fact: penetration testing of customer facing domains

fact: CIS Critical Security Controls

fact: incident response plan with simulated incidents testing

reasoning: The majority of text describes program activities — third-party engagements for program enhancement, penetration testing, incident response planning, and vendor diligence — making RMP the dominant category despite trailing SI materiality statements. Specificity reaches Level 2 via domain terms (penetration testing, CIS Critical Security Controls) that pass the ERM test, but no firm-specific roles/committees or verifiable claims push it higher.

thinking:
Let me analyze this paragraph carefully.

Content category: This paragraph covers multiple topics - third-party engagements, risk management processes, incident response, and materiality assessments. The bulk describes what the cybersecurity program does (RMP), but the last sentences contain materiality assessments (SI). Let me weigh: the first ~60% describes program activities (third-party engagements for program enhancement, penetration testing, incident response plan, etc.) = RMP. The latter portion has clear SI materiality statements. The majority of text is about RMP activities, but there's also significant TP content and SI content.

Actually, looking more carefully - the paragraph starts with third parties hired to serve the company (assessors, pen testers) → RMP per Rule 3.

Then it moves through vendor oversight, incident response planning, and concludes with a materiality statement about cybersecurity risks. The SI disclosure at the end is explicit and unambiguous, but the dominant portion of the text focuses on program activities and processes. I'm going to categorize this as RMP since that's where most of the content sits, though I should note the materiality statement is clearly SI material.

Now I'm looking at the specific facts to extract - I see "penetration testing" as a domain term, and I need to identify what other specific practices or metrics are mentioned. I'm identifying the domain-specific terms that push this into Level 2—penetration testing and the CIS Critical Security Controls framework are both technical practices rather than generic statements. The incident response plan itself is too broad without additional specificity, and there aren't any firm-specific facts or verifiable claims that would elevate this further. This lands at Level 2.


content_category: Risk Management Process

fact: National Institute of Standards and Technology (NIST) framework referenced

type: framework

fact: International Organization for Standardization (ISO) framework referenced

fact: Confidentiality, security and availability (CIA triad)

category_confidence: medium

specificity_confidence: high

reasoning: While the paragraph opens with Board oversight, the majority of text describes the cybersecurity program's framework alignment, ERM integration, and risk management approach, making RMP the dominant category. Named frameworks (NIST, ISO) and the CIA triad reference demonstrate domain knowledge elevating to Level 2, but 'based on' rather than 'certified to' keeps these as aspirational references rather than verifiable claims.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Category: The paragraph starts with Board oversight (BG) but then shifts to describing the company's cybersecurity program - frameworks, ERM integration, approach to risk management. The "what question" test: it answers multiple questions. The Board sentences are about oversight (BG), but the bulk describes what the program does (RMP). The majority of text is about the program's approach, frameworks, and integration. → RMP

Specific facts:
- NIST (framework reference) → domain_term/framework

- ISO (framework reference) → domain_term/framework
- "confidentiality, security and availability" (CIA triad concept) → domain_term
- The company references both NIST and ISO frameworks as foundational to their approach, though the language suggests alignment rather than formal certification, making these Domain-Adapted framework references. No firm-specific facts or named roles beyond generic Board references emerge. Specificity lands at Level 2 due to the framework citations.


content_category: Board Governance

category_confidence: high

reasoning: The paragraph describes how the Board receives cybersecurity reports from management, directly answering how the board oversees cybersecurity — classic Board Governance. No domain-specific terminology, firm-specific facts, or verifiable claims are present; 'annual reports,' 'Board,' and 'management' are all generic governance language.

thinking:
Classify this paragraph.

Category: Board Governance - describes how the board receives reports on cybersecurity risks and incidents from management. This is about oversight structure and information flow to the board.

Specific facts: "annual reports" is a generic cadence. "Board" is generic. No domain terms, no firm-specific facts, no verifiable claims.

Specificity: Level 1 - Generic Boilerplate.


content_category: Strategy Integration

reasoning: The paragraph states a backward-looking materiality conclusion ('have not identified any cybersecurity incidents or threats that have materially affected us') and a forward-looking one ('reasonably likely to materially affect us'), triggering SI under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present—the negative self-assertion about no material incidents is not externally verifiable.

thinking: SI materiality rule applies here.


reasoning: The paragraph describes the board's delegation of cybersecurity oversight to the audit committee, directly answering how the board oversees cybersecurity → Board Governance. No domain terms passing the ERM test, no firm-specific facts (board and audit committee are generic), and no verifiable claims → Level 1.

thinking:
Classify this paragraph.

Category: Board delegates cybersecurity oversight to audit committee. This is about board/committee oversight structure → Board Governance.

Specificity: Let me scan for facts.
- "board of directors" — generic, every company has one
- "audit committee" — generic, every company has one
- No domain terms that pass ERM test
- No firm-specific facts
- No verifiable claims

Level 1.


content_category: None/Other

reasoning: This paragraph is a pure cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions, with no substantive cybersecurity disclosure of its own. No specific facts elevate specificity above Level 1.

thinking: Cross-reference to risk factors, no substantive cybersecurity disclosure.


content_category: Management Role

fact: Global Director of IT role responsible for cybersecurity

fact: Over 30 years of experience in various information technology roles

type: quantified

fact: Over 20 years of experience as an IT Director

fact: CFO has over 10 years of experience in risk management

reasoning: The paragraph describes who is responsible for cybersecurity (Global Director of IT, CEO, CFO) and their qualifications — the person-removal test leaves almost no substantive content, confirming MR. Multiple lower-bound experience figures (30+, 20+, 10+ years) are verifiable against resumes, driving Level 4.

thinking:
Let me analyze this paragraph.

Category: This is about management roles, responsibilities, and qualifications. The person-removal test: remove names, titles, qualifications → almost nothing remains except "assessing and managing material risks from cybersecurity threats, as well as managing and responding to material cybersecurity incidents." That's thin. This is MR.

Specific facts:
- "Global Director of IT" — Director-level title without security qualifier → per rules, NOT firm-specific. Wait, "Director of IT" is explicitly listed as NOT firm-specific.

- CEO and CFO are generic roles that don't qualify as firm-specific either.
- The experience metrics are all quantified and verifiable: over 30 years in IT roles, over 20 years as an IT Director, and over 10 years in risk management.

This pushes the specificity to Level 4 due to those concrete experience numbers.


reasoning: The paragraph is a governance-chain description: Audit Committee oversight of cybersecurity, reporting to the Board, then management roles (COO, Senior Director of IT) — per Rule 1, this defaults to BG since the primary purpose is describing the oversight structure. No domain terms pass the ERM test ('information security program,' 'cybersecurity risk,' 'risk mitigation' are generic); 'Senior Director of Information Technology' lacks a security qualifier so is not firm-specific; COO and Audit Committee are generic roles present at most companies.

thinking:
Classify this paragraph.

