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, incidents, or strategy impacts. Under the instructions, such non-substantive regulatory/contextual disclosure is classified as None/Other.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily describes cybersecurity program activities: workforce training, penetration testing, vulnerability scanning, and remediation of identified vulnerabilities. Its focus is on what the company’s cybersecurity processes do, not on board oversight, management structure, or third-party vendor risk.

provider: openai

stage: benchmark


content_category: Strategy Integration

reasoning: The paragraph primarily gives 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 of operations, or financial condition, which is a Strategy Integration assessment. The remainder is cautionary language and a cross-reference to risk factors rather than discussion of governance, management, or program processes.


content_category: Management Role

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity, including the Cyber Risk Committee, the CIO’s role, and the use of a virtual CISO. Although it mentions oversight and certain activities, the focus is on management structure, responsibilities, and qualifications rather than the cybersecurity program itself.


specificity_confidence: medium

reasoning: The paragraph primarily provides the company's materiality assessment regarding whether cybersecurity incidents affected or are reasonably likely to affect business strategy or financial results. That makes it a Strategy Integration disclosure rather than an incident description or process discussion.


reasoning: The paragraph is primarily about who within management is responsible for cybersecurity and how that responsibility is organized, including the Cybersecurity Committee and a senior IT executive overseeing cyber risk management. Although it references monitoring and incident-related processes, those are mentioned only in the context of management oversight roles rather than describing the program itself.


content_category: Board Governance

reasoning: The paragraph primarily describes how the board and a board-level committee oversee cybersecurity, including policy approval, risk appetite setting, and monitoring mitigation efforts. Although it mentions risk assessments and mitigation plans, those are presented in the context of board oversight rather than operational process.


content_category: Third-Party Risk

reasoning: The paragraph is primarily about how the company manages cybersecurity risks from vendors and service providers, making third-party oversight the central topic. It describes vendor evaluation and review of SOC reports, which are cybersecurity-specific practices but not firm-unique or externally verifiable company-specific facts.


category_confidence: medium

reasoning: The paragraph primarily explains how executive management supervises cybersecurity efforts and receives information about cyber risks and incidents, which is mainly about management's role rather than board oversight. Although it references operational inputs like threat intelligence and security-tool alerts, those details mainly support how management is informed.


reasoning: The paragraph primarily describes management's cybersecurity leadership structure by focusing on the CISO's responsibilities, tenure, and qualifications. Although it briefly mentions program activities, the main question answered is how management is organized and who leads cybersecurity.


reasoning: The paragraph primarily explains management’s responsibility for assessing and managing cybersecurity risk and how management is informed, which makes it chiefly about management’s organizational role rather than board oversight or detailed security processes. Although it references monitoring and incident-related activities, those are framed at a high level through management responsibility rather than describing the cybersecurity program itself.


content_category: Incident Disclosure

reasoning: The paragraph describes an actual cybersecurity incident, including what happened, the nature of the intrusion, and key timing details from the investigation. Its primary purpose is to disclose incident facts rather than discuss governance, management, or general risk processes.


reasoning: The paragraph primarily describes a real cybersecurity event, including its nature and timing, and the resulting legal and investigative consequences. That makes it an incident-focused disclosure rather than a general risk management or strategy discussion.


reasoning: Although the paragraph references real cybersecurity incidents, its primary focus is the resulting financial and business impact, including significant costs, insurance coverage limits, and potential material adverse effects. That makes it principally about how cybersecurity affects the business and finances rather than about the incident details themselves.


reasoning: This paragraph describes an actual cybersecurity incident, including what occurred, investigative findings, and the timing of the unauthorized activity. Its primary purpose is to disclose incident facts rather than governance, management, or general risk processes.


reasoning: This paragraph primarily describes how a board-level committee oversees cybersecurity risk through specific reporting channels and decision-making authority, which is board oversight rather than management operations. It is firm-specific because it names a non-generic board committee and identifies specific internal cybersecurity reports reviewed by that committee.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and third-party solutions, including vendor reviews and security requirements in service agreements. It describes cybersecurity-specific practices, but does not include firm-unique or externally verifiable facts.


reasoning: The paragraph’s central disclosure is the company’s materiality assessment: it states that known cybersecurity threats have not materially affected the company in the last fiscal year but are reasonably likely to materially affect it if realized. Although it also mentions management responsibility and ERM, the primary question answered is how cybersecurity affects business outcomes and materiality.


reasoning: The paragraph primarily describes how the board oversees cybersecurity risk, specifically by delegating primary oversight to a board committee as part of the board’s risk oversight structure. It does not provide qualifying firm-specific or verifiable facts beyond generic governance language.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party providers, including due diligence, contractual requirements, monitoring, and reassessment. Although it includes cyber risk-management practices, the central focus is vendor and provider oversight rather than the internal security program generally.


reasoning: The paragraph primarily describes how management is organized to oversee cybersecurity, focusing on the responsibilities and reporting relationship of the Senior Director and Head of Information Technology and the management committee on cybersecurity. Although it references cybersecurity activities such as prevention and detection, those activities are presented mainly through management roles and oversight responsibilities.


reasoning: The paragraph is primarily about management organization and qualifications, specifically identifying the executive responsible for cybersecurity in Latin America and describing that person's experience. It does not describe the cybersecurity program or board oversight process.


reasoning: The paragraph primarily describes which management personnel are responsible for cybersecurity-related oversight and their qualifications and experience. Although it briefly mentions board updates, most of the content focuses on management roles rather than board oversight or the operational cybersecurity program.


content_category: None/Other

reasoning: The paragraph only states general dependence on internal and third-party technology systems and does not describe any actual cybersecurity governance, management role, risk process, third-party oversight measure, incident, or materiality assessment. It is contextual boilerplate rather than substantive cybersecurity disclosure.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it was announced, the operational disruption it caused, remediation timing, and related costs. Although it also includes a materiality-style statement, the dominant focus is the specific incident and its effects.


reasoning: This paragraph primarily describes an actual cybersecurity incident, including when it was identified, what operations were affected, remediation timing, and related costs. Although it also includes a materiality statement and risk-factor cross-reference, the real-event narrative and impacts are the dominant content.


reasoning: The paragraph primarily describes how the company’s cybersecurity incident response program operates, including coordination, escalation, tracking, reporting, and testing activities. Although teams are mentioned, the focus is on the incident management process rather than management structure or board oversight.


reasoning: The paragraph primarily provides a materiality assessment, stating that no known cyber incidents were material and that cybersecurity threats are not reasonably likely to materially affect strategy, results of operations, or financial condition. The cross-reference to risk factors is secondary and does not change the paragraph’s main function.


reasoning: This is a cross-reference to a risk factor and contains only hypothetical adverse-effect language about possible outages or security breaches, not a substantive description of cybersecurity governance, management, process, third-party risk, incident, or strategy assessment.


reasoning: The paragraph primarily provides a cybersecurity materiality assessment, stating that the company is not aware of any material cybersecurity risks that have materially affected or are reasonably likely to materially affect its business, results, or financial condition. The remainder is largely generic risk language and a cross-reference to risk factors.


reasoning: The paragraph primarily explains how the company approaches cybersecurity risks arising from third-party vendors, making third-party risk the central topic. It does not provide concrete cybersecurity practices, named programs, firms, roles, or verifiable details beyond general statements about developing a vendor risk management program.


reasoning: The paragraph primarily describes management’s organizational structure for cybersecurity, including reporting lines and which functions handle incidents, rather than the board’s oversight or the company’s cyber processes. It focuses on who is responsible and how management is arranged to address cybersecurity.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third parties, especially through vendor reviews, oversight, and assessment of critical third-party cyber risk protocols. Although it also mentions using outside experts for testing and monitoring, the dominant theme is third-party risk oversight.


reasoning: This paragraph is primarily a generic cautionary statement about possible consequences if a cybersecurity incident were to occur, rather than a substantive description of governance, management, processes, third-party oversight, strategy impact assessment, or an actual incident. The brief reference to a program designed to prevent, detect, and respond is too generic to make risk management the paragraph’s main content.


reasoning: The paragraph primarily addresses how cybersecurity could affect the company's financial protection posture by referencing cyber risk insurance coverage. It does not describe governance, management structure, or risk management activities, and the statement is a generic caution without firm-specific detail.


