but contains no specific details - no named frameworks, specific dates, dollar amounts, named third-party firms, or unique firm-specific facts. All elements are generic boilerplate that could appear in any company's disclosure.


reasoning: The paragraph describes the company's internal cybersecurity risk management system as a 'comprehensive framework' for identifying, assessing, and mitigating risks - this is a generic description of internal processes with no specific details, frameworks named, dates, or firm-specific facts.


content_category: Board Governance

reasoning: The paragraph's grammatical subject is 'The Company's Board of Directors' providing oversight, with discussion of periodic quarterly updates and annual enterprise risk management discussions - all standard board governance language with no company-specific details.


reasoning: The paragraph describes management's internal process for monitoring cybersecurity incidents through notifications from service providers and communications with Investment Manager personnel. This is a generic internal process description that could apply to any company, with no specific dates, named entities, frameworks, or quantifiable details.


category_confidence: medium

reasoning: The paragraph describes the company's plans to implement a process for identifying and managing cybersecurity risks as part of their broader risk management system. This is about internal risk management processes, though it's forward-looking and contains no specific details about current implementation, frameworks, or firm-unique facts.


reasoning: This is a negative disclosure stating no cybersecurity breaches or related expenses occurred, which is not substantive cybersecurity disclosure content - it's essentially a statement about the absence of incidents. The specific fiscal year-end dates (2023 and 2022) provide temporal specificity but are standard financial reporting dates, not unique cybersecurity facts.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management - developing, implementing, and maintaining measures to safeguard systems and protect data. This is about internal processes with no board oversight, management roles, vendors, incidents, or financial details. It contains only generic boilerplate language with no specific facts, dates, named frameworks, roles, or any company-specific details.


reasoning: The paragraph describes the company's general goals for cybersecurity risk management (business continuity, protecting technology, safeguarding data) but contains no specific details, named entities, dates, or frameworks. This is standard boilerplate language applicable to any company.


reasoning: This paragraph describes common security awareness practices (phishing simulations and annual training) that are standard across virtually all companies. It contains no specific dates, named frameworks, unique roles, or any other firm-specific identifying information — these are generic security practices that could appear in any company's filing unchanged.


reasoning: The paragraph describes the company's internal cybersecurity and IT risk management processes (policies, procedures, assessments, monitoring, response plans, testing), which falls under Risk Management Process. It contains no specific facts—no named frameworks, roles, dates, tools, or any details that would distinguish this company's disclosure from any other company's generic boilerplate language about having a cybersecurity program.


reasoning: Paragraph discusses who handles day-to-day cybersecurity management (IT staff) and their qualifications (no specialized training), which falls under Management Role. Contains no specific facts - no named roles, dates, dollar amounts, named third parties, or framework references; it's a generic statement about IT staff handling cybersecurity without specialized expertise that could apply to any company.


reasoning: The paragraph describes the company's ongoing internal investigation process (forensic analysis to determine nature, scope, impact) rather than describing what happened in the incident itself. This is standard boilerplate language about incident investigation that could appear in any 8-K filing.


reasoning: The paragraph describes the company's internal training programs and risk management processes. Third-party vendors are mentioned as a component of the internal process, not as a standalone topic about vendor oversight requirements, so this is Risk Management Process, not Third-Party Risk. No specific dates, dollar amounts, named frameworks, or firm-specific details are present - just generic descriptions of security practices that could apply to any company.


content_category: Incident Disclosure

reasoning: Paragraph describes an active cybersecurity incident involving system disruption, restoration efforts, engagement of experts and law enforcement, and regulatory notification - all core elements of incident disclosure. No specific dates, named third-party firms, dollar amounts, or other verifiable facts are present.


reasoning: Paragraph describes an internal multi-disciplinary team created to raise cybersecurity awareness and provide training, which is an internal risk management process. The named program 'CyberSmart Defender Network' is a unique identifier specific to this company's disclosure.


reasoning: This paragraph is a generic functional description of what cybersecurity professionals do, not identifying specific roles, processes, or substantive disclosure. It reads as descriptive language or section header rather than meaningful cybersecurity disclosure.


reasoning: The paragraph describes the company's own internal cybersecurity program and processes (multi-layered program, incident response plan) for managing cyber risk. It contains no specific dates, named roles, named frameworks, products, or any firm-specific details — only generic security terminology that could appear in any company's filing.


reasoning: This is a standalone materiality conclusion about the incident's financial impact without describing the incident itself (no dates, scope, or response actions). Per tiebreakers, paragraphs that ONLY discuss materiality without incident narrative map to Strategy Integration. The language is standard boilerplate that could appear in any company's filing with no firm-specific details.


reasoning: This paragraph describes what happened in the cybersecurity incident (unauthorized access, data exfiltration, PII) and the company's response actions (providing notifications), which is the core of Incident Disclosure. However, it contains no specific dates, dollar amounts, named third-party firms, or other verifiable facts that would make it firm-specific.


reasoning: This is a negative assurance statement stating no material cybersecurity threats were identified in 2024. It contains no substantive disclosure about governance, processes, incidents, or strategy - only a boilerplate materiality statement directing readers to Risk Factors for more information.


reasoning: Paragraph describes the company's internal IRP and annual tabletop exercises - this is describing the company's own internal processes for incident response, which falls under Risk Management Process. However, it contains no firm-specific details: 'IRP' is a generic acronym, 'annual' is a generic cadence, no specific dates, named programs, roles, tools, or third-party firms.


reasoning: This paragraph ONLY discusses the financial materiality assessment of an incident without describing what happened, when, or how. Per tiebreakers, this is Strategy Integration. It contains no specific dates, dollar amounts, named firms, or any other firm-specific details - it's standard SEC materiality language that could appear in any company's filing.


reasoning: The grammatical subject is the 'internal cybersecurity coordinator,' a management role responsible for assessing cybersecurity risks and reporting to the CEO. While this describes a management function, the paragraph lacks any firm-specific details—it uses generic terms like 'IT team,' 'CEO,' and 'senior management' that could appear in any company's disclosure. No specific titles (CISO, CTO), named committees, dates, frameworks, or quantifiable facts are present.


reasoning: This paragraph discusses insurance reimbursement for a cyber incident without describing the incident itself, which aligns with Strategy Integration (financial/business impact). It contains no specific dates, dollar amounts, named insurers, or other verifiable facts—all language is generic boilerplate that could appear in any company's filing.


reasoning: This paragraph discusses the potential financial/material impact of an incident without describing what happened. Per tiebreakers, when a paragraph ONLY discusses financial cost, insurance, or materiality WITHOUT describing the event, it maps to Strategy Integration.


reasoning: The paragraph identifies specific management roles (CFO, COO, CEO) and their cybersecurity responsibilities as the grammatical subjects, clearly placing it in Management Role rather than Board Governance or other categories.


reasoning: This paragraph solely discusses the materiality assessment and financial impact of an incident without describing the incident itself. It contains standard boilerplate language about 'material impact' and 'reasonably likely to materially impact' that appears in virtually all cybersecurity incident disclosures.


reasoning: This paragraph discusses financial impact and materiality without describing the incident itself — it only mentions that operations were not disrupted and lists potential financial risks (diversion of management attention, revenue loss, remediation costs, regulatory penalties, litigation). Per tiebreakers, discussing financial/materiality implications without incident narrative maps to Strategy Integration.


reasoning: Paragraph only discusses materiality/impact conclusions about the incident without describing what happened. This is standard boilerplate materiality language that could appear in any company's filing.