Category: This describes how the board (Audit Committee) oversees cybersecurity AND how management (COO, Senior Director of IT) is organized. The first half is about board oversight, the second half about management roles. The dominant frame is oversight structure - BG vs MR. The paragraph starts with reporting to the Audit Committee, describes the Audit Committee's oversight role, then describes management roles. It's a governance-chain paragraph. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure.

Specificity:
- "Audit Committee" - generic, every company has one → not firm-specific

- "Chief Operating Officer" - generic C-suite role → not firm-specific
- "Senior Director of Information Technology" - Director-level without security qualifier → not firm-specific per rules
- "third-party consultants" - unnamed → not firm-specific
- No domain terms that pass ERM test - "information security program", "cybersecurity risk", "risk mitigation" are all generic ERM language
- "preventing, mitigating, detecting, and addressing cybersecurity incidents" - generic process description

The Senior Director of Information Technology falls under the same rule - it's a generic IT director title without a security-specific qualifier, so it doesn't meet the firm-specific threshold. A COO handling cybersecurity might seem unusual, but it's still just a generic governance role. None of the language here goes beyond standard enterprise risk management terminology, so this is clearly Level 1.


reasoning: This is a pure cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure. N/O paragraphs always get Generic Boilerplate.


reasoning: The paragraph answers how the board oversees cybersecurity: delegation to the Audit Committee for oversight of cybersecurity risks. No domain-specific terminology (risk oversight, implementation, strategy are all generic ERM language), no firm-specific facts (Audit Committee is generic), and no verifiable claims.

thinking:
Classify this paragraph.

Category: Board governance - describes board/committee oversight of cybersecurity risks, delegation to Audit Committee.

Specific facts: "Audit Committee" is generic (every company has one) → not firm-specific. The language is standard governance boilerplate without domain terms.

Specificity: Level 1 - Generic Boilerplate. No domain terms passing ERM test, no firm-specific facts, no verifiable claims.


fact: NIST CSF framework with named principles (Identify, Protect, Detect, Respond, Recover)

reasoning: The paragraph describes the company's cybersecurity program and its framework adoption, squarely answering 'what does the program do?' → RMP. NIST CSF is a named standard with its five functions enumerated, passing the ERM test for Level 2, but the explicit disclaimer ('does not imply that we meet any particular technical standards') prevents treating this as a verifiable certification claim, capping at Domain-Adapted.

thinking:
Classify this paragraph.

Category: This describes what the cybersecurity program does - risk management methodology, framework adoption. RMP.

Specificity:
- NIST CSF named with principles (Identify, Protect, Detect, Respond, Recover) → domain term/framework (Level 2)
- "cybersecurity incident response plan" → generic
- They say "based on" NIST CSF but then disclaim meeting any standards → "aligned with" not "certified" → Domain-Adapted, not verifiable

- So I'm settling on Level 2 for this one.


reasoning: The paragraph describes how the board has ultimate oversight of risk management and receives presentations on cybersecurity risks from the executive leadership team — this answers 'how does the board oversee cybersecurity?' No domain-specific terminology, no firm-specific facts (board of directors and executive leadership team are generic), and no verifiable claims.

thinking:
Classify this paragraph.

This is about board oversight of risk management, with cybersecurity mentioned as one of several risk areas presented to the board.

Category: Board Governance - describes how the board oversees cybersecurity risks and how information flows to the board.

Specificity: No domain terms beyond generic "information technology and cybersecurity." No firm-specific roles beyond generic "board of directors" and "executive leadership team." No verifiable facts.

Level 1.


reasoning: This is a generic introductory statement expressing the company's commitment to cybersecurity without answering any of the six substantive questions. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: Simple classification task.


reasoning: The first sentence is a backward-looking materiality assessment ('have not materially affected') combined with a forward-looking SEC 106(b)(2) statement ('not reasonably likely to materially affect'), both triggering SI under Rule 5. The remainder is a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims elevate specificity above Level 1.


fact: phishing attacks

fact: malware infections

fact: unauthorized access attempts

reasoning: The paragraph describes past cyber attempts but its primary purpose is a materiality assessment—stating that these attempts, if successful, would not have resulted in a material adverse effect on business, financial condition, or results of operations. Per Rule 5, this backward-looking materiality conclusion drives SI. Specificity reaches Level 2 via specific threat types (phishing, malware infections, unauthorized access attempts) that pass the ERM test, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Discusses risk of cyber incidents, mentions past attempts (phishing, malware, unauthorized access), states belief these wouldn't have been material, references Item 1A.

Category: This mentions actual attempts (phishing attacks, malware infections, unauthorized access attempts) - but states they were attempts, not successful incidents. There's a materiality assessment ("We do not believe that these attempts, if successful, would have resulted in a material adverse effect"). The paragraph is mixed - it has incident-adjacent language about attempts, a materiality assessment, and forward-looking risk language.

The materiality statement here is really a backward-looking assessment of whether past cybersecurity attempts would've impacted the business if they'd succeeded. That's SI territory. But the paragraph's framing is fundamentally about what happened to us—the attempts themselves—with the materiality conclusion layered on top. Since the incident description dominates the structure, this leans toward ID under Rule 4. The materiality assessment is really the crux here—they're acknowledging actual attempts but concluding they wouldn't have caused material harm if successful. That frames this as a strategy integration decision rather than incident disclosure. The specific threat types like phishing and malware infections are domain-specific enough to meet the ERM threshold, and the cross-reference to Item 1A ties it to risk disclosure standards.


reasoning: The paragraph contains a materiality assessment ('have not experienced any cybersecurity incidents which have materially affected...business strategy, results of operations or financial condition'), making it SI under Rule 5. The first sentence is a cross-reference to Item 1A, and the second is a negative assertion about material incidents. No domain terms pass the ERM test, no firm-specific facts, and the negative self-assertion is not externally verifiable per the rules, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. A cross-reference to Item 1A risk factor about cybersecurity risks
2. A statement that in the last three fiscal years, they have not experienced any material cybersecurity incidents

Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI (negative assertion). The second sentence is a backward-looking materiality assessment.

The first sentence is a cross-reference, which would be N/O, but the second sentence contains a substantive materiality assessment → SI.

Specificity: "In the last three fiscal years" is a soft timeframe.