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


reasoning: This is a high-level introductory statement about the company’s business and general commitment to a secure environment, but it does not describe cybersecurity governance, management, processes, third-party risk, incidents, or business impact. It therefore does not provide substantive cybersecurity disclosure.


reasoning: The paragraph primarily states a conclusion about materiality—namely that cybersecurity risks and incidents during 2024 have not materially affected and are not reasonably likely to materially affect the company—so it is best categorized as Strategy Integration. The brief mention of third-party due diligence is secondary and generic.


reasoning: This paragraph primarily explains how the board oversees cybersecurity risk through committee-level oversight and information flow from management to the board. Although it mentions management roles and risk topics, its main purpose is describing the board oversight structure.


reasoning: The paragraph primarily states a conclusion about the historical material impact of cybersecurity incidents on the company’s operations and financial reporting, which is a materiality/business-impact assessment. It does not describe governance, management roles, or risk management processes.


reasoning: The paragraph primarily explains how the board oversees cybersecurity risk by assigning oversight responsibility to a board-level committee. Its focus is the governance structure and delegation of cyber oversight, not management operations or risk processes.


reasoning: The paragraph primarily gives a materiality assessment 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. That makes it a Strategy Integration disclosure rather than an incident description or risk-process discussion.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from third parties, making Third-Party Risk the best fit. It describes the existence and purpose of a third-party risk program but provides only high-level, generic process language without concrete cyber-specific or verifiable details.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from vendors and other external service providers, making third-party risk the central topic. It describes contractual cybersecurity requirements for higher-risk third parties, but does not include firm-unique names, roles, committees, or verifiable details.


reasoning: The paragraph primarily provides a materiality assessment, stating that past cyber incidents did not have a material adverse effect on the company's business strategy, operations, or financial condition. The cross-reference to Item 1A is secondary and does not change the main focus.


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. That is a materiality/business-impact assessment, which fits Strategy Integration rather than risk process or incident disclosure.


reasoning: The paragraph primarily describes how the company structures its cybersecurity program and risk identification process, which is a risk management process topic. Its main concrete detail is use of the NIST CSF as a guiding framework, which reflects cybersecurity domain knowledge but is not an externally verifiable claim.


reasoning: The paragraph primarily states management's conclusion about whether known cybersecurity threats and prior incidents have materially affected, or are reasonably likely to materially affect, the company's business, operations, and financial condition, which is a materiality/business-impact assessment. The cross-reference to risk factors is secondary and does not change the main focus.


reasoning: The paragraph primarily describes what the company's cybersecurity program does: it uses a layered security model and is integrated into enterprise risk management. It does not focus on board oversight, management roles, third-party risk, or any actual incident.


reasoning: This paragraph is primarily a cross-reference directing readers to risk factor disclosures in Item 1A rather than providing substantive cybersecurity governance, management, process, third-party risk, incident, or strategy information itself. Under the rules, cross-references about where material effects may be discussed are classified as None/Other.


reasoning: The paragraph primarily explains how management is organized to carry out cybersecurity responsibilities: the CISO, an Executive Steering Committee, and multidisciplinary teams implement and monitor the program. Although it mentions reporting to the Audit Committee and sometimes the Board, that oversight is secondary to the management structure and responsibilities described.


reasoning: This paragraph is a generic forward-looking risk statement about possible cybersecurity harms and costs if breaches occur, without describing actual governance, management roles, processes, third-party oversight, incidents, or a concrete materiality assessment. Because it is speculative boilerplate rather than substantive cybersecurity disclosure, it fits None/Other.


reasoning: The paragraph primarily describes how the Board and its Audit Committee oversee cybersecurity risk, including reporting flows from management to the committee and Board. Although it mentions the CISO, the main focus is the Board-level oversight structure rather than management organization or operational security processes.


reasoning: This paragraph is a cross-reference to another risk-factor disclosure rather than a substantive cybersecurity discussion. It does not describe governance, management, processes, third-party risk, a real incident, or an actual materiality conclusion.


reasoning: The paragraph primarily frames cybersecurity in terms of potential material effects on the business and includes a negative status assertion that, to date, the company has not had a cybersecurity incident. Although it briefly mentions detecting and investigating attacks, the dominant focus is business-impact assessment and risk framing rather than a detailed cybersecurity process.


reasoning: The paragraph primarily describes cybersecurity program activities—vulnerability scanning, network assessments, and penetration testing—rather than vendor oversight or management structure. Although third parties are involved, they are serving as assessors within the company's internal security process, which fits Risk Management Process.


reasoning: The paragraph primarily states management's conclusion that cybersecurity threats and prior incidents have not materially affected, and are not expected to materially affect, the business, results of operations, or financial condition. That is a business-impact/materiality assessment, which fits Strategy Integration.


reasoning: This paragraph primarily describes who in management is responsible for cybersecurity and why they are qualified, focusing on the CISO and President of Technology’s experience, tenure, and responsibilities. While it references cybersecurity architecture and systems, those details are presented in service of management qualifications rather than describing the company’s risk management process.


reasoning: The paragraph primarily describes the oversight chain for cybersecurity—management brings material threats to the Board, with oversight by the Audit Committee—so it is chiefly about board-level governance. The management references are generic and do not provide meaningful organizational detail beyond that governance structure.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from vendors and service providers, making third-party oversight the central topic. It describes concrete vendor review and due diligence practices, but without externally verifiable dates, numbers, or named outside firms.


reasoning: This paragraph primarily describes how the Board oversees cybersecurity through periodic reviews and updates from management and Prudential personnel. Its focus is the Board's oversight structure and information flow, which makes Board Governance the best fit.


reasoning: The paragraph primarily describes cybersecurity program activities: employee security awareness training and integration of cybersecurity risk tracking into the company’s risk management processes. Although it mentions enterprise risk management integration, it does not make a business-impact/materiality assessment, so Risk Management Process fits best.


reasoning: The paragraph primarily describes how the Board oversees cybersecurity risk, including direct oversight, review of risk management policies, and reporting from management to the Board. Although it mentions the CISO, the main question answered is the Board’s oversight role rather than management’s organization or the operational cybersecurity program.


reasoning: The paragraph primarily describes that the Fund has processes and a cybersecurity program in place to assess, identify, and manage cybersecurity risks. Although it mentions reliance on the Adviser and other service providers, it does not centrally discuss how third-party cyber risk is overseen.


reasoning: The paragraph primarily provides a materiality assessment of cybersecurity risk and prior incidents, stating that past incidents have not had a material adverse effect on the Partnership's business, financial condition, results of operations, or cash flows. It does not describe a specific incident, governance structure, or cybersecurity program activities in substantive detail.


reasoning: The paragraph primarily describes how the board, through the Audit Committee, oversees cybersecurity risk and receives information from management. Although it includes some cybersecurity-specific terms such as vulnerability assessments and the threat environment, it does not provide qualifying firm-specific or externally verifiable facts.


reasoning: The paragraph primarily describes how management is organized to handle cybersecurity, including leadership roles, reporting lines, and management-level committee structure. Although it mentions oversight of cyber risk, the main focus is the management hierarchy rather than board oversight or detailed security processes.


reasoning: The paragraph primarily describes how the company is developing its cybersecurity program and response capabilities, which is a risk management process topic. The references to outside counsel and third-party service providers are generic support elements rather than a central discussion of vendor risk oversight.


reasoning: The paragraph primarily describes the board-level oversight chain for cybersecurity through the RACC, including how management reports up to that committee and how incidents are escalated for oversight and disclosure consideration. Although it includes management responsibilities and program activities, the dominant focus is governance and information flow to the board committee.


reasoning: The paragraph primarily states management's conclusion that cybersecurity challenges have not materially affected operations or financial standing and mentions cyber liability insurance, which speaks to business/financial impact rather than governance or operational process. The cross-reference to Risk Factors is secondary.


reasoning: The paragraph primarily describes how the board oversees cybersecurity risk, including delegation to and reporting from the Audit Committee. It does not provide qualifying specific or verifiable cybersecurity facts beyond generic governance language.


reasoning: The paragraph primarily discusses an actual cybersecurity event, including when it was identified and that it involved unauthorized activity in the company’s IT networks and systems. Although it also includes a material-impact statement and cross-references, the dominant focus is disclosure of a real incident.


