fact: CISO (cybersecurity leadership role at VP level or above)

fact: over 20 years of information technology and cybersecurity experience

fact: technical degree in computer science from an accredited public university

fact: team comprises security engineers, detection specialists, and business cybersecurity experts

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, detailing the CISO's leadership, specific qualifications (20+ years experience, computer science degree), team composition, and reporting lines to the CEO. Specificity reaches Level 4 due to externally verifiable claims about the CISO's years of experience and educational credentials.


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: The paragraph provides biographical and role information about the Chief Human Resources Officer (Adrian J. Holt) and his HR-related responsibilities, with no mention of cybersecurity, information security, or IT oversight. As non-cybersecurity content, it is classified as None/Other with Generic Boilerplate specificity.

provider: moonshotai

stage: benchmark


content_category: Incident Disclosure

fact: February 21, 2024 (date of Change Healthcare incident notification)

fact: Change Healthcare (named third-party firm)

fact: UnitedHealth Group (named parent company)

fact: February 28, 2024 (status assessment date)

fact: payment claims for all payors (specific business function affected)

reasoning: The paragraph primarily describes an actual cybersecurity incident involving Change Healthcare on February 21, 2024, detailing the notification timeline, response actions (severing connections, forensic investigation), and operational impact on payment claim submissions, which qualifies as Incident Disclosure. Specificity is Quantified-Verifiable due to the inclusion of specific dates (February 21, 2024 and February 28, 2024) and the named third-party entity (Change Healthcare, a subsidiary of UnitedHealth Group) involved in the incident, which are externally verifiable facts.


content_category: Risk Management Process

fact: Senior Vice President of Information Technology (SVP IT)

reasoning: The paragraph primarily describes cybersecurity activities—monitoring information systems, deploying security measures, conducting audits, and maintaining an incident response plan—which are core Risk Management Process elements. Applying the person-removal test (Rule 2) confirms RMP over MR, as substantive descriptions of the program's operations remain after removing references to the SVP IT. Specificity is Firm-Specific (Level 3) due to the identification of a specific VP-level leadership role (Senior Vice President of Information Technology) responsible for these functions.


fact: February 21, 2024 - specific date of incident notification

fact: Change Healthcare - named third-party vendor

fact: UnitedHealth Group - named parent company of third-party vendor

fact: payment claims for all payors - specific business function affected by the incident

reasoning: The paragraph primarily describes a real cybersecurity incident involving third-party vendor Change Healthcare (UnitedHealth Group) on February 21, 2024, detailing the timeline, response actions (severing business connections, conducting forensics), and operational impact on claims submission, fitting Incident Disclosure. Specificity is Level 4 due to the verifiable specific date, named third-party entities, and precise scope of the affected payment processing function.


fact: In 2021 (specific year of ransomware attack)

fact: ransomware (specific threat type)

fact: began work on IT initiatives earlier than originally planned (firm-specific timing change)

reasoning: The paragraph primarily describes an actual historical cybersecurity incident (ransomware attack in 2021), including its timing, nature, and impact, making it Incident Disclosure. The specific year 2021 constitutes a quantified, externally verifiable fact tied to a real event, supporting Level 4 specificity.


content_category: Management Role

fact: CRO, CIO, and CISO each have over 15 years experience in managing cybersecurity

fact: CRO has more than 30 years of experience

fact: CRO is a member of RGA's Executive Committee

fact: CIO is a member of RGA's Executive Committee

fact: CRO served as the Company's Global Chief Risk Officer

fact: CISO oversees the Company's global security and privacy teams

fact: CISO responsible for implementing the Company's cybersecurity risk management strategy

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by detailing the roles, responsibilities, qualifications, and reporting structure (Executive Committee membership) of the CRO, CIO, and CISO. Specificity reaches Level 4 due to quantified experience claims ('over 15 years,' 'more than 30 years') that set verifiable thresholds for external validation.


fact: June 21, 2023 (incident detection date)

fact: June 22, 2023 (email notification date)

fact: August 2023 (mail notification date)

fact: 429,252 customers affected

fact: MOVEit filesharing software

reasoning: Paragraph provides a detailed narrative of an actual cybersecurity incident (MOVEit vulnerability via vendor), including specific timeline (June 21-22, 2023), precise scope (429,252 customers), data types compromised, and remediation actions. Specificity is driven by externally verifiable hard numbers (429,252), specific dates, and named software product (MOVEit).


content_category: Third-Party Risk

fact: The ISP (Information Security Program) - named internal program with distinguishing identifier

reasoning: The paragraph centrally addresses how third-party cyber risks are managed through a vendor due diligence process, fitting the Third-Party Risk category under Rule 3 (vendor oversight as central topic). Specificity is Firm-Specific because the reference to 'The ISP' identifies the company's specific Information Security Program, distinguishing it from generic vendor risk disclosures; no quantified or externally verifiable facts are present.


fact: third party security risk assessment

fact: information assets

fact: cybersecurity threats

fact: continuously monitors and addresses cybersecurity threats and incidents at third-party service providers

specificity_confidence: medium

reasoning: The paragraph centrally addresses vendor cybersecurity oversight, including due diligence, risk assessments, and continuous monitoring of third-party threats, which falls under Third-Party Risk. It demonstrates domain expertise (Level 2) through cybersecurity-specific terminology like 'information assets,' 'cybersecurity threats,' and describing continuous monitoring of vendor environments—language that reflects cybersecurity operational knowledge beyond generic enterprise risk management.


fact: managed services agreement for incident response

fact: comprehensive cybersecurity assessment

fact: cyber maturity and readiness

fact: firewall maintenance and upgrade initiatives

reasoning: The paragraph describes specific cybersecurity program activities involving the engagement of external service providers for incident response, assessments, and infrastructure maintenance, which falls under Risk Management Process (Rule 3: third parties hired to serve the company). Specificity is Domain-Adapted due to cybersecurity domain terminology like 'firewall maintenance,' 'incident response,' and 'cyber maturity' that would not naturally appear in general ERM discourse, with no firm-specific roles, named vendors, or quantifiable details present.


content_category: Board Governance

reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the Audit Committee's oversight role and the specific governance chain for incident escalation. The mention of a 'Cybersecurity Sub-Committee of the Board of Directors' constitutes a firm-specific organizational detail that distinguishes this company's governance structure from generic board oversight descriptions.


fact: CompTIA certifications

fact: Head of Global IT (cybersecurity leadership role)

fact: IT Security Team (specific team designation)

fact: PCI, SOC1 and SOC2 level compliance experience

reasoning: The paragraph primarily describes the organizational structure, reporting lines, and qualifications of the Head of Global IT and IT Security Team, fitting Management Role. Specificity is driven by the quantified, verifiable claim of 'over 20 years of combined infrastructure architecture experience' and the naming of specific certification bodies (CompTIA), which constitute hard facts that could be independently verified.


fact: July 2018 (specific date of ransomware incident)

fact: Dx information technology systems (firm-specific business segment systems)

fact: ransomware (specific threat type)

reasoning: The paragraph primarily answers what happened in a specific cybersecurity incident, describing the July 2018 ransomware attack, affected systems, and investigation results, making it Incident Disclosure. Specificity is Level 4 because the paragraph contains the verifiable date 'July 2018' tied to a real event, along with firm-specific references to 'Dx' (Diagnostics) systems and the domain-specific threat type 'ransomware'.


reasoning: The paragraph primarily describes the oversight structure for cybersecurity, including the Board of Directors, audit committee, and disclosure committee responsibilities, which falls under Board Governance. The language consists entirely of generic governance terms (e.g., 'risk oversight,' 'IT governance,' 'data security') that any ERM professional would use, with no domain-specific cybersecurity practices, firm-specific details, or verifiable facts present.


fact: May 14, 2019 (specific date of incident notification)

fact: Retrieval-Masters Credit Bureau, Inc. d/b/a/ American Medical Collections Agency (AMCA) (named third-party firm)

fact: Note 15 Commitments and Contingencies (specific financial statement reference)

reasoning: Paragraph describes an actual cybersecurity incident (the AMCA Incident) including specific timing (May 14, 2019) and the named third party involved, making it Incident Disclosure. Specificity is Level 4 due to the verifiable date, named external agency, and specific reference to Note 15 in the financial statements.


fact: appointed to the role in March 2022

fact: CIO reports to the CFO

fact: CIO is peer to the CSO

fact: nearly 20 years of experience in managing IT functions

reasoning: Paragraph describes management reporting structure (CIO peer to CSO, both reporting to CFO) and specific qualifications of the incumbent CIO, fitting Management Role. The specific appointment date 'March 2022' constitutes an externally verifiable fact, establishing Level 4 specificity despite the approximate 'nearly 20 years' experience claim.


fact: ISC (Information Security Committee) - named non-generic committee

fact: CIO - cybersecurity leadership role at VP level or above

fact: Director of IT Security, Risk and Compliance - Director-level title with security qualifier

fact: combined 20 years of risk management experience - quantified experience claim

reasoning: The paragraph describes the composition of the Information Security Committee (ISC) and the qualifications of its management members (CIO and Director of IT Security, Risk and Compliance), including their specific areas of expertise and tenure, which falls under Management Role. The 'combined 20 years of experience' constitutes a quantified, externally verifiable claim (Level 4), supported by firm-specific titles and committee names.