reasoning: This paragraph provides only a standalone materiality conclusion about an incident without describing the incident itself (no dates, scope, or response actions). Per the category tiebreakers, this maps to Strategy Integration. It contains no specific facts—only boilerplate language about operational and financial impact that could appear in any company's filing.


reasoning: This paragraph describes a corporate leadership change (CEO resignation and interim appointment) unrelated to cybersecurity. While filed under Item 1.05 (cybersecurity incident disclosure), the content concerns executive management rather than cybersecurity risks, incidents, or governance.


reasoning: This paragraph discusses cybersecurity insurance coverage in general terms (incident response, forensic investigations, business interruption, regulatory fines) without naming an insurer, specific coverage amounts, or policy details. It describes financial/risk transfer mechanisms rather than an actual incident, making Strategy Integration the appropriate category.


reasoning: This paragraph discusses waiver provisions under credit and lease agreements with no cybersecurity content whatsoever. It is purely legal/financial language unrelated to cybersecurity disclosure requirements.


reasoning: This paragraph discusses only the materiality conclusion about an incident (whether it will materially impact financial condition) without describing the incident itself, which maps to Strategy Integration per the category tiebreakers. It contains no specific dates, dollar amounts, named entities, frameworks, or any other specific facts — only boilerplate materiality language that appears in virtually every 8-K incident disclosure.


reasoning: The paragraph primarily describes management roles (CTO, senior director) and their reporting structure to the Audit Committee, with the first sentence about professional certifications of an individual. The named certifications (CISSP, PMP, SANS) are specific recognized standards, but no unique firm-specific details like named programs, specific dates, or company-unique information are present.


reasoning: This paragraph discusses the financial/material impact of an incident and materiality assessment without describing the incident itself (no dates, scope, or event details). This is a standalone materiality conclusion, which falls under Strategy Integration.


reasoning: This paragraph discusses the financial/insurance aspects of incident response (cyber insurance provider involvement, potential claims process) and the ongoing nature of the investigation without describing the incident itself. The focus is on business recovery and insurance coverage, not on incident details or internal processes.


reasoning: This paragraph discusses the financial/materiality assessment of the incident without describing what happened, making it Strategy Integration. It's standard boilerplate language about materiality that appears in many filings.


reasoning: This paragraph discusses the Company's ongoing investigation and materiality assessment but does not describe what happened in the incident. The main point is the financial impact conclusion ('does not believe the incident is reasonably likely to materially impact...'), which per tiebreakers classifies as Strategy Integration rather than Incident Disclosure.


reasoning: This paragraph provides only a standalone materiality conclusion about an incident without describing what happened, the scope, or response actions. Per tiebreakers, this is Strategy Integration. It contains no specific dates, dollar amounts, named firms, or other verifiable facts—it is standard boilerplate language that could appear in any company's filing.


reasoning: This paragraph describes response actions to a cybersecurity incident (containing the incident, restoring IT environment, restoring business operations). While it doesn't describe what happened in the incident, it describes ongoing response and recovery from a previously disclosed real event, fitting the Incident Disclosure category.


reasoning: This paragraph discusses the aftermath and potential consequences of the cybersecurity incident (litigation risk, customer behavior changes, regulatory scrutiny, insurance changes) without describing the incident itself. Per tiebreaker rules, when a paragraph ONLY discusses financial/insurance impact or materiality WITHOUT describing the event, it maps to Strategy Integration. The language is entirely generic boilerplate with no specific dates, dollar amounts, named entities, or other verifiable facts.


reasoning: This paragraph discusses only the financial/materiality assessment of an incident (not having material impact on operations or financial condition) without describing what happened in the incident itself. Per tiebreakers, this is Strategy Integration. The language is standard boilerplate materiality language with no specific dates, amounts, named entities, or firm-specific details.


reasoning: This paragraph discusses ongoing evaluation of scope, potential impacts, and financial/reputational considerations without describing what happened in the incident. Per tiebreakers, discussing financial/materiality implications without incident narrative maps to Strategy Integration. Contains no specific dates, dollar amounts, named entities, or other verifiable facts—pure boilerplate language about ongoing assessment.


reasoning: Paragraph describes an actual cybersecurity incident with specific dates (August 14 and October 28, 2025), identifying the third-party source and confirming customer information was exposed - this is an incident narrative describing what happened.


reasoning: This paragraph describes a cybersecurity incident - it references 'this incident' and 'the point of unlawful access' as the security event, and describes response actions taken (closing access point, providing notice to impacted customers). The grammatical subject is the company's own actions in response to a past event, which aligns with incident disclosure content.


reasoning: This paragraph describes the company's response actions to a cybersecurity incident - specifically the notification process to law enforcement, regulatory bodies, and consumer protection agencies. While it references 'the matter' (indicating a real incident) and describes response activities, it contains no firm-specific details, dates, or named entities that would elevate it beyond generic boilerplate language describing standard incident notification procedures.


reasoning: This paragraph describes operational impact from a cybersecurity incident (disrupted online ordering, uninterrupted deliveries) - the operational scope is the central topic. It contains no specific dates, dollar amounts, named third parties, or other verifiable facts - only general descriptions of affected vs. unaffected operations.


reasoning: The paragraph discusses financial cost recovery through insurance for incident-related costs but does not describe the incident itself. This focuses on financial/strategic impact rather than incident disclosure, making Strategy Integration the appropriate category. The language is generic boilerplate with no specific dates, dollar amounts, or named entities.


reasoning: Paragraph describes an actual cybersecurity incident (exfiltration of personal information), ongoing investigation, scope assessment, and notification plans - all core elements of incident disclosure. Contains no specific dates, dollar amounts, headcounts, percentages, named third-party firms, or named products/tools.


reasoning: This paragraph discusses monitoring the timing and materiality of the incident without describing what happened in the incident itself, which aligns with Strategy Integration per the tiebreakers. The content is generic boilerplate language about assessing financial impact that could appear in any company's filing.


reasoning: The paragraph describes the incident's technical aspects - unauthorized access, data exfiltration, and encryption of non-production systems - which is the core narrative of an incident disclosure. It contains no specific dates, named entities, dollar amounts, or other hard verifiable facts; all elements are described generically as 'certain Company systems' and 'certain non-production systems'.


reasoning: The paragraph describes incident response actions (notifying law enforcement and regulatory bodies), which falls under incident disclosure. However, it contains no specific details—no dates, named entities, or firm-specific facts—and uses only generic references like 'legal counsel' and 'relevant law enforcement.'


reasoning: This paragraph describes an actual cybersecurity incident that occurred on a specific date (March 1, 2025), including what happened (system outage), the discovery, and response actions (activated incident response team with internal personnel and external experts). This is a narrative description of a real event.


content_category: Third-Party Risk

reasoning: The paragraph explicitly focuses on a fourth-party vendor (vendor of a vendor) as the cause of the incident, making vendor oversight the central topic rather than the company's internal response process.


reasoning: This paragraph only discusses the materiality assessment of the incident without describing what happened, making it Strategy Integration per the tiebreaker rules. It contains no specific details, dates, named entities, or quantifiable facts — only boilerplate language about financial impact determination that could appear in any company's filing.


reasoning: This paragraph describes the operational impact of a disclosed cybersecurity incident (shipping, manufacturing, back office functions affected), which falls under Incident Disclosure. However, it contains no specific verifiable facts—no dates, dollar amounts, named third parties, named tools, or quantified metrics—just generic operational descriptions.


reasoning: This paragraph is essentially a cross-reference directing readers to external status updates. It does not describe what happened in the incident, provide any narrative, or disclose scope/response actions. It merely notes that networks may not be accessible and points to a status page for further information, which is placeholder content rather than substantive disclosure.