reasoning: This paragraph is only a cross-reference to another section for discussion of potential cybersecurity effects and does not itself provide substantive disclosure about governance, management, risk processes, third-party risk, incidents, or strategy integration. Under the rules, cross-references of this type are classified as None/Other.


reasoning: The paragraph is primarily about how the Company oversees cybersecurity risks arising from suppliers, vendors, and service providers, making third-party cyber risk the central topic. While it is fairly general, it includes a company-specific organizational detail about using the Adviser's risk management, legal, IT, and compliance personnel for this oversight.


reasoning: The paragraph primarily addresses how the company manages cybersecurity risks arising from third-party service providers, making Third-Party Risk the best fit. It remains high-level and generic, without named vendors, contractual controls, specific assessment methods, or other qualifying specific facts.


reasoning: The paragraph primarily describes management’s organizational responsibility for cybersecurity by identifying the security team’s leader and that leader’s responsibilities. While it references cybersecurity activities, the focus is on who oversees them rather than how the program operates.


reasoning: The paragraph primarily describes a cybersecurity program activity—employee training and awareness measures used to identify and manage cyber risk—rather than board oversight or management structure. It discusses how the company educates employees on cybersecurity risks and reporting of security issues, which fits risk management process.


reasoning: This paragraph only describes general hypothetical cybersecurity exposure and dependence on system security, without discussing governance, management roles, processes, third-party oversight, a real incident, or a materiality assessment. It is therefore non-substantive boilerplate rather than a substantive Item 1C disclosure category.


reasoning: The paragraph primarily explains that the company evaluates and manages cybersecurity risks arising from third-party service providers, making third-party risk the central topic. It does not provide concrete vendor controls, named frameworks, firms, systems, or other specific cybersecurity details beyond high-level boilerplate.


reasoning: The paragraph primarily states management's conclusion about whether cybersecurity threats have materially affected the company's business and could materially affect it in the future, which is a business-impact/materiality assessment. It does not describe governance, management roles, or cybersecurity processes.


reasoning: The paragraph primarily explains who in management is responsible for cybersecurity oversight and how that responsibility is carried out, which makes it a management-organization disclosure rather than a process description. Although it mentions third-party support and breach alerts, those details are secondary to identifying management responsibility.


reasoning: The paragraph is primarily about how the company addresses cybersecurity risk arising from third-party service providers, making third-party risk the central topic. It does not provide concrete details about the program's methods, structure, or any company-specific facts.


reasoning: The paragraph primarily states a materiality-related conclusion that the company had not had any known material cybersecurity incidents as of the stated period, which falls under Strategy Integration under the materiality rule. The rest of the paragraph is generic cautionary language and a risk-factor cross-reference rather than process, governance, or incident-detail disclosure.


reasoning: The paragraph primarily describes how cybersecurity information flows upward to the Board and how the Board is kept informed, which is board oversight structure. Although management roles are mentioned, they are presented mainly as part of the governance and escalation chain to the Board.


reasoning: This paragraph primarily describes how board-level oversight of cybersecurity is structured, including the committee responsible, the information it receives, and how matters are elevated to the full board. Although management is mentioned, the focus is on board and committee oversight rather than management organization or operational processes.


reasoning: The paragraph primarily describes what the cybersecurity program does—using external experts to evaluate, test, audit, and assess cyber risk management systems. Although third parties are mentioned, they are engaged as advisors/assessors supporting the company’s internal program rather than as vendors whose risks are being overseen.


reasoning: The paragraph primarily describes what the company's cybersecurity program does—its procedure for detecting, containing, responding to, and remediating incidents—so it fits Risk Management Process. It includes cybersecurity-specific operational terminology, but no firm-unique or externally verifiable facts.


reasoning: The paragraph primarily describes management’s cybersecurity organization through the CISO’s role, qualifications, and responsibility for the information security team. Although it mentions reporting to the RCOC, the main focus is on management leadership rather than board oversight.


reasoning: The paragraph primarily describes what the cybersecurity program does operationally: testing infrastructure, assessing resilience, managing incident response, training employees, and monitoring phishing awareness. Although one bullet addresses third-party service providers, it is one component of the broader cybersecurity program rather than the central topic.


reasoning: The paragraph primarily describes management’s responsibilities for cybersecurity, including who handles staffing, budgeting, incident preparation, and review of security-related reports. It does not focus on board oversight or provide substantive detail about how the cybersecurity program operates.


reasoning: The paragraph describes a component of the company's cybersecurity program—using outside parties to assess or test cybersecurity controls—which is an operational risk management activity. Although third parties are mentioned, they are engaged to assist the company's own program rather than as the subject of vendor/supply-chain oversight.


reasoning: The paragraph primarily describes a real cybersecurity event—its timing, nature, and resulting litigation—so it is best classified as Incident Disclosure. Although it also includes materiality language and forward-looking risk language, the actual 2021 ransomware incident is the central subject.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk from third-party service providers by imposing security and breach-notification requirements on them. It does not provide firm-specific, quantified, or distinctly cybersecurity-technical details beyond generic vendor security obligations.


reasoning: The paragraph is primarily about the Company's dependence on its external Manager for information systems and cybersecurity risk processes, making third-party reliance the central topic. While it also mentions management affiliation, the main disclosure is that cybersecurity risk assessment and management are undertaken through the Manager.


reasoning: The paragraph primarily describes what the company's cybersecurity program does, including assessments, backups, external testing support, and awareness training, which fits risk management process. It does not provide board or management structure details, nor does it include qualifying firm-specific or verifiable facts.


reasoning: The paragraph primarily describes how the board receives oversight information about cybersecurity risk: the full board oversees business risk, does not receive regular scheduled cyber reports, and would be informed of material changes. The mention of management consulting a third-party IT firm is secondary to the board-reporting and oversight structure.


reasoning: The paragraph primarily describes what the company's cybersecurity program does—maintaining and periodically testing incident response and recovery plans—so it fits Risk Management Process. It does not describe an actual incident, board oversight, or management structure.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from third-party service providers, including pre-engagement assessments and contractual cybersecurity requirements. Its focus is vendor oversight rather than the company's broader internal cybersecurity program.


reasoning: This sentence is a generic statement about reliance on information technology systems and potential business disruption from failures, without describing cybersecurity oversight, management, processes, third-party risk, incidents, or a materiality assessment. It is speculative boilerplate rather than substantive cybersecurity disclosure.


reasoning: The paragraph primarily provides a materiality conclusion that cybersecurity threats or incidents did not materially affect, and are not reasonably likely to materially affect, the partnership’s business strategy, results of operations, or financial condition. That is a business-impact assessment rather than a description of governance, management, or security processes.


reasoning: The paragraph primarily provides a materiality assessment of cybersecurity incidents and addresses whether the company carries cyber insurance, both of which speak to how cybersecurity affects business and financial outcomes. It does not describe governance, management structure, or operational cyber processes.


reasoning: The paragraph primarily describes the company’s general approach to handling cybersecurity threats by reviewing and updating safeguards and involving outside consultants, which is about the cybersecurity program’s activities rather than board oversight or management structure. Its language is high-level and generic, without concrete cybersecurity practices, named frameworks, roles, firms, or verifiable details.


reasoning: The paragraph is primarily about dependence on service providers' cybersecurity protections and how those protections are evaluated when selecting providers, making third-party cyber risk the central topic. While much of the language is simple, the disclosure that all bookkeeping and accounting functions are outsourced to a third-party accounting firm is a company-specific operational fact.


reasoning: The paragraph primarily describes activities in the company's cybersecurity program—internal audits, evaluating cyber readiness, hardening systems and infrastructure, and employee training—rather than board oversight or management structure. Although it includes a statement about not identifying material cybersecurity risks, the dominant focus is on ongoing risk management measures.


reasoning: This paragraph is generic background about cyberattacks in general and does not describe the company's governance, management, processes, third-party risk oversight, an actual incident, or a materiality/business impact assessment. It therefore does not provide substantive cybersecurity disclosure about the registrant itself.


reasoning: The paragraph primarily describes management responsibility and qualifications for cybersecurity oversight, centered on the CISO's role and experience rather than the underlying cybersecurity program. It is not board-focused, and the discussion of prevention and remediation is secondary to who is responsible and why they are qualified.


reasoning: The paragraph primarily describes the cybersecurity program’s operational measures and safeguards, such as technical controls, patch management, recovery planning, and employee training. Although it mentions a third-party service provider, vendor oversight is not the central topic; the focus is on what the company’s cybersecurity process does.