This is a negative self-assertion that lacks external verifiability, domain-specific terminology, or firm-specific facts beyond generic statements. The cross-reference to a risk factor heading doesn't add substantive content. There's nothing here that meets any level of specificity or informativeness—this is Level 1 Generic Boilerplate.


fact: Mr. Lee is named as the individual providing cybersecurity updates to the board

reasoning: The paragraph describes how cybersecurity information flows to the Board and Audit Committee via periodic updates, squarely answering the Board Governance question. Mr. Lee is a named individual in a cybersecurity reporting context, making this Firm-Specific; the Audit Committee is generic and does not elevate specificity.

thinking:
Classify this paragraph.

The paragraph describes how Mr. Lee reports cybersecurity information to the Board and Audit Committee. This is about how information flows to the board — Board Governance.

Specific facts:
- "Mr. Lee" — named individual in cybersecurity context → firm-specific
- "Audit Committee" — generic, every company has one → NOT firm-specific

Specificity: Firm-Specific (Level 3) due to named individual.


fact: Chief Information Consultant — distinctive firm-specific title for cybersecurity/IT leadership

reasoning: The paragraph's opening frame is ERM integration ('assessment and management of material risks from cybersecurity threats are integrated into our overall risk management processes'), with roles described as actors in that process (prioritizing, mitigating, evaluating risks). While it contains a governance chain (CIC → management → CFO → Audit Committee), the primary question answered is what the program does — integrate into ERM and prioritize/mitigate threats. 'Chief Information Consultant' is an unusual, firm-specific title at Chief level that distinguishes this company, elevating specificity to Level 3.

thinking:
Let me analyze this paragraph.

Category: This describes how cybersecurity risk management is integrated into overall risk processes, mentions the Chief Information Consultant working with management to prioritize and mitigate threats, CFO evaluating risks and reporting to Audit Committee. It's a governance-chain paragraph. The primary question answered is about how cybersecurity risks are managed and integrated into ERM, with reporting lines. It touches RMP (integration into risk management), MR (roles), and BG (Audit Committee oversight).

The paragraph primarily describes how risks are assessed and managed, with roles mentioned as part of that process. The person-removal test: remove "Chief Information Consultant" and "CFO" and "Audit Committee" - there's still "assessment and management of material risks from cybersecurity threats are integrated into our overall risk management processes" and "prioritize risk management processes and mitigate cybersecurity threats." Some substance remains but it's quite generic.

I'm seeing this as fundamentally about ERM integration—the opening establishes how cybersecurity fits into the broader risk management framework, and while there's a governance chain running through it, that's secondary to explaining the integration itself. The reporting structure to the Audit Committee supports the ERM narrative rather than being the main point. The governance structure here is really the core of what's being described—the reporting chain from CIC through management to the CFO and up to the Audit Committee. But the opening frame about ERM integration and the focus on how risks are actually prioritized and mitigated pulls this toward RMP territory. I think RMP is the right call since the paragraph is fundamentally explaining what the cybersecurity program does within that governance structure, not just who reports to whom. The "Chief Information Consultant" title is specific to this organization, while CFO is standard across companies. - "Audit Committee of the Board of Directors" - generic
- ERM integration - Level 1 language

"Chief Information Consultant" is an unusual title - it's firm-specific as it's a distinctive role title. It's not a standard C-suite title. But is it VP-level or above? It's "Chief" level, so yes, firm-specific.

Specificity: Firm-Specific (Level 3) due to "Chief Information Consultant" being a distinctive firm-specific role.

Wait, let me reconsider. The rules say "cybersecurity leadership roles at VP level or above (CISO, CTO, CIO, VP/SVP/EVP of IT...)" count as firm-specific. "Chief Information Consultant" is a Chief-level role related to IT/cybersecurity, so it qualifies.

Also, the SI materiality rule: "assessment and management of material risks" - but here "material" is just describing the type of risks, not serving as an assessment conclusion, so this doesn't trigger the SI threshold.


content_category: Third-Party Risk

reasoning: The paragraph centrally addresses how the company manages third-party vendor cybersecurity risk—due diligence, periodic reviews, and contractual requirements imposed on vendors—making TP the clear category. All language (vendor due diligence, contractual clauses, reporting requirements, insurance coverage) is generic ERM vocabulary with no domain-specific terms, firm-unique facts, or verifiable claims.

thinking:
Third-party risk management is the central topic here.

Specific facts: "vendor due diligence evaluation during onboarding", "periodically review vendors", "contracts with third parties to incorporate industry and regulatory standard clauses", "cybersecurity insurance coverage" - these are all generic process descriptions.

Let me check for domain terms: "cybersecurity threats and incidents", "cybersecurity insurance coverage" - these are fairly generic. The paragraph describes requirements imposed ON vendors (contractual clauses, reporting requirements, insurance requirements) → TP.

Specificity: No domain terms that pass the ERM test. "Vendor due diligence", "onboarding", "contractual clauses" - an ERM professional would use all of this language.

The cybersecurity insurance requirement for vendors lacks firm-specific details or verifiable claims, so this lands at Level 1.


reasoning: Both sentences are materiality assessments — backward-looking ('have not materially affected') and forward-looking ('not reasonably likely to materially affect') — triggering the SI materiality rule. No domain terms, firm-specific facts, or verifiable claims are present, so specificity remains Level 1.


reasoning: The paragraph describes how the executive team provides updates to the Board and audit committee on cybersecurity status—a governance-chain paragraph about oversight structure, defaulting to BG per Rule 1. No domain terms pass the ERM test ('cybersecurity operations,' 'risks, threats or incidents' are generic), 'audit committee' is not firm-specific, and 'executive team' is not a named role, leaving this at Level 1.

thinking:
Classify this paragraph.

The paragraph describes the executive team's involvement in cybersecurity oversight and their reporting to the Board/audit committee. The primary question answered is about how information flows from management to the board - this is governance chain.

Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. The paragraph describes how the executive team reports to the Board/audit committee - this is about oversight structure flowing upward.

Specificity: No domain terms that pass the ERM test. "Cybersecurity operations," "risks, threats or incidents" - generic.

The roles mentioned here aren't specific to the company - "executive team" and "audit committee" are standard across organizations with no firm-specific details or verifiable facts. This points to Level 1.


fact: Chief Information Security Officer (CISO)

fact: Information security risk committee

fact: Committee chaired by CISO and comprised of employees and executive management

reasoning: The paragraph primarily describes management-level organizational structure: a named committee (information security risk committee), its chair (CISO), and its membership composition, making it MR per Rule 1 for management-level committees focused on structure/membership. Specificity reaches Level 3 via the firm-specific CISO role and the named non-generic committee, but no verifiable claims push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes internal reporting to senior leadership monthly, an information security risk committee chaired by CISO, comprised of employees and executive management, and mentions cybersecurity program focus areas.

