reasoning: The paragraph primarily states management’s materiality assessment that cybersecurity risks have not materially affected the company to date but could reasonably likely materially affect operations, strategy, results, or financial condition in the future. The rest is a cross-reference to risk factors, so the central question answered is how cybersecurity affects the business and finances.


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is a cross-reference to Item 1A risk factors and contains hypothetical adverse-effect language rather than a substantive description of governance, management, process, third-party risk, strategy assessment, or an actual incident. Under the rules, cross-references and pure speculative risk language fall into None/Other.

provider: openai

stage: benchmark


content_category: Risk Management Process

category_confidence: medium

reasoning: The paragraph primarily describes cybersecurity integration and review activities undertaken after the merger, which is chiefly about how the company’s cybersecurity program is being assessed and managed. Although it references a merger and comparative security posture, the main focus is the review and deployment of cybersecurity policies, procedures, and tools.


content_category: Board Governance

reasoning: The paragraph primarily describes how the board oversees cybersecurity by delegating oversight to a board committee and positioning that committee above management's program implementation. It does not provide qualifying firm-specific or verifiable details beyond generic board and audit committee oversight language.


content_category: Strategy Integration

specificity_confidence: medium

reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity risks and past threats have not materially affected the company's business strategy, results of operations, or financial condition to date. Although it mentions malware and computer virus attacks, the disclosure remains a high-level, generic statement rather than a detailed cybersecurity program or incident description.


content_category: Management Role

reasoning: The paragraph primarily describes which management roles are responsible for cybersecurity and briefly notes management expertise, which fits management organization rather than program activities. It does not meaningfully describe the cybersecurity process itself beyond assigning responsibility.


reasoning: This paragraph is a cross-reference to Risk Factors and contains speculative language about threats that may materially affect the company, rather than describing cybersecurity governance, management, processes, third-party risk, an actual incident, or a materiality assessment conclusion.


reasoning: The paragraph primarily provides a cybersecurity materiality assessment—stating that known cybersecurity threats and prior incidents have not materially affected, and are not reasonably likely to materially affect, the company—which falls under Strategy Integration. The mention of cyber insurance supports the business/financial impact framing rather than describing governance, management, or operational security processes.


reasoning: The paragraph primarily describes how the board, through the Audit Committee, oversees cybersecurity risk and receives information from management. Although management roles are mentioned, they are included mainly to explain the reporting flow to the board.


reasoning: The paragraph primarily explains how management is organized to oversee cybersecurity, emphasizing named leadership roles, their qualifications, and responsibility for incident reporting and management. Although it mentions incident response activities, the dominant focus is on who leads the function and what credentials they have.


content_category: Incident Disclosure

reasoning: The paragraph primarily describes a real cybersecurity incident—its nature (ransomware), affected systems, response, recovery, and investigative findings—so it is best categorized as Incident Disclosure. Although it includes a statement about financial impact, that is secondary to the incident narrative.


reasoning: The paragraph primarily describes how the board oversees cybersecurity by delegating oversight responsibility to a board committee and receiving management input. Although it mentions management responsibility, the main focus is the board-level oversight structure.


reasoning: The paragraph primarily describes how cybersecurity information flows to and is overseen by the Board through the Audit Committee, including management reporting and committee review responsibilities. Although it mentions the CFO's role, the main focus is the board-level oversight structure rather than management organization or the underlying cybersecurity program.


content_category: Third-Party Risk

reasoning: The paragraph primarily addresses cybersecurity risk arising from third parties—the hotel manager and franchisors—and the company’s reliance on those parties to manage their own systems. Although it also mentions insurance, the main question answered is how third-party cyber risk is handled.


reasoning: The paragraph primarily describes a cybersecurity activity—using tabletop exercises to simulate incident response and develop detection, mitigation, and remediation strategies—so it is about the risk management process. Although it mentions a specific internal team, the focus is on what the cybersecurity program does rather than management structure.


reasoning: The paragraph primarily describes management's cybersecurity organization: the VP of IT's responsibilities, experience, and reporting lines. Although it mentions updates to the board and audit committee, those references are secondary to explaining management's role.


reasoning: The paragraph is primarily about how the company addresses cybersecurity risks arising from third-party vendors, making third-party risk the central topic. It does not provide concrete cybersecurity methods, named vendors, frameworks, or other specific facts beyond generic vendor oversight language.


reasoning: The paragraph primarily describes what the cybersecurity program does: policy and procedure preparation, incident response plan testing, penetration testing, and incident response activities. Although management is the actor, the substance is about cybersecurity operational processes rather than management qualifications or organizational structure.


reasoning: The paragraph primarily states management's conclusion that known cybersecurity threats and prior incidents have not materially affected and are not reasonably likely to materially affect the company, which is a materiality/business-impact assessment. The rest of the paragraph is only a cross-reference to risk factors.


reasoning: The paragraph primarily describes which members of management are responsible for cybersecurity processes and highlights their relevant experience. Although it mentions risk assessment and management processes, the focus is on management responsibility and qualifications rather than the substance of the cybersecurity program.


reasoning: The paragraph primarily describes how the Board, through the Audit Committee, oversees cybersecurity and data privacy risk reporting and review. It focuses on board-level oversight and information flow from management rather than management organization or specific cybersecurity processes.


reasoning: The paragraph primarily states management's conclusion that cybersecurity threats and prior incidents have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which is a Strategy Integration materiality assessment. The remaining language is a generic reference to possible incidents and a cross-reference to risk factors.


reasoning: The paragraph primarily states a conclusion about whether cybersecurity incidents or threats have materially affected, or are reasonably likely to materially affect, the company, which is a materiality assessment. The references to occasional threats/incidents and the Risk Factors section are secondary and generic.


reasoning: The paragraph primarily describes management’s responsibility and qualifications for handling cybersecurity, focusing on who is responsible rather than detailing the underlying cybersecurity program. It does not include firm-specific roles, committees, named frameworks, or verifiable facts.


reasoning: The paragraph primarily describes what the company’s cybersecurity program does: assessing cyber risk, maintaining policies and practices, using frameworks, and obtaining penetration testing and independent audits. Although third parties are mentioned, they are described as one component of the broader cybersecurity risk management program rather than the central topic.


reasoning: The paragraph is primarily about how cybersecurity risks from vendors and service providers are overseen, making third-party risk the central topic. Although it includes some cyber-risk process language, the focus is specifically on vendor oversight rather than the broader cybersecurity program.


reasoning: This paragraph primarily explains how the board oversees cybersecurity, including delegation of oversight and reporting flows from management to the board and its committee. Although management officers are mentioned, their role is mainly to inform the board, so the paragraph is chiefly about board-level governance.


reasoning: The paragraph primarily describes how cybersecurity risk assessment and mitigation are integrated into the company's broader risk management processes, which fits Risk Management Process. Although it mentions reporting to the board's Audit Committee, the main focus is on the company's internal process for identifying and managing material cyber risk.


reasoning: The paragraph is primarily a high-level statement about the importance of cybersecurity and potential cyber threats, without describing a concrete governance structure, management role, risk management activity, vendor oversight process, or actual incident. Its material-adverse-effect language is speculative rather than an Item 106 materiality assessment, so it fits best as non-substantive boilerplate.


reasoning: The paragraph primarily describes how the Committee and full Board oversee cybersecurity through reports, briefings, escalation updates, and education. Although it mentions a management role, the main purpose is the board oversight structure and information flow.


reasoning: This paragraph only provides definitional language by referencing Regulation S-K Item 106 and does not describe governance, management, processes, third-party risk, incidents, or business impact. It is therefore non-substantive disclosure support text rather than a cybersecurity program disclosure.


reasoning: The paragraph primarily describes that the cybersecurity program is supported by the Board of Directors and the Audit Committee, which most directly addresses governance oversight rather than operational details. However, it is stated at a very high level without describing actual oversight mechanisms or management structure.


reasoning: The paragraph primarily describes management responsibility and qualifications by focusing on the Head of IT’s leadership role and experience. Although it mentions reviewing threat intelligence, that activity is secondary to explaining who in management is responsible and what qualifies them.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company has not identified cybersecurity threats reasonably anticipated to materially affect its business, results, or financial condition. The remaining language about maintaining security and evaluating risks is general and does not shift the main focus away from business-impact assessment.


reasoning: The paragraph primarily describes the company's cybersecurity program activities and controls, including assessments, technical safeguards, training, phishing simulations, incident response, and monitoring. Although it mentions third-party reviews and insurance, those are subordinate elements within a broader description of the risk management process.