reasoning: The paragraph primarily gives a materiality assessment of how cybersecurity threats and past incidents have affected, and are reasonably likely to affect, the company's business strategy, results of operations, and financial condition; that makes Strategy Integration the best fit. The insurance reference is secondary to that business-impact conclusion.


reasoning: The paragraph primarily describes the framework used to structure the company's cybersecurity risk identification, assessment, and management activities, which is a risk management process topic. It does not focus on board oversight, management roles, or a specific incident.


reasoning: The paragraph primarily describes what the cybersecurity program does: threat intelligence intake, employee training, phishing exercises, monitoring and detection, vendor security assessment, and incident response planning. Although third-party vendors and service providers are mentioned, they are components of the broader cybersecurity program rather than the central topic.


reasoning: The paragraph is primarily about how the company manages cybersecurity-related risks from vendors, suppliers, and external partners, making third-party risk the central topic. It describes the existence of a vendor management process in generic terms without providing cybersecurity-specific, firm-unique, or externally verifiable details.


reasoning: The paragraph primarily describes cybersecurity program activities—external assessments of the company’s systems and resulting network upgrades—so it is about the risk management process rather than vendor risk oversight. It is more specific than generic boilerplate because it gives company-specific timing and actions, but it lacks named firms, exact dates, or other clearly externally verifiable details.


reasoning: This paragraph describes an actual cybersecurity incident, including when it was detected and the immediate containment and remediation actions taken. Its primary purpose is to explain what happened and how the company responded, which fits Incident Disclosure.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats and incidents have not materially affected and are not reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition. That makes it Strategy Integration rather than Incident Disclosure, since it does not describe any actual incident.


reasoning: The paragraph primarily explains how cybersecurity information flows to and is overseen by the Board, including Board updates, education, and director expertise. Although it mentions the CISO and Steering Committee, those details mainly support the Board oversight structure rather than describe management’s standalone role.


reasoning: The paragraph primarily explains how cybersecurity-related information flows to leadership and the Board, which is a board oversight/governance function. Although third-party risk is mentioned, the focus is on reporting and informing oversight rather than describing the vendor risk management process itself.


reasoning: The paragraph primarily explains management's organization and responsibilities for cybersecurity, centered on the CIO, the CIO's team, and management's coordination and reporting roles. Although it mentions program activities like prevention and response, the main focus is who in management carries them out and how they are organized.


reasoning: The paragraph primarily describes what the cybersecurity program does—continuous system monitoring, threat detection, assessments, and mitigation support—even though third-party firms help perform those activities. Because the third parties are discussed mainly as service providers supporting the company’s internal security processes, this fits Risk Management Process rather than Third-Party Risk.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats did not materially affect and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition. The remaining sentences are standard cautionary and cross-reference language rather than discussion of governance, management, or risk-management processes.


reasoning: The paragraph primarily describes the company’s overall cybersecurity program posture—using assessments, certifications, and reporting structure—rather than board oversight, management qualifications, or a specific incident. However, it remains high-level and does not provide concrete cybersecurity measures or firm-specific details.


reasoning: The paragraph primarily provides a conclusion about the business impact/materiality of cybersecurity by stating that the company had not experienced any cybersecurity incidents as of a specific date. Although it briefly mentions risk management processes, the main takeaway is the negative incident/materiality assessment.


reasoning: This paragraph is a generic introductory statement about the existence of cybersecurity risks and lists possible risk types, but it does not describe the company's actual governance, management roles, risk management processes, third-party oversight, incident details, or business-impact assessment. Because it contains no substantive cybersecurity program disclosure, it is best classified as None/Other.


reasoning: The paragraph primarily describes a component of the company's cybersecurity program—risk assessments used to identify material cybersecurity risks to systems and information—so it is about the risk management process. It does not include firm-specific roles, named frameworks, tools, dates, vendors, or other qualifying specific facts.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks posed by vendors and service providers, making Third-Party Risk the best fit. It provides only high-level, generic statements about due diligence and oversight without any firm-specific details or verifiable facts.


reasoning: This paragraph is primarily a generic risk-oriented statement about cybersecurity threats and possible adverse effects, plus a cross-reference to risk factors, rather than a substantive description of governance, management, processes, third-party oversight, strategy, or an actual incident. It does not describe concrete cybersecurity measures beyond boilerplate statements about securing systems.


reasoning: The paragraph primarily describes how information about cybersecurity risks and incidents flows from management to a board-level committee, which is a board oversight function. It does not provide named committees, roles, dates, or other qualifying specific facts.


reasoning: The paragraph primarily describes the company's cybersecurity risk management processes and their objective of protecting systems and information, which is about what the program does. It does not discuss board oversight, management roles, third-party risk, or any actual incident.


reasoning: This paragraph is primarily a forward-looking risk warning with a cross-reference to the risk factors section, rather than a substantive description of governance, management, processes, third-party risk, incidents, or strategy impact. It does not describe any actual cybersecurity measure or assessment beyond generic boilerplate language.


reasoning: This paragraph primarily describes how the Board oversees cybersecurity risk through reports it receives from management and external parties. Its focus is the board’s oversight and information flow rather than the underlying cybersecurity program itself.


reasoning: The paragraph describes an actual cybersecurity incident, its operational effects, the timeline of recovery, and the status of system restoration, so it primarily answers what happened in the incident. It does not include qualifying specific facts such as named firms, dates, quantified impacts, or named systems.


reasoning: This paragraph is a cross-reference directing readers to Item 1A risk factors rather than providing substantive cybersecurity governance, management, process, third-party, incident, or strategy disclosure itself. It does not state an actual materiality conclusion or describe concrete cybersecurity measures.


reasoning: This paragraph is primarily a risk-factor style discussion of hypothetical cybersecurity and privacy harms, with a cross-reference to Item 1A and speculative statements about what could happen. Although it mentions generic protective measures, it does not substantively describe the company's cybersecurity governance, management structure, or risk management process.


reasoning: The paragraph primarily describes how the Board of Directors and its audit committee oversee cybersecurity, including delegation and review responsibilities. It does not meaningfully describe management organization, operational cybersecurity processes, or any actual incident.


reasoning: The paragraph primarily states an overall conclusion about cybersecurity’s status and impact on the company, including that it did not experience any cybersecurity incident during 2024, which fits the materiality/status-assessment function of Strategy Integration rather than describing a specific incident or governance process. The rest of the paragraph is high-level commitment language without substantive cybersecurity program detail.


reasoning: The paragraph primarily describes the board's role in overseeing cybersecurity risk and comments on the board's ability to do so, which squarely addresses board oversight. It does not include qualifying firm-specific or externally verifiable cybersecurity facts beyond generic board-level statements.


reasoning: The paragraph primarily describes how the company structures its cybersecurity program and assesses cyber risk, including use of recognized frameworks and annual risk assessments. It is not focused on board oversight or management roles, but on the risk management approach itself.


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


reasoning: The paragraph primarily describes components of the company’s cybersecurity program—using external providers for threat intelligence, cybersecurity software, penetration testing, and related support to identify, assess, and manage cyber risks. Although third parties are central to the description, they are presented as tools/resources within the company’s risk management process rather than as a vendor oversight program.


reasoning: This paragraph is primarily about which management roles are responsible for cybersecurity and how management is organized to oversee those responsibilities. It focuses on leadership positions, team responsibility, and the VP, Technology & CISO's background rather than describing board oversight or detailed security processes.


reasoning: This paragraph is a cross-reference directing readers to Item 1A risk factors rather than providing a substantive cybersecurity governance, management, process, third-party, incident, or materiality assessment itself. Because it contains no actual cybersecurity disclosure beyond pointing elsewhere, it fits None/Other.


reasoning: The paragraph primarily addresses how the company uses cybersecurity insurance to mitigate potential business and financial consequences of cyber incidents, which fits Strategy Integration. It does not describe board oversight, management structure, or operational cybersecurity processes.


reasoning: The paragraph primarily describes the company's cybersecurity program activities and controls—technical safeguards and external evaluations of security controls—so it is about how cybersecurity risk is managed. Although third parties are mentioned, they are engaged to assess the company's controls rather than as the central topic of vendor risk oversight.