Category: This describes management-level organization - a committee (information security risk committee), its chair (CISO), membership, and purpose. The governance chain here is at management level. Per Rule 1, management-level committees → MR if about structure/membership. This is about structure/membership, so MR.

Specific facts:
- CISO (named role, firm-specific)

- "information security risk committee" (named committee, firm-specific)
- "monthly" reporting cadence - generic cadence, not firm-specific
- Committee chaired by CISO, comprised of employees and executive management - structure

The CISO and the named committee are both firm-specific identifiers at Level 3, with no verifiable facts like numbers or certifications present.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not...materially affected') and a forward-looking one ('reasonably likely to materially affect'), which are SI per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present — the language is standard SEC Item 106(b)(2) boilerplate.

thinking: Materiality assessment paragraph.


fact: SVP reports directly to President

fact: SVP has served in role for over four years

fact: More than 25 years of experience in information technology roles

fact: More than ten years with the Company

fact: Management reports to audit committee on cybersecurity at least semi-annually

reasoning: Governance-chain paragraph bookended by audit committee oversight responsibilities and reporting cadence, with management role details in between; per Rule 1, defaults to BG when describing oversight structure. Specificity reaches Level 4 due to multiple lower-bound verifiable claims about the SVP's tenure (>4 years in role, >25 years experience, >10 years with the company).

thinking:
Let me analyze this paragraph.

Category: This covers both board governance (audit committee oversight) and management role (SVP Technology Solutions). The paragraph describes the audit committee's oversight responsibility, the SVP's role and qualifications, and reporting lines. It's a governance-chain paragraph. The audit committee oversight bookends the paragraph, but there's substantial MR content about the SVP. Let me assess which dominates.

Text breakdown:
- Sentence 1: Audit committee oversight of cybersecurity → BG

- Sentence 2: SVP Technology Solutions responsible for day-to-day management, reports to President → MR
- Sentence 3: SVP's tenure and experience → MR
- Sentence 4: Audit committee oversees, management reports semi-annually → BG

It's roughly split. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. This describes the oversight chain from board (audit committee) through management (SVP) back to board reporting. I'll go BG.

Specificity:
- "audit committee" → NOT firm-specific (every company has one)
- "Senior Vice President – Technology Solutions" → This is a VP-level title whose specific naming and the focus on this individual's tenure and experience makes it more firm-specific than a generic governance role.
- "reports directly to our President" → reporting line, firm-specific organizational detail
- "over four years" in role → lower bound, verifiable (≥4 years)
- "more than 25 years of experience" → lower bound, verifiable (≥25)
- "more than ten years with the Company" → lower bound, verifiable (≥10)
- "semi-annual basis" → specific cadence but generic

The verifiable lower bounds on tenure and experience, combined with the specific title and reporting relationship, push this toward Level 4.


fact: References 'integrity, confidentiality, and availability' (CIA triad)

specificity_confidence: medium

reasoning: The paragraph describes the purpose and scope of the company's cybersecurity measures (safeguarding systems, networks, data), answering what the program does, albeit at a very high level. The explicit reference to 'integrity, confidentiality, and availability'—the CIA triad—is a domain-specific concept that a non-security ERM professional would not naturally invoke, elevating specificity to Level 2.

thinking:
Classify this paragraph.

This is generic introductory language about cybersecurity commitment. No specific practices, no domain terms, no firm-specific facts.

Category: Risk Management Process? Or None/Other? It mentions "cybersecurity measures" designed to safeguard systems - but it's extremely generic. Let me think... It's describing the company's commitment and purpose of their cybersecurity measures. It's so generic it could be N/O, but it does reference "cybersecurity measures" as a topic. It answers "what does the cybersecurity program do?" albeit very generically.

Actually, "integrity, confidentiality, and availability" - the CIA triad - is a domain term. That passes the ERM test - a non-security ERM professional wouldn't naturally use "integrity, confidentiality, and availability" as a specific grouping. That's the CIA triad, a fundamental cybersecurity/infosec concept.

So this lands in Risk Management Process because it describes what their cybersecurity measures accomplish, and the CIA triad reference elevates it to Level 2 specificity.


reasoning: This is a blank check company (SPAC) explicitly stating it has no operations, no personnel, and no cybersecurity processes of its own, falling squarely under the N/O rule for no-operations companies. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: SPAC/blank check company with no operations, no personnel, no cybersecurity program.


fact: Senior Director - Information Security

fact: over 15 years' experience in information technology and cybersecurity

fact: information security architecture (domain expertise area)

fact: CISO Academy Workshop completed

reasoning: The paragraph is entirely about the qualifications, credentials, education, and career history of the Senior Director - Information Security, making it a clear Management Role paragraph. Multiple externally verifiable facts drive specificity to Level 4: 'over 15 years' experience' (lower-bound verifiable), a named degree from Ohio Wesleyan University, and the Information Systems Auditor certification (verifiable via ISACA).

thinking:
Classify this paragraph.

This is about the qualifications and experience of the Senior Director - Information Security. It's about a person's role, qualifications, credentials, and career history → Management Role.

Specific facts:
- "Senior Director - Information Security" — named role with security qualifier at director level → firm-specific
- "over 15 years' experience in IT and cybersecurity" — lower bound, verifiable → QV
- "over 15 years' experience in auditing information security" — lower bound, verifiable → QV
- "CISO Academy Workshop" — named program → firm-specific

- "BA in math and computer science from Ohio Wesleyan University" — named institution, verifiable → QV
- "Information Systems Auditor certification" (CISA) — verifiable certification → QV
- "information security architecture" — domain term


reasoning: This is a generic introductory statement about the company's commitment to cybersecurity with no substantive disclosure — no processes, oversight structure, materiality assessment, or program details. It reads as a preamble/header sentence. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

This is a generic statement about cybersecurity commitment. No specific processes, roles, or facts.

Category: Strategy Integration? Let me check - "cybersecurity is a fundamental aspect of our operational strategy" - this talks about how cybersecurity fits into business strategy. But it's extremely generic. Actually, it's more of an introductory/header statement. Let me think...

It mentions "operational strategy" and "protection of information assets, continuity of operations, trust of stakeholders" - but this is just a generic opening statement. There's no materiality assessment, no specific business impact. It's really just a preamble.

Since it's essentially a header with no substantive content, I'm leaning toward Not Obligatory rather than Strategy Integration, even though it references strategy. The language is pure boilerplate—no domain-specific terminology, no firm-specific details, nothing that could actually be verified.


reasoning: The opening sentence delivers a materiality assessment — 'not aware of any cybersecurity threats that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition' — which is the SEC Item 106(b)(2) backward-and-forward-looking conclusion, squarely SI. The remainder is speculative disclaimer and generic insurance mention. No domain terms pass the ERM test, no firm-specific facts, and the negative materiality assertion is not externally verifiable, so specificity stays at Level 1.

thinking:
SI materiality assessment + speculative language + insurance mention.