reasoning: This paragraph is only a cross-reference directing readers to risk factors elsewhere in the filing and does not itself describe cybersecurity governance, management, processes, third-party risk, incidents, or strategy impact. Under the cross-reference rule, this is None/Other.


reasoning: The paragraph primarily explains how management is organized to oversee cybersecurity, focusing on the SGC’s leadership, composition, reporting line, and responsibilities. Although it mentions reporting to the Audit Committee, the main emphasis is the management-level governance structure rather than board oversight.


reasoning: The paragraph primarily states management's conclusion that known cybersecurity threats are not reasonably likely to materially affect the company, which is a business/materiality assessment. The rest of the paragraph is a cross-reference to risk factors rather than describing governance, management roles, or cybersecurity processes.


reasoning: The paragraph primarily describes how the Board oversees cybersecurity risk, including updates, incident escalation, and presentations to directors, which makes it a board oversight disclosure. It does not include qualifying firm-specific or externally verifiable facts, and the language remains largely generic governance boilerplate.


reasoning: The paragraph primarily describes how the Board and a board committee oversee cybersecurity, including responsibility for the cyber risk management program and review of cybersecurity-related reporting. It does not provide meaningful detail about management structure or the underlying cybersecurity processes themselves.


reasoning: This paragraph is primarily a hypothetical risk/disclaimer discussion about possible IT disruptions and cyber-attacks, with a cross-reference to Risk Factors, rather than describing governance, management roles, a cybersecurity program, third-party risk, an actual incident, or a materiality assessment conclusion. It contains no substantive cyber-specific measures or firm-specific details.


reasoning: The paragraph primarily provides a materiality assessment, stating that no cybersecurity threat or incident has materially affected the company while warning that future threats could do so, which fits Strategy Integration under the materiality rule. The remaining language about continued investment and a risk-factor cross-reference is generic and does not change the paragraph’s main focus.


reasoning: The paragraph primarily describes which management officials are responsible for cybersecurity processes and why they are qualified, focusing on titles, reporting responsibility, and credentials rather than the underlying cybersecurity program activities. It contains multiple externally verifiable facts, including named individuals, prior positions, educational background, and a named certification.


reasoning: The paragraph primarily describes the Board’s oversight of the company’s cybersecurity program, including alignment with strategy, risk appetite, and resource allocation, which is board-level governance. It does not include qualifying firm-specific or externally verifiable cybersecurity facts beyond generic board oversight language.


reasoning: This paragraph primarily describes how the board and its committee oversee cybersecurity risk and how updates flow from management to the board, which is board-level governance. It does not provide qualifying firm-specific or verifiable cybersecurity facts beyond generic oversight structure.


reasoning: The paragraph primarily describes management's cybersecurity organization: the CIO leads the program, the team's experience, and management reporting responsibilities. Although it mentions reporting to the Board, the main focus is on who in management runs cybersecurity and their qualifications.


reasoning: The paragraph primarily describes who within management is responsible for cybersecurity and the general qualifications and training of those personnel, which fits Management Role. It does not provide substantive detail about cybersecurity activities or tools, nor does it include qualifying firm-specific or verifiable facts.


reasoning: The paragraph primarily explains how the board, through the Audit Committee, is informed about and oversees cybersecurity risks and incidents. Although it mentions management reporting, the main focus is the board oversight structure and information flow to the committee.


reasoning: The paragraph primarily provides a materiality assessment: it states that no cybersecurity threats or incidents are reasonably likely to materially affect results of operations or financial condition, which fits Strategy Integration. Although it mentions no breaches during the year, the main purpose is the business-impact conclusion rather than describing an actual incident or cybersecurity process.


reasoning: The paragraph primarily describes what the cybersecurity program does: use of external support, penetration testing, incident response planning, simulated testing, and risk mitigation activities. Although it includes third-party oversight and a materiality conclusion, the dominant focus is the company’s overall cybersecurity risk management process.


reasoning: The paragraph primarily provides a materiality-oriented assessment that past cyber attempts were not believed likely to have caused a material adverse effect on the business, financial condition, or results of operations. Although it mentions attempted phishing, malware, and unauthorized access, the main question answered is business impact rather than incident details or program operations.


reasoning: The paragraph primarily provides management’s assessment of whether cybersecurity incidents and threats have materially affected, or are reasonably likely to affect, the company’s business strategy, results of operations, financial condition, and costs. Although it mentions protective measures in passing, the dominant focus is business/materiality impact rather than the cybersecurity program itself.


reasoning: The paragraph primarily explains how the Audit Committee oversees cybersecurity risk through the enterprise risk management structure and receives management reporting, which is board-level oversight. It does not provide substantive detail about the cybersecurity program itself beyond generic governance and ERM review language.


reasoning: The paragraph primarily explains which members of management are responsible for cybersecurity and how that responsibility is organized, which fits Management Role. It mentions oversight of the cybersecurity program, but the focus is on management responsibility and supervision rather than specific program activities.


reasoning: The paragraph primarily describes an operational cybersecurity risk process—continuous monitoring, incident tracking, and remediation tracking—rather than governance or management roles. Its specificity is elevated by the named software solution, Ontrack, which is a concrete system used in the company's cybersecurity risk management process.


reasoning: This paragraph is primarily a cross-reference to risk factors and contains speculative risk language about possible cybersecurity consequences rather than describing governance, management, processes, third-party risk oversight, strategy assessment, or an actual incident. Under the rules, cross-references and hypothetical material-effect language are classified as None/Other.


reasoning: The paragraph primarily describes what the company's cybersecurity program does—using referenced frameworks and guidance to assess, identify, and manage cybersecurity risks—so it is about the risk management process. Although it cites named frameworks, it does not provide firm-unique organizational details or externally verifiable quantified claims.


reasoning: The paragraph primarily describes how cybersecurity information flows to the Board and Audit Committee and how the Board is briefed and educated on cybersecurity matters, which is board oversight. It includes a firm-specific organizational detail by identifying the Chief Technology Officer as part of that reporting and education structure.


reasoning: The paragraph primarily describes actual cybersecurity incidents, including when they occurred, what happened operationally, and how the company responded and recovered. Although it briefly mentions post-incident security enhancements and expected business impact, the dominant focus is the disclosure of real events.


reasoning: The paragraph primarily describes which management personnel are responsible for cybersecurity-related duties, budgets, incident preparation, and review activities, so it is about management organization and responsibilities rather than board oversight or program operations. It does not include qualifying firm-specific or externally verifiable facts under the stated rules.


reasoning: The paragraph primarily provides a materiality assessment, stating that prior cybersecurity incidents have not had a material impact and are not reasonably likely to materially affect operations, which fits Strategy Integration. Although it references prior attacks, the focus is not on describing a specific incident but on concluding the business impact is not material.


reasoning: The paragraph primarily explains how management is structured to lead cybersecurity, including reporting lines, management committees, and the qualifications of specific officers. Although it mentions reporting up to the Audit Committee, the dominant focus is management organization rather than board oversight.


reasoning: The paragraph primarily states management's conclusion about whether cybersecurity threats have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which is a Strategy Integration assessment. The remaining language is generic cautionary and cross-reference language rather than process, governance, or incident detail.


reasoning: The paragraph primarily explains how the company evaluates and manages cybersecurity risks posed by vendors and other external providers, making third-party risk the central topic. It describes vendor assessment measures such as security questionnaires and cybersecurity-related contractual requirements, which reflect cybersecurity-specific practices but provide no firm-unique or externally verifiable facts.


reasoning: This paragraph is a cross-reference to the risk factors section and contains hypothetical adverse-effect language rather than describing cybersecurity governance, management, processes, third-party oversight, a real incident, or a materiality assessment. Under the cross-reference and speculation rules, it is best classified as None/Other.


reasoning: The paragraph most directly describes the purpose of the company’s cybersecurity risk management efforts—minimizing the likelihood and impact of breaches. However, it provides no concrete details about processes, tools, roles, or incidents, making it highly generic.


reasoning: The paragraph primarily describes how the Board, through its Audit Committee, oversees cybersecurity and receives reporting from management, making board oversight the central question answered. Although management roles are mentioned, they are included mainly as part of the oversight and reporting structure.


reasoning: The paragraph primarily describes how the board, through the Audit Committee, oversees cybersecurity and technology-related risk management. It does not provide cybersecurity-specific operational detail or qualifying firm-specific/verifiable facts beyond generic governance structure.


reasoning: The paragraph primarily explains how management is organized to handle cybersecurity, including management reporting and the structure of a management-level information security risk committee chaired by the CISO. Although it references the cybersecurity program, the main focus is on roles, reporting, and committee structure rather than specific security activities.