reasoning: This paragraph discusses financial/business impact (costs of rebuilding website, new server/hosting platform, security enhancements) without describing the incident itself — it focuses on the economic consequences, making Strategy Integration the appropriate category.


reasoning: This paragraph provides a standalone materiality conclusion about the incident without describing the incident itself — it only discusses operational and financial impact assessments, which maps to Strategy Integration per the tiebreakers. The language is entirely generic boilerplate with no specific dates, amounts, named entities, or firm-specific details.


reasoning: This paragraph describes a response action (notification letters) taken in connection with a cybersecurity incident investigation. While it doesn't describe the incident itself, it is part of the incident disclosure narrative and describes the company's response to a real event. The mention of SouthState as the specific company makes it firm-specific.


reasoning: This paragraph discusses only the financial/material impact of an incident without describing what happened. Per tiebreakers, when a paragraph ONLY discusses cost, insurance, or materiality WITHOUT describing the event, it maps to Strategy Integration. The language is entirely boilerplate materiality language with no company-specific details.


reasoning: The paragraph describes a cybersecurity incident involving unauthorized access to IT systems containing sensitive personal information, along with notification response actions. No specific dates, named entities, frameworks, or verifiable facts are present.


reasoning: The paragraph describes an actual cybersecurity incident involving unauthorized access to information and mentions response actions (notifying regulatory authorities and working with law enforcement), which falls under Incident Disclosure. However, it contains no specific dates, dollar amounts, named firms, products, or other firm-specific details that would elevate it beyond Generic Boilerplate.


reasoning: This paragraph discusses the materiality assessment of an incident's financial impact without describing the incident itself, which aligns with Strategy Integration. The paragraph contains no firm-specific details, dates, dollar amounts, or named entities.


reasoning: Paragraph describes an ongoing forensic investigation into a cybersecurity incident to determine if PII was exfiltrated by threat actors, which is describing the incident scope and response. No specific dates, named firms, dollar amounts, or other verifiable facts present.


reasoning: This paragraph describes temporary measures (manual processing, alternative distribution channels) implemented to maintain business functions while systems are being restored, which constitutes incident response actions describing what the company is doing in response to an incident.


reasoning: The paragraph describes incident response actions (containing the incident, restoring systems, resuming operations) which falls under Incident Disclosure, though it lacks any specific details about what happened, when, or the scope of the incident.


reasoning: This paragraph only discusses the financial/materiality assessment of an incident without describing what happened in the incident. Per tiebreakers, this is Strategy Integration, not Incident Disclosure.


reasoning: Paragraph describes an actual cybersecurity incident with specific date (February 3, 2025), what happened (systems outage caused by cybersecurity attack), and response actions (activated incident response team). The specific date is the one hard verifiable fact that elevates this to Firm-Specific, while the rest uses generic language ('external cybersecurity experts' without naming them).


reasoning: The paragraph describes the company's own internal processes for assessing, identifying, and managing cybersecurity risks, including threat assessment, layered security, training, and third-party risk management. While third-party risk is mentioned, it is a component of the broader internal process rather than the central topic.


reasoning: Paragraph describes a cybersecurity incident with a specific date (August 21, 2024) and what happened (unauthorized third party gained access to certain systems), which is an incident narrative. This fits the Incident Disclosure category per the tiebreakers.


reasoning: This paragraph discusses only the financial/materiality impact of an incident without describing what happened in the incident. Per tiebreakers, when a paragraph ONLY discusses financial cost, insurance, or materiality of an incident WITHOUT describing the event, it maps to Strategy Integration.


reasoning: This paragraph provides a status update on a previously disclosed incident (referencing 'the Original Report') rather than describing the incident itself. It focuses on restoration progress, ongoing operational impacts, and investigation closure - essentially business/operational outcomes rather than incident details. No specific dates, named entities, or quantifiable metrics are provided.


reasoning: This paragraph describes the Company's response to the Change Healthcare cybersecurity incident, including interim measures and restoration timeline, which constitutes incident disclosure. It contains firm-specific details including the named subsidiary (Change Healthcare), a specific date (March 7, 2024), and references an attached exhibit, making it Firm-Specific rather than generic boilerplate.


reasoning: This paragraph describes operational impact from an incident (website inaccessibility) and response actions (creating a special communications website), which aligns with Incident Disclosure. It contains one specific verifiable fact (the named URL www.firstamupdate.com), making it Firm-Specific but not reaching Quantified-Verifiable threshold as it lacks dates, dollar amounts, headcounts, or named third-party firms.


reasoning: Paragraph describes management roles (Senior Director of IT, CFO/Treasurer) implementing cybersecurity risk assessment processes — grammatical subject is 'certain individuals in Company management', making Management Role the appropriate category.


reasoning: The paragraph describes the operational impact of an actual cybersecurity incident (limited access to business applications, affected systems, duration of approximately six weeks), which is the core of Incident Disclosure. However, it contains no specific dates, dollar amounts, named third-party firms, or named products—it only provides approximate duration and generic system descriptions that could apply to any company.


reasoning: This paragraph discusses only the financial/materiality implications of the incident (expected impact on Q4 2023 results vs. no material impact on overall financial condition) without describing the incident itself. Per tiebreakers, financial materiality language without incident narrative maps to Strategy Integration. The paragraph contains no specific dates, dollar amounts, named entities, or other verifiable facts—it uses generic boilerplate materiality language common to all disclosures.


reasoning: The paragraph comprehensively describes Wendy's internal cybersecurity risk management processes, including framework adoption (CIS Controls), risk assessments, infrastructure design, dedicated personnel, and training programs. While it mentions the Technology Committee as a recipient of reporting, the central topic is the company's own internal processes for managing cyber risk, not board governance or management roles.


reasoning: This paragraph is a forward-looking risk disclosure describing the general threat landscape and potential impacts of cybersecurity incidents. It contains no substantive disclosure about actual governance structures, management processes, or specific incidents - it's essentially boilerplate risk language that could appear in any company's filing.


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management, including policies, standards, processes, and practices for assessing, identifying, and managing material risks from cybersecurity threats. While it mentions regulatory bodies, these are standard compliance requirements for any financial services company and do not constitute firm-specific cybersecurity facts.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes across six key areas (governance, collaborative approach, technical safeguards, incident response, third-party risk, education). While it mentions the Board and Audit Committee, they are discussed as components of the company's internal governance structure rather than as the primary subject. No specific dates, dollar amounts, named frameworks, certifications, or other verifiable facts are present - all elements are generic descriptions of standard cybersecurity practices.


reasoning: The paragraph primarily describes the management structure overseeing cybersecurity, identifying specific roles (IT Manager, General Counsel, CEO, COO) and their qualifications, responsibilities, and reporting relationships. While it mentions the Cybersecurity Program, the grammatical subjects and main focus are on named management individuals and their roles.


reasoning: The paragraph describes an actual cybersecurity incident: the detection date (February 21, 2024), what happened (attempted fraudulent fund extraction), and how it was detected (through operational controls). This is clearly an Incident Disclosure as it describes a real event with specific temporal details.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach, including the systems it protects, the threats it faces, and the general precautions it takes. While it mentions general threats, the focus is on the company's own infrastructure and controls, not board oversight or specific incident details.


reasoning: This paragraph describes an actual cybersecurity incident - it specifies when the company was notified (November 29, 2024), what happened (unauthorized activity on IT systems), and initial response actions (investigating, containing, remediating with cybersecurity experts). This is clearly an incident disclosure as it narrates what occurred. The specific date qualifies as a firm-specific fact.