reasoning: The paragraph primarily states management’s conclusion that cybersecurity has not affected the company’s results of operations or financial condition to date, which is a business-impact/materiality assessment. The remaining sentence is forward-looking cautionary language rather than process, governance, or incident-detail disclosure.


reasoning: The paragraph primarily describes how cybersecurity information is escalated to the board through committee reporting, which is a board oversight structure. While it mentions senior management and the CISO, the main focus is the board-level governance chain rather than management organization or operational security processes.


reasoning: The paragraph primarily describes the company’s cybersecurity risk management activities and controls—how it assesses, identifies, and manages cyber risks within its IT function. It does not focus on board oversight, management qualifications, or a specific incident, and the descriptions remain generic rather than cybersecurity-specific or firm-unique.


reasoning: The paragraph primarily describes oversight responsibilities: the Board has overall responsibility for cybersecurity risk management while management identifies and monitors risks. Although it also states that no cybersecurity incidents occurred in fiscal year 2024, the dominant focus is the governance structure rather than incident details or business impact.


reasoning: The paragraph primarily describes what the cybersecurity program does: incident prevention, mitigation, detection, remediation, and employee security training and awareness activities. Although senior leadership is mentioned, the focus is on operational cybersecurity processes rather than management structure or board oversight.


reasoning: The paragraph describes general business reliance on technology and information systems, but it does not discuss cybersecurity oversight, management roles, risk processes, third-party risk, incidents, or cyber-related business impact assessments. It therefore does not provide substantive cybersecurity disclosure.


reasoning: The paragraph primarily describes the components of the company's cybersecurity program—risk assessments, security controls, training, incident response, and related processes—so it is about what the program does rather than board oversight or management qualifications. It does not include qualifying firm-specific or externally verifiable facts such as named frameworks, named roles, committees, vendors, products, dates, or quantified details.


reasoning: The paragraph primarily describes who makes up management's cybersecurity leadership team and their qualifications, which is about management organization and credentials rather than program activities or board oversight. Although it includes a numeric experience claim, the main content is management expertise and team composition.


reasoning: The paragraph primarily describes how the Board oversees cybersecurity risk by receiving updates from management about the cybersecurity program, threat landscape, and incidents. It does not focus on management qualifications or operational processes, so Board Governance is the best fit.


reasoning: This paragraph describes general IT consulting and service-delivery functions of vCIO services rather than a substantive cybersecurity oversight, management, risk, third-party cyber-risk, incident, or strategy disclosure. It does not describe any actual cybersecurity-specific measure or assessment.


reasoning: The paragraph primarily describes how the company’s cybersecurity program operates through third-party support for monitoring, investigation, remediation, and risk management activities. Although it mentions evaluating critical supplier risk, third-party vendor oversight is not the central focus; the main emphasis is on the company’s broader cybersecurity risk management process.


reasoning: This paragraph is only a cross-reference to a risk factor and contains speculative adverse-effect language, without describing any actual cybersecurity governance, management, process, third-party oversight, incident, or materiality assessment.


reasoning: The paragraph primarily explains how management is organized to handle cybersecurity by identifying the CIO and Information Security Officer, their responsibilities, and their experience. Although it also describes third-party risk oversight, that appears as one component of the management-led cybersecurity function rather than the central topic.


reasoning: The paragraph is primarily about cybersecurity risk arising from third-party service providers and the company's limited ability to oversee vendors' cybersecurity practices, making Third-Party Risk the best fit. It does not provide firm-specific roles, named programs, committees, vendors, dates, or verifiable details beyond generic vendor-risk language.


reasoning: The paragraph primarily describes how the Board is informed about cybersecurity matters, including periodic updates on the framework's effectiveness and notice of material incidents, which makes it a board oversight disclosure. The reference to the Information Technology department is secondary to the governance flow toward the Board.


reasoning: This paragraph is a cross-reference directing the reader to Item 1A Risk Factors for discussion of cybersecurity-related impacts, rather than providing substantive disclosure about governance, management, processes, incidents, third parties, or strategy. Because it contains no qualifying cybersecurity-specific facts, it is generic boilerplate.


reasoning: The paragraph primarily explains how the company addresses cybersecurity risks arising from vendors, service providers, and other external parties, making third-party risk the central topic. It remains high-level and does not provide concrete cybersecurity practices, named programs, roles, firms, or verifiable details.


reasoning: The paragraph primarily describes how management-level cybersecurity leaders—the Vice President of IT and Digital and the CISO—stay informed, which speaks to management’s role and organization rather than the underlying cybersecurity program itself. The references to these specific leadership roles make the paragraph firm-specific.


reasoning: This paragraph is a forward-looking, hypothetical risk statement about possible consequences of cybersecurity incidents, not a description of governance, management, processes, third-party risk, an actual incident, or a concrete business-impact assessment. It contains no substantive cybersecurity measures or company-specific facts.


reasoning: This paragraph is primarily a cautionary statement about the possibility and consequences of future cyberattacks, plus a cross-reference to Risk Factors, rather than a substantive description of governance, management, process, third-party risk, incident, or strategy assessment. It contains only generic boilerplate language about cyber risk and security limitations.


reasoning: The paragraph primarily describes the purpose of the company's cybersecurity program—establishing and maintaining measures to protect information systems and data. It does not discuss board oversight, management organization, third-party risk, or any actual incident.


reasoning: The paragraph primarily describes how the company's cybersecurity risk management program operates within its broader risk management structure, specifically its integration with enterprise risk management. It does not provide firm-specific roles, tools, frameworks, or verifiable details, so it is generic boilerplate.


reasoning: The paragraph primarily states the company's conclusion that cybersecurity threats and prior incidents have not materially affected, and are not reasonably anticipated to materially affect, the organization, which is a materiality/business-impact assessment. Although it also mentions enhancements to risk management practices and tabletop exercises, those details are secondary to the overall impact assessment.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from service providers, including vendor qualification, reliance on provider notifications, and remediation expectations. Its focus is third-party oversight rather than the company's broader internal cybersecurity program.


reasoning: The paragraph primarily describes how the board oversees cybersecurity risk, including delegation of oversight responsibility to a board committee. It does not provide substantive detail about management organization or cybersecurity program activities.


reasoning: The paragraph primarily provides management’s conclusion that known cybersecurity threats are not reasonably likely to materially affect the company’s operations, business strategy, results of operations, or financial condition, which is a materiality/business-impact assessment. The references to management responsibility and cross-referenced risk factors are secondary to that assessment.


reasoning: The paragraph primarily describes what the company's cybersecurity program does: assessing cyber threats, monitoring for vulnerabilities, testing systems, using security tools, collaborating with third parties, and conducting third-party due diligence. Although it also mentions board involvement and a materiality conclusion, the dominant focus is the cybersecurity risk management process.


reasoning: The paragraph primarily describes how the board-level oversight structure works for cybersecurity, with the audit committee overseeing cyber risk and receiving updates from management before informing the board. It does not provide substantive detail about management organization or the cybersecurity program itself.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from outside service providers by imposing security and breach-reporting requirements on them. Although it mentions consultants assisting with risk assessment, the central focus is third-party oversight rather than the company's internal cybersecurity program.


reasoning: The paragraph primarily describes management responsibility for cybersecurity by assigning leadership and reporting duties to the Chief Executive Officer. It does not meaningfully describe the board’s oversight structure or a substantive cybersecurity program beyond high-level boilerplate responsibilities.


reasoning: The paragraph primarily provides a materiality-oriented assessment of how cybersecurity has affected, and may affect, the company’s business, expenses, results of operations, and financial condition. Its statement that the company has not experienced any material cybersecurity incidents is treated as a Strategy Integration disclosure rather than an incident description.


reasoning: The paragraph primarily describes how the company handles cybersecurity operations—protection, detection, and response—so it is best categorized as Risk Management Process. Although it mentions a third-party subcontractor, the focus is not vendor oversight but outsourcing the cybersecurity function itself.


reasoning: The paragraph primarily provides a conclusion about the business and financial impact of cybersecurity matters—stating that they have not materially impaired operations or financial standing—which fits Strategy Integration. The cross-reference to Item 1A is secondary and does not add substantive cybersecurity detail.


reasoning: The paragraph primarily addresses the potential business/financial implications of cybersecurity incidents by stating that the company lacks insurance coverage for resulting damages. The first sentence is generic speculative risk language, but the insurance statement makes Strategy Integration the best fit.