First sentence: "not aware of any cybersecurity threats that have materially affected or are reasonably likely to materially affect us" → This is a materiality assessment (both backward and forward-looking) → SI.

Rest is speculative/disclaimer language.

Primary: SI (materiality assessment is the key substantive claim).

Specificity: The materiality statement is a negative self-assertion — not externally verifiable. "cybersecurity insurance" mentioned but generic. No domain terms passing ERM test. No firm-specific facts. No verifiable claims.

The materiality claim itself doesn't elevate this beyond generic boilerplate — it's a standard negative assertion without concrete details or firm-specific context.


reasoning: The paragraph's central assertion is a materiality-adjacent self-assessment: acknowledging potential material adverse consequences and stating no cybersecurity incidents since IPO. The negative assertion ('have not encountered any cybersecurity incidents') is a backward-looking materiality statement pushing toward SI. However, as a SPAC with no operations and no cybersecurity program described, the content is entirely generic speculation and self-reported negatives with no domain terms, firm-specific facts, or verifiable claims, yielding Generic Boilerplate.

thinking: SPAC with no real operations.


fact: Incident Response Team includes SVP Finance and General Counsel

fact: Senior Director, Information Technology role with cybersecurity responsibility

fact: incident response, cybersecurity assessment, breach notifications

fact: over twenty years of experience in IT, security and cybersecurity

reasoning: The paragraph primarily describes who is responsible for cybersecurity (Senior Director IT, Incident Response Team composition, qualifications), making it MR by the person-removal test—removing roles and qualifications leaves little substance. Specificity reaches Level 4 because 'over twenty years of experience' is a verifiable lower bound.

thinking:
Let me analyze this paragraph.

Content: Describes management roles (Senior Director IT, Incident Response Team members including SVP Finance and General Counsel), their responsibilities, support from external providers, and the Senior Director's qualifications (20+ years experience).

Category: This is about management organization and roles. The person-removal test: remove names, titles, qualifications, team composition - what remains? "primarily responsible to assess and manage our material risks from cybersecurity threats" and mention of external providers monitoring/assessing threats. The core content is about WHO is responsible and their qualifications. → MR

Now I'm checking whether these specific roles and titles qualify as firm-specific. The Senior Director of IT role doesn't have a security qualifier, so it wouldn't meet the threshold for firm-specific designation. The Incident Response Team is named and firm-specific, but the SVP Finance and General Counsel are portfolio-based roles without IT or cybersecurity focus, so they don't qualify either. whose portfolio includes IT, cybersecurity, or information security." SVP Finance doesn't qualify.
- "General Counsel" - generic role, not firm-specific
- "managed service provider" and "incident response provider" - unnamed, not firm-specific
- "over twenty years of experience" - this is a lower bound, verifiable (≥20 years). This counts as QV.
- Cybersecurity assessment and prevention, incident responses, breach notifications, remediation - these are domain terms

So the Incident Response Team with its specific composition of SVP Finance and General Counsel is firm-specific, while "over twenty years of experience" provides a verifiable lower bound that qualifies as QV. This puts it at Level 4 specificity.


fact: Program based on ISO 27001

fact: Program based on NIST 800-53

fact: GDPR frameworks referenced

reasoning: The paragraph primarily answers what the cybersecurity program does — frameworks adopted, threat identification processes, countermeasures, and monitoring — making it RMP. Third parties and board reporting are mentioned but subordinate. Named frameworks (ISO 27001, NIST 800-53, GDPR) pass the ERM test as domain-specific references, elevating to Level 2, but 'based on' rather than 'certified' prevents verifiability, and no firm-specific facts (no named roles, teams, or unique identifiers) are present.

thinking:
Let me classify this paragraph.

Category: This describes what the cybersecurity program does - frameworks, tools, processes, threat identification, countermeasures. Primary question: "What does the cybersecurity program do?" → RMP. There's mention of third parties but it's not the central topic. There's mention of informing the board but that's subordinate.

Specific facts:
- ISO 27001 (framework reference, domain term)
- NIST 800-53 (framework reference, domain term)
- GDPR (framework/regulation reference, domain term)

- The countermeasures and mitigation strategies mentioned are generic, but the named frameworks elevate this to Level 2 domain-adapted specificity. These are standards rather than certifications, and "based on" doesn't indicate verified compliance, so the specificity caps out there.


reasoning: The paragraph describes board and Audit Committee oversight of cybersecurity risk, directly answering 'how does the board oversee cybersecurity?' → Board Governance. The language is entirely generic — 'Board,' 'Audit Committee,' 'assessing and managing risk,' 'may review' — with no domain terms, firm-specific facts, or verifiable claims. The hedging 'may review' further underscores the boilerplate nature.

thinking:
Classify this paragraph.

Category: Board/Audit Committee oversight of cybersecurity risks → Board Governance

Specificity: "Board", "Audit Committee" - generic governance roles every company has. "may review" is weak/hedging. No domain terms, no firm-specific facts, no verifiable claims. This is generic boilerplate.


fact: vulnerability management

reasoning: The paragraph centers on the Principal Accounting Officer's responsibilities—receiving reports, working with the incident response team, and assessing materiality—making it primarily about a management role in cybersecurity oversight. The person-removal test leaves little substantive program description beyond generic escalation. 'Vulnerability management' is a domain-specific security practice that passes the ERM test, elevating to Level 2, but the Principal Accounting Officer is a generic corporate role (not a VP+ security title), so it does not reach firm-specific.

thinking:
Let me analyze this paragraph.

Category: This describes how incidents escalate to management and what the Principal Accounting Officer does. The person-removal test: remove "Principal Accounting Officer" and "incident response team" - what remains? Escalation processes, regular reports on cybersecurity measures, mitigating/remediating incidents, assessing materiality. There's a mix of management role and process. But the primary focus is on the Principal Accounting Officer's role - receiving reports, working with the team, assessing materiality. The grammatical subject is the PAO and what they do. This feels like MR - it's about who is responsible and how they're organized.