reasoning: Paragraph focuses on the third-party cybersecurity team structure, including the vCISO and team member roles/qualifications, with management (CEO) oversight. This is about identifying who manages cybersecurity rather than board oversight. Contains multiple hard verifiable facts: specific role titles, specific years of experience (30), and three named certifications - meeting the two+ hard facts threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes including defense, monitoring, policies, training, and supplier engagement. It contains no firm-specific facts—no named roles, committees, dates, tools, firms, or quantified metrics—and could apply to any company.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, including framework adoption (NIST), internal team structure, security measures, and vendor oversight as one component. Per tiebreakers, internal processes mentioning vendors as one component → Risk Management Process, not Third-Party Risk.


reasoning: The paragraph describes the company's general approach to cybersecurity: monitoring networks, preventing/detecting/mitigating unauthorized access. While it discusses internal security processes, it contains no firm-specific details—no named roles, frameworks, dates, tools, or quantifiable metrics. It's a generic risk factor applicable to any company handling sensitive data.


reasoning: The paragraph describes the company's internal incident response and evaluation processes, including how incidents are assessed, who evaluates them (CSO), escalation procedures, and the Incident Response Program. This is clearly about the company's own internal risk management processes rather than board oversight, third-party risk, or incident disclosure (no actual incident described).


reasoning: The paragraph primarily describes the company's internal cybersecurity program and processes (hiring, training, monitoring, penetration testing), with vendor oversight as one component of those internal processes. The third-party requirements (SOC reports, access reviews) are mentioned as part of the company's overall risk management approach rather than being the central topic.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach covering security controls, awareness training, third-party oversight, monitoring, and business continuity. While third-party oversight is mentioned, it's presented as one component of the internal risk management process rather than as a standalone topic about vendor oversight. The mention of NIST CSF is the only specific element, making this Sector-Adapted.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes including risk identification, mitigation, monitoring, incident response planning, and disaster recovery. While it mentions specific internal programs (IRP, BCP, Disaster Recovery Plan), these are generic names used by any company rather than firm-specific identifiers. The key distinguishing feature is the explicit naming of the NIST Framework, which elevates it to Sector-Adapted.


reasoning: Paragraph primarily describes the CISO and CTO roles, their qualifications, reporting lines, and responsibilities — the grammatical subjects are management roles. Contains multiple hard verifiable facts: two specific experience durations (13 years, 20 years), multiple named companies (IBM, Axway, OWASP), and specific program names (GIS), meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes internal processes for incident response, including the Agility Preparedness Plan, Crisis Management Team structure, third-party assessments, and training programs. These are all internal risk management activities, not board governance, management role identification, or third-party vendor oversight.


reasoning: The paragraph describes the company's internal cybersecurity processes, tools, and procedures - including EDR, SIEM, email security, network protections, and incident reporting requirements. While third-party services are mentioned, they are a component of the internal security program rather than the central topic of vendor oversight.


reasoning: The paragraph describes board and Risk Committee oversight of cybersecurity risks using standard governance language. While 'Risk Committee' is named, the description of their oversight activities (quarterly meetings, reviewing penetration testing, evaluating information security programs) contains no firm-specific details, dates, or verifiable facts unique to this company.


reasoning: The paragraph focuses on management roles responsible for cybersecurity oversight, specifically naming the Chief Digital Officer, Chief Information Officer, and CISO with their detailed qualifications and experience. This is clearly a Management Role disclosure. The specificity is Firm-Specific because it contains multiple unique identifiers (named executives with specific titles) and specific quantified facts (years of experience, tenure in roles) that are unique to this company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes across five areas (identification/escalation, technical safeguards, incident response, third-party risk, education). While third-party risk is mentioned, it's presented as one component of the broader internal risk management framework rather than the central topic. No specific facts, named frameworks, dates, or firm-specific details are present.


reasoning: This paragraph describes general cybersecurity threats and risks (viruses, worms, phishing, denial-of-service) but does not describe the company's specific internal processes, frameworks, or risk management approach. It is a standard risk factor disclosure that could appear in any company's filing.


reasoning: The paragraph's primary grammatical subject is the Chief Information Officer, detailing his qualifications, experience, certifications, and reporting structure. While the Board and Audit Committee are mentioned, they are only referenced as recipients of management reports, making this fundamentally about management's role in cybersecurity governance.


reasoning: The paragraph describes the company's own internal processes, policies, and technical safeguards for managing cybersecurity risks - this is the core definition of Risk Management Process. It contains no specific facts that would identify this as unique to Cohen & Steers; all listed measures (anti-virus software, firewalls, incident response plans, employee training, vulnerability scanning) are generic security practices that could apply to any company.


reasoning: This paragraph contains a standalone materiality conclusion (no material incidents in 2024) with discussion of potential future financial impacts, which aligns with Strategy Integration. It contains no specific facts - the date reference 'year ended December 31, 2024' is a standard fiscal year, and there are no named frameworks, roles, tools, third-party firms, or quantifiable metrics.


reasoning: This paragraph is general risk disclosure describing types of incidents the company occasionally experiences, with a forward-looking disclaimer and cross-reference to risk factors. It does not describe a specific incident with dates, scope, or response actions, nor does it discuss governance, management roles, or internal processes substantively.


reasoning: This paragraph is a forward-looking risk discussion that describes potential cybersecurity threats and their potential impacts, but does not describe any actual incident, internal process, or governance structure. It primarily serves as a cross-reference to a risk factor in Item 1A and contains only generic cybersecurity risk language applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes across multiple areas (risk identification, technical safeguards, incident response, third-party oversight, training). While it mentions third-party risk management, it's presented as a component of the company's overall internal processes rather than as a standalone central topic. All language is generic with no specific dates, named roles, frameworks, tools, or firm-specific details.


reasoning: The paragraph primarily discusses management-level roles and responsibilities for cybersecurity (CISO, CCO, Information Security Team), their qualifications, expertise, and reporting structure. The board is not mentioned; this focuses on identifying who manages cyber risk and their credentials.


reasoning: Paragraph describes the company's internal cybersecurity risk management processes including monitoring, incident response planning, and third-party engagements - all internal processes rather than vendor oversight. No specific dates, dollar amounts, headcounts, named third-party firms, named products, or unique identifiers are provided. All elements are generic descriptions of standard security practices that could apply to any company.


reasoning: Paragraph describes the company's own internal information security program, including tools, controls, monitoring, policies, and training - this is the company's own risk management process. While it mentions the Board and Risk Committee, they are not the grammatical subject of the main disclosure; the paragraph shifts to describing Schwab's internal security program and practices.


reasoning: The paragraph's primary focus is on identifying management roles and their qualifications for cybersecurity oversight—the CTO is the grammatical subject, their experience and certifications are detailed, and the committee structure is described. While it mentions processes like the incident response plan, these are secondary to describing who is responsible for cybersecurity governance.


reasoning: Paragraph focuses entirely on Board of Directors oversight and Audit Committee review responsibilities, with no mention of management-level cyber roles. The governance structure described (Board oversight, Audit Committee delegation) is standard boilerplate with no firm-specific details.


reasoning: The paragraph describes the company's risk assessment program and cybersecurity risk management processes in generic terms without any firm-specific details. It lists common threat types (ransomware, phishing, etc.) and standard security practices that could appear in any company's disclosure. The materiality conclusion is boilerplate forward-looking language.


reasoning: The paragraph describes the company's cybersecurity program elements (governance, collaborative approach, technical safeguards, IR planning, third-party risk management, education) - these are internal processes. While board and CISO are mentioned, they are components of the overall program description rather than the central focus. No specific dates, dollar amounts, named third-party firms, or unique firm-specific details are present.