reasoning: The paragraph primarily describes what the cybersecurity program does: control reviews, external testing, employee training, training effectiveness testing, and use of service providers to assess and mitigate cyber risk. Third parties are mentioned only as part of the broader security program, so the central topic is risk management process rather than third-party risk.


reasoning: The paragraph primarily describes what the cybersecurity program does and how it operates, including use of a cybersecurity framework and security tools to identify, manage, and respond to threats. Although it mentions governance structure, the main focus is the program’s risk management activities rather than board or management roles.


reasoning: The paragraph primarily provides a materiality assessment, stating whether cybersecurity threats or incidents have materially affected or are reasonably likely to materially affect the company's business, results, or financial condition. That is the core Strategy Integration question, not a description of governance, management, or security processes.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party service providers, making Third-Party Risk the best fit. It describes generic vendor due diligence and oversight practices without naming any specific vendors, programs, frameworks, systems, roles, or verifiable details.


reasoning: The paragraph primarily describes how the Board is informed about cybersecurity matters through management reporting and incident updates, which is board oversight. It contains no qualifying firm-specific or verifiable facts, only generic reporting language.


reasoning: The paragraph primarily describes how the board oversees cybersecurity by delegating oversight responsibility to a board committee and framing cybersecurity within the board's risk oversight function. It does not provide qualifying firm-specific or verifiable details beyond generic governance structure.


reasoning: The paragraph primarily describes how cybersecurity oversight flows through the governance structure: the audit committee oversees cybersecurity risk and management reports upward on the program and mitigation efforts. Although it includes management-role details about the Senior Vice President – Technology Solutions, those details are subordinate to the board/committee oversight description.


reasoning: The paragraph primarily describes how the company's cybersecurity program is structured and guided, specifically its risk management approach and incident response planning. Its main purpose is to explain the process/framework used to identify, assess, and manage cybersecurity risks, rather than governance or management roles.


reasoning: The paragraph primarily describes how cybersecurity information flows to the Board through the audit committee, which is a board oversight structure question. The references to the executive team are subordinate to explaining Board-level oversight rather than detailing management organization or program activities.


reasoning: The paragraph primarily describes how the company manages cybersecurity risk arising from vendors, including due diligence, periodic reviews, and contractual requirements imposed on third parties. While it does not include firm-unique or verifiable details, it uses cybersecurity-specific third-party risk management concepts beyond generic boilerplate.


reasoning: This paragraph is a cross-reference to risk factors and contains only hypothetical adverse-effect language rather than substantive disclosure about governance, management, process, third-party risk management, strategy assessment, or an actual incident. Under the rules, cross-references and pure speculation without cybersecurity measures are classified as None/Other.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity incidents or threats have not materially affected and are not reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition. The remainder is generic cautionary language and a cross-reference to risk factors.


reasoning: The paragraph primarily describes the board’s oversight role and how management reports material risks, including cybersecurity, to the board. It does not provide meaningful detail about management structure or cybersecurity processes beyond a generic governance statement.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company is not aware of cybersecurity threats that have materially affected or are likely to affect its business strategy, results of operations, or financial condition. The rest is generic forward-looking caveat and a cross-reference to risk factors, not process or governance detail.


reasoning: The paragraph primarily explains which members of management are responsible for handling cybersecurity risk and incidents, and it describes their experience and responsibilities rather than the board’s oversight or the company’s cybersecurity processes. Although it includes years-of-experience statements, those are hedged ('over 30 years,' 'over 20 years,' 'over 10 years') and the roles mentioned do not qualify as firm-specific cybersecurity facts under the rules.


reasoning: The paragraph primarily describes how the board oversees cybersecurity, including delegation of oversight responsibility to a board committee and supervision of management’s strategy implementation. It does not include qualifying firm-specific or externally verifiable cybersecurity facts.


reasoning: The paragraph primarily explains which members of management are responsible for assessing and managing cybersecurity risks and highlights the experience of the senior IT leader, so it is about management organization and qualifications rather than the cybersecurity program itself. Although it includes cybersecurity-specific responsibilities and terminology, it does not provide a qualifying firm-specific or clearly verifiable fact under the stated rules.


reasoning: The paragraph primarily describes how cybersecurity information flows to the board, which is a board oversight question. Its only qualifying specific detail is the named individual, Mr. Lee, who reports cyber incidents and threats upward.


reasoning: Although the paragraph opens with board oversight, most of the text describes the company's cybersecurity program itself—its integration into ERM, use of recognized frameworks, and its approach to identifying, preventing, mitigating, and responding to cyber threats. That makes the primary question answered what the cybersecurity risk management program does, rather than how the board is structured to oversee it.


reasoning: This is a high-level statement of commitment and importance, but it does not describe board oversight, management roles, cybersecurity processes, third-party risk, an incident, or a materiality/business-impact assessment. It is therefore non-substantive boilerplate rather than a substantive Item 1C disclosure category.


reasoning: The paragraph primarily explains management's role in handling cybersecurity by describing how incidents are escalated to management and the responsibilities of the Principal Accounting Officer in receiving reports, coordinating with the incident response team, and assessing materiality. Although it references incident response and vulnerability management processes, the focus is on management involvement rather than the broader cybersecurity program itself.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from third-party service providers, especially through required certifications, security obligations, and breach reporting. Although it mentions third parties assisting with internal risk processes, the central focus is vendor-related cybersecurity oversight rather than the company’s broader program.


reasoning: The paragraph primarily describes cybersecurity in terms of protecting information and systems from cyber threats, which most closely fits the company’s cybersecurity risk management process. However, it does so at a highly general level without describing concrete practices, tools, frameworks, roles, or oversight structures.


reasoning: This paragraph is only a cross-reference to another risk factor section for additional information and does not itself describe cybersecurity governance, management, processes, third-party risk, an incident, or strategy impact. Under the rules, cross-references without substantive disclosure are classified as None/Other.


reasoning: The paragraph primarily describes the purpose of the company's cybersecurity measures—protecting systems, networks, data, and information from unauthorized access, disruption, or misuse—which fits risk management process. It does not discuss board oversight, management structure, third-party risk, or any actual incident.


reasoning: The paragraph primarily explains how the company evaluates cybersecurity-related risks posed by suppliers that handle or access its data, making third-party risk the central topic. However, it does so in generic terms without naming specific frameworks, roles, committees, vendors, systems, dates, or other distinguishing facts.


reasoning: The paragraph primarily describes what the company's cybersecurity program does: its framework basis, threat identification and monitoring, mitigation steps, and reporting of significant threats. References to third-party vendors are only one component of the broader process, so the central topic is risk management rather than third-party risk.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company is not aware of cybersecurity threats that have materially affected or are reasonably likely to materially affect its business strategy, results of operations, or financial condition. The remaining discussion of possible control limitations and generic insurance coverage supports that business-impact framing rather than describing governance, management, or specific risk processes.


reasoning: This paragraph primarily describes the qualifications, experience, and training of a specific cybersecurity leader, which makes it about management organization and capability rather than the cybersecurity program itself. The named role, quantified experience, education, and certification make the disclosure highly specific and externally verifiable.


reasoning: The paragraph primarily describes the board’s oversight of cybersecurity and the governance chain from the board to management, which makes Board Governance the best fit. Although it mentions management responsibility, the main question answered is how the board oversees the cybersecurity program.


reasoning: This paragraph describes a person's general business background in marketing and management and does not provide substantive cybersecurity disclosure. It therefore does not answer any of the defined cybersecurity category questions.


reasoning: The paragraph primarily describes board-level oversight of cybersecurity risk by stating that the Board, together with the Audit Committee, oversees and reviews the company's risk assessment and mitigation measures. It does not meaningfully describe management organization or the underlying cybersecurity program itself.


reasoning: This paragraph is a general statement of concern about protecting information and shareholder value from cyber threats, but it does not describe any actual governance structure, management role, risk process, third-party oversight, incident, or business impact assessment. It is therefore non-substantive boilerplate rather than a substantive cybersecurity disclosure category.


reasoning: The paragraph does not describe any substantive cybersecurity governance, management, process, or incident; it mainly states that the SPAC has no operations and no internal cybersecurity personnel or processes. This fits the no-operations/blank-check company exception and is therefore None/Other.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition. The rest is a cross-reference to risk factors, which does not change the paragraph’s main function.


reasoning: The paragraph primarily states the company's conclusion about whether cybersecurity threats or prior incidents have materially affected, or are reasonably likely to materially affect, its business strategy, results, or financial condition. That is a materiality/business-impact assessment, which fits Strategy Integration.