reasoning: The paragraph primarily states management’s conclusion that cybersecurity risks and attacks have not materially affected the company’s operations, business strategy, or financial results to date, which is a business-impact/materiality assessment. The rest of the paragraph is forward-looking caution and a cross-reference, not a description of governance or process.


reasoning: The paragraph primarily provides a materiality assessment of cybersecurity threats and incidents on the company's business strategy, results of operations, and financial condition, and also mentions insurance coverage. That makes it chiefly about how cybersecurity affects the business and finances rather than governance, management, or operational processes.


reasoning: The paragraph primarily describes the Board’s oversight role and how cybersecurity risk information flows to the Board, which is a governance question. It contains only generic references to the Board and executive officers, without cybersecurity-specific structures, roles, or verifiable details.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats did not materially affect and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition. That makes Strategy Integration the best fit, while the remaining sentence is only generic forward-looking risk language.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats and breach attempts have not materially affected the company's business, strategy, results of operations, or financial condition, which fits Strategy Integration. The remaining language is generic forward-looking risk language and a cross-reference to risk factors.


reasoning: The paragraph primarily describes who oversees cybersecurity at the board level, stating that the Board of Directors is responsible for oversight and referencing management's role beneath that oversight chain. It does not provide substantive detail about processes, qualifications, or any verifiable firm-specific cybersecurity facts.


reasoning: The paragraph primarily states a materiality conclusion that known cybersecurity threats and prior incidents have not materially affected and are not reasonably likely to materially affect the company, which is Strategy Integration. Although it also mentions oversight by the Cybersecurity Governance Board, that governance detail is secondary.


reasoning: The paragraph primarily explains how the company relies on and oversees CROs for cybersecurity, including reviewing their policies and requiring incident reporting, so third-party risk is the central topic. Although it mentions some security controls, those controls are described in the context of vendor oversight rather than the company's own cybersecurity program.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from third-party service providers, including security certifications and breach-reporting obligations imposed on them. Although it mentions consultants helping with internal processes, the central focus is oversight and requirements for third parties.


reasoning: The paragraph primarily describes the oversight chain for cybersecurity risk: senior management assesses and manages risk, briefs the Audit Committee, and the committee reports to the Board. Although it mentions management responsibilities, its main purpose is explaining how cybersecurity information flows to board-level oversight.


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, which fits Strategy Integration. The references to controls and cyber insurance are generic and secondary to that assessment.


reasoning: The paragraph primarily provides a materiality assessment of how known and ongoing cybersecurity threats have affected or are reasonably likely to affect the company's operations, business strategy, results, cash flows, and financial condition, which fits Strategy Integration. Although mostly standard Item 1C language, the reference to interactions with children's hospitals and insurance prior approvals adds a company-specific detail.


reasoning: The paragraph primarily describes the oversight role of the board, including approving cybersecurity investments and participating with management in compliance and legal oversight. It does not meaningfully describe management organization or specific cybersecurity processes.


reasoning: The paragraph primarily explains how the company uses and plans to oversee third-party service providers in its cybersecurity efforts, especially by requiring significant providers to maintain security measures and report suspected breaches. Although it also mentions consultants assisting with internal risk assessment, the central emphasis is on third-party cybersecurity expectations and oversight.


reasoning: The paragraph primarily describes the oversight chain for cybersecurity, including management updating the Board and the Board receiving reports on cyber risks and the risk management program. Although it mentions the CEO’s operational involvement, the main question answered is how cybersecurity oversight reaches the Board.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company does not believe it experienced any material cybersecurity incidents or material related costs in the past two years and discussing potential future business and financial impacts. That makes it a Strategy Integration paragraph rather than an incident description or process discussion.


reasoning: The paragraph primarily states management's conclusion 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, which is a Strategy Integration materiality assessment. The remaining language is generic cautionary context and a cross-reference to risk factors.


reasoning: The paragraph primarily explains management’s responsibilities and reporting duties for day-to-day cybersecurity operations and escalation of incidents, rather than describing the cybersecurity program itself. Although it references committee oversight, the main substance is how senior management and business units handle and report cyber events.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats have not materially affected the company and are not reasonably likely to do so, which fits Strategy Integration under the materiality rule. The remaining language is forward-looking and cautionary rather than describing governance, management, or specific cybersecurity processes.


reasoning: The paragraph primarily explains how the company oversees cybersecurity risks from third-party service providers, including pre-engagement assessments and ongoing monitoring. Although it ends with a material-impairment statement, most of the text is focused on vendor-risk oversight rather than business impact.


reasoning: The paragraph primarily describes how the board oversees cybersecurity by delegating oversight responsibility to a board committee and having that committee monitor management's program. It does not provide company-distinguishing or verifiable details beyond generic governance structure.


reasoning: The paragraph primarily describes the cybersecurity-related processes used to monitor, detect, mitigate, and report cyber risks, such as system alerts, dashboards, and status reporting. Although it mentions Mr. Dennis's role and reporting to the Audit Committee, the main substance is how the cybersecurity monitoring process operates.


reasoning: The paragraph primarily addresses the state of the company's cybersecurity program by stating that it has not yet adopted formal cybersecurity risk management programs or formal risk assessment processes. It does not focus on board oversight, management roles, third-party risk, or an actual incident.


reasoning: The paragraph primarily describes what the company's cybersecurity program does: incident response planning, threat intelligence monitoring, vulnerability management, and employee training activities. It does not focus on board oversight, management qualifications, or a specific incident.


reasoning: The paragraph primarily describes how cybersecurity information flows to the Board and how board-level oversight occurs for cyber risks and incidents, which is board governance. Its specificity is driven by firm-unique governance entities such as the SMIS and Cybersecurity Committee and SMIS's team, but it lacks hard verifiable numbers or dates.


reasoning: The paragraph primarily describes how the company oversees cybersecurity risks arising from third-party service providers, including pre-engagement assessments and ongoing monitoring. Although it includes a negative statement about not having experienced materially impairing cybersecurity challenges, the central focus is vendor-related cyber risk management.


reasoning: The paragraph primarily states management's conclusion about cybersecurity's effect on the business—specifically that the company has not experienced unauthorized access from cybersecurity incidents with a materially adverse effect on its business, operations, or financial condition. The remaining language is general cautionary wording and a cross-reference to risk factors, not a description of governance, management structure, or cybersecurity processes.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats have not materially impaired operations or financial standing and that a future material incident could affect business outcomes. This is about cybersecurity's impact on the business rather than governance structure, management roles, or specific risk-management activities.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party service providers, including onboarding, monitoring, renewal, and evaluation of vendor security controls. It describes third-party oversight processes rather than internal governance or a specific incident.


reasoning: The paragraph primarily provides a materiality assessment, stating that no cybersecurity threats or incidents have materially affected, or are reasonably likely to materially affect, the company’s business strategy, results of operations, or financial condition. Although it mentions an external assessment, the dominant purpose is the business-impact conclusion, which fits Strategy Integration.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from third-party service providers, including due diligence, contractual security requirements, and incident notification obligations. Its focus is vendor oversight rather than the company's broader internal cybersecurity program.


reasoning: This paragraph primarily explains how management is organized to handle cybersecurity by identifying the CISO's responsibilities and qualifications. Its focus is on the leadership role and background of the executive responsible for cybersecurity, not on board oversight or the operational details of the program itself.


reasoning: The paragraph primarily discusses how cybersecurity threats could affect the company's business strategy, performance, results of operations, and resource allocation, which fits Strategy Integration best. It does not describe governance, management structure, or specific risk-management processes.


reasoning: The paragraph primarily provides the company's materiality assessment of cybersecurity risk and incidents on its business strategy, results of operations, and financial condition, which is Strategy Integration. The rest of the paragraph is mainly cautionary language and a risk-factor cross-reference.


reasoning: The paragraph primarily provides a materiality assessment by stating that the company did not experience a material cybersecurity incident during the fiscal year, which falls under Strategy Integration. The remainder is a cross-reference to risk factors rather than a description of governance, management, or cybersecurity processes.


reasoning: The paragraph primarily describes cybersecurity program activities—using external consultants to assess, test, enhance, monitor, and respond to incidents—so it is about the risk management process. Although third parties are mentioned, they are engaged to support the company’s internal program rather than as the subject of vendor oversight.


reasoning: The paragraph primarily states management’s conclusion that no known cybersecurity incidents have materially affected or are reasonably likely to materially affect the company’s business, results, or financial condition, which is a materiality/business-impact assessment. The cross-reference to Item 1A does not change the primary focus.