reasoning: The paragraph describes USCF's internal cybersecurity risk management processes including risk assessments, policy evaluations, and third-party due diligence. It contains no specific dates, dollar amounts, headcounts, named third-party firms, named products/tools, or other verifiable facts that would make it firm-specific. All elements are generic descriptions of security practices.


reasoning: The paragraph describes Northern Trust's internal cybersecurity risk management program, including the policy framework, organizational structure, and governance processes. While it mentions third-party vendors, this is presented as a component of the internal program rather than the central topic. The presence of the named Business Risk Committee, specific policy names, and named internal programs provides firm-specific details beyond generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes including continuous monitoring, defense-in-depth approaches, framework adoption, penetration testing, vendor assessments, and policy reviews. While it mentions vendors, this is within the context of the company's own risk management program rather than being the central topic. The paragraph names recognized frameworks (ISO 27001, ISO 42001, NIST, CIS) but contains no firm-specific details such as named personnel, specific dates, dollar amounts, or unique organizational details that would elevate it to Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity processes including monitoring, detection, access controls, training, disaster recovery, and vulnerability management. No specific facts are present - all security measures mentioned are generic practices (two-factor authentication, penetration testing, vulnerability scanning) with no named frameworks, tools, dates, dollar amounts, or firm-specific identifiers.


reasoning: The paragraph's grammatical subject is the President/CEO (a management role) who is identified as principally responsible for cybersecurity oversight, with detailed discussion of his qualifications, experience, and coordination with the General Counsel - clearly Management Role content. The specificity is Quantified-Verifiable because it contains multiple independently verifiable facts: specific time periods (2003-2012, 2010-2011, 2000-2002), named companies (Elk Creek Ventures, Co3 Systems, HomeSphere, Basil Systems, IBM), and specific durations (over 30 years, over 15 years) that an outsider could verify.


reasoning: The paragraph's grammatical subject is the internal management team ('We have an internal management team...'), with the Audit Committee and Board mentioned as recipients of briefings, making Management Role the appropriate category. The Sr. Director of IT is a cybersecurity-specific role and the Risk Management Team is a named internal committee with specific departmental composition—these firm-specific details differentiate it from boilerplate.


reasoning: The paragraph's central topic is third-party vendor risk management, discussing vendor security assessments, the FAIR model for quantifying third-party cyber risk, and contractual security measures. While internal processes are mentioned, they are in service of managing third-party risk rather than being the primary focus.


reasoning: The paragraph describes the company's internal cybersecurity processes: incident response planning, technical safeguards, education/awareness, third-party risk management, and threat intelligence. These are all internal risk management activities. While third-party risk management is mentioned, it is presented as one component of the company's overall internal risk management strategy rather than the central topic.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes including its incident response plan, CISO responsibilities, and internal escalation procedures. While it mentions third parties and the Department of Defense, these are discussed as resources the company uses for its own risk management rather than as the central topic of vendor oversight. The paragraph names NIST RMF and CMMC frameworks, making it Sector-Adapted rather than Firm-Specific, as it contains no firm-unique details like specific dates, dollar amounts, headcounts, or named third-party firms.


reasoning: The paragraph describes the company's overall approach to cybersecurity risk management, including policies, standards, and practices for assessing and managing material risks. It mentions Board and management involvement but only in a generic oversight capacity. No specific frameworks, roles, tools, dates, or other firm-specific details are provided.


reasoning: Paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks, which fits Risk Management Process. It contains only generic definitions and boilerplate language with no specific facts (no named roles, frameworks, dates, tools, or firm-specific details).


reasoning: The paragraph describes the company's own internal processes for assessing, identifying, and managing cybersecurity risks, including incident management, monitoring, and integration with overall enterprise risk management. The mention of third-party service providers is contextualized within the company's internal risk management approach rather than as a standalone third-party risk topic.


reasoning: The paragraph's grammatical subjects are management roles (CTO, CIO, CISO) with very detailed qualification statements about their decades of experience. While board reporting is mentioned briefly, the primary focus is on identifying WHO is responsible for cybersecurity risk management and their specific expertise — this is a Management Role disclosure.


reasoning: The paragraph describes the company's internal risk management framework (policies, standards, processes, practices for assessing and managing cybersecurity threats), which is the core of Risk Management Process. While board oversight is mentioned, it's not the primary grammatical subject—'We have established' is the main verb phrase. The content is entirely generic boilerplate with no named frameworks, specific dates, dollar amounts, named roles, or any other firm-specific details.


reasoning: The paragraph's grammatical subject is the Audit Committee and Board, describing their oversight role. The mention of CIO/CISO is in the context of reporting TO the board, not as the main focus. This is clearly board governance.


reasoning: The paragraph describes the company's internal security infrastructure: subsidiary security programs based on risk and regulatory requirements, an enterprise-wide IT working group with regular meetings, incident reporting requirements based on severity classification, and escalation procedures. This is fundamentally about the company's own internal risk management processes rather than board oversight, specific management roles as the main topic, or third-party vendor risk.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes including risk identification, evaluation, mitigation strategies, SOC monitoring, and program review. While it mentions CIO and CISO, they are referenced in the context of program oversight rather than as the main topic. The mention of NIST framework qualifies as Sector-Adapted as it names a recognized standard but contains no firm-specific details.


reasoning: The paragraph describes the company's internal risk management and mitigation processes including policies, audits, vulnerability management, incident response planning, and various security measures. This is about the company's own internal processes, not board oversight, management roles, third-party vendor requirements, or incident disclosure.


reasoning: This paragraph provides a materiality conclusion (no material incident in 2023, not aware of risks likely to materially affect business) and discusses insurance coverage. It does NOT describe an actual incident with dates, scope, or response actions, so it is not Incident Disclosure. The primary focus is business/financial impact and materiality assessment.


reasoning: The paragraph describes the company's internal incident response plan, annual testing procedures, and tabletop exercise coordination - all internal risk management processes. While it mentions specific departments participating in exercises, this is more of an organizational detail than a hard verifiable fact, making it Firm-Specific rather than Quantified-Verifiable.


reasoning: This paragraph describes an actual cybersecurity incident in detail: it specifies what happened (website defacement), when it occurred (August 25, 2025), the scope (wytecintl.com), response actions (website taken down, restored from backups, temporary page placed, FBI reported), and operational impact (seminar cancelled, website inoperable). This is a clear incident narrative with specific details about a real event.


reasoning: This is a standard forward-looking statement disclaimer using safe harbor language under the Private Securities Litigation Reform Act. It does not discuss actual cybersecurity incident details, governance, processes, or strategy - it merely contextualizes what forward-looking statements might cover regarding 'the Incident' without describing the incident itself.


reasoning: The paragraph's central topic is vendor oversight - describing a vendor management program, assessments of third-party providers, and contractual cybersecurity obligations imposed on those providers. This is not merely mentioning vendors as a component of internal processes but rather the vendor management function itself. For specificity, the paragraph contains no specific dates, dollar amounts, headcounts, named third-party firms, named products/tools, or cybersecurity-specific roles - only generic references like 'third-party cybersecurity software providers' and 'vendor management program'.


reasoning: This paragraph is a forward-looking disclaimer stating no material incidents have been identified, with generic reference to third-party vendors and a cross-reference to the Risk Factors section. It contains no substantive cybersecurity disclosure about governance, processes, incidents, or strategy.


reasoning: The paragraph describes the company's internal disaster recovery and incident response frameworks, crisis management team structure, and oversight activities - all internal risk management processes. The board is mentioned only in the context of coordination during incidents, not as a governance topic. Contains firm-specific identifiers (named plan, named team, CIO role) but no hard verifiable external facts like dates, dollar amounts, or named third-party firms.