reasoning: The paragraph primarily provides the company's materiality assessment that cybersecurity threats and prior incidents have not materially affected, and are not reasonably likely to materially affect, its business strategy, results of operations, or financial condition. That is a Strategy Integration disclosure rather than a description of governance, management, or risk processes.


reasoning: The paragraph primarily explains how management is organized to oversee and administer cybersecurity, focusing on the IT Security Steering Committee, IT Security Team, their membership, leadership, and responsibilities. Although it also mentions program activities like vulnerability testing and employee training, the dominant emphasis is on management structure and roles.


reasoning: The paragraph primarily gives a materiality assessment, stating that the company knows of no cybersecurity incident that has materially affected or is likely to materially affect its business strategy, results of operations, or financial condition. That makes it a Strategy Integration disclosure rather than an incident description or process discussion.


reasoning: The paragraph is primarily about how the company addresses cybersecurity risks arising from suppliers, vendors, and service providers, making third-party risk the central topic. It includes a company-specific organizational detail about the Adviser’s cross-functional personnel involved in that oversight.


reasoning: The paragraph primarily describes what the cybersecurity program does after risk assessments: redesigning and maintaining safeguards, monitoring and testing them, and training employees. The reference to IT leadership reporting to the CEO is incidental and does not outweigh the paragraph’s focus on process activities.


reasoning: The paragraph primarily describes how the company manages cybersecurity risk by using a third party to assess its cybersecurity risk processes. Because the third party is unnamed and the description is generic without specific cybersecurity practices, tools, or frameworks, it is not third-party risk management and remains a high-level process statement.


reasoning: The paragraph primarily describes how cybersecurity information and incidents flow upward to the Board and its committee, which is a board oversight structure. Although management roles are mentioned, they are included mainly to explain escalation to board-level oversight.


reasoning: The paragraph primarily discusses the potential business and financial consequences of cybersecurity issues and states that the company has not encountered cybersecurity incidents since its Initial Public Offering, which is most aligned with cybersecurity’s impact on the business rather than governance or operational processes. It does not describe a real incident, management structure, or concrete cybersecurity program measures.


reasoning: The paragraph primarily describes the Board's oversight role over cybersecurity, including delegation to a board committee or board-appointed officer for review and approval of cybersecurity matters. It does not provide any named committees, roles, frameworks, or other qualifying specific details.


reasoning: The paragraph primarily describes the company’s incident response and escalation process—how cybersecurity incidents are escalated, handled, and reported—rather than focusing mainly on board oversight or management qualifications. Although it mentions management and the audit committee, those references are part of the response workflow.


reasoning: The paragraph primarily explains how the board oversees cybersecurity, including receiving management updates and executive-session briefings, which makes it a board governance disclosure. It includes a firm-specific management role—the CIO—as part of the oversight structure, but no externally verifiable quantified fact.


reasoning: Although the paragraph begins with incident response process language, its primary purpose is to describe an actual cybersecurity incident, its operational disruption, and the company’s assessment of the outcome. The real-event framing and June 2024 CDK incident make Incident Disclosure the best fit.


reasoning: The paragraph primarily states a materiality conclusion: the company has not experienced any material cybersecurity incidents and third-party incidents have not had a material impact. Under the materiality rule, this is Strategy Integration rather than incident disclosure or third-party risk management.


reasoning: The paragraph is primarily about how management is organized to handle cyber-related risk through the ERMC—its responsibilities, composition, leadership, and reporting line. Although it mentions reporting to a board committee, the main focus is the management-level committee structure rather than board oversight itself.


reasoning: Although the paragraph mentions a specific security leader and qualifications, most of the text describes what the cybersecurity program does, including testing, phishing simulations, vulnerability scanning, intrusion detection, and awareness activities. The primary question answered is how the company manages cybersecurity risk in practice.


reasoning: The paragraph primarily addresses how the company manages cybersecurity risks arising from third parties, making third-party risk the central topic. However, it provides only generic statements about consultants and processes without naming firms, roles, frameworks, or other qualifying specific facts.


reasoning: The paragraph primarily states management's conclusion about whether cybersecurity risks or past incidents have materially affected, or are reasonably likely to materially affect, the company's business strategy, results of operations, or financial condition. That is a materiality/business-impact assessment, which fits Strategy Integration.


reasoning: This fragment is a generic forward-looking risk statement about potential disruptions, costs, and reputational harm from cyber-related issues and regulation, not a substantive disclosure about governance, management, processes, third-party risk, incidents, or strategy assessment.


reasoning: The paragraph is primarily about how the company evaluates cybersecurity risks posed by vendors and business partners, making third-party risk the central topic. It does not include concrete cybersecurity methods, named frameworks, firms, roles, or other qualifying specific facts.


reasoning: The paragraph primarily describes a component of the company's cybersecurity risk management program—using outside consultants to assess risks, test controls, and support incident readiness. Although third parties are mentioned, they are serving JLL's internal program rather than describing oversight of vendor or supplier risk, so this is not Third-Party Risk.


reasoning: The paragraph primarily describes what the cybersecurity program does: use of a monitoring platform for real-time threat detection and mitigation, and processes for prevention, detection, mitigation, remediation, and incident notification. Although management and the CCO are mentioned, those references mainly frame oversight of the program rather than describe management organization in detail.


reasoning: This is a cross-reference directing readers to another section for cybersecurity risk information, rather than describing governance, management, processes, third-party risk, incidents, or strategy impact. As a non-substantive reference, it falls under None/Other.


reasoning: The paragraph is centrally about how the company manages cybersecurity risks arising from third-party service providers and business partners, including assessments, contractual requirements, and remediation or termination. It uses cybersecurity/vendor-risk terminology, but does not provide firm-unique or externally verifiable facts.


reasoning: The paragraph primarily describes management's organizational structure and reporting lines for cybersecurity-related responsibilities, especially the IT Risk and Compliance Team reporting to the VP Security. Although it mentions audits and control monitoring, the emphasis is more on who is responsible than on the details of the cybersecurity process itself.


reasoning: The paragraph primarily provides a materiality assessment that the company has not experienced a cybersecurity threat or incident with a material adverse impact on its business or operations, which fits Strategy Integration. The remaining language is forward-looking caution and a cross-reference, not a description of governance, management, or risk processes.


reasoning: The paragraph primarily describes how management is organized to handle cybersecurity, including the CIO-led IT team and the management-level cybersecurity governance committee’s composition and responsibilities. Although it mentions communication to the Audit Committee and Board, the focus is on management structure rather than board oversight.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including its nature, timing, and operational effects, so it is best classified as Incident Disclosure. It also includes a specific date and quantified impact details, making it Quantified-Verifiable.


reasoning: The paragraph primarily describes the board-level oversight structure for cybersecurity, including the Audit Committee's oversight role and how management reports cyber risks and incidents up to the Board. Although it mentions a management role, the main focus is the governance chain from management to the Board and Audit Committee.


reasoning: This paragraph is a forward-looking caution and cross-reference to Risk Factors rather than a substantive disclosure about governance, management, processes, third-party risk, incidents, or strategy. It does not describe any actual cybersecurity measure, structure, or assessment.


reasoning: The paragraph primarily explains how management is organized to handle cybersecurity risk, emphasizing management responsibility, expertise, and the internal reporting/communication structure. Although much of the language is general, the reference to reliance on specific functional personnel of the Adviser makes it company-specific.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it occurred, how it happened, and what was accessed, which makes Incident Disclosure the best fit. Although it also mentions materiality and potential future effects, those statements are secondary to the real-event narrative.


reasoning: The paragraph primarily gives the company's materiality assessment of cybersecurity threats and incidents—stating they have not materially affected the company to date but could reasonably likely do so in the future. The remaining content is largely cross-reference to risk factors rather than describing governance, management, or operational processes.


reasoning: The paragraph primarily describes what the cybersecurity program does—specifically asset identification, assessment, monitoring, and classification procedures used to evaluate and mitigate cyber risk. It does not focus on board oversight, management roles, or a specific incident.


reasoning: The paragraph primarily describes how cybersecurity-related information is escalated to a board-level committee, which is a board oversight mechanism. Its main purpose is to explain board governance rather than management operations or risk process details.


reasoning: The paragraph primarily describes management’s role in overseeing cybersecurity and emphasizes the management team’s qualifications and responsibilities. Its focus is on who within management is responsible and what credentials they have, rather than on board oversight or detailed security processes.