content_category: Strategy Integration

reasoning: The paragraph makes a backward-looking materiality assessment stating that the company has not experienced material cybersecurity incidents, which falls under Strategy Integration per Rule 5 (negative assertion about material impact). It contains no verifiable facts (negative assertions about absence of incidents are explicitly excluded from Level 4), no firm-specific details (no roles, committees, or organizational specifics), and no domain terminology beyond generic references to 'cybersecurity incidents,' resulting in Generic Boilerplate specificity.


reasoning: The paragraph contains a negative materiality assertion regarding past cybersecurity incidents ('we have not experienced any material adverse events related to a security breach or cyber-attack'), which per Rule 5 qualifies as Strategy Integration. However, it lacks specific cybersecurity domain terminology, firm-unique organizational details, or quantifiable facts, consisting entirely of generic risk disclosure language about IT system dependencies and potential operational impacts.


reasoning: The paragraph provides only generic value statements about protecting data and broadly distributed responsibility ('From the Board...to our Customer Service Representatives') without describing specific board oversight mechanisms, management structures, risk processes, or incident details that would answer any of the six substantive questions. It contains no domain-specific terminology beyond basic references to 'confidentiality, integrity, and availability' used in a boilerplate manner, no firm-specific organizational details, and no quantifiable or verifiable claims.


fact: On October 11, 2023 (specific date of cybersecurity incident)

fact: disruption of our business operations for approximately three days

fact: restore our operations within three days

fact: fulfill our backlog of orders caused by the operational disruption within one week

reasoning: The paragraph primarily answers what happened in a specific cybersecurity incident, providing the exact date (October 11, 2023), nature of unauthorized activity, remediation steps, and resolution timeline. Specificity reaches Level 4 due to externally verifiable claims including the specific incident date and quantified durations for business disruption (approximately three days), operational restoration (within three days), and backlog clearance (within one week).


fact: penetration testing

fact: security posture

fact: unauthorized access

reasoning: The paragraph centrally addresses vendor risk management, describing oversight of third-party service providers through security assessments, monitoring programs, and contractual requirements. Specificity is driven by cybersecurity domain expertise demonstrated through terms like 'penetration testing,' 'security posture,' and 'unauthorized access,' which reflect technical knowledge beyond generic risk management language.


reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business, including a backward-looking negative materiality assertion ('has not identified any cybersecurity threats that have materially affected operations') that falls under Strategy Integration per Rule 5. While it references an 'Incident Response Team,' this term fails the ERM test (similar to 'incident response plan' which is explicitly listed as Level 1 generic language) and the description lacks firm-specific details such as named departments, team size, or leadership titles. The paragraph contains no quantified metrics, dates, certifications, or other externally verifiable claims.


reasoning: The paragraph contains the negative assertion 'we have not experienced any recent material cybersecurity incidents' and forward-looking materiality language regarding potential future impacts on 'business strategy, results of operations, or financial condition,' which per Rule 5 constitutes a Strategy Integration assessment. Specificity is Generic Boilerplate (Level 1) because the paragraph contains only vague temporal references ('recent'), generic disclaimers, and cross-references without any domain-specific terminology, firm-unique organizational details, or quantifiable/verifiable facts.


fact: RCSC (Risk and Compliance Steering Committee)

fact: CISO (Chief Information Security Officer)

category_confidence: medium

reasoning: Paragraph describes management oversight structure, specifically that the CISO provides quarterly updates to the RCSC committee on cybersecurity matters, establishing reporting lines between management roles. Contains firm-specific facts including the named RCSC committee and the CISO leadership position, which is a VP-level or above cybersecurity role.


fact: Director - Information Systems is identified as the Company's chief information officer (CIO)

reasoning: The paragraph describes Board oversight of cybersecurity risk supported by the Audit and Compliance Committee and details the information flow between the Committee and senior management. The identification of the specific executive role (CIO) as the 'Director - Information Systems' constitutes a firm-specific fact (Level 3), as CIO is a VP-level or above cybersecurity leadership position.


fact: Chief Technology Officer

fact: Chief Risk Officer

fact: Technology Leadership Centre

fact: Controlling Department

fact: IT and cybersecurity teams at subsidiaries

fact: corporate and subsidiary risk teams

reasoning: The paragraph describes a three-lines-of-defense governance structure explicitly framed as oversight architecture, placing board committees (Risk Committee, Audit Committee) within the governance chain alongside management roles. Specificity is Firm-Specific due to multiple VP-level+ leadership titles (CTO, CRO) and distinct organizational unit names (Technology Leadership Centre, Controlling Department) that identify this company's unique governance structure.


fact: Enterprise Risk Management Committee (ERM Committee)

fact: SOC1 reports

reasoning: The paragraph primarily answers what the cybersecurity program does by describing risk assessment processes, the flow of risk identification through oversight committees, and specific third-party oversight activities including SOC1 report reviews. While it mentions the ERM Committee and its reporting relationship to the Audit Committee, applying the person-removal test leaves substantive descriptions of risk management activities (assessing, identifying, and managing risks; reviewing third-party SOC1 reports), confirming RMP as the primary category. Specificity is Firm-Specific due to the named Enterprise Risk Management Committee (a non-generic committee designation) and the domain-specific reference to SOC1 audit standards.


reasoning: The paragraph describes the company's cybersecurity processes, policies, and monitoring activities, fitting the Risk Management Process category. The language consists entirely of generic governance terms (disaster recovery, incident response, access control) that fail the ERM test for domain expertise, with no firm-specific details or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a pure cross-reference to Item 1A Risk Factors, stating that materiality assessments are 'incorporated by reference' rather than describing any actual cybersecurity governance, processes, or assessments. As a structural pointer with no substantive cybersecurity content, it falls under None/Other and receives Generic Boilerplate specificity.


reasoning: The paragraph exclusively addresses vendor cybersecurity oversight through annual evaluations, contractual safeguards, and integration into incident response, fitting the Third-Party Risk category. The terminology (e.g., 'evaluate policies,' 'contractual safeguards,' 'internal control reports') represents generic risk management language that an ERM professional would use for any vendor risk type, with no domain-specific cybersecurity practices, firm-unique organizational details, or quantifiable metrics present.


reasoning: The paragraph contains a backward-looking materiality assessment ('we have not experienced a cybersecurity threat or incident that resulted in a material adverse impact'), which per Rule 5 classifies as Strategy Integration. However, the text contains no firm-specific details (no roles, committees, or organizational specifics), no quantified data, and no domain-adapted cybersecurity practices—only generic risk speculation about potential future impacts, making it Generic Boilerplate.


reasoning: The paragraph describes the Board's retention of cybersecurity oversight responsibility and the information flow from management to the Board, which is a classic governance-chain description falling under Board Governance. For specificity, the paragraph contains only generic governance language (Board, ERM program, management, regularly scheduled meetings) with no domain-specific cybersecurity terms, named roles/committees, or verifiable facts, resulting in Level 1.


fact: System Organization and Control Reports (SOC Reports)

fact: pre-acquisition diligence

fact: imposition of contractual obligations

reasoning: The paragraph centrally addresses vendor risk management by describing specific oversight mechanisms for third-party technology providers, including obtaining SOC Reports, conducting pre-acquisition diligence, and imposing contractual security obligations. Specificity is Domain-Adapted due to the use of cybersecurity vendor risk management terminology (SOC Reports, pre-acquisition diligence) that demonstrates specialized domain knowledge beyond generic risk management language, without providing firm-specific program details or quantifiable metrics.


fact: offered identity protection services including credit monitoring for two years (specific quantified duration)

fact: credit monitoring (domain-specific incident response practice)

fact: all current and former customers (firm-specific remediation scope)

reasoning: The paragraph describes ongoing response to an actual incident through engagement with law enforcement and remediation efforts (credit monitoring), fitting Incident Disclosure. Specificity is Quantified-Verifiable due to the hard number 'two years' specifying the service duration, alongside domain-specific terminology (credit monitoring) and firm-specific scope (all current and former customers).


fact: February 16, 2022 - specific date of cybersecurity intrusion

reasoning: The paragraph primarily answers 'What happened?' by describing an actual cybersecurity intrusion that occurred on February 16, 2022, including detection, network disruption, and response efforts involving third-party experts, which is classic Incident Disclosure content. The specificity reaches Level 4 because the paragraph contains the externally verifiable hard date of the incident (February 16, 2022), which is a concrete fact tied to a real event.


fact: Chief Information Security Officer

fact: Trust, Security and Reliability department

fact: Cybersecurity Risk Management Team

reasoning: The paragraph answers how management is organized to handle cybersecurity by identifying the CISO, the specific department they oversee (Trust, Security and Reliability), and the Cybersecurity Risk Management Team. Under the person-removal test, removing these role and organizational identifiers collapses the paragraph to a generic statement that processes are maintained by management. Specificity is Firm-Specific due to the named executive-level role (CISO) and the specific department and team names that distinguish Confluent's organizational structure.


reasoning: The paragraph centrally addresses vendor oversight through a Third Party Risk Management program, describing due diligence requirements and monitoring of suppliers, which falls under Third-Party Risk per Rule 3. Specificity remains at Level 1 because the language consists of generic process descriptions ('cybersecurity due diligence reviews,' 'periodic reviews') that any ERM professional could write without cybersecurity domain expertise, and contains no firm-specific organizational details (e.g., named committees, specific team structures) or verifiable facts (e.g., dates, numbers, named certifications) that would elevate it to Level 2, 3, or 4.


fact: 21st Century Security vision

fact: ransomware

fact: denial-of-service

fact: nation state actors

fact: defense industrial base

reasoning: The paragraph primarily answers how cybersecurity affects business strategy by linking it to Lockheed Martin's specific '21st Century Security vision' and digital transformation, while assessing potential material impacts on operations and results. Specificity reaches Firm-Specific due to the named strategic initiative '21st Century Security vision' (a distinguishing internal program) and domain-adapted terminology including specific threat types like ransomware and nation state actors.