Now I'm checking whether these terms are firm-specific. "Principal Accounting Officer" is a generic corporate role, not a specialized cybersecurity position, so it doesn't qualify as firm-specific. Same with "incident response team" - that's standard terminology. But "vulnerability management" is a recognized domain term that passes the ERM test, while "incident response" is flagged as commonly confused terminology that stays at L1.


reasoning: The paragraph states a backward-looking materiality conclusion ('not aware of any cybersecurity threats that have materially affected or are likely to affect us, including our business strategy, results of operations or financial condition'), which is the SEC Item 106(b)(2) assessment → SI. No domain terms, firm-specific facts, or verifiable claims are present; the negative materiality assertion is a self-reported claim about absence and is not externally verifiable.

thinking: SI materiality rule applies here.


reasoning: The paragraph primarily answers who is responsible for cybersecurity and what qualifies them — the CCO's responsibility, management's qualifications (advanced degrees, unspecified certifications), and how they stay informed. The person-removal test leaves little substantive program description. No domain-specific cybersecurity terms pass the ERM test ('prevention, detection, mitigation, and remediation' is standard risk language), no named certifications or specific roles beyond CCO (a generic corporate role, not cybersecurity leadership), and no verifiable facts.

thinking:
Let me analyze this paragraph.

Category: This is about management's role - responsibilities, qualifications, expertise. The person-removal test: remove names/titles/qualifications and what remains? "monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents" and "receipt of notifications from service providers and reliance on communications with risk management, legal, information technology, and/or compliance personnel." Some program activity remains but the primary focus is on who is responsible and their qualifications. This is MR.

Specific facts:
- CCO (Chief Compliance Officer) - this is a named role but is it VP-level or above? CCO is typically a C-suite role.

Now I'm reconsidering whether CCO counts as firm-specific. The rules exclude generic governance roles like Board, Audit Committee, CEO, CFO, and General Counsel, and they specifically flag cybersecurity leadership roles like CISO, CTO, and CIO as firm-specific. CCO isn't a cybersecurity-focused role, so it falls into the same category as General Counsel - a standard corporate position that's not firm-specific.

- "advanced degrees in business administration and legal studies" - generic qualifications
- "industry certifications focused on financial services and information technology,

Looking at the rest of the language, the certifications are mentioned but never specifically named, making them unverifiable. The departments referenced—risk management, legal, IT, compliance—are described generically without firm-specific details. The domain terms like "prevention, detection, mitigation, and remediation" are broad enough that any ERM professional could apply them to any risk type, not just cybersecurity. "Information security" itself is vague boilerplate. Overall, this reads as Level 1 generic management language without concrete cybersecurity expertise or firm-specific facts.


fact: IT Security Steering Committee (named management-level committee)

fact: Committee led by Chief Financial Officer

fact: VP of Software Engineering on the committee

fact: Director of Information Systems and Security on the committee

fact: IT Security Team (named team)

fact: Collectively over 40 years of experience

fact: Vulnerability testing and monitoring

reasoning: The paragraph primarily describes the organizational structure of cybersecurity management—committee composition, membership, leadership, and team roles—making it MR despite some RMP activities (testing, monitoring, training) appearing in subordinate clauses. The 'over 40 years of experience' claim is a verifiable lower bound, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes a management-level committee (IT Security Steering Committee) and its composition, leadership, and the IT Security Team. It covers roles, responsibilities, qualifications, and some program activities.

Using the person-removal test: Remove CFO, VP of Software Engineering, Director of Information Systems and Security, 40 years experience, team composition. What remains? "oversight of cybersecurity risk", "administration of our cyber program", "works with various vendors and external providers to test and monitor for vulnerabilities and threats", "employees to complete annual security and awareness training." Some program description remains but the paragraph is primarily about the organizational structure - who leads, who's on the committee, who's on the team.

The paragraph splits between organizational structure and actual program activities, but most of the content focuses on the committee membership and leadership roles. Looking at the specific facts, I see firm-specific details like the named committee, the CFO's leadership role, and the specific VP and Director titles. The "over 40 years of experience" is a quantified claim that's verifiable. The vulnerability testing and security awareness training are the only domain-specific activities mentioned, though they're brief. Given the heavy emphasis on who's involved rather than what they do, this is clearly MR.

The "over 40 years of experience" pushes this to Level 4 because it's a lower bound that can be verified.


fact: Chief Information Officer (CIO) holds periodic executive sessions with the Board on cybersecurity

reasoning: The paragraph primarily answers how the board oversees cybersecurity—describing Board reviews, management updates, and executive sessions with the CIO—making it Board Governance. The CIO is a VP-level+ role in cybersecurity context, elevating specificity to Firm-Specific, but no verifiable claims (specific numbers, dates, certifications) are present.

thinking:
Classify this paragraph.

The paragraph describes board oversight of cybersecurity risks, including reviews, updates from management, and sessions with the CIO. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- CIO (Chief Information Officer) — named role, firm-specific (VP-level+)
- "key risk indicators" — this is an ERM term, not cybersecurity-specific
- "emerging risks" — generic

The CIO is a firm-specific fact (Level 3). No verifiable claims.


reasoning: The paragraph describes how the Board will oversee cybersecurity risk management and how a committee or appointed officer will review policies — answering the board oversight question. All language is generic and aspirational ('will oversee', 'a dedicated committee or an officer'), with no domain terms passing the ERM test, no firm-specific details, and no verifiable claims.

thinking:
Classify this paragraph.

This is about board oversight of cybersecurity - future tense ("will oversee"), describing governance structure. Category: Board Governance.

Specificity: No domain terms beyond generic "cybersecurity risk management framework" and "policies, strategies and risk management practices." No firm-specific facts (just "the Board" and generic committee/officer references). No verifiable claims. This is generic boilerplate language - any company could write this.

Level 1.


reasoning: The paragraph describes using a third party to assess the company's cybersecurity risk management processes; per Rule 3, third parties hired to serve the company (assessors) → RMP. The language is entirely generic ('processes and practices for managing and mitigating cybersecurity risks') with no domain terminology passing the ERM test, no firm-specific details, and no verifiable claims.

thinking:
Classify this paragraph.

Content: Uses a third party to help assess processes for managing cybersecurity risks. This is about risk management process - the third party is hired to serve the company (assessor), which per Rule 3 → RMP.

Specificity: No domain terms beyond generic "cybersecurity risks," "risk management." No firm-specific facts. No verifiable claims. This is generic boilerplate.


reasoning: The paragraph states a conclusion about whether cybersecurity has or is likely to materially affect business strategy, results of operations, or financial condition — a backward-looking and forward-looking materiality assessment triggering SI under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present; the negative assertion about no material incidents is not externally verifiable per the rules.

thinking:
Materiality assessment - "no cybersecurity incident that has or is likely to materially affect us" → SI per Rule 5.

Negative assertion about no material incidents - not externally verifiable per the rules.

No domain terms, no firm-specific facts, no verifiable claims.

Wait - "vendors and government agencies that we rely on" - not firm-specific enough. This is generic.