reasoning: Paragraph describes the company's internal cybersecurity risk management processes including policies, committee oversight, controls, tools, and third-party risk management - all internal processes. No specific named entities, dates, dollar amounts, or other hard facts that would elevate specificity.


reasoning: The paragraph's grammatical subject is 'Senior management' discussing their responsibility to create and recommend risk appetite metrics for board approval. This focuses on management's role in cybersecurity governance rather than board oversight. The content contains no specific facts - only generic references to 'senior management' and 'Board of Directors' without any cybersecurity-specific titles, named roles, dates, frameworks, or firm-unique details.


reasoning: Paragraph discusses both board oversight and management roles extensively, but the tiebreaker favors Management Role since it provides more detail on management responsibilities and personnel. The only specific fact is 'Director of IT' - a cybersecurity-specific title that qualifies as firm-specific per the IS list, but this single fact doesn't overcome the high bar for Firm-Specific; the paragraph is otherwise generic governance language that could appear in any company's filing.


reasoning: This paragraph describes an actual cybersecurity incident with specific details: date of detection (May 1, 2024), what happened (unauthorized access, encryption deployment, file exfiltration), scope (internal corporate IT systems, business applications, financial/operating reporting), and response actions (containment, investigation, system shutdown, law enforcement notification). This is a clear incident narrative.


reasoning: This paragraph describes the company's internal security training program, which is a component of risk management processes. It contains no specific facts - the training is described in generic terms (recurring, mandatory, based on access/risk/roles/behaviors) that could apply to any company.


reasoning: The paragraph's grammatical subject is the Board and Audit Committee, discussing their oversight responsibilities for the cybersecurity program, which fits Board Governance. However, it contains only one potentially specific fact (CTO) that is offset by generic governance language (Audit Committee, Board, Advisor), and lacks any hard verifiable facts, frameworks, or firm-specific details.


reasoning: The paragraph focuses on management-level roles and responsibilities for cybersecurity, specifically identifying the IT department, management team, and a Software Engineer with information security experience as key actors. The grammatical subjects are management and the Software Engineer, making this a Management Role disclosure.


reasoning: This paragraph describes the cybersecurity incident in detail: it provides specific dates of the updates, investigation findings (33 million accounts accessed, 3,000 accounts with saved data), perpetrator cooperation details, and the customer compensation program with specific monetary values. This is a classic Incident Disclosure narrative describing what happened, the scope, and response actions.


reasoning: The paragraph describes the company's internal risk management procedures for cybersecurity, including policies and employee training. While it mentions supplier/customer relationships, this is presented as part of internal processes rather than as a central topic. The policy name 'Internet, Email and Computer Use Policy' is generic boilerplate that any company could have, and there are no specific dates, dollar amounts, named frameworks, third-party firms, products, or cybersecurity-specific roles that would elevate specificity.


reasoning: Paragraph describes the company's own internal cybersecurity capabilities (policies, processes, personnel) — their lack thereof — and intent to develop a framework. This is describing the company's internal risk management state, not board oversight, management roles, third-party risks, or incident disclosure.


reasoning: Paragraph describes AFG's general awareness and approach to assessing and managing cybersecurity risks, including threat types and potential consequences, but contains no firm-specific details, frameworks, roles, dates, or other specific facts that would differentiate it from any other company's generic risk acknowledgment.


reasoning: This paragraph describes JetBlue's overall cybersecurity strategy and priorities (detection, analysis, response, risk management, resilience) but contains no specific processes, frameworks, or details about how these are implemented. It is strategic positioning rather than operational disclosure, making Strategy Integration the appropriate category.


reasoning: The paragraph primarily describes WHO reviews audit results and remediation — management roles (CFAO, VP of Risk Management, MSSP principal) are the grammatical subjects and main focus. The Audit Committee oversight is mentioned secondarily ('also discussed with'), fitting the tiebreaker for Management Role. Contains firm-specific role titles and specific review cadences.


reasoning: Paragraph describes a real cybersecurity incident including unauthorized access, exfiltration of files with sensitive personal information, system shutdowns, operational disruption, and restoration efforts. This is clearly an incident disclosure narrative. The specific date July 25, 2024 makes it firm-specific, though other details are vague (e.g., 'certain files,' 'certain systems').


reasoning: The paragraph describes the company's internal cybersecurity program and risk management processes. While it mentions third-party service providers, this is presented as one component of the company's own internal program rather than as a standalone third-party risk management topic. The content is entirely generic boilerplate with no specific dates, named frameworks, named third-party firms, or any other firm-specific details.


reasoning: The paragraph's grammatical subject is the board-level Risk Committee, and it describes the committee's oversight responsibilities, reporting cadence, and engagement with management on cybersecurity risks. This is clearly board governance content.


reasoning: The paragraph directly describes the company's internal processes (or lack thereof) for assessing, identifying, and managing cybersecurity risks — this is a core element of the company's own risk management approach.


reasoning: The paragraph describes the company's internal incident response plan and its components (immediate actions, evaluation/oversight, remediation strategies), which is a core internal risk management process. The mention of CEO involvement is about internal governance structure, not board-level oversight.


reasoning: The paragraph's central topic is vendor oversight—specifically ensuring third-party service providers meet contractual cybersecurity obligations—which is the core of Third-Party Risk. It contains no specific facts: no named vendors, dates, dollar amounts, frameworks, or firm-specific details—just generic statements about annual risk assessments and contractual requirements.


reasoning: The paragraph describes the company's internal process for ensuring security oversight during onboarding of new products, projects, and vendors through its Project Management Office and Vendor Management Office routines. While third-party vendors are mentioned, they are part of the internal process rather than the central topic.


reasoning: The paragraph's grammatical subject is the CISO and management team members, describing their roles and oversight responsibilities for cybersecurity risk management. While it mentions management collectively, the primary focus is on the CISO's role in overseeing cybersecurity risk, with specific management positions identified.


reasoning: The paragraph describes the company's internal cybersecurity safeguards, vulnerability assessments, and incident response planning - all internal risk management processes. It contains no company-specific details, named frameworks, specific dates, or unique identifiers; all elements are generic security practices that could appear in any company's filing.


reasoning: The grammatical subject is the CISO and VP of Information Security (management roles), and the paragraph describes their qualifications, experience, and activities — this is management cyber expertise, not board oversight. Contains two specific numbers (25+ and 30+ years) plus two named cybersecurity-specific roles, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph primarily focuses on management roles (CISO, CIO, CTO) and their reporting lines to the CEO, with management roles as the grammatical subject in most sentences. While board oversight is mentioned briefly in the first sentence, management roles are the main focus throughout. The paragraph contains no firm-specific details—no named frameworks, specific dates, dollar amounts, headcounts, named third-party firms, or unique organizational structures beyond standard C-suite roles.


reasoning: The paragraph describes the company's internal process for investigating cybersecurity threats, determining incident occurrence, involving the ISC, isolating systems, and engaging outside advisors. This is a generic incident response process that could appear in any company's filing - no company-specific details, named frameworks, or unique identifiers are present.


reasoning: Paragraph describes internal security processes: multi-layered defense, vulnerability management, incident response and disaster recovery planning. These are the company's own internal risk management practices, not board oversight or third-party vendor oversight.


reasoning: The paragraph describes the company's approach to implementing security controls using a risk-based methodology and discusses inherent limitations of security measures. This focuses on internal processes for managing cybersecurity risk rather than board oversight, specific roles, incident disclosure, or financial materiality.


reasoning: This paragraph is a standalone materiality conclusion stating no cybersecurity threats have materially affected or are likely to affect the company, with no incident narrative or reference to actual events—consistent with Strategy Integration category.