fact: threat intelligence services

reasoning: The paragraph primarily answers how third-party cyber risks are managed, describing the Third-Party Risk Management program and requirements imposed on vendors handling material information. Specificity is Domain-Adapted because 'threat intelligence services' is cybersecurity domain terminology that would not naturally be used by a non-security enterprise risk management professional.


reasoning: The paragraph provides backward-looking ('not aware of any cybersecurity incidents that have materially affected') and forward-looking ('do not believe it to be reasonably likely... that a cybersecurity threat will materially impact') materiality assessments regarding cybersecurity effects on business strategy and financial condition, which falls squarely under Strategy Integration per Rule 5. The text contains no firm-specific details, quantified verifiable metrics, or domain-specific terminology that would pass the ERM test; the date 'January 1, 2021' merely anchors a negative self-assertion about the absence of incidents, which is not externally verifiable, resulting in Generic Boilerplate specificity.


reasoning: The paragraph broadly describes the existence of systems and programs to mitigate cybersecurity incidents and the need for continual monitoring, which answers what the cybersecurity program does (Risk Management Process). However, the language is entirely generic—terms like 'systems,' 'programs,' and 'monitor' could apply to any enterprise risk function and do not demonstrate cybersecurity domain expertise, nor are there any firm-specific details or verifiable facts.


reasoning: The paragraph primarily answers whether cybersecurity affects the business by providing the required SEC materiality assessment (backward-looking 'have not materially affected' and forward-looking 'not reasonably likely to materially affect'), placing it in Strategy Integration. Specificity is Generic Boilerplate as the text contains only standard compliance language and generic threat descriptions without domain-specific practices, firm-specific organizational details, or verifiable data points.


fact: Chief Risk Officer (dedicated senior leadership role)

reasoning: The paragraph answers how management is organized by identifying a specific senior executive role (Chief Risk Officer) responsible for risk oversight, which is a firm-specific organizational detail qualifying as Level 3. It describes the role's existence and general function rather than specific board governance or program activities, placing it in Management Role under the person-removal test (removing the CRO role collapses the content).


reasoning: The paragraph describes information flow regarding cybersecurity from the Audit Committee and management to the full Board, directly answering how the board oversees cybersecurity (Board Governance). It employs generic governance language ('reports to,' 'receives briefings') that would apply to any oversight topic and contains no specific cybersecurity practices, firm-unique details, or verifiable facts, resulting in Generic Boilerplate specificity.


fact: CSO (Chief Security Officer) role oversees cybersecurity risk management program

fact: Chief Information Officer receives regular briefings from CSO on cybersecurity risks

fact: CSO informs senior management team of cybersecurity risks and incidents

reasoning: The paragraph describes management reporting lines and information flows between specific senior leadership positions (CSO and CIO), fitting the Management Role category. Specificity is Firm-Specific because it identifies distinct VP-level roles (CSO, CIO) and their specific reporting relationships regarding cybersecurity, which distinguishes this company's organizational structure from others.


fact: FFIEC framework

fact: NIST guidance and best practices

fact: confidentiality, integrity, and availability

reasoning: The paragraph primarily answers what the cybersecurity program does by describing its design based on specific industry frameworks (FFIEC, NIST) and mentioning risk mitigation controls. Specificity is Domain-Adapted because it references named cybersecurity standards (FFIEC, NIST) and domain-specific concepts (confidentiality, integrity, availability) that demonstrate expertise beyond generic risk management language.


fact: National Institute of Standards and Technology Cybersecurity Framework

fact: Center for Internet Security – Top 18 Critical Security Controls

fact: phishing tests

fact: cybersecurity tabletop exercises

fact: employee information security assessments

reasoning: The paragraph comprehensively describes the company's cybersecurity program activities, including framework adoption (NIST CSF, CIS Top 18), threat prevention measures, and training protocols, which directly answers what the program does (RMP). Specificity is Domain-Adapted because it cites recognized cybersecurity frameworks and specific practices like phishing tests and tabletop exercises that demonstrate domain expertise beyond generic risk management language, but lacks firm-specific details such as leadership titles, team compositions, or verifiable metrics.


fact: endpoint detection and response systems

fact: intrusion prevention

fact: vulnerability assessments

fact: cybersecurity threat intelligence

reasoning: The paragraph describes technical security controls and monitoring activities (firewalls, EDR, IPS, vulnerability assessments, threat intelligence), which are core risk management processes. Specificity is Domain-Adapted because terms like 'endpoint detection and response,' 'intrusion prevention,' and 'threat intelligence' demonstrate cybersecurity domain expertise that would not naturally appear in generic enterprise risk management language.


reasoning: The paragraph centrally addresses vendor risk management, describing policies and processes for assessing IT vendors and service providers, which falls under Third-Party Risk. The language consists of generic process descriptions (pre-onboarding assessments, annual re-assessments, tracking remediation) that any ERM professional could use for non-cyber risks, lacking specific domain expertise indicators, firm-unique details, or verifiable facts.


fact: CISO has 27 years of cybersecurity experience

fact: 17 of which are in the oil and gas industry

fact: CISO is one of less than 400 CISOs globally that has graduated from the FBI's CISO Academy in Quantico, Virginia

reasoning: The paragraph describes the management organizational structure for cybersecurity, including the CISO and CIO roles, reporting lines, team composition, and specific qualifications of the CISO, fitting the Management Role category. Specificity is Quantified-Verifiable due to the precise, externally verifiable claims regarding the CISO's years of experience (27 total, 17 in oil and gas) and graduation from the FBI's CISO Academy.


fact: Information Technology Automated Solutions (ITAS) - specific organizational unit responsible for vendor audits

reasoning: The paragraph centrally addresses how Alcoa manages cybersecurity risks from third-party service providers through pre-engagement security assessments, contractual audit rights, and post-engagement validation of certifications, making Third-Party Risk the appropriate category. Specificity is Firm-Specific due to the identification of the 'Information Technology Automated Solutions (ITAS)' organizational unit as the specific department conducting vendor audits.


reasoning: This paragraph contains only forward-looking speculation about potential future incidents ('could have a material adverse effect') and a cross-reference to Risk Factors (Item 1A), with no substantive description of actual cybersecurity governance, management, processes, or incidents. As it lacks any specific facts, domain terminology, or verifiable claims, it is classified as None/Other with Generic Boilerplate specificity.


fact: CISO has more than 20 years of experience in cybersecurity and information technology

fact: CISO holds a Master's degree in Business Administration with a focus on Information Technology

fact: CISO holds a Certified Information Security Manager (CISM) certification

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the CISO's qualifications, reporting structure (to SVP – Enterprise Risk Officer, then CEO), and specific credentials. Specificity is Quantified-Verifiable due to externally verifiable claims regarding the CISO's years of experience, academic degree, and professional certification.


fact: threat landscape

fact: information theft

fact: destruction

fact: inaccessibility

fact: unauthorized disclosure

fact: extortion

reasoning: The paragraph primarily answers whether cybersecurity has affected the business through the backward-looking materiality assessment required by SEC Item 106(b)(2) ('do not believe we have...experienced a cybersecurity incident that materially affected'), which Rule 5 explicitly classifies as Strategy Integration. Specificity is Domain-Adapted because the paragraph employs cybersecurity domain expertise including 'threat landscape,' 'information theft,' 'destruction,' 'inaccessibility,' and 'extortion'—terms that fail the ERM test and demonstrate specialized security knowledge beyond generic risk management language.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third parties, fitting the Third-Party Risk category. The description uses generic enterprise risk management terminology ('risk-based approach,' 'identifying and overseeing risks') that would apply equally to financial or operational risk, failing the ERM test for domain-adapted content, and contains no firm-specific details or verifiable facts.


reasoning: The paragraph primarily describes the establishment, composition, and reporting structure of a management-level committee (Cyber ERM), fitting Management Role under Rule 1 and Rule 2. Specificity is Firm-Specific (Level 3) due to the named non-generic committee 'Cyber ERM (Enterprise Risk Management) Committee,' which distinguishes this company's organizational structure; remaining content uses generic governance and process terms.


fact: security questionnaires

fact: review of vendor security programs

fact: review of available security assessments, reports, and audits

fact: tiered assessment levels based on service nature, data sensitivity, and provider type

fact: contractual obligations related to cybersecurity imposed on providers

reasoning: The paragraph centrally addresses vendor oversight and supply chain risk management, describing how cybersecurity requirements are imposed on third parties. Specificity is Domain-Adapted because the description includes cybersecurity-specific vendor risk management practices—such as security questionnaires, review of vendor security programs, and tiered assessments based on data sensitivity—that demonstrate specialized domain knowledge beyond generic enterprise risk management language.


reasoning: The paragraph centers on vendor cybersecurity oversight, describing due diligence processes, contractual security requirements, and incident notification procedures for third-party service providers. The language employs generic risk management terminology ('due diligence,' 'risk-based approach,' 'appropriate security controls') that would be natural for any enterprise risk management professional and lacks specific cybersecurity domain expertise, firm-unique organizational details, or quantifiable facts.


fact: Chief Information Security Officer (CISO)

fact: Executive Vice President and Chief Information Officer (CIO)

reasoning: The paragraph primarily describes the company's processes for assessing, identifying, and managing cybersecurity risks through its enterprise information security program, which falls under Risk Management Process. Specificity reaches Firm-Specific (Level 3) because it identifies the precise executive-level roles (CISO and EVP/CIO) responsible for maintaining and overseeing the program, distinguishing the company's organizational structure from generic disclosures.