reasoning: This paragraph primarily describes an actual cybersecurity event, the company's response, operational disruption, and resulting effects, which makes it an incident disclosure. Although it includes company-specific facts about timing and impact, it does not provide hard quantified or clearly externally verifiable details such as exact dates, amounts, or named firms.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats and prior incidents have not materially affected and are not reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition. The remaining language is generic cautionary and cross-referential rather than describing governance, management, or specific cybersecurity processes.


reasoning: The paragraph primarily describes how the company identifies and evaluates cybersecurity risk through periodic assessments and review of existing safeguards, which is a risk management process. It does not include firm-specific roles, named frameworks, tools, committees, dates, or other qualifying specific facts.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company has not identified cybersecurity threats that have materially affected or are reasonably likely to materially affect its business strategy, results, or financial condition. The remaining language is cautionary and cross-referential, reinforcing the business-impact framing rather than describing governance, management, or operational processes.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from service providers, including vendor reviews, contractual requirements, assessments, inspections, and reassessments. It focuses on third-party oversight rather than the company's broader internal cybersecurity program.


reasoning: The paragraph primarily states management's conclusion that cybersecurity threats or incidents have not materially affected the company's strategy, results of operations, or financial condition, which is a business-impact/materiality assessment. It does not describe governance, management roles, or cybersecurity processes.


reasoning: The paragraph primarily describes the existence of the company's cybersecurity program and its general use of policies, controls, and assessments to manage cyber risk, which is a risk management process description. It does not provide specific cybersecurity practices, named frameworks, roles, committees, or verifiable facts.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company has not identified cybersecurity incidents that have materially affected or are reasonably likely to materially affect its business, results, or financial condition. The remaining statements about staying up to date and educating personnel are generic and secondary to that business-impact conclusion.


reasoning: The paragraph primarily describes the oversight and escalation structure for cybersecurity, including how information flows from management to senior committees and the board. Although it mentions management roles, its main purpose is to explain governance and board-level oversight.


reasoning: The paragraph primarily provides a materiality assessment by stating that the company has not experienced a cybersecurity threat that has materially affected it, which fits Strategy Integration under the negative-assertion rule. The cross-reference to risk factors is secondary and does not change the paragraph's main purpose.


reasoning: The paragraph primarily describes how the board oversees cybersecurity risk, including delegation of responsibility from the full Board to a specific board committee. The named Technology Committee makes this governance structure firm-specific.


reasoning: The paragraph primarily addresses cybersecurity risks arising from third-party service providers and states that the company monitors those risks, making third-party risk the central topic. It does not include qualifying firm-specific details, named vendors, standards, or verifiable facts.


reasoning: The paragraph primarily describes how the board oversees cybersecurity risk, including direct oversight by the full board and delegation through a board committee, which makes it a board-governance disclosure. It does not provide qualifying firm-specific or verifiable cybersecurity facts beyond generic governance language.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks posed by vendors, making third-party oversight the central topic. It describes cyber-specific vendor practices such as vendor risk assessments, required cybersecurity controls, and compliance monitoring, but includes no firm-unique or externally verifiable facts.


reasoning: The paragraph primarily describes what Cleco’s cybersecurity response program does—its incident response activities and escalation process—so it is best classified as Risk Management Process. The reference to Cleco’s CSIRPs is a company-specific named program, which makes the paragraph more specific than generic process boilerplate.


reasoning: The paragraph primarily explains how the company evaluates and manages cybersecurity risks posed by vendors and other external service providers, making third-party risk the central topic. It includes cybersecurity-specific vendor oversight concepts such as onboarding assessments, renewal reviews, and contractual security obligations, but no firm-unique or externally verifiable facts.


reasoning: The paragraph primarily describes what the company's cybersecurity program does to identify and evaluate cyber risk, including vulnerability scanning, penetration testing, and third-party assessments. It is about operational risk management activities rather than board oversight, management structure, or a specific incident.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats and prior incidents have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition. The remaining language is cautionary and cross-referential rather than describing governance, management, or operational cybersecurity processes.


reasoning: The paragraph primarily describes what the company's cybersecurity program does—using external assessors for audits and threat assessments and deploying detection tools to evaluate and protect its environment. Although third parties are mentioned, they are presented as support for the company's internal cybersecurity activities rather than vendor-risk oversight.


reasoning: This paragraph is a standard forward-looking statements disclaimer about legal and financial disclosure language, not a substantive cybersecurity disclosure. It does not describe cyber oversight, management, processes, third-party risk, incidents, or strategy impact.


reasoning: The paragraph primarily describes the board's oversight of cybersecurity, including delegation to the Audit Committee and the information/oversight chain involving management. The named Technology Steering Committee adds a company-specific governance detail, but the main question answered is how the board oversees cybersecurity.


reasoning: The paragraph primarily addresses what the company seeks to do in its cybersecurity program—identify and mitigate threats—so it fits Risk Management Process. However, it is highly general and does not describe any concrete practices, frameworks, roles, or systems.


reasoning: The paragraph primarily describes what the cybersecurity program does: identifying, monitoring, mitigating, assessing, and monitoring cybersecurity risks and vulnerabilities within the company's broader risk management processes. Although it mentions oversight by a committee, the dominant focus is on program activities rather than board oversight or management qualifications/structure.


reasoning: The paragraph primarily describes the Board of Directors' oversight responsibility for cybersecurity risk, which is board-level governance. It contains only generic oversight language and no cybersecurity-specific, firm-specific, or verifiable details.


reasoning: The paragraph primarily provides a materiality assessment: it states that no cybersecurity incident in the referenced period caused operational interruption, loss of critical data, or a material impact on strategy, financial condition, or results of operations. References to future incidents and the risk-factor cross-reference are secondary to that business-impact conclusion.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from vendors and external technology/service providers, making third-party risk the central topic. It describes concrete vendor-risk practices such as diligence, contractual protections, and security rating monitoring, but does not include firm-unique or externally verifiable facts.


reasoning: This paragraph primarily provides regulatory background and a cross-reference to another section rather than describing the company’s cybersecurity governance, management, processes, third-party risk, incident details, or strategy impact. Under the rules, cross-referential and non-substantive regulatory context falls into None/Other.


reasoning: The paragraph primarily states a materiality-related conclusion that the company had not experienced material cybersecurity incidents as of a stated date, which makes it a Strategy Integration disclosure under the materiality rule. The rest of the paragraph is mostly cautionary, forward-looking risk language and a cross-reference rather than a description of governance, management, or specific cyber processes.


reasoning: The paragraph primarily describes management's cybersecurity leadership structure, responsibilities, reporting relationships, and qualifications, which makes Management Role the best fit. Although it mentions reporting to a board committee, the focus is on who in management is responsible for cybersecurity and their experience.


reasoning: This paragraph is a cross-reference to risk factors and a speculative statement that the organization may be materially affected by cybersecurity threats. It does not describe governance, management, processes, third-party risk controls, a real incident, or a concluded business-impact assessment.


reasoning: The paragraph primarily provides regulatory background and a cross-reference to another section rather than describing the board’s oversight, management’s role, the company’s cybersecurity processes, or any actual incident. Under the instructions, such non-substantive regulatory/contextual disclosure is classified as None/Other.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party service providers, including vendor monitoring and due diligence at selection or renewal. Its focus is vendor-related cyber risk oversight rather than the company’s broader internal cybersecurity program.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party service providers, especially through contract review and amendments. It does not provide firm-unique, verifiable, or meaningfully technical details beyond a general description of vendor-related cybersecurity controls.


reasoning: This paragraph is a general forward-looking risk disclaimer about potential cyberattacks and their possible effects, ending with a cross-reference to Risk Factors. It does not describe actual governance, management, processes, third-party oversight, incident details, or a concrete materiality assessment.


reasoning: The paragraph primarily describes which members of management are responsible for cybersecurity-related responsibilities, decision-making, and escalation, which makes it about management organization and roles rather than board oversight or the underlying security program. Although it includes some process-related duties, the focus is on who in management carries them out.


reasoning: The paragraph primarily provides the company's materiality assessment that cybersecurity threats and prior incidents have not materially affected, and are not reasonably likely to materially affect, its business strategy, results of operations, or financial condition. The reference to Risk Factors is secondary and does not change the paragraph's main function.


reasoning: This paragraph is primarily a general risk description about the company's dependence on technology systems and the kinds of cybersecurity threats it may face. It does not describe board oversight, management organization, a concrete cybersecurity process, third-party risk controls, an actual incident, or a materiality/business impact assessment.


reasoning: The paragraph primarily explains how management is structured to oversee cybersecurity, highlighting the CISO, Security Steering Committee, senior executives, and internal reporting from CSIRT and PSIRT. Although it mentions monitoring and incident-handling activities, the main focus is management responsibility and information flow rather than the broader cybersecurity program itself.