reasoning: This paragraph is a disclosure explaining why the company (a blank check company with no operations) does not have cybersecurity risk management programs. It is a qualifying statement about the absence of cybersecurity content rather than substantive cybersecurity disclosure, fitting the None/Other category. It contains no specific facts - no named roles, frameworks, dates, tools, or firm-specific details - making it Generic Boilerplate.


reasoning: The paragraph describes organizational roles in cybersecurity risk management, mentioning the Board, CIO, Director of IT, and ERM group. While the Board is mentioned, the focus is on multiple management-level parties having roles, making Management Role the appropriate category. All entities mentioned are generic (CIO, Director of IT, Board of Directors) with no cybersecurity-specific titles or firm-unique details.


reasoning: The paragraph describes internal security practices including employee training, phishing simulations, and mandatory onboarding training, which falls under the company's own risk management processes. It contains no specific facts—no named frameworks, tools, dates, dollar amounts, or firm-specific details—and could be pasted into any company's disclosure unchanged.


reasoning: Paragraph contains a standalone materiality conclusion (no incidents materially affecting or likely to materially affect the company) with no incident narrative, fitting the Strategy Integration category per tiebreaker rules. It contains no specific facts - no dates, dollar amounts, named roles, frameworks, products, or third-party firms; all references are generic boilerplate language that could appear in any company's filing.


reasoning: The paragraph describes how the company uses third-party providers as part of their cybersecurity risk management approach. While it mentions various types of service providers, they are described as assisting the company rather than being the central topic of vendor oversight/management. This is internal process description where vendors are a component.


reasoning: This paragraph provides a comprehensive overview of BlackRock's cybersecurity program covering multiple areas (governance, cross-functional approach, safeguards, incident response, third-party risk). While it mentions third-party risk management, it is presented as one component within the broader ERM framework rather than the central topic. The primary focus is describing the company's internal risk management processes and strategy.


reasoning: The paragraph's grammatical subjects are the CIO, CTO, and ISO, who are explicitly named as accountable for managing the information security program. This focuses on management roles and their responsibilities rather than board oversight, making Management Role the appropriate category.


reasoning: The paragraph's grammatical subjects are 'meetings of our board of directors' and 'the board of directors' describing their oversight activities (discussions, presentations, reviews of cybersecurity risk profile), which aligns with Board Governance. It contains no specific facts - all descriptors like 'throughout the year,' 'annual basis,' 'periodic basis,' and 'key performance indicators' are generic boilerplate that could appear in any company's filing.


reasoning: The paragraph's central topic is vendor oversight - specifically the due diligence process performed before engaging vendors that handle sensitive company information. This focuses on third-party risk management rather than internal processes.


reasoning: The paragraph's grammatical subject is the Head of Cybersecurity, describing their responsibilities for monitoring incidents and informing senior leadership and the Board. While board oversight is mentioned, the primary focus is on the management role's duties and reporting structure.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes including audits, vulnerability testing, patching, and monitoring. It contains no firm-specific details - all elements mentioned (internal/external audits, OCC exams, annual penetration testing, third-party vendors, SOC as a Service) are generic practices that could appear in any company's disclosure.


reasoning: This paragraph is a forward-looking risk disclaimer stating that cybersecurity threats could potentially affect the business, with a reference to a risk factor in Item 1A. It contains no substantive disclosure about governance, management roles, processes, incidents, or strategy integration.


reasoning: The paragraph's grammatical subjects are 'Oblong's Audit Committee' and 'The Audit Committee', and the content focuses on board/committee oversight of cybersecurity risks, receiving updates, and overseeing incident communication protocols. No management roles are the subject, no actual incident is described, and no internal processes are detailed as the central focus.


reasoning: Paragraph describes engaging third-party service providers to evaluate the company's own cybersecurity program through tabletop exercises - this is internal risk management process, not vendor oversight. Contains no specific dates, named entities, frameworks, or verifiable facts - just generic descriptions of common security practices.


reasoning: Paragraph describes the company's general approach to security controls and risk-based prioritization - internal processes for managing cyber risk. No specific frameworks, roles, dates, tools, or firm-specific details are mentioned - purely generic boilerplate language about limitations of security controls that could appear in any company's filing.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes - threat assessment, protection, detection, response, recovery, vulnerability assessments, and the overall risk management framework. While third-party vendor risk is mentioned, it's presented as a component of the internal processes rather than the central topic.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and mitigation processes, including comparing to CIS standards and tools like monitoring and penetration testing. It is Sector-Adapted because it names specific recognized standards (CIS, FERPA) but contains no firm-specific details like named roles, specific dates, dollar amounts, or unique company facts.


reasoning: The paragraph identifies specific management roles (SVP/IT Manager and ISO) and describes their qualifications and experience, making Management Role the appropriate category. It contains multiple firm-specific facts including cybersecurity-specific titles and specific years of experience.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes and objectives, which is the core of Risk Management Process. While it mentions the CTO and Technology Leadership Centre, these are mentioned in the context of who oversees the processes rather than as the main topic. The mention of 'Technology Leadership Centre' is a specific internal entity, making this Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph describes internal incident response and vulnerability management processes, including escalation procedures and reporting lines. It contains no specific facts - CEO and CFO are generic C-suite roles, VP of Operational Engineering is not a recognized cybersecurity-specific title, and the audit committee is a standard board committee. No dates, dollar amounts, named frameworks, or other identifiable details are present.


reasoning: The paragraph describes the company's internal cybersecurity practices: penetration testing, framework measurement, incident response engagements, and threat intelligence sharing. These are internal risk management processes, not vendor oversight (which would require the topic to be about managing third-party risk as the central focus).


reasoning: Paragraph describes generic technical safeguards (firewalls, anti-malware, monitoring software) without naming any specific products, frameworks, roles, or company-specific details. These are standard protective measures that could appear in any company's disclosure.


reasoning: The paragraph describes internal risk management processes including vulnerability testing, vendor control reviews, and weakness evaluation. It contains no specific dates, named entities, frameworks, or firm-specific details - all language is generic and could appear in any company's disclosure.


reasoning: The paragraph's grammatical subject is the Audit Committee, and the primary focus is on its oversight responsibilities for cybersecurity risks, including what it reviews and receives. The brief mention of the CISO is subordinate to the board oversight topic. Contains two firm-specific facts: a named cybersecurity role (CISO) and a named internal program (Cybersecurity Incident Response Plan), but lacks hard verifiable external facts to reach Quantified-Verifiable.


reasoning: The paragraph describes Western Digital's internal enterprise risk management (ERM) process for identifying, assessing, and managing cybersecurity risks. The grammatical subjects are 'management team' and 'ERM process' rather than the Board or specific management roles, making Risk Management Process the appropriate category. The content contains only generic references to 'Board of Directors,' 'its committees,' and 'cybersecurity incidents' with no specific dates, named entities, frameworks, roles, or other identifiable details—making this entirely generic boilerplate applicable to any company.


reasoning: The paragraph focuses on management-level bodies (Cybersecurity Executive Council and Cybersecurity Compliance Committee) - their composition, responsibilities, and functions. The Board is mentioned only as a recipient of discussions, not as the subject performing oversight. Contains firm-specific details including named committees with 'Executive Council' and 'Compliance' designations, and the CISO role - a cybersecurity-specific title that goes beyond generic C-suite positions.


reasoning: The paragraph focuses on management roles (CCO and CISO), their qualifications, experience, and reporting relationships. The board is not mentioned. This is about who is responsible for cybersecurity risk management at the management level, not board oversight.