fact: CSO (Chief Security Officer)

fact: Global Security Organization

fact: ERM Steering Committee

reasoning: Paragraph primarily answers how the board oversees cybersecurity by describing the governance chain from the Risk Committee of the Board through the ERM Steering Committee to the Global Security Organization. Specificity is Firm-Specific due to identification of distinct organizational elements including the CSO leadership role, the Global Security Organization unit, and the ERM Steering Committee.


fact: August 2023 incident date (specific timeframe for actual cybersecurity incident)

reasoning: The paragraph primarily answers whether cybersecurity incidents have materially affected the business, explicitly stating that prior incidents 'have not materially affected us' and warning that future incidents 'could materially affect us,' which per Rule 5 constitutes a materiality assessment (Strategy Integration). Specificity is Quantified-Verifiable because the paragraph cites the specific month and year (August 2023) of an actual incident, providing a concrete, externally verifiable timeframe.


fact: Vice President of IT & Digitization

reasoning: The paragraph describes management's organizational structure for cybersecurity, identifying the specific leadership role (Vice President of IT & Digitization) and IT Team responsible for oversight, along with their qualifications and experience. The specific VP-level title with IT portfolio constitutes a firm-specific fact (Level 3), distinguishing this company's structure from generic descriptions.


fact: Chief Information Security Officer (CISO) - cybersecurity leadership role at VP level or above

reasoning: The paragraph centrally answers how third-party cyber risks are managed through pre-engagement assessments and ongoing monitoring, making Third-Party Risk the appropriate category. Specificity reaches Firm-Specific due to the identification of the 'Chief Information Security Officer' (CISO), which is a firm-specific cybersecurity leadership role at VP level or above that distinguishes this company's organizational structure.


fact: February 13, 2023 (specific date of security breach disclosure)

reasoning: The paragraph primarily answers what happened in a specific cybersecurity incident disclosed on February 13, 2023, involving a third-party vendor's secure file transfer platform, fitting Incident Disclosure. The inclusion of the specific disclosure date constitutes an externally verifiable fact, establishing Quantified-Verifiable specificity.


fact: February 16, 2022 - specific date of cybersecurity intrusion

reasoning: The paragraph primarily describes an actual cybersecurity incident that occurred on February 16, 2022, including the detection, network disruption scope, and response efforts involving third-party experts, which answers 'What happened in a cybersecurity incident?' The specific date tied to a real event provides a verifiable fact (Level 4).


reasoning: The paragraph centrally addresses how third-party cyber risks are managed (vendor oversight), fitting the Third-Party Risk category. It contains only generic ERM language ('risk-based approach', 'identifying and overseeing risks') that could apply to any risk type without demonstrating cybersecurity domain expertise, and lacks any firm-specific details (e.g., specific adviser name, committee names, team structure) or quantifiable/verifiable facts.


fact: ransomware

fact: malware

fact: phishing attempts

reasoning: The paragraph primarily constitutes a Strategy Integration disclosure by stating the negative materiality assessment that no material cybersecurity incidents occurred as of December 31, 2023, and mentioning the company's cyber insurance coverage. Specificity is Domain-Adapted because the text enumerates specific cyber threat types (ransomware, malware, phishing) that demonstrate cybersecurity domain expertise beyond generic risk management language, even though the underlying processes described remain high-level.


fact: Age 51

fact: Joined the Company in December 1992

fact: Appointed Vice President and General Manager, Performance Films in July 2012

fact: Appointed for both Performance Films and Advance Interlayers in April 2018

fact: Appointed Senior Vice President with responsibility for the AFP segment effective October 2022

fact: Appointed to current position effective January 2025

reasoning: Classified as Management Role because the paragraph details the career history, qualifications, and specific responsibilities of a VP-level executive (Travis Smith) within the Item 1C cybersecurity disclosure, indicating his role in management's cybersecurity oversight structure. Specificity is Quantified-Verifiable due to multiple externally checkable facts including the executive's age (51) and precise appointment dates (December 1992, July 2012, April 2018, October 2022, and January 2025).


fact: CIO has more than 30 years of experience

fact: CISO has more than 20 years of cybersecurity experience

fact: CISO holds Certified Information Systems Auditor (CISA) certification

fact: CISO holds Certified Information Security Manager (CISM) certification

fact: CISO holds Certified Information Systems Security Professional (CISSP) certification

fact: CIO's prior business and technology leadership roles at Aegon N.V., Citigroup, Inc. and JP Morgan Chase & Company

fact: CISO's prior role as Senior Vice President, Chief Information Security Officer at Brighthouse Financial

fact: CISO's prior role as Technology Vice President & Chief Information Security Officer for GE Healthcare

fact: CISO started career at Allstate Insurance Company

reasoning: The paragraph focuses entirely on the qualifications, career history, and credentials of the CIO and CISO, making it Management Role. Specificity is Quantified-Verifiable due to specific experience thresholds (more than 30 years, more than 20 years) and named professional certifications (CISA, CISM, CISSP) that are externally verifiable through certification bodies, plus verifiable employment history at named firms.


fact: ransomware

fact: state-sponsored cyber attacks

fact: exploitation in software or code with malicious intent

fact: generative AI

fact: testing of cybersecurity incident response plan

reasoning: The paragraph describes specific cybersecurity program activities (controls, preventative actions, and testing of the incident response plan), which answers what the risk management process does, even though embedded in risk context. Specificity is Domain-Adapted due to explicit mention of distinct threat types (ransomware, state-sponsored attacks, generative AI) and attack vectors that demonstrate cybersecurity domain expertise beyond generic risk management language.


reasoning: The paragraph describes how cybersecurity risks are included in the enterprise risk management (ERM) process and how risk-based audit plans are developed, which answers what the risk management process does. It contains no domain-specific cybersecurity terminology (only generic ERM and audit terms), no firm-specific organizational details beyond standard reporting lines, and no quantifiable or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph contains only generic forward-looking speculation about potential cyber risks and the importance of security to business success, without describing any actual governance structures, management organization, risk management processes, or specific cybersecurity measures. Per Rule 6, this lacks substantive cybersecurity disclosure and falls under None/Other, which by definition receives Generic Boilerplate specificity.


fact: prioritization guidelines

fact: data collection and evidence handling

fact: law enforcement engagement

fact: evaluate security incidents on a scale of severity

reasoning: The paragraph describes the company's incident response procedures and severity evaluation protocols, which are core risk management activities. It achieves Domain-Adapted specificity through cybersecurity-specific terminology like 'evidence handling' and 'law enforcement engagement' that demonstrate specialized incident response knowledge beyond generic risk management language, though it lacks firm-specific details (named roles, team size) or verifiable metrics.


reasoning: This paragraph is purely a cross-reference directing readers to Item 1A Risk Factors for additional information, containing no substantive disclosure about governance structures, management roles, or cybersecurity processes. As a navigational pointer with no domain-specific terminology, firm-unique details, or verifiable data points, it falls under None/Other with Generic Boilerplate specificity.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers, including contractual obligations and security assessments of vendors, which falls squarely under Third-Party Risk. For specificity, the language describes a generic vendor management process ('reviewing cybersecurity practices,' 'conducting security assessments') that any ERM professional could write about non-cyber risks; it lacks specific cybersecurity domain expertise (e.g., SOC 2, penetration testing), firm-unique details (e.g., named roles, specific team structures), or verifiable facts (e.g., numbers, dates, named tools), resulting in Generic Boilerplate classification.


reasoning: The paragraph describes the Board and Audit Committee's oversight structure, specifically how they receive regular reports and incident updates from management, which directly answers how the board oversees cybersecurity. The language consists entirely of generic governance terminology ('regular reports', 'management updates') that could apply to any risk area and contains no domain-specific practices, firm-unique organizational details, or quantifiable facts.


reasoning: The paragraph describes risk assessment activities (identifying threats, evaluating likelihood/damage, assessing safeguards) which fall under Risk Management Process. However, the language consists of generic enterprise risk management terminology ('risk assessments,' 'identification of risks,' 'policies and procedures') that could apply to financial or operational risks and lacks specific cybersecurity domain expertise, firm-unique details, or verifiable facts.


reasoning: This paragraph is purely a cross-reference to Item 1A Risk Factors and contains no substantive cybersecurity disclosure regarding governance, management, processes, or incidents. As a forward-looking pointer with no actual cybersecurity measures described, it falls under None/Other and receives Generic Boilerplate specificity.


fact: critical vendors

fact: data security incident including loss, compromise, unauthorized use, access, or disclosure

reasoning: The paragraph centers on contractual cybersecurity requirements imposed on the Custodian and its critical vendors, including specific incident notification obligations to MetLife, Inc., which falls squarely under Third-Party Risk management. Specificity is Domain-Adapted because the text employs cybersecurity-specific incident terminology (loss, compromise, unauthorized use, access, or disclosure) and distinguishes 'critical vendors' as a risk management category, demonstrating domain expertise beyond generic risk management language, though it lacks firm-specific details like named vendors or quantifiable metrics.