reasoning: The paragraph primarily describes cybersecurity program activities—an incident response plan/policy and employee cybersecurity training—rather than board oversight, management structure, or a specific incident. Its statements are generic and do not include qualifying firm-specific or externally verifiable facts.


reasoning: The paragraph is primarily about management organization and responsibility, focusing on the CISO’s role and experience rather than describing cybersecurity program activities or board oversight. The presence of a cybersecurity-specific executive role makes the disclosure firm-specific.


reasoning: The paragraph primarily describes cybersecurity program activities—employee security awareness training and phishing simulations used to identify and manage cyber risk. Although a third-party vendor is mentioned, the focus is not vendor oversight but the company's internal security training process.


reasoning: The paragraph primarily describes a real cybersecurity incident, including when it was discovered, what occurred, and how the company responded and remediated it. That makes it an incident-focused disclosure rather than a general risk management description.


reasoning: This paragraph is a hypothetical risk statement about possible cybersecurity harms and does not describe board oversight, management roles, a cybersecurity program, third-party risk management, or an actual incident. Its reference to potential material adverse effects is speculative boilerplate rather than a stated business-impact assessment.


reasoning: The paragraph primarily describes how cybersecurity information flows to a board-level committee for oversight, which is a board governance function. It contains no qualifying firm-specific or verifiable facts beyond generic oversight language.


reasoning: The paragraph primarily explains how the company evaluates and manages cybersecurity risk arising from third-party service providers, making third-party risk the central topic. It describes a generic assessment and contracting process without firm-unique details, named frameworks, or verifiable facts.


reasoning: The paragraph primarily describes which management roles are responsible for cybersecurity-related training, so it is about management organization and responsibility rather than the company’s broader security processes. The named officer roles make the disclosure company-specific, but it includes no verifiable numbers, dates, or named external standards.


reasoning: The paragraph primarily provides the company's materiality assessment, stating that cybersecurity threats and prior incidents have not materially affected its business strategy, results of operations, or financial condition. Although it includes a cross-reference to risk factors, the main purpose is this business-impact conclusion rather than describing governance or risk management processes.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from third-party service providers, including onboarding assessments, contractual terms, and periodic reassessments. Although it also mentions penetration testing and cyber insurance, the most developed topic is vendor-related cyber risk oversight.


reasoning: This paragraph provides general background about dependence on information systems and exposure to cyber threats, but it does not describe board oversight, management roles, cybersecurity processes, third-party risk management measures, a real incident, or a material business impact assessment. It is primarily generic contextual and forward-looking risk language.


reasoning: The paragraph primarily describes what the cybersecurity program does to identify and mitigate threats, including software deployment, internal audits, and use of assurance reports. Although service providers are mentioned, vendor oversight is only one component of the broader program rather than the central topic.


reasoning: This paragraph is a cross-reference to another section's risk factors rather than a substantive cybersecurity disclosure. It does not describe governance, management, processes, third-party risk management practices, an actual incident, or a materiality assessment.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and service providers, including assessments, tiering, due diligence, and incident procedures. Its focus is vendor oversight rather than the company's internal cybersecurity program more generally.


reasoning: The paragraph is primarily about oversight responsibilities for cybersecurity policy implementation and corporate commitment, which aligns most closely with governance rather than operational process details. However, because the excerpt does not explicitly identify the overseeing body, the category is somewhat ambiguous.


reasoning: The paragraph primarily explains how the board oversees cybersecurity risk, including delegation to a board committee and how management reports up to that committee. That makes board oversight structure, rather than management operations or risk processes, the central topic.


reasoning: The paragraph primarily describes how cybersecurity information flows from management to the Audit and Finance Committee and Board of Directors, which is board oversight. While it mentions management participants, the main focus is the board and committee briefing structure rather than management organization itself.


reasoning: The paragraph primarily describes cybersecurity activities and improvements in the company's program—testing, observations, and implementation of new processes, procedures, and tools—so it is best categorized as Risk Management Process. The management roles are mentioned, but mainly as context for how the process operates rather than to describe management organization itself.


reasoning: The paragraph primarily states management's conclusion that cybersecurity threats have not materially affected the company's business strategy, results of operations, or financial condition, which is a materiality/business-impact assessment. The forward-looking caution and risk-factor cross-reference are secondary.


reasoning: The paragraph primarily describes a real cybersecurity event, including when it occurred, what happened, and how the company responded, which makes Incident Disclosure the best fit. Although it also includes a materiality conclusion, the incident narrative and remediation details dominate the paragraph.


reasoning: The paragraph primarily gives the company’s materiality assessment that known cybersecurity threats are not reasonably likely to materially affect its business strategy, results of operations, or financial condition, which fits Strategy Integration under the materiality rule. The rest is a cross-reference to risk factors rather than a description of governance, management, or cybersecurity processes.


reasoning: The paragraph primarily explains how the Board of Directors oversees cybersecurity through briefings, ongoing dialogue, strategic guidance, and annual review, which makes board oversight the central topic. Although management roles are mentioned, they are described mainly as part of the information flow supporting the board's governance function.


reasoning: This paragraph primarily describes what the cybersecurity program does—employee training, phishing simulations, and preparedness testing—so it is about the company’s risk management process rather than governance or management roles. It uses cybersecurity-specific practices such as malware detection and phishing simulations, but provides no firm-unique or externally verifiable facts.


reasoning: This paragraph primarily describes an actual cybersecurity incident, including when it was discovered, what occurred, and the company's response. Its focus is the incident itself rather than general risk management or governance.


reasoning: The paragraph primarily states management’s conclusion that cybersecurity incidents have not materially affected, and are not reasonably likely to materially affect, the company, which is a materiality/business-impact assessment. It does not describe governance, management structure, or risk management activities.


reasoning: This paragraph is a cross-reference to risk factors and only states that the company is subject to cybersecurity risks without describing governance, management, processes, third-party risk, incidents, or business impact. It therefore does not contain substantive cybersecurity disclosure.


reasoning: This paragraph primarily describes an actual cybersecurity incident, including its cause, affected data, and response actions. Although a third-party vendor is involved, the main purpose is to explain what happened in the incident rather than the company's ongoing vendor risk management process.


reasoning: This paragraph says the company is a SPAC with no operations and therefore has not adopted a cybersecurity program; it does not describe a substantive cybersecurity governance, management, or risk process. Under the no-operations/SPAC rule, this is best classified as None/Other.


reasoning: The paragraph primarily describes how the board, through its audit committee, oversees cybersecurity risk management and receives information from management. It focuses on governance structure and reporting flow rather than management organization or cybersecurity program activities.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk from third-party service providers through due diligence, evaluation, and contractual requirements. It does not provide firm-unique or verifiable details, but it reflects cybersecurity-specific vendor risk management practices.


reasoning: The paragraph primarily explains how the company addresses cybersecurity risks involving vendors, customers, and third-party technologies, making third-party risk the central topic. However, it provides only generic descriptions of measures like vendor assessments and insurance-related risk assessments without firm-specific or verifiable detail.


reasoning: This paragraph is primarily a no-operations/SPAC disclosure stating that the company has not adopted a cybersecurity program because it currently has no business operations. Under the rules, SPAC-style statements with no substantive cybersecurity measures or processes are classified as None/Other rather than a substantive cybersecurity category.


reasoning: The paragraph primarily states management’s conclusion that known cybersecurity threats and prior incidents have not materially affected the company’s business, operations, or financial condition, which is a materiality assessment. It does not describe governance, management structure, or specific cybersecurity processes.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and suppliers, making Third-Party Risk the best fit. It focuses on vendor due diligence, vendor security requirements, and ongoing oversight of third-party relationships rather than general internal cybersecurity processes.


reasoning: This paragraph describes an actual cybersecurity incident, including what happened, when it was identified, the investigation outcome, recovery, and remediation steps. The presence of specific dates and a dollar amount makes it quantified and externally verifiable.


reasoning: The paragraph primarily describes who within management implements and maintains the company’s cybersecurity processes and highlights the experience supporting that role. It is about management responsibility and qualifications rather than the substance of the cybersecurity program itself.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including the investigation, scope of affected data, and operational impact, so its main function is incident disclosure. Although it also includes a materiality conclusion, most of the paragraph is devoted to what happened and the company’s response.


reasoning: The paragraph primarily describes the oversight chain for cybersecurity, with the Board delegating oversight and receiving updates through management, which makes board oversight the central topic. Although it also mentions management roles and ERM linkage, those details are secondary to the governance structure.