Level 1.


reasoning: This is a standard SEC Item 106(b)(2) materiality conclusion stating that cybersecurity risks have not materially affected and are not reasonably likely to materially affect the company — a backward-and-forward-looking assessment → SI. No domain terms, firm-specific facts, or verifiable claims are present; the negative materiality assertion is a self-reported claim not externally verifiable.


reasoning: The paragraph's central topic is how third-party vendor cybersecurity risks are managed—assessments, policy alignment—making it Third-Party Risk. The language is entirely generic ('rigorous cybersecurity risk assessments,' 'robust policies,' 'align with our standards') with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Category: This is about how third-party cyber risks are managed - vendor assessments, ensuring alignment with standards. Third-party risk management is the central topic. → Third-Party Risk

Specificity: Let me scan for facts.
- "rigorous cybersecurity risk assessments" - generic process description
- "vendors and business partners with access to our networks or sensitive information" - generic
- "third-party cybersecurity policies are robust and align with our cybersecurity standards" - generic

No domain terms that pass ERM test, no firm-specific facts, no verifiable claims.

The paragraph is just generic vendor oversight language. "The Sponsor" appears as a firm-specific reference tied to fund structure, but that's standard terminology in the industry, not truly distinctive. This lands at Level 1.


content_category: Incident Disclosure

fact: ransomware attack

fact: January 18, 2023 announcement date

fact: fewer than 300 restaurants closed in one market for one day

fact: personal information of former and current employees was taken

reasoning: The paragraph describes a real ransomware incident with timeline, scope, and impact details, making it clearly Incident Disclosure. Specificity reaches Level 4 due to the specific date (January 18, 2023) and quantified impact (fewer than 300 restaurants), both externally verifiable claims.

thinking: Incident disclosure - describes a real ransomware attack with specific details.


fact: Named individual Mr. Tao in cybersecurity governance context

fact: More than 20 years of professional experience (verifiable lower bound)

reasoning: Paragraph describes qualifications and career background of a named individual (Mr. Tao) within Item 1C, making it a Management Role paragraph about who is responsible and what qualifies them. 'More than 20 years' sets a verifiable lower bound on experience, elevating specificity to Quantified-Verifiable.

thinking:
Classifying this paragraph about Mr. Tao's experience.

This describes a person's qualifications/experience. It's about a management role's background. Category: Management Role.

Specific facts:
- "more than 20 years of professional experience" — quantified, verifiable (lower bound ≥ 20 years)
- But wait — this is about business consultation/operations/management with focus on marketing. No cybersecurity connection at all.

Actually, is this even cybersecurity content? It's about marketing industry experience. In context of Item 1C, companies sometimes describe their leadership even if not cyber-specific.

So the key verifiable claim here is the "more than 20 years" experience threshold for Mr. Tao, which is a firm-specific reference to a named individual in the cybersecurity governance context of Item 1C.


fact: Incident occurred in fourth quarter of fiscal 2025

fact: incident response plan activated

fact: systems proactively taken offline as containment measure

fact: Named incident: 'Cybersecurity Incident'

fact: Customer order fulfillment and distribution temporarily impacted

fact: Reduced sales volume and increased operational costs in Q4 fiscal 2025

reasoning: The paragraph describes a real cybersecurity incident — unauthorized activity, containment, operational impact, and financial consequences — making it primarily Incident Disclosure (with some SI elements, but the incident narrative dominates per Rule 4). Specificity is Firm-Specific due to the named 'Cybersecurity Incident' and firm-specific operational details (order fulfillment disruption, Q4 fiscal 2025 timing), but no externally verifiable hard numbers or named third parties push it to Level 4.

thinking: Incident disclosure with financial impact discussion.


reasoning: The paragraph primarily describes what the cybersecurity program does — evaluating safeguards, monitoring, testing, and training — making it RMP. The IT leadership → CEO reporting line is secondary context. All language (risk assessments, safeguards, monitor and test, train employees) is standard ERM vocabulary; CEO and 'IT leadership' are generic roles, and 'human resources, IT, and management' is not a distinguishing team composition, so nothing elevates above Level 1.

thinking:
Classify this paragraph.

Category: This describes risk assessment follow-up, safeguard implementation, monitoring, testing, training. There's a mention of IT leadership reporting to CEO. The primary question answered is "What does the cybersecurity program do?" → RMP. The reporting line (IT leadership → CEO) is secondary.

Specific facts:
- "IT leadership" - not VP+ named role
- "Chief Executive Officer (CEO)" - generic role every company has
- "human resources, IT, and management" - specific team composition? This is pretty generic actually.

Person-removal test: Remove "IT leadership reports to CEO" - substantial program description remains about safeguards, monitoring, testing, training → RMP.

The language here is entirely generic—risk assessments, safeguards, monitoring, testing, and employee training are all standard ERM terminology with no firm-specific details. The CEO reference is universal, and IT leadership without a security title doesn't add specificity. This is Level 1.


fact: Deputy Chief Executive Officer and Chief Financial Officer manages cybersecurity program

fact: external IT team

fact: more than seven years of operational responsibility for IT

reasoning: The first sentence describes board oversight (BG), but the majority of the paragraph details management's organizational roles, responsibilities, and qualifications — making MR the dominant category. Specificity reaches Level 4 because 'more than seven years' of IT operational responsibility is a lower-bound quantified claim (≥7) that is externally verifiable against the individual's career history.

thinking:
Classify this paragraph.

Content: Board oversight + management roles (Deputy CEO/CFO, external IT team) with responsibilities and experience.

Category: This is a governance-chain paragraph. It starts with board oversight (BG) then shifts to management roles. The bulk describes management organization - who manages the program, their responsibilities, qualifications. Applying Rule 1: it's a mix. The first sentence is BG, but the rest is about management's organizational role. The majority of text is about management roles → MR.

Wait, let me re-read. First sentence: board oversight (BG). Rest: Deputy CEO/CFO manages program, responsibilities, 7+ years experience, manages external IT team.

That's clearly MR content with more text devoted to it. I'm identifying the specific facts here: the Deputy Chief Executive Officer and Chief Financial Officer is a named firm-specific role at VP+ level, the "more than seven years" of IT operational responsibility is a quantified lower bound that's verifiable, and the external IT team reference is another firm-specific organizational detail. The "more than seven years" qualifier makes this a quantified value per the rules, so this lands at Level 4.


reasoning: The paragraph centrally addresses how cybersecurity risks from third-party suppliers/vendors/service providers are identified and overseen, making Third-Party Risk the best fit. The language is entirely generic—'the Adviser' is an unnamed entity, the listed personnel types (risk management, legal, IT, compliance) are generic departments, and no cybersecurity domain terms or firm-specific facts appear.

thinking:
Classify this paragraph.