reasoning: The paragraph describes the company's internal cybersecurity processes including identification of critical systems, network segmentation, access controls, continuous monitoring, and patch management. This is clearly about the company's own risk management approach. It contains no specific facts - no named frameworks (NIST, ISO, etc.), no specific dates, no dollar amounts, no named products/tools, no cybersecurity-specific roles, and no named third-party firms. All security practices mentioned (defense-in-depth, firewalls, vulnerability scanning, least-privilege) are generic industry practices that could appear in any company's disclosure.


reasoning: This paragraph is a boilerplate disclaimer stating the company is not aware of material cyber incidents and cannot guarantee no undetected incidents. It contains no substantive cybersecurity disclosure—only forward-looking acknowledgment of inherent security risks and a reference to the Risk Factors section.


reasoning: The paragraph describes the company's general cybersecurity risk management approach with generic practices like policies, monitoring, training, and third-party assessments that could apply to any company without specific details.


reasoning: The paragraph describes the company's internal cybersecurity program, policies, controls, and framework adoption (risk assessment, framework adoption, compliance assessments) - clearly falling under Risk Management Process. It is Firm-Specific because it claims an active HITRUST certification and SOC 2 Type II compliance, which are specific verifiable facts about the company's security posture that go beyond merely naming frameworks.


reasoning: The paragraph describes board/committee oversight structure - specifically who receives cybersecurity briefings (CEO, CFO, Audit Committee) and the cadence (not less than once per year). The grammatical focus is on the Audit Committee as recipient of cybersecurity information, making Board Governance the primary category.


reasoning: The paragraph explicitly describes a 'third-party security program' to identify, prioritize, assess, mitigate and remediate third-party risks, making third-party vendor oversight the central topic rather than a component of internal processes. It contains no specific dates, dollar amounts, named frameworks, named vendors, or any other verifiable facts — only generic descriptions of risk management mechanisms.


reasoning: The paragraph describes the company's internal cybersecurity risk management program including risk assessments, framework adoption (NIST), technical controls, third-party risk management, data loss prevention, security training, and regular assessments. This is clearly about the company's own internal processes for managing cyber risk, not board governance, management roles, or incident disclosure.


reasoning: The paragraph primarily describes the CISO's role, qualifications, reporting structure, and management responsibilities — the grammatical subject is the CISO throughout most of the paragraph. The brief mention of the COO serving on the Risk Committee is incidental and secondary to the main focus on management roles.


reasoning: The paragraph focuses on the VP of IT and Facilities, a specific management role, and describes their responsibilities related to cybersecurity budget, processes, and oversight — making Management Role the primary category.


reasoning: The entire paragraph focuses on third-party service provider risks and monitoring - this is the central topic, not a component of internal processes. However, it contains no specific facts: no named vendors, specific dates, dollar amounts, frameworks, or firm-specific details - it's generic boilerplate about third-party risk that could appear in any company's filing.


reasoning: This paragraph describes the company's internal cyber incident response plan, including roles, responsibilities, and reporting protocols. This is a description of the company's own internal risk management processes, not board governance, not management role identification, and not an actual incident disclosure. The presence of the specific title 'VP Security' and named team 'Global Information Security Team' makes this firm-specific rather than generic boilerplate.


reasoning: The paragraph focuses on third-party procurement and contracting due diligence as the central topic, which aligns with Third-Party Risk oversight. However, it contains no specific details—no named vendors, specific procedures, dates, or unique practices—only generic references to 'applicable regulations and industry benchmarks' that could appear in any company's disclosure.


reasoning: The paragraph describes internal security processes: a planned awareness program, training for employees, policy review/updates, threat landscape evaluation, and control testing. These are all internal risk management activities, not board governance, management roles, third-party risk, or incident disclosure.


reasoning: The paragraph identifies the CIO role, their reporting line to the President/CEO, and their responsibilities. While it mentions a cybersecurity focus, the CIO is a generic C-suite role that exists at every company, and there are no specific dates, dollar amounts, headcounts, named third-party firms, or named products/tools to make it firm-specific.


reasoning: This paragraph is generic risk factor language stating they have not experienced attacks but any attack could adversely affect business. It contains no substantive disclosure about governance, management roles, processes, or incidents - only forward-looking risk disclaimers typical of boilerplate filings.


reasoning: The paragraph discusses executive management's responsibility for cybersecurity strategy and risk oversight, making Management Role the appropriate category. It contains no specific facts—no named roles (CISO/CTO/CIO), no dates, no frameworks, no firm-specific details—and reads as generic boilerplate about management's oversight duties.


reasoning: The paragraph's grammatical subject is the Board of Directors, and the content focuses on board oversight duties (reviewing cybersecurity programs, evaluating controls, assessing response plans, receiving annual updates). This is classic board governance content. For specificity, there are no named entities, frameworks, dates, roles, numbers, or any other specific facts - only generic references to 'the Board', 'management', 'information technology systems', and 'security breach' that could appear in any company's filing.


reasoning: Paragraph describes internal security team activities (monitoring threats, vulnerability awareness, risk mitigation) which falls under the company's own risk management processes. It contains no specific facts - no named roles, frameworks, products, dates, dollar amounts, or any details unique to Bunge; all language is generic and could apply to any company's filing.


reasoning: The paragraph focuses on the Cybersecurity Council's composition and function, with the CISO as the grammatical subject and chair. The Board is mentioned only once as the ultimate recipient of information, making this primarily about management-level governance rather than board oversight. The paragraph contains multiple firm-specific facts including named cybersecurity-specific roles (CISO, CIDO), named internal programs, and specific meeting frequency.


reasoning: The paragraph describes the company's internal process for initial assessment and escalation of potential cybersecurity incidents - this is the company's own internal risk management/incident response process, not board governance or management role descriptions.


reasoning: The paragraph describes the company's internal incident response process and cross-functional team involvement, which falls under risk management. However, it contains no firm-specific details - the policy name is generic, the C-suite roles are standard corporate positions, and third-party advisors are unnamed.


reasoning: The Technology Committee is the grammatical subject, and the paragraph describes its oversight responsibilities for cybersecurity risks, fitting the Board Governance category. The Technology Committee is a specific committee name (not a standard committee like Audit Committee), making this Firm-Specific.


reasoning: The paragraph describes internal security processes (vulnerability management, monitoring, backup/recovery, physical security, third-party evaluation) that are universal to any company. The mention of third-party services is about internal evaluation before authorization, not vendor oversight as a central topic. No specific facts, frameworks, or firm-specific details are present.


reasoning: The paragraph's grammatical subject is the Audit Committee, a board committee, and the content describes their oversight role and reporting structure to the Board of Directors. This is a standard governance disclosure with no specific facts—'Audit Committee' and 'Board of Directors' are generic governance terms, 'periodic updates' is a vague cadence, and there are no named roles, dates, frameworks, or firm-specific details.


reasoning: Paragraph describes what a risk assessment process would include if implemented, which is an internal risk management topic. It contains no specific facts, dates, named entities, frameworks, or firm-specific details - only generic language about risk identification and safeguards.


reasoning: The paragraph describes the company's internal cybersecurity processes including monitoring, detection, and response capabilities, as well as use of third-party consultants and participation in grid exercises. However, it contains no firm-specific details—no named roles, frameworks, dates, tools, or other unique identifiers—and could apply to many companies. The mention of third-party consultants is about resources the company uses, not vendor oversight, so Third-Party Risk is not appropriate.


reasoning: The paragraph's grammatical subject is the CISO, discussing their reporting structure, meeting cadence with the IOC, and how they stay informed about cybersecurity operations through their team. This focuses on a management role's responsibilities and information flow, not board oversight.