reasoning: This paragraph is primarily a cross-reference to the Risk Factors section and a general statement that the company faces cybersecurity and data leakage risks. It does not describe governance, management roles, risk processes, third-party risk, a specific incident, or a materiality/business impact assessment.


reasoning: The paragraph primarily explains how the company identifies, assesses, and monitors cybersecurity risks arising from third parties such as vendors, service providers, counterparties, and clients. Although it mentions broader cybersecurity activities like penetration testing and forensic analysis, the central focus is third-party cyber risk oversight.


reasoning: This paragraph only describes the company's use of information systems and collection of confidential information; it does not explain board oversight, management roles, cybersecurity processes, third-party risk management, incident details, or business impact assessments. Because it lacks any substantive cybersecurity measure or assessment, it fits None/Other.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company has not experienced a cybersecurity incident that materially affected its business strategy, results of operations, or financial condition. The rest is largely hypothetical risk language and a cross-reference, which does not change the primary focus.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from vendors and other third parties, making third-party risk the central topic. It uses cybersecurity-specific concepts such as vendor cyber risk oversight and heightened review for vendors handling personally identifiable information or trade secrets, but provides no firm-unique or externally verifiable facts.


reasoning: The paragraph primarily describes how the Board oversees cybersecurity, including the governance structure and information flow from management to the Board. Although it mentions a management committee, the main purpose is Board-level oversight rather than management organization or program activities.


reasoning: This paragraph primarily describes an actual cybersecurity incident, including when it occurred and what happened, which makes Incident Disclosure the best fit. Although it also mentions financial impact, that point is presented as part of the incident discussion rather than as a standalone business-strategy assessment.


reasoning: The paragraph primarily states the company's conclusion that it is not aware of cybersecurity threats that have materially affected or are reasonably likely to materially affect its business strategy, results of operations, or financial condition, which is a materiality/business-impact assessment. The references to confidentiality agreements and document management are generic and do not change the paragraph's main focus.


reasoning: The paragraph primarily describes cybersecurity activities the company performs—insider threat monitoring, alerting on suspicious activity, and preventing data loss—so it is about the operation of the cybersecurity program rather than governance or management structure. It uses cybersecurity-specific concepts such as insider threats and data loss prevention, but provides no firm-unique or externally verifiable details.


reasoning: The paragraph primarily explains how management is organized to handle cybersecurity by describing the information security team, the CISO's oversight role, and reporting relationships. Its emphasis is on leadership responsibilities and qualifications rather than on the operational cybersecurity program itself.


reasoning: The paragraph primarily explains how the company oversees cybersecurity risks from third-party providers, including due diligence, monitoring, and coordination with service providers. It does not name any specific vendors, committees, roles, dates, systems, or other qualifying firm-specific facts.


reasoning: The paragraph primarily provides the company's materiality assessment that cybersecurity threats and prior incidents have not materially affected and are not reasonably likely to materially affect its business strategy, results of operations, or financial condition. The cross-reference to Risk Factors is secondary to that strategy/financial-impact conclusion.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party service providers, including pre-engagement assessments and ongoing monitoring. Although it ends with a material no-impact statement, the central focus is vendor-related cybersecurity oversight.


reasoning: The paragraph primarily explains how the company manages cybersecurity dependence on vendors and third-party IT environments, making third-party risk the central topic. It includes cybersecurity-specific concepts such as hosted architecture, sensitive data handling, and vendor cybersecurity reporting, but provides no firm-unique or externally verifiable details.


reasoning: The paragraph primarily describes how a board committee oversees cybersecurity through discussions with management and review of the cybersecurity program, which is a board oversight function. It does not provide qualifying firm-specific or verifiable details beyond generic governance language.


reasoning: The paragraph primarily describes how the company manages cybersecurity risks posed by business partners, making third-party risk the central topic. It does so in generic terms without naming specific vendors, controls, frameworks, committees, or other company-specific details.


reasoning: This paragraph primarily describes which management personnel are responsible for cybersecurity risk oversight and their relevant tenure and experience. It focuses on management roles and qualifications rather than the company’s cybersecurity processes or board oversight.


reasoning: This paragraph does not describe cybersecurity governance, management, processes, third-party risk, incidents, or strategy impacts; it only states that the company is a blank check company with no operations. Under the rules for no-operations/SPAC-style disclosures, this is None/Other.


reasoning: This paragraph mainly explains that, as a blank check company with no operations, the company does not maintain its own cybersecurity personnel or processes and only faces generalized exposure through third-party technologies. It does not describe a substantive cybersecurity governance, management, or risk management program, so it fits None/Other.


reasoning: The paragraph primarily describes the existence and purpose of the company's cybersecurity-related processes—identifying, assessing, and managing risks to systems and data—so it fits Risk Management Process. However, it provides only high-level, generic descriptions without cybersecurity-specific practices, frameworks, tools, roles, or verifiable facts.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk arising from third-party providers, making Third-Party Risk the best fit. It describes vendor security assessment and monitoring activities rather than broader internal cybersecurity governance or program operations.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party service providers, including pre-engagement assessments and ongoing monitoring. Although it includes general process language, its central topic is vendor-related cyber risk oversight.


reasoning: This paragraph only defines the term "cybersecurity threat" and does not describe the board's oversight, management roles, risk processes, third-party risk, an actual incident, or business impact. It is definitional boilerplate rather than substantive cybersecurity disclosure.


reasoning: The paragraph primarily describes operational cybersecurity measures—continuous monitoring and threat response through a SOC and SIEM—which makes it about the company’s cybersecurity program activities. It is firm-specific because it includes the distinctive organizational claim of a 24x7 SOC, even though it does not provide a clearly externally verifiable named product, date, or quantified metric beyond that.


reasoning: The paragraph primarily describes the Board of Directors' role in addressing and planning to develop cybersecurity policies and a cybersecurity risk management program, which makes board oversight the central topic. Although it mentions the absence of current policies and possible outsourcing, it does not provide substantive program details or firm-specific governance facts.


reasoning: This paragraph is a high-level, forward-looking statement about the general importance of cybersecurity and possible risks. It does not describe board oversight, management roles, risk processes, third-party risk, an actual incident, or a concrete materiality assessment.


reasoning: The paragraph primarily describes cybersecurity measures implemented to reduce risk, specifically stronger privileged access policies and expanded multi-factor authentication. Although it references a prior incident and possible future material effects, it does not actually describe the incident itself in substantive detail, so the main focus is the risk management response.


reasoning: The paragraph primarily describes how management is organized to oversee cybersecurity, including who directs the program and who reports cyber updates internally. While it references cybersecurity activities like prevention and detection, those are mentioned in the context of management responsibility rather than describing the program itself.


reasoning: The paragraph primarily states management’s conclusion that cybersecurity threats and incidents have not materially affected the company’s business strategy, results of operations, or financial condition, which is a materiality/business-impact assessment. It does not describe governance, management structure, or operational cybersecurity processes.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party service providers, making Third-Party Risk the best fit. It describes vendor security assessments and ongoing monitoring, which reflects cybersecurity-specific process language, but includes no firm-unique or externally verifiable facts.


reasoning: This paragraph primarily explains that the company is a SPAC with no operations and therefore has no meaningful cybersecurity program or exposure. Although it briefly mentions board oversight and absence of incidents, the main disclosure is that there is no substantive cybersecurity risk management structure to describe.


reasoning: The paragraph primarily describes cybersecurity program activities: employee awareness training, system scans, threat intelligence analysis, and related controls. Although it mentions contractual requirements for certain third-party providers, third parties are described as one component of the broader cybersecurity program rather than as the central topic.


reasoning: The paragraph primarily describes a component of the company’s cybersecurity program—its use of external consultants and providers as part of its risk management approach—rather than oversight, management structure, or vendor oversight requirements. Because it mentions only generic consultants and industry-recognized providers without naming firms, tools, standards, or concrete practices, it is boilerplate rather than specific.


reasoning: This paragraph only states that the company may collect and store customer and sensitive business information; it does not describe cybersecurity oversight, management roles, risk processes, third-party risk, an incident, or a materiality/business impact assessment. It is a generic contextual statement rather than a substantive cybersecurity disclosure.


reasoning: The paragraph primarily describes how the board oversees cybersecurity risk, including delegation to a board committee and reporting up to that committee. It does not provide meaningful firm-specific or verifiable cybersecurity detail beyond generic governance structure.


reasoning: The paragraph primarily provides a materiality assessment, stating that past cybersecurity incidents have not been determined to materially affect the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration under the materiality rule. The remaining references to future evaluation, business continuity, incident response, and risk factor cross-reference are secondary and generic.