reasoning: Paragraph describes the Board's ultimate oversight responsibility for risk management and delegation to standing committees and senior management, which in Item 1C context constitutes governance structure for cybersecurity oversight. However, the language contains only generic risk management terms ('enterprise risk', 'risk exposure', 'standing committees') with no named committees, specific titles, cybersecurity domain terminology, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: This paragraph provides generic introductory context about technology reliance and associated security risks without describing any actual cybersecurity governance structures, management organization, risk management processes, or incidents. It contains no domain-specific cybersecurity terminology, firm-specific organizational details, or quantifiable facts that would elevate it above boilerplate language applicable to any technology-dependent company.


fact: Chief Information Officer (CIO) provides updates to the board on cybersecurity

fact: Executive Director of Information Security provides updates to the board on cybersecurity

reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the audit and risk committee's specific oversight responsibilities and the information flow from management to the board, which is classic Board Governance content. It reaches Firm-Specific specificity by identifying two distinct senior leadership roles—Chief Information Officer and Executive Director of Information Security (a director-level title with a security qualifier)—who are specifically tasked with briefing the board on security matters, distinguishing this company's governance structure from generic descriptions.


fact: Chief Operating Officer oversees cybersecurity policies and processes (C-suite role with cybersecurity portfolio)

reasoning: The paragraph identifies the Chief Operating Officer as the executive responsible for overseeing cybersecurity, which directly answers how management is organized to handle cybersecurity (MR vs. BG). The identification of a specific C-suite executive (COO) as having cybersecurity oversight responsibilities constitutes a firm-specific fact (Level 3), as it distinguishes this company's governance structure from others that might delegate this to a CISO, CTO, or CIO.


reasoning: The paragraph primarily serves as a cross-reference to Item 1A Risk Factors and contains only generic forward-looking statements about investing in cybersecurity and adapting controls. It does not substantively answer any of the six category questions (e.g., no specific governance structure, management roles, program activities, or materiality assessments are described). The language consists entirely of generic ERM terms ('internal controls,' 'processes,' 'resiliency') that fail the domain expertise test, with no firm-specific details or quantifiable facts present.


reasoning: The paragraph contains a backward-looking materiality assessment per Rule 5 ('have not materially affected our business strategy, results of operations, or financial condition to date'), making it Strategy Integration. For specificity, the paragraph contains only generic risk language and common threat references ('malware,' 'computer virus') that any business professional would use, failing the ERM test for domain expertise; there are no firm-specific details or verifiable facts.


fact: current security posture

fact: on-going cybersecurity events

reasoning: The paragraph describes the Board's oversight mechanism, including quarterly reporting and incident escalation thresholds, which clearly answers how the board oversees cybersecurity (Board Governance). While the description of reporting cadence is generic, the use of domain-specific terms such as 'security posture' and 'cybersecurity events' (rather than generic 'risks' or 'issues') demonstrates cybersecurity domain expertise sufficient for Domain-Adapted classification.


fact: self-attestation questionnaires

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers, including due diligence processes, contractual security requirements, and ongoing monitoring. The reference to 'Service Organization Controls (SOC) reports' demonstrates cybersecurity domain expertise (Level 2), as this is specific IT audit terminology an ERM professional would not naturally use, though the paragraph lacks firm-specific organizational details or verifiable quantitative claims.


fact: In early April 2023, we detected a cybersecurity incident

fact: security monitoring protocols

fact: cybersecurity experts

reasoning: The paragraph describes an actual cybersecurity incident detected in early April 2023 and the subsequent response actions (investigation, law enforcement engagement, security enhancements), directly answering what happened in the incident. The specific date 'early April 2023' tied to the incident detection constitutes a verifiable fact, establishing Level 4 specificity.


reasoning: The paragraph describes the board's oversight of cybersecurity risks and delegation of oversight responsibility to the audit committee, which is classic Board Governance content. For specificity, the language consists of generic risk management phrases ('prevention, timely detection and mitigation,' 'risk oversight function') that pass the ERM test—any enterprise risk professional could use this language for non-cyber risks. It lacks domain-specific cybersecurity practices, firm-specific governance structures (e.g., the audit committee is a generic committee common to all public companies), or quantifiable facts.


fact: vulnerability scans

fact: security questionnaires

fact: contractual obligations related to cybersecurity

fact: Information Systems and Data

reasoning: The paragraph centrally addresses how third-party cyber risks are managed, describing vendor assessment processes (security questionnaires, vulnerability scans) and contractual security requirements, which falls under Third-Party Risk. Specificity is Domain-Adapted because it employs cybersecurity-specific practices like 'vulnerability scans' and 'security questionnaires' that demonstrate domain expertise beyond generic enterprise risk management language (failing the ERM test).


reasoning: This paragraph is a pure cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions and contains no substantive disclosure about governance, management, processes, or incidents. As a None/Other paragraph containing no domain-specific terminology, firm-specific details, or verifiable facts, it is classified as Generic Boilerplate.


reasoning: This paragraph is purely a cross-reference to Item 1A Risk Factors and contains no substantive cybersecurity disclosure regarding governance, management, processes, or incidents. As a boilerplate pointer with no specific facts, domain terminology, firm-specific details, or verifiable claims, it is classified as Generic Boilerplate.


fact: Paresh Patel (named Board member with information technology expertise)

reasoning: The paragraph describes Board oversight activities (receiving reports on risks and incidents) and identifies a specific named individual (Paresh Patel) as the board member possessing IT expertise, which is a firm-specific fact elevating it to Level 3.


reasoning: The paragraph centrally addresses how the company evaluates and manages cybersecurity risks from third-party vendors, including pre-engagement assessments and contractual confidentiality requirements, which falls under Third-Party Risk. It contains only generic descriptions of vendor oversight ('carefully evaluated,' 'appropriate controls,' 'safeguard confidential information') without domain-specific cybersecurity practices (e.g., SOC 2 reviews, penetration testing), firm-specific details (e.g., named roles, specific committees), or verifiable facts (e.g., dates, numbers, certifications), resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risks, including briefing cadence ('at least annually') and scope of discussions, which falls squarely under Board Governance. The language consists of generic risk management terms ('risk mitigation,' 'business continuity planning') that any ERM professional would use, failing the ERM test for cybersecurity domain expertise, and contains no firm-specific details or verifiable facts.


reasoning: The paragraph primarily answers whether cybersecurity has affected the business by providing the mandatory backward-looking materiality assessment that no incidents have had a material adverse effect, placing it in Strategy Integration per Rule 5. It contains no specific facts—no named individuals, organizational structures, technical domain terms (e.g., specific frameworks or tools), dates, or quantifiable metrics that would elevate it above generic boilerplate.


reasoning: This paragraph is purely a cross-reference to Item 1A Risk Factors and contains only hypothetical forward-looking speculation about potential consequences of a compromise ('could experience adverse consequences'). It does not describe actual board governance, management roles, risk management processes, third-party oversight, incidents, or strategic assessments, and thus falls under None/Other per the cross-reference rule. As a None/Other paragraph, it automatically receives Generic Boilerplate specificity.


fact: IS Steering Committee

fact: Chief Information Officer

reasoning: The paragraph centrally addresses how third-party cyber risks are managed, describing the vendor management program for outsourcing arrangements and structured assessments of service providers. Specificity is Firm-Specific due to the mention of the non-generic 'IS Steering Committee' and the C-level 'Chief Information Officer' who chairs it, distinguishing this company's governance structure from generic descriptions.


reasoning: This paragraph is purely a cross-reference to Item 1A 'Risk Factors' and contains no substantive cybersecurity disclosure regarding governance, management, processes, or incidents. As a None/Other paragraph per Rule 6, it receives Generic Boilerplate specificity.


reasoning: This paragraph is a pure cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions, containing no substantive disclosure about the company's actual governance, management, processes, or incidents. As a None/Other paragraph with no specific facts, domain terminology, or verifiable claims, it receives Generic Boilerplate specificity.


reasoning: This paragraph is a pure cross-reference to Item 1A Risk Factors containing no substantive cybersecurity disclosure about governance, management, processes, or strategy. It consists entirely of generic forward-looking disclaimer language and a standard risk factor citation without any firm-specific details, domain-adapted terminology, or verifiable facts.


reasoning: The paragraph primarily describes the Board of Directors and Audit Committee's oversight responsibilities for cybersecurity, including reporting lines from management to the committee and the flow of information (audits, advisor reports) to the board, which fits Board Governance. The language is generic enterprise risk management terminology ('periodic updates,' 'annual audits,' 'information security programs') without domain-specific cybersecurity practices, named individuals, specific organizational structures beyond standard board committees, or verifiable quantitative claims, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses specifically on vendor oversight procedures for managing cybersecurity threats from material third-party vendors, which falls under Third-Party Risk per Rule 3. The language consists of generic risk management terminology ('internal controls', 'procedures to mitigate risks') that passes the ERM test without demonstrating cybersecurity domain expertise, and contains no firm-specific details or verifiable facts.


fact: ransomware actors

fact: exfiltrated personal information

reasoning: The paragraph describes an actual cybersecurity incident involving ransomware and unauthorized data exfiltration, as well as subsequent breach notifications to individuals and regulators, fitting Incident Disclosure. It demonstrates cybersecurity domain expertise through specific terminology ('ransomware actors', 'exfiltrated') that fails the ERM test, but contains no firm-specific organizational details (e.g., named roles, committees) or quantifiable facts (dates, numbers) to reach higher specificity levels.


reasoning: The paragraph contains a definitive materiality assessment per SEC Item 106(b)(2), stating the company is not aware of cybersecurity risks that have materially affected or are reasonably likely to materially affect its business strategy, results of operations, or financial condition, which Rule 5 explicitly classifies as Strategy Integration. The text lacks specific facts above Level 1, using generic ERM language ('identifying, assessing, and managing risks') and vendor management terms without domain-specific cybersecurity expertise, named service providers, or organizational details.