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, operations, or financial condition. The remaining language is generic cautionary and cross-referential rather than describing governance, management, or operational processes.


reasoning: The paragraph is primarily about how the company manages cybersecurity-related risks arising from third-party service providers, including due diligence, monitoring, security assessments, and contingency planning. Its central question is vendor oversight rather than general cybersecurity program operations.


reasoning: This paragraph is a cross-reference directing readers to another section for discussion of cybersecurity risks and potential material effects, rather than providing substantive disclosure itself. It does not describe governance, management, process, third-party risk management, an actual incident, or a concrete materiality assessment in this paragraph.


reasoning: The paragraph primarily explains how management is organized to handle cybersecurity by identifying the executive responsible, describing that person’s responsibilities, experience, and management reporting relationship. It is not board-focused, and the cybersecurity process details are secondary to the role description.


reasoning: The paragraph is primarily a generic cautionary statement and cross-reference to Risk Factors rather than a substantive description of governance, management, process, third-party risk, strategy impact, or a specific cyber incident. Although it notes past incidents have occurred, it provides no actual event details and functions mainly as boilerplate disclosure.


reasoning: The paragraph primarily describes management organization and qualifications: the reporting relationship between the CISO and CDO and the CDO's experience, prior roles, and education. It is not mainly about cybersecurity processes or board oversight.


reasoning: This paragraph describes an actual cybersecurity incident, including its nature (ransomware attack) and timing, along with recovery timing after remediation. The specific dates make the disclosure externally verifiable.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party service providers, including contractual requirements and audits, making third-party risk the central topic. It uses cybersecurity-specific concepts, but does not provide firm-unique or externally verifiable details.


reasoning: The paragraph primarily explains how cybersecurity risks from third-party service providers are evaluated and mitigated, making third-party risk the central topic. It includes a specific named firm, BNY Mellon, which is an externally identifiable fact.


reasoning: The paragraph primarily explains how cybersecurity information flows to the Board and how the Board oversees cybersecurity through briefings, ongoing dialogue, and strategic decision-making. Although management participants are identified, the main focus is the Board’s oversight structure rather than management organization itself.


reasoning: The paragraph primarily provides a materiality assessment, stating that past cybersecurity incidents and threats have not materially affected the company and are not reasonably likely to materially affect it, which fits Strategy Integration under the SEC materiality rule. The rest of the paragraph is generic cautionary language and a cross-reference rather than a description of a specific incident or concrete cybersecurity process.


reasoning: The paragraph primarily describes cybersecurity program activities—continuous security improvement, evaluation of protective technologies, and use of outside experts to assess controls—rather than board oversight or management qualifications. The reference to an IT Committee is a firm-specific organizational detail, but the rest of the paragraph is otherwise fairly general.


reasoning: The paragraph primarily provides a materiality assessment, stating that no cybersecurity incident resulted in unauthorized access with a material adverse effect on the business, operations, or financial condition, which fits Strategy Integration. The rest of the paragraph is generic forward-looking risk language and a cross-reference, without specific cybersecurity program details.


reasoning: The paragraph primarily describes what the company's cybersecurity program does: security controls, monitoring, risk-based architecture, risk register use, penetration testing, and backup/recovery practices. It focuses on operational risk management activities rather than board oversight, management roles, or third-party vendor oversight as a central topic.


reasoning: The paragraph primarily describes a real cybersecurity incident, including when it was discovered, what was accessed, and the related extortion threat, which makes Incident Disclosure the best fit. Although it ends with a materiality assessment, the incident narrative is the dominant focus.


reasoning: The paragraph primarily gives a materiality assessment of whether known cybersecurity threats or prior breaches have affected or are reasonably likely to affect the company's business, financial condition, and results of operations, which fits Strategy Integration. The rest is generic forward-looking risk language and a cross-reference to risk factors rather than process, governance, or incident details.


reasoning: This paragraph primarily describes an actual cybersecurity incident, including when it was discovered, what happened, and the company’s immediate response. The specific date and named law-enforcement agency make the disclosure externally verifiable.


reasoning: The paragraph primarily describes how the board oversees cybersecurity risk, including reporting to the Audit Committee and Board, escalation of incidents, and board-level discussion of cybersecurity matters. Its most specific qualifying detail is the involvement of the Chief Information Security Officer, which makes the disclosure firm-specific rather than purely generic.


reasoning: The paragraph primarily describes what the cybersecurity program does: testing, assessments, threat modeling, vulnerability testing, and use of external assessments to evaluate and improve controls. Although it mentions reporting results to the Board, that is secondary to the description of the underlying risk management activities.


reasoning: This paragraph does not provide substantive cybersecurity disclosure; it merely cross-references another risk-factor section for discussion of potential effects. Because it is a pointer rather than an actual assessment or process description, it fits None/Other.


reasoning: This paragraph is only a cross-reference to another risk factor section and does not itself describe cybersecurity governance, management, processes, third-party risk, an incident, or a business impact assessment. It therefore falls outside the substantive disclosure categories.


reasoning: The paragraph primarily explains who within management is responsible for cybersecurity and why they are qualified, emphasizing leadership roles, team structure, and experience. Although it mentions the cybersecurity program, the focus is on management organization and credentials rather than operational security activities.


reasoning: The paragraph primarily states a conclusion about material business impact—namely that cybersecurity risks have not materially affected the company’s business strategy, results of operations, or financial condition to date. The remaining language is generic risk/disclaimer text and a cross-reference, not a description of governance, management, or process.


reasoning: The paragraph primarily describes how cybersecurity information flows through the Board oversight structure, from the CISO to the Risk and Compliance Committee and then to the Board. Although management roles are mentioned, the main purpose is explaining Board-level oversight and reporting.


reasoning: The paragraph primarily explains how the company evaluates cybersecurity-related risks posed by vendors, focusing on due diligence factors for high-risk and vital vendors. It is not describing the internal cyber program generally, but rather vendor oversight criteria.


reasoning: The paragraph primarily describes what the company's cybersecurity program does to identify, detect, and remediate risks, such as scanning, penetration testing, malware containment, and log monitoring. Although it mentions vendor due diligence, third-party risk is only one component of a broader description of cybersecurity operations.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it occurred, what was accessed, customer notification timing, and remediation steps. Although it briefly references third-party relationships and incident response, the dominant content is the real event and its aftermath.


reasoning: Although the paragraph includes a concrete past cyber incident, its primary purpose is to assess business impact and materiality, stating that cybersecurity risks and incidents have not materially affected the company and are not reasonably likely to do so over the long term. That makes the paragraph chiefly about how cybersecurity affects business outcomes rather than about governance or operational processes.


reasoning: The paragraph primarily describes how a board committee oversees cybersecurity risk through briefings and review of risk-management reporting, which is a board oversight function. Although it mentions cybersecurity topics reviewed, it does so at a high level without firm-specific or verifiable details.


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


reasoning: This paragraph describes what happened in an actual cybersecurity incident and the remediation steps taken afterward, so it primarily answers the incident-disclosure question. The reference to a February 2023 ransomware attack is a concrete, externally checkable fact, supporting Quantified-Verifiable specificity.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats did not materially affect and are not reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition, which is Strategy Integration under the SEC rules. The remaining language is standard cautionary and cross-reference disclosure rather than discussion of governance, management, or program processes.


reasoning: The paragraph primarily describes how management is organized to handle cybersecurity by focusing on the CISO’s responsibilities, qualifications, and experience. It is not mainly about board oversight or program activities, but about the management role and credentials of the executive leading cybersecurity.


reasoning: This paragraph is only a cross-reference to another section's risk factor and does not describe cybersecurity governance, management, processes, third-party risk, incidents, or strategy impacts. It is therefore non-substantive for Item 1C classification.


reasoning: This paragraph is only a cross-reference to another section for additional information and does not itself describe cybersecurity governance, management, processes, third-party risk, incidents, or strategy impact.


reasoning: The paragraph primarily describes incident-management and notification processes—how cybersecurity events are handled and escalated—rather than board oversight, management organization, or a specific realized incident. Although it references affiliated entities, the central focus is the response process itself, making Risk Management Process the best fit.