reasoning: The paragraph is a high-level statement of the importance of cybersecurity and data protection, but it does not describe any actual oversight structure, management role, concrete process, third-party practice, incident, or business impact assessment. Because it contains no substantive cybersecurity disclosure beyond generic aspirational language, it fits None/Other.


reasoning: This paragraph primarily explains management’s qualifications and roles in handling cybersecurity, especially by highlighting the CTO and CISO and their relevant backgrounds. It does not meaningfully describe the cybersecurity program’s activities, so it is better classified as Management Role than Risk Management Process.


reasoning: The paragraph primarily describes how cybersecurity risk information flows through board-level oversight, with the Audit Committee reporting to the Board and the Board reviewing material cybersecurity risks and events. Its details are generic governance boilerplate rather than company-specific or technically detailed cybersecurity disclosure.


reasoning: The paragraph primarily describes what the cybersecurity program does and how it operates: integration into enterprise risk management, cybersecurity assessments, security controls, incident response responsibilities, and use of external service providers for testing and assessment. It is not mainly about board oversight or management qualifications/structure.


reasoning: The paragraph provides only general business context about dependence on IT systems and sensitive data, without describing cybersecurity governance, management roles, risk processes, third-party oversight, incident details, or a materiality/business-impact assessment. It is therefore non-substantive cybersecurity context rather than a Item 1C process disclosure.


reasoning: The paragraph primarily provides a materiality-style assessment that the company has not experienced cybersecurity incidents to date and discusses the potential business consequences if incidents occur, which fits Strategy Integration. It does not describe governance, management structure, or an actual incident, and the language is largely generic and cautionary.


reasoning: This paragraph is a hypothetical risk warning about possible cyberattacks and their potential consequences, not a description of governance, management roles, a cybersecurity program, third-party risk management, a real incident, or a materiality conclusion. It uses generic speculative language common in risk factors, so it falls outside the substantive Item 1C categories.


reasoning: The paragraph primarily describes how cybersecurity information flows to the Audit Committee and Board of Directors, including escalation of material breaches and board briefings, which is board oversight. Although it mentions continuous monitoring, the dominant focus is governance and reporting to the board.


reasoning: This paragraph describes an actual cybersecurity-related incident, including how the fraud occurred, what was transferred, and the recovery efforts. Its primary purpose is to disclose the nature and impact of a real event, making Incident Disclosure the best fit.


reasoning: This paragraph does not describe a substantive cybersecurity governance structure or risk management program; instead, it states that the company has no cybersecurity personnel or processes of its own and relies on third parties. The board reference is generic oversight language, and for a no-operations/SPAC-style disclosure with no real program described, the best fit is None/Other.


reasoning: The paragraph primarily describes how a management-level committee is involved in handling cybersecurity through monitoring, receiving updates, and reviewing policies, rather than describing board oversight or a detailed operational process. Its language reflects cybersecurity functions such as incident response, threat mitigation, and third-party assessments, but it contains no firm-unique or externally verifiable facts.


reasoning: The paragraph primarily explains board-level oversight by stating that management updates the Audit Committee on cybersecurity matters, describing the information flow to a board committee. Although it mentions the CEO's direction of the program, the main focus is governance oversight rather than management organization.


reasoning: This paragraph is primarily generic background and risk language about cybersecurity threats and possible adverse effects, without describing actual governance, management roles, concrete cybersecurity processes, third-party oversight, or a real incident. Its statements about securing systems are too general to constitute a substantive risk management process disclosure.


reasoning: The paragraph is primarily about how the company addresses cybersecurity risks arising from third parties such as vendors and service providers, making Third-Party Risk the best fit. It remains high-level and does not describe specific cyber practices, named programs, roles, firms, or verifiable details.


reasoning: The paragraph primarily describes oversight structure: the board-level Audit Committee oversees cybersecurity policy and reviews cybersecurity risk management and resources, which makes board governance the central topic. Although it also mentions management of the program by a CISO, that detail is secondary to the board oversight description.


reasoning: The paragraph primarily describes what the company's cybersecurity program is intended to do—supporting ongoing evaluation and improvement of security over systems, data, and operations—so it fits Risk Management Process. Its use of confidentiality, integrity, and availability reflects cybersecurity-specific domain language, but it contains no firm-unique or externally verifiable facts.


reasoning: This paragraph primarily describes an actual cybersecurity incident, including when it occurred, what was affected, and the remediation outcome. Its focus is the event’s nature, scope, and containment rather than general program design or governance.


reasoning: The paragraph primarily describes how the board and its audit committee oversee cybersecurity and receive updates from management, which makes board oversight the central topic. The mention of a VP-level IT leadership role adds a company-specific organizational fact, but the paragraph is still mainly about governance.


reasoning: The paragraph primarily explains management’s responsibility and involvement in overseeing cybersecurity risk, including its coordination with an external IT specialist and its accountability for the overall framework. Although it mentions program activities, the main question it answers is how management is organized and what management is responsible for.


reasoning: The paragraph primarily describes how the board oversees cybersecurity risk by delegating oversight to the Audit Committee. It contains only generic governance statements without qualifying firm-specific or verifiable details.


reasoning: The paragraph primarily describes what the cybersecurity program does—conducting an IT security assessment and implementing policies and controls using recognized cybersecurity frameworks. It does not focus on board oversight, management roles, or third-party/vendor risk.


reasoning: The paragraph primarily describes cybersecurity program activities—risk assessment, maintenance of security controls, incident-response coordination, and use of outside support—rather than board oversight or management qualifications. Although third parties are mentioned, they are engaged to support the company's own security program, so the central topic is the risk management process rather than third-party risk oversight.


reasoning: The paragraph primarily describes who in management is responsible for cybersecurity and highlights the CIO’s role and qualifications. Although it mentions ongoing risk evaluation and safeguarding activities, those appear secondary to explaining management ownership of the program.


reasoning: This paragraph describes an actual cybersecurity-related event, including what happened, when it occurred, and the outcome, so it is primarily an incident disclosure. The inclusion of a specific date (May 2014) makes the paragraph quantified/verifiable.


reasoning: The paragraph primarily explains how the company manages cybersecurity-related risk from vendors by assessing third-party data protection practices. It provides only a generic statement about having a documented process, without cybersecurity-specific detail, named frameworks, roles, committees, or verifiable facts.


reasoning: The paragraph primarily describes that management and the board will meet to evaluate the situation and consider further action, which most directly relates to board oversight. However, it provides only generic oversight language without substantive cybersecurity detail.


reasoning: The paragraph primarily explains how cybersecurity threats could affect the company's business strategy, performance, results of operations, and resource allocation, which fits Strategy Integration. It does not describe an actual incident or a concrete risk-management process, and its material-impact language is framed at the business level.


reasoning: The paragraph primarily describes post-incident remediation steps and the stated outcome of a real cybersecurity event, which makes Incident Disclosure the best fit. Although it includes a material-impact conclusion, the dominant focus is what was done in response to the incident and the operational status afterward.


reasoning: This paragraph is a cross-reference directing readers to Item 1A risk factors rather than describing cybersecurity governance, management, processes, third-party risk handling, an incident, or a materiality assessment. It contains no substantive cybersecurity disclosure beyond pointing elsewhere.


reasoning: This paragraph primarily describes a real cybersecurity event, including when it was detected, what occurred, the monetary loss, and the company’s response, which makes it an incident disclosure. It also includes concrete dates, a specific dollar amount, and a named cybersecurity role, making it externally verifiable.


reasoning: The paragraph most directly addresses the company’s cybersecurity risk management process by briefly stating that it continuously monitors and develops its IT networks and infrastructure to prevent, detect, address, and mitigate cyber risks. However, most of the language is generalized risk disclosure and hypothetical impact discussion rather than detailed, company-specific process description.


reasoning: The paragraph primarily answers whether cybersecurity risks or incidents have materially affected the company, led by the explicit statement that no cybersecurity incidents have materially impacted its business strategy, results of operations, or financial condition. The remaining discussion is supporting context about potential cyber threats and possible material impact if those risks are realized.


reasoning: The paragraph primarily describes the board’s oversight structure for cybersecurity, including delegation to a board-level committee and reporting from management up to that committee and the full Board. Although it mentions the CISO and certain cybersecurity activities, the dominant focus is how oversight flows through the Board and its committee.


reasoning: The paragraph primarily states a materiality conclusion that cybersecurity threats or incidents have not materially affected the company's business strategy, results of operations, or financial condition, which fits Strategy Integration. The remaining language is forward-looking caution and a cross-reference to risk factors rather than discussion of governance, management, or process.