fact: National Institute of Standards and Technology

fact: International Organization for Standardization

fact: confidentiality, security and availability

fact: identifying, preventing, mitigating and remediating cybersecurity threats

fact: effectively responding to cybersecurity incidents

reasoning: While the paragraph opens with Board involvement, the substantive content describes the company's cybersecurity program frameworks (NIST, ISO) and operational approach to managing threats (identifying, preventing, mitigating, remediating, responding), which answers what the program does rather than how the Board oversees it. Specificity is Domain-Adapted due to explicit references to NIST/ISO standards and cybersecurity-specific terminology (CIA triad, threat remediation) that demonstrate domain expertise beyond generic risk management language.


reasoning: Paragraph describes the Board's delegation of cybersecurity oversight to the Audit Committee and the Committee's oversight of management's program implementation, constituting a governance chain description. The text contains only generic risk oversight terminology ('risk oversight function,' 'delegated to the Audit Committee') without domain-specific cybersecurity practices, firm-specific organizational details, or verifiable facts.


reasoning: The paragraph describes general characteristics of the company's information security program (integration into operations, cross-functional approach with privacy stakeholders) without detailing specific risk management activities, governance structures, or management roles. It answers 'What does the cybersecurity program look like?' at a high level, fitting Risk Management Process as the default category for program descriptions. The language is entirely generic ('comprehensive and trustworthy,' 'fully integrated,' 'cross-functional approach') and passes the ERM test for enterprise risk management professionals; it contains no domain-specific cybersecurity practices, firm-specific organizational details, or quantifiable facts.


reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business, opening with a specific backward-looking materiality assessment ('have not been materially adversely affected'), which per Rule 5 defines Strategy Integration. The remaining content contains only generic statements about risk trends and ongoing activities without specific facts, domain terminology demonstrating cybersecurity expertise, firm-specific details, or quantifiable/verifiable claims.


fact: CISO

fact: CPO

fact: CIO

fact: VP of Global IT Security

fact: Certified Information Systems Auditor (CISA)

fact: Certified Information Systems Security Professional (CISSP)

fact: Fellow of Information Privacy (FIP)

fact: Certified Information Privacy Professional (CIPP)

fact: Incident Response team

fact: meets weekly

reasoning: The paragraph primarily answers how management is organized for cybersecurity by identifying specific leadership roles (CISO, CPO, CIO, VP of Global IT Security), their qualifications, and the Incident Response team structure. Specificity reaches Level 4 due to the enumeration of externally verifiable professional certifications (CISA, CISSP, FIP, CIPP) held by these leaders.


reasoning: The paragraph primarily answers how the Board oversees cybersecurity, describing the oversight chain from Board to Audit Committee and integration with ERM, which is classic Board Governance content. Specificity remains at Level 1 because the text contains only generic governance terminology ('Audit Committee,' 'enterprise risk management,' 'annual ERM assessment') applicable to any public company, with no firm-specific organizational details, named individuals, or verifiable facts.


reasoning: This paragraph constitutes a materiality assessment under SEC Item 106(b)(2), stating that known cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company's business strategy, operations, or financial condition, which falls under Strategy Integration. The language consists entirely of generic negative assertions and cross-references without any domain-specific terminology (failing the ERM test), firm-specific details, or externally verifiable facts, resulting in Generic Boilerplate specificity.


fact: Director of Information Security (firm-specific leadership title with security qualifier)

fact: over 30 years of experience in IT and information security (verifiable quantity)

fact: Certified Information Systems Security Professional (CISSP) certification (externally verifiable credential)

fact: OD Technology Department (firm-specific organizational unit)

fact: reports to the Risk Committee (governance reporting line)

reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing the Director of Information Security's qualifications (CISSP, 30 years experience), the OD Technology Department structure, multidisciplinary teams, and reporting lines to senior management and the Risk Committee. Specificity is Quantified-Verifiable due to externally verifiable claims including the CISSP certification and 'over 30 years' of specific experience, alongside firm-specific organizational details.


fact: over 25 years of work experience in various roles in information technology and cybersecurity

reasoning: The paragraph identifies specific management positions (Senior Director of IT and CFO) responsible for cybersecurity processes and details their qualifications; under the person-removal test, removing these role-specific details leaves only a generic statement that management maintains the processes, confirming Management Role. Specificity is Quantified-Verifiable because the 'over 25 years' claim sets a concrete, externally verifiable threshold of experience.


fact: HITRUST framework

fact: SOC2 framework

fact: penetration testing

fact: threat modeling

fact: network firewalls

fact: intrusion prevention and detection systems

fact: identity and access management systems

fact: vulnerability assessments

fact: cybersecurity threat intelligence

fact: phishing email simulations

fact: tabletop exercises

fact: NIST framework

fact: triage, assess severity, escalate, contain, investigate and remediate processes

reasoning: The paragraph comprehensively describes the company's cybersecurity program activities, including risk assessment methodologies, technical controls, training programs, and incident response procedures, which aligns with Risk Management Process. Specificity is Domain-Adapted due to extensive use of cybersecurity domain terminology (e.g., HITRUST, SOC2, penetration testing, IDS/IPS, endpoint protection, threat intelligence, phishing simulations) that demonstrates specialized security expertise beyond generic risk management language.


reasoning: The paragraph describes the Audit Committee's oversight responsibilities and the governance chain for cybersecurity briefing (Board → Audit Committee → Management), which is Board Governance. Specificity is Firm-Specific because it identifies specific VP-level and SVP-level officers ('Vice President, Information Security and Privacy' and 'Senior Vice President, Chief Strategy and Digital Officer') who jointly brief the committee, distinguishing this company's oversight structure from generic descriptions.


fact: digital controls reviewed at least annually

reasoning: The paragraph centrally addresses how third-party vendor risks are managed through pre-onboarding assessments, contractual security requirements, and access monitoring, fitting the Third-Party Risk category. Specificity is driven by the verifiable claim that digital controls are reviewed 'at least annually,' which sets a measurable threshold for control frequency that an external party could verify.


fact: Chief Technology Officer (CTO) tasked with assessing and managing significant cybersecurity risks across the Company

reasoning: The paragraph describes the organizational structure for cybersecurity oversight, specifically the responsibilities of the Chief Technology Officer and IT Director, and the IT Director's qualifications, fitting Management Role. The identification of the Chief Technology Officer—a VP-level executive with specific cybersecurity risk management duties—constitutes a firm-specific fact.


reasoning: The paragraph contains the SEC Item 106(b)(2) mandated forward-looking materiality assessment ('reasonably likely to materially affect') and a backward-looking negative assertion about prior impacts, which per Rule 5 classifies as Strategy Integration. It contains no domain-specific cybersecurity terminology (fails the ERM test), no firm-specific organizational details (roles, committees), and no quantifiable or verifiable facts (specific incidents, dates, numbers, certifications), resulting in Generic Boilerplate specificity.


fact: Chief Information Security Officer (CISO) - VP-level cybersecurity leadership role

reasoning: The paragraph primarily describes the company's cybersecurity program activities (risk assessment processes, business continuity plans, system evaluations, and infrastructure enhancements), making it Risk Management Process. While it mentions Board oversight, the focus is on operational implementation led by management. The paragraph qualifies as Firm-Specific due to the explicit identification of a 'Chief Information Security Officer' (CISO), which is a VP-level cybersecurity leadership role that distinguishes this company's governance structure from generic disclosures.


fact: Board's Cybersecurity Special Committee

fact: four-phase incident response methodology: preparation, detection/analysis, containment/recovery, post-incident analysis

fact: severity and impact-based incident prioritization

fact: breach management processes

reasoning: The paragraph primarily describes the company's four-phase incident response lifecycle and breach management methodology, which constitutes a Risk Management Process (RMP). While it mentions reporting lines, the substantive content focuses on the program's activities (preparation through post-incident analysis). Specificity reaches Level 3 due to the named 'Board's Cybersecurity Special Committee,' a non-generic governance body that distinguishes ARKO's oversight structure, alongside Level 2 domain terminology describing the structured incident response phases.


reasoning: The paragraph centrally addresses third-party cybersecurity risk management by describing vendor due diligence processes and contractual security obligations imposed on providers (Rule 3: requirements imposed ON vendors → TP). However, it employs generic ERM language ('risk assessments,' 'cybersecurity obligations,' 'due diligence') without specifying particular security practices, assessment methodologies (e.g., SOC 2 reviews, security questionnaires), or controls that would demonstrate cybersecurity domain expertise. While it mentions business-specific vendor types (CROs, CMOs), these are industry-standard categories rather than firm-specific cybersecurity facts or verifiable claims.


reasoning: This paragraph functions as a generic introductory preamble that does not substantively answer any of the six disclosure questions (it merely states the company recognizes the importance of cybersecurity and engages in unspecified 'principles'). It contains no firm-specific details, quantifiable metrics, or domain-specific terminology that would demonstrate cybersecurity expertise beyond standard business risk language, warranting a Generic Boilerplate classification.


reasoning: This paragraph provides definitional context referencing SEC regulatory definitions (Item 106 of Regulation S-K) without disclosing any actual cybersecurity governance structures, management roles, risk processes, or incidents. It contains no specific facts about the company's cybersecurity program, serving purely as definitional boilerplate.