reasoning: The paragraph primarily addresses how cybersecurity risk is addressed through business/financial planning by stating that the company maintains cyber liability insurance. The cross-reference does not change the main topic from cybersecurity insurance, which fits Strategy Integration.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and other third parties, making Third-Party Risk the best fit. It includes a company-specific control artifact—its Vendor Management Policy—which raises specificity above generic process language.


reasoning: This fragment appears to list external cybersecurity collaboration and information-sharing bodies that support the company's cybersecurity activities, which fits best under risk management process. It is not about board oversight, management organization, or vendor risk, and no actual incident is described.


reasoning: The paragraph primarily states a conclusion about cybersecurity’s historical business and financial impact—namely that the company has not experienced a material security breach or related material expenses or settlements. That makes it a Strategy Integration disclosure rather than an incident description or process discussion.


reasoning: The paragraph primarily describes management’s cybersecurity leadership structure and the qualifications and background of the Chief Security Officer, which fits Management Role. It is not mainly about board oversight or cybersecurity program activities.


reasoning: This paragraph describes an actual cybersecurity incident: what the threat actors accessed, what they exfiltrated and released, and the company's response measures. Its primary purpose is to explain the nature and remediation of a real event, which makes Incident Disclosure the best fit.


reasoning: The paragraph primarily addresses how cybersecurity affects the company financially by stating that it maintains insurance coverage for various cyber-related losses and expenses. It does not describe governance, management structure, or operational security processes.


reasoning: The paragraph describes the status and resolution of an actual cybersecurity incident, including operational impact and restoration timing. Its primary purpose is to report what happened and the incident's outcome, which fits Incident Disclosure.


reasoning: The paragraph primarily describes how the company’s cybersecurity risk management program operates by using outside specialists to help identify, assess, and manage cyber risks. Although third parties are mentioned, they are service providers supporting the company’s internal process rather than vendors being overseen as a distinct third-party risk topic.


reasoning: The paragraph primarily describes a real cybersecurity incident, including when it occurred, what systems were affected, and the company's response actions. Because it centers on an actual event and its timeline rather than general risk management or governance, Incident Disclosure is the best fit.


reasoning: The paragraph primarily describes how the board and its committee oversee cybersecurity, including reporting flows and escalation of incidents, which is board-level oversight. Although it includes some cybersecurity-specific terminology such as vulnerability assessments and threat environment, it does not contain qualifying firm-specific or externally verifiable facts.


reasoning: The paragraph primarily describes how management is organized to oversee cybersecurity and related technology risks, centering on a management-level steering committee and its membership. It is not mainly about board oversight or detailed security processes.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party suppliers, including assessment procedures and contractual safeguards. Its focus is vendor-related cyber risk rather than the company’s broader internal cybersecurity program.


reasoning: The paragraph primarily describes how the board oversees cybersecurity, including delegation of primary oversight responsibility to a board committee and how that oversight fits into enterprise risk evaluation. The references to the Board and Audit Committee are standard governance boilerplate and do not add qualifying specific facts under the rules.


reasoning: The paragraph primarily explains how cybersecurity information is reported to and overseen by the Board, including updates from a committee and notice of significant threats or incidents between meetings. It does not provide qualifying firm-specific or verifiable details such as a named committee, specific role, framework, date, or quantified fact.


reasoning: The paragraph primarily describes what the cybersecurity program does—protect information systems from cybersecurity threats and respond to incidents under incident response and recovery plans. Although it mentions the CSO, the main focus is the operation of the program rather than management qualifications or board oversight.


reasoning: This paragraph primarily describes how management is organized to oversee cybersecurity and related risks through the ISSC, including its membership and responsibilities. Although it mentions oversight activities, the central focus is the management-level committee structure rather than the underlying cybersecurity processes.


reasoning: The paragraph primarily describes the oversight chain for cybersecurity risk information flowing from management to the Board, which makes it a board-governance disclosure. It does not provide qualifying specific facts such as named cyber roles, non-generic committees, dates, frameworks, vendors, products, or verifiable numbers.


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 materiality/business-impact assessment. The remaining language is largely cautionary and cross-referential rather than describing governance, management structure, or specific cybersecurity processes.


reasoning: Although the paragraph mentions management responsibility, its primary purpose is to describe the oversight chain for cybersecurity, including reporting up through a committee and to the board. Under the governance-chain rule, that makes Board Governance the best fit.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats have not materially affected the company to date, which makes Strategy Integration the best fit. The remaining language is high-level and includes a risk-factor cross-reference rather than substantive governance, management, or process detail.


reasoning: The paragraph primarily describes a cybersecurity program activity—having an incident response plan to address, contain, and recover from cyber incidents—so it fits Risk Management Process. It does not describe a real incident, board oversight, or management qualifications, and the language is generic rather than cybersecurity-specific or company-distinctive.


reasoning: The paragraph primarily describes what the company's cybersecurity program does: implementing controls and processes to assess, identify, and manage cybersecurity risks, including the use of outside reviewers. It is not centered on board oversight, management structure, or vendor risk, and the details remain high-level and generic rather than cybersecurity-specific enough to elevate specificity.


reasoning: The paragraph primarily states management's conclusion that cybersecurity threats and incidents have not materially affected, and are not reasonably likely to materially affect, the business, results of operations, or financial condition. That is a materiality/business-impact assessment, which falls under Strategy Integration.


reasoning: The paragraph primarily explains how management is organized to handle cybersecurity by describing the Head of IT’s reporting line, qualifications, experience, and responsibility for assessing and managing cyber risks. Although it also includes an enterprise risk management reference and a materiality conclusion, the dominant focus is management role and credentials.


reasoning: The paragraph primarily explains how management is organized to oversee cybersecurity, emphasizing that the CEO and CFO lead risk assessment, strategy review, and employee awareness efforts. Although it mentions some cybersecurity activities, the focus is on management responsibility and reporting structure rather than a detailed cybersecurity program.


reasoning: The paragraph primarily explains management’s cybersecurity organization: the CISO’s responsibilities, reporting line to the CRO, and the CISO’s qualifications. Although it mentions monitoring cybersecurity incidents, the main focus is on who is responsible and how management oversight is structured.


reasoning: The paragraph is primarily about the company's reliance on third-party vendors for technology services and potential cybersecurity support, which most directly addresses third-party cyber risk. It does not describe any specific cybersecurity practices, named vendors, or concrete requirements imposed on those third parties.


reasoning: The paragraph is primarily a regulatory/cross-reference statement noting that the company is subject to privacy laws and banking agency oversight, and directing the reader to another section. It does not describe the board, management, cybersecurity processes, third-party risk, an incident, or a materiality/strategy assessment.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from service providers, including vendor due diligence, contractual requirements, and ongoing oversight. Although it mentions outside firms assisting with security activities, the central focus is vendor-risk governance rather than the internal cybersecurity program.


reasoning: The paragraph primarily provides management's conclusion about the material impact of cybersecurity threats and incidents on the business, results of operations, financial condition, and business strategy, which fits Strategy Integration. The references to insurance and preventative measures are secondary to that materiality assessment.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from third-party service providers, especially by imposing security and breach-reporting requirements on them. Although it also mentions outside consultants assisting with risk assessment, the central focus is vendor/service-provider oversight.


reasoning: The paragraph describes the status, operational impact, and resolution timing of an actual cybersecurity incident, which squarely fits incident disclosure. It includes concrete, externally checkable facts such as named services and a specific restoration date.


reasoning: The paragraph primarily describes a real cybersecurity incident, including when it occurred, what systems were affected, and subsequent response and disclosure steps. Its focus is the nature and timeline of the event rather than general risk management or governance.


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 rather than a description of governance, management, or operational processes.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk arising from suppliers, making third-party risk the central topic. It describes supplier-focused security assessments and review of cybersecurity certifications and audit results, which reflects cybersecurity-specific practice but no firm-unique or externally verifiable fact.


reasoning: The paragraph primarily describes what the company's cybersecurity program is based on and how it approaches identifying and managing cyber risk, which is a risk management process topic. Although it names recognized cybersecurity frameworks, those references are not unique to the company or externally verifiable firm-specific claims.


reasoning: The paragraph primarily states management’s conclusion that known cybersecurity risks are not reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition, which is a materiality assessment. It does not provide substantive detail about governance, management structure, or cybersecurity processes.