fact: penetration testing

fact: independent audits

fact: security controls

reasoning: The paragraph primarily describes the company's cybersecurity activities and processes, including working with consultants, implementing frameworks, and conducting evaluations of security controls through penetration testing and independent audits. These terms represent specific cybersecurity practices that demonstrate domain expertise (Level 2), as they would not naturally appear in general enterprise risk management discourse.


fact: Vice President of Information Systems and Architecture (VP-level IT leadership role)

fact: reports directly to the Chief Executive Officer

fact: provides periodic reporting to the board of directors and the audit committee

reasoning: The paragraph primarily describes the organizational structure of cybersecurity leadership, focusing on the VP of IT's responsibilities, reporting lines to the CEO, and upward reporting to the board/audit committee, which aligns with Management Role. Specificity is Firm-Specific due to the VP-level title, the specific reporting line to the CEO, and the governance chain to the board/audit committee, though no quantifiable or externally verifiable facts (e.g., named certifications, specific dates, or headcounts) are provided.


reasoning: The paragraph describes the Audit Committee's oversight responsibilities regarding cybersecurity risks and data privacy policies, as well as management's reporting obligations to the Board, which falls under Board Governance. The language is entirely generic governance terminology (Audit Committee, internal controls, risk management processes, policies) that would apply to any risk domain and lacks any firm-specific details, domain-specific cybersecurity practices, or verifiable facts, resulting in Generic Boilerplate specificity.


fact: cyberthreat landscape

fact: breach notification

reasoning: The paragraph describes engaging third-party service providers to assess the security program and provide threat intelligence, which falls under Risk Management Process (external assessors serving the company per Rule 3). Specificity is Domain-Adapted because the terms 'cyberthreat landscape' and 'breach notification' demonstrate cybersecurity domain expertise that would not naturally appear in generic enterprise risk management language.


fact: CISO (Chief Information Security Officer) - cybersecurity leadership role at VP level or above

fact: Cybersecurity Executive Committee - named non-generic committee

fact: Audit Committee composed of two Board members who are also members of the Cybersecurity Executive Committee - specific governance structure

reasoning: The paragraph primarily answers how the Board oversees cybersecurity by describing the Audit Committee's annual briefings from the CISO and the specific composition of the Committee (two members who also serve on the Cybersecurity Executive Committee). The inclusion of the specific leadership title 'CISO' and the named 'Cybersecurity Executive Committee' elevates the specificity to Firm-Specific.


reasoning: The paragraph describes the Board's oversight responsibilities for the cybersecurity program, including reviewing strategic direction and ensuring resource allocation, which is classic Board Governance content. The language is entirely generic—describing standard fiduciary duties and listing broad expertise areas without specific domain terminology, named committees, individuals, or quantifiable details that would elevate specificity above boilerplate.


fact: over 25 years of IT Risk Management experience

fact: more than 30 years of collective information and product security experience

fact: Senior Vice President and Chief Information Officer

fact: early-career professionals with cybersecurity degrees

fact: seasoned professionals with multiple cybersecurity-related certifications

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by detailing the CIO's specific title, the team's composition, and reporting structures. The specificity reaches Level 4 due to verifiable quantitative claims about the CIO's experience (over 25 years) and the team's collective experience (more than 30 years), which set externally checkable thresholds.


reasoning: The paragraph describes the governance oversight structure, noting that the cybersecurity program is supported by the Board of Directors and Audit Committee, which falls under Board Governance per Rule 1. For specificity, the paragraph contains only generic commitments and boilerplate language ('committed to safeguarding,' 'industry best practices') with no domain-specific terminology, firm-specific details, or verifiable facts.


reasoning: The paragraph primarily answers whether cybersecurity affects the business by stating a conclusion that no threats are reasonably anticipated to have a material effect on business strategy or financial condition, which is a classic Strategy Integration materiality assessment per Rule 5. The text contains no domain-specific cybersecurity terminology (failing the ERM test), no firm-specific organizational details, and no quantifiable or verifiable facts—only generic forward-looking statements about priorities and risk evaluation.


reasoning: This paragraph consists of forward-looking risk speculation ('could result,' 'could be negatively affected,' 'could materially harm') and cross-references to Item 1A Risk Factors without describing any actual cybersecurity governance, management, processes, or third-party oversight. Per Rule 5, speculative language about potential material effects does not constitute a Strategy Integration materiality assessment. The text contains no domain-specific cybersecurity terminology (fails ERM test), firm-specific details, or verifiable facts.


reasoning: This paragraph describes the governance chain for cybersecurity oversight, flowing from the Board to the Audit Committee and then to management (General Counsel), which is the defining scope of Board Governance. Specificity is Generic Boilerplate because it relies solely on generic governance titles (Audit Committee, General Counsel) and universal oversight verbs without any domain-specific practices, firm-specific organizational details, or externally verifiable facts.


reasoning: The paragraph describes incident response procedures and notification workflows (what the program does), placing it in Risk Management Process. It employs generic risk management terminology ('evaluate, mitigate, and remediate') that could apply to any operational risk context, mentions only standard governance roles (CEO, CFO, Board of Managers), and lacks specific cybersecurity domain expertise, firm-unique details, or verifiable claims, resulting in Level 1 specificity.


reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business through the required SEC Item 106(b)(2) materiality safe harbor language ('have not... materially affected or are reasonably likely to materially affect') and mentions cyber insurance coverage, but contains no firm-specific details, quantifiable metrics, or domain-adapted terminology beyond generic risk management concepts.


reasoning: This paragraph states a conclusion about whether cybersecurity risks have materially affected or are reasonably likely to materially affect business outcomes, which falls under Strategy Integration per Rule 5 (matching the example: 'Have not materially affected our business strategy, results of operations, or financial condition'). It contains no specific facts—only a generic negative materiality assertion without quantified data, domain-specific security terminology, or firm-unique details—resulting in Generic Boilerplate specificity.


fact: Vice President and Chief Information Officer has 27 years of technology leadership experience

fact: Vice President and Chief Information Officer holds a Doctor of Business Administration

fact: Director of Information Security has 27 years of experience in infrastructure and security operations

fact: Director of Information Security holds a degree in Information Technology Management

reasoning: The paragraph primarily answers how management is organized for cybersecurity, detailing the roles, reporting lines (Director reports to VP/CIO), committee structures (Information Security Committee, Executive Information Security Oversight Committee), and qualifications of specific officers. Specificity is Level 4 due to quantified, externally verifiable claims regarding the officers' years of experience (27 years each) and educational credentials (Doctor of Business Administration, Information Technology Management degree).


reasoning: The paragraph primarily answers how the board oversees cybersecurity by describing the Audit Committee's responsibility for overseeing the cybersecurity program and the frequency of management's risk reports (annual assessment reviews and quarterly updates). No specific facts elevate the specificity: the risk assessment methodology described (likelihood and monetary impact) is generic ERM language that fails the domain expertise test, and there are no firm-specific organizational details, named individuals, or quantifiable claims.


reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business, containing explicit backward-looking ('none...have resulted in a material impact') and forward-looking ('do not believe...are reasonably likely to affect') materiality assessments per SEC Item 106(b)(2). Specificity is Generic Boilerplate because the paragraph contains only vague, generic language ('preventative actions,' 'significant costs,' 'continuous learning') without domain-specific terminology, firm-specific details, or verifiable facts.


fact: Ransomware attack occurred in early 2019

fact: Retained professional cybersecurity investigation firm to conduct forensic analysis

fact: Exchange on-premises accounts were part of the compromised environment investigated

reasoning: The paragraph primarily answers what happened in a cybersecurity incident by describing the 2019 ransomware attack, investigation, recovery, and forensic findings, making it Incident Disclosure. Specificity is Firm-Specific because the paragraph contains details unique to this company's experience—the ransomware attack in early 2019 and the retention of a forensic firm—distinguishing it from generic disclosures, though it lacks quantified verifiable facts like specific dates, dollar amounts, or named third parties that would elevate it to Level 4.


reasoning: The paragraph provides introductory context regarding the importance of cybersecurity and describes the threat landscape (e.g., ransomware, denial-of-service, nation-state actors) but does not substantively answer any of the six category questions—it does not describe board governance, management organization, specific risk management processes, third-party oversight, actual incidents, or materiality assessments (the 'could materially adversely affect' language is speculative per Rule 5, not a Strategy Integration assessment). Per the annotation guidelines, None/Other paragraphs always receive Generic Boilerplate specificity.


fact: Vaidyanathan Raghavan (named individual)

fact: General Manager of Technology at Wayfair (previous employment)

fact: Master of Science in Electrical Engineering degree from the University of Minnesota (educational credential)

fact: Brendan Hamilton (named individual)

fact: Certified Information Systems Security Professional (professional certification)

fact: Vice President of Information Technology and Security (firm-specific leadership title)

reasoning: This paragraph primarily answers how management is organized to handle cybersecurity by identifying specific leaders (CTO and VP of IT and Security), their names, prior employment, educational backgrounds, and professional certifications. Per Rule 2 (person-removal test), removing the person-specific content leaves only the generic statement that processes are maintained by management, confirming Management Role classification. Specificity is Quantified-Verifiable due to multiple externally verifiable facts including named individuals, a specific degree from the University of Minnesota, CISSP certification, and prior employment at Wayfair.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions, containing no substantive disclosure about the company's actual cybersecurity governance, management, or program. As a pure cross-reference with no specific facts about the company's cybersecurity posture, it receives the None/Other category and Generic Boilerplate specificity.


reasoning: The paragraph states a forward-looking materiality conclusion that known cybersecurity threats are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which falls under Rule 5 for Strategy Integration. It contains no specific facts, domain terminology, firm-specific details, or verifiable claims—only a subjective belief statement and a cross-reference to Item 1A risk factors.


fact: Security Governance Council (the 'SGC') - named management-level committee

fact: CISO - cybersecurity leadership role at VP level or above

fact: SGC members from specific departments: Operations, Information Technology, Finance, Internal Audit, Legal, Human Resources and Organizational Development, and Risk Management

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by describing the Security Governance Council (SGC), a management-level committee chaired by the CISO and composed of specific departmental representatives, distinguishing it from Board-level oversight (BG) or process descriptions (RMP). Specificity is Firm-Specific (Level 3) due to the named committee (SGC), the CISO role, and the enumerated list of participating departments which uniquely identifies Paychex's organizational structure.


fact: Chief Information Officer (CIO)

fact: Chief Information Technology Architect & Chief Information Security Officer (CISO)

reasoning: The paragraph primarily describes the Board committee's oversight structure, including the frequency of reports received from management and the flow of cybersecurity information to the full Board, which is characteristic of Board Governance. Specificity is Firm-Specific because it identifies distinct executive leadership roles (CIO and CISO) that are unique to the company's organizational structure, meeting the Level 3 threshold for cybersecurity leadership titles.


reasoning: The paragraph contains only generic, aspirational forward-looking language stating the goal of minimizing breach likelihood without describing any specific governance structures, management organization, risk management processes, or third-party oversight. It functions as a concluding statement with no substantive cybersecurity measures or verifiable facts.


fact: phishing attacks

fact: malware infections

fact: unauthorized access attempts

fact: state-sponsored actors

reasoning: The paragraph primarily answers how cybersecurity affects the business by assessing that past attempts (phishing, malware, unauthorized access) would not have resulted in material adverse effects, which is a backward-looking materiality assessment under Rule 5. Specificity is Domain-Adapted due to precise cybersecurity threat terminology including 'phishing attacks,' 'malware infections,' and 'state-sponsored actors' that demonstrate domain expertise beyond generic risk management language.


fact: Chief Financial Officer responsible for managing cybersecurity risk

fact: discusses cybersecurity risk with Audit Committee at least annually

fact: outside consultants perform the internal audit function

fact: Audit Committee chair may report to Chairman of the Board or full Board at his discretion

reasoning: This paragraph describes the governance chain for cybersecurity oversight (CFO → Audit Committee → Board), including the Audit Committee's primary responsibility and reporting protocols, which defaults to Board Governance under Rule 1. Specificity is Firm-Specific because it identifies the CFO as the responsible executive (a C-suite leadership role), notes the annual briefing cadence, and specifies that internal audit is performed by outside consultants—details that distinguish this company's governance structure from others.


reasoning: The paragraph contains the SEC-mandated forward-looking materiality assessment ('reasonably likely to have a material effect on our results of operations or financial condition') and backward-looking negative incident assertion ('There have not been any breaches'), both of which trigger Strategy Integration under Rule 5. It lacks specific cybersecurity domain terminology (Level 2), firm-specific details like leadership titles or team composition (Level 3), or externally verifiable facts like specific dates of incidents, certifications, or named vendors (Level 4), consisting only of generic risk disclaimers and reporting period context.


fact: Completed merger with SomaLogic Operating Co, Inc.

fact: SomaLogic maintains ongoing ISO 27001 compliance certification

reasoning: The paragraph describes post-merger integration activities involving the review and deployment of cybersecurity policies, procedures, and tools to reinforce security presence, which constitutes Risk Management Process activities. Specificity is Quantified-Verifiable because it names the specific merger partner (SomaLogic Operating Co, Inc.) and contains an externally verifiable claim regarding SomaLogic's ISO 27001 compliance certification status.


reasoning: The paragraph primarily constitutes a materiality assessment required by SEC Item 106(b)(2), 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. It contains no specific facts—no domain terminology demonstrating cybersecurity expertise (failing the ERM test), no firm-specific organizational details, and no verifiable quantitative claims or named entities—resulting in generic boilerplate specificity.


fact: engagement of vendors to conduct penetration tests

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by describing their oversight responsibilities, incident response team membership, and role in directing response efforts. The reference to 'penetration tests' constitutes cybersecurity domain terminology that fails the ERM test (a non-security risk professional would not naturally specify this assessment type), elevating specificity to Level 2.


fact: CISO (Chief Information Security Officer) - cybersecurity leadership role at VP level or above

reasoning: The paragraph describes the Board's oversight mechanisms, specifically how the Audit and Risk Committee receives briefings from management on cybersecurity matters at defined intervals (quarterly, semi-annual, annual). This governance-chain description defaults to Board Governance under Rule 1. The specificity is elevated to Firm-Specific by the mention of a 'CISO,' which qualifies as a cybersecurity leadership role at the VP level or above, distinguishing the company's organizational structure from generic disclosures.


fact: over thirty years of experience leading information technology teams

reasoning: The paragraph primarily describes the organizational role of the Head of IT, including their responsibilities and specific qualifications (over thirty years of experience), which fits Management Role. The 'over thirty years' claim provides a verifiable lower-bound threshold regarding the incumbent's experience, satisfying the Quantified-Verifiable level.


reasoning: The paragraph states a conclusion about whether cybersecurity incidents have materially affected or are reasonably likely to materially affect the company, which is a materiality assessment classified as Strategy Integration under Rule 5. Despite mentioning past threats and incidents, it provides no specific details, organizational facts, or domain terminology beyond generic disclosure language, resulting in Generic Boilerplate specificity.


fact: In the fourth quarter of fiscal year 2019 (specific timing of ransomware incident)

fact: Note 18 to the consolidated financial statements in Part II, Item 8 (specific document reference)

fact: ransomware (specific attack type)

fact: phishing emails (specific attack vector)

reasoning: The paragraph describes a specific historical cybersecurity incident (ransomware attack in Q4 2019), including its nature, timing, remediation efforts involving forensic experts and law enforcement, and operational/financial impacts, which fits Incident Disclosure. Specificity is Quantified-Verifiable because it contains the hard temporal fact 'fourth quarter of fiscal year 2019' tied to the actual event and a specific citation to 'Note 18' in the financial statements, both of which are externally verifiable claims.


reasoning: The paragraph describes oversight and security requirements imposed on third-party service providers, fitting the Third-Party Risk category. It uses generic language ('assess the ability,' 'appropriate security measures') without specific domain terminology, firm-unique details, or verifiable facts, resulting in Generic Boilerplate specificity.


fact: penetration test

fact: threat landscape

fact: Enterprise Risk Management Committee (management-level committee)

fact: Chief Information Officer (committee member)

fact: Chief Risk Officer (committee member)

fact: Chief Executive Officer (committee member)

fact: Chief Financial Officer (committee member)

fact: Chief Operating Officer (committee member)

fact: Chief Credit Officer (committee member)

fact: Chief Administrative Officer (committee member)

reasoning: The paragraph primarily answers how management is organized for cybersecurity by detailing the management-level Enterprise Risk Management Committee's specific C-suite membership (CIO, CRO, CEO, CFO, COO, etc.) and its oversight responsibilities. While it mentions testing activities, the emphasis is on the governance structure and roles. Specificity is Firm-Specific due to the enumeration of VP-level cybersecurity leadership roles on the committee and domain terminology like 'penetration test,' but lacks quantified-verifiable elements such as named third-party firms, specific dates, or headcounts.


fact: In February 2022 (specific date of cyber-attack incident)

fact: Chief Information Security Officer (CISO) (VP-level cybersecurity leadership role)

fact: CSRM program (named internal cybersecurity program)

fact: approximately three weeks (duration of operational impact)

fact: connectivity, operating and accounting systems (specific systems affected by shutdown)

reasoning: The paragraph primarily answers what happened in a specific cybersecurity incident, describing the February 2022 attack's timing, scope (global system shutdown), duration (three weeks of limited operations), and operational impact. Specificity is Level 4 due to the externally verifiable date of the incident and firm-specific organizational details including the addition of a CISO and named CSRM program.


reasoning: The paragraph describes how management is organized for cybersecurity oversight, assigning specific responsibilities to the Senior Director of IT and General Counsel. It contains no firm-specific details (titles below VP without security qualifiers), no domain-specific terminology beyond generic 'security assessments' and 'cybersecurity incidents' that any ERM professional would use, and no quantifiable or verifiable facts.


reasoning: This paragraph is a pure cross-reference to Item 1A Risk Factors and contains no substantive cybersecurity disclosure about the company's program, governance, or incidents. As a None/Other paragraph with no domain terms, firm-specific details, or verifiable claims, it receives Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for cybersecurity risk factors, containing no substantive disclosure about the company's cybersecurity governance, management, processes, or incidents. As a cross-reference with no specific facts regarding the company's program, it is classified as None/Other with Generic Boilerplate specificity.


fact: CTO (cybersecurity leadership role at VP level or above)

reasoning: Paragraph describes management's organizational responsibility for cybersecurity, identifying the CTO and IT Manager as responsible for assessing risks and supervising personnel. The mention of the CTO qualifies as a firm-specific fact (VP-level leadership role), establishing Level 3 specificity.


reasoning: The paragraph focuses on management's responsibility for developing cybersecurity programs, their qualifications (education and experience), and their oversight role in monitoring incident prevention and remediation. This describes organizational roles and expertise rather than board governance or detailed program mechanics. The disclosure contains no specific job titles, credentials, team compositions, or technical details—only generic references to 'Management,' 'relevant degrees,' and 'prior work experience.'