The paragraph discusses reliance on third parties and how the company oversees cybersecurity risks from those third parties, using the Adviser's personnel. The central topic is managing third-party cyber risks, but it's quite generic.

Category: Third-Party Risk - the paragraph is about how third-party cyber risks are managed, relying on the Adviser's personnel.

Wait - let me reconsider. The first sentence is about dependence on third parties. The second sentence is about relying on the Adviser's personnel to identify and oversee risks from cybersecurity threats associated with third parties.

Third-Party Risk is the right classification. The specificity here is interesting - "the Adviser" is a firm-specific reference that identifies a particular organizational relationship unique to this BDC, even though it's a common structure in that context. The departments mentioned (risk management, legal, IT, compliance) are standard functions, and there aren't any specialized ERM terms that would elevate the specificity further.

Actually, reconsidering - "the Adviser" functions more like an unnamed entity reference, similar to how "external consultants" would be treated. It's a generic role without a specific name attached, so it doesn't cross into firm-specific territory. No domain terminology passes the ERM test here either. This lands at Level 1.


fact: CISSP (Certified Information Systems Security Professional) certification

fact: CCSP (Certified Cloud Security Professional) certification

fact: penetration testing

fact: email phishing test campaigns

fact: email security monitoring

fact: real-time vulnerability scanning

fact: intrusion detection

fact: information security management system

reasoning: Person-removal test: removing the Director's name/qualifications leaves a substantial program description (penetration testing, vulnerability scanning, intrusion detection, phishing campaigns, etc.), so this is RMP. Specificity is Level 4 because CISSP and CCSP are named certifications verifiable via (ISC)² registry.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the information security team leader and then extensively describes what the program does. Person-removal test: remove "Director of Information Security and Privacy" and their qualifications - a substantial program description remains (penetration testing, incident response, phishing tests, vulnerability scanning, etc.). → RMP

Specificity: Let me list facts:
- "Director of Information Security and Privacy" — named role with security qualifier, firm-specific
- "decades of experience" — soft number, not verifiable
- "CISSP" — verifiable certification

- "CCSP" — verifiable certification
- Penetration testing, incident response plans, phishing test campaigns, email security monitoring, vulnerability scanning, intrusion detection — domain terms

Both CISSP and CCSP are externally verifiable credentials, which puts this at Level 4.


reasoning: The paragraph makes backward-looking materiality assessments ('has not experienced any material cybersecurity events' and third-party incidents 'have not resulted in a material impact'), which are conclusions about whether cybersecurity has affected business outcomes → SI per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present; negative self-assertions about absence of incidents are not externally verifiable → Level 1.

thinking:
Classify this paragraph.

The paragraph states conclusions about whether cybersecurity has affected the business - "has not experienced any material cybersecurity events" and third-party incidents "have not resulted in a material impact." These are backward-looking materiality assessments → Strategy Integration per Rule 5.

Specificity: "has not experienced any material cybersecurity incidents" is a negative self-assertion, NOT externally verifiable. No domain terms, no firm-specific facts, no verifiable claims. Level 1.


reasoning: This is a fragment of a risk factor title or cross-reference, containing no substantive cybersecurity disclosure. No specific facts are present.

thinking: This is a fragment of a risk factor title/cross-reference, not substantive cybersecurity disclosure.


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

fact: TISC meetings referenced as a distinct named committee

fact: ERMC reports to Audit and Risk Committee quarterly

reasoning: The paragraph describes a management-level committee (ERMC) — its structure, membership composition, responsibilities, reporting lines, and leadership — making it MR per Rule 1. Named non-generic committees (ERMC, TISC) are firm-specific facts elevating this to Level 3.

thinking:
Let me analyze this paragraph.

Content: Describes the ERMC committee - its responsibilities, composition, reporting to Audit and Risk Committee, and leadership.

Category: This is about the ERMC, which is a management-level committee. It describes oversight structure - reporting to the Audit and Risk Committee quarterly. The ERMC reviews cyber risk, reports to the Audit and Risk Committee. Per Rule 1, management-level committees → MR if about structure/membership. This paragraph is about the ERMC's structure, membership, and reporting lines. But it also describes what the ERMC does (reviews cyber risk exceptions, emerging risks, minutes from TISC meetings).

The governance chain here is ERMC reporting to the Audit and Risk Committee, making it a management-level committee with clear structural and reporting responsibilities. Rule 1 indicates that governance-chain paragraphs describing oversight structure default to BG, but management-level committees focused on structure and membership lean toward MR. Since the ERMC is clearly management-level and the paragraph emphasizes its organizational role and composition, this should be categorized as MR.

For specificity, the ERMC and TISC are both named, non-generic committees specific to this firm, while the Director of Enterprise Risk Management title lacks VP+ status and security qualifications, so it doesn't meet the firm-specific threshold. The CRO role is generic, and quarterly reporting is standard cadence. This puts the specificity at Level 3.


reasoning: Per Rule 3, third parties hired to serve the company (assessors, consultants providing testing/advisory) are RMP, not TP. The language is entirely generic ERM ('assessing, identifying and managing material risks,' 'testing and advisory services') with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: About engaging third-party consultants for cybersecurity program - assessing, identifying, managing risks, testing, advisory services.

Category: These are third parties hired to serve the company (assessors, pen testers) → RMP per Rule 3.

Specificity: No domain terms beyond generic language. "Testing and advisory services" is generic. "Assessing, identifying and managing material risks" is generic ERM language. No firm-specific facts, no verifiable claims.

Level 1.


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors, with no substantive cybersecurity disclosure. No specific facts of any kind are present.

thinking: Cross-reference to Risk Factors, no substantive cybersecurity content.


reasoning: The paragraph is introductory framing: it states the company relies on AB/Adviser technology, lists generic cyber threats, and provides a dictionary-level definition of information security. No actual cybersecurity measures, processes, governance structures, or assessments are described—it sets context rather than answering any of the six substantive questions. As None/Other, specificity defaults to Generic Boilerplate.

thinking:
Classify this paragraph.

Content: General statements about relying on digital technology, mentioning cyber threats, and defining information security as a process. No specific program details, no board oversight, no management roles, no incidents, no materiality assessment.

Category: This is general context about cybersecurity risks and a generic definition of information security. It mentions "denial of service attacks" which is a domain term. But the paragraph doesn't really answer any of the six questions substantively. It's more of an introductory/contextual paragraph. However, it does describe what information security is designed to do - "protect corporate, client and employee information and systems from unauthorized access, destruction, disclosure, disruption and modification of use" - this is very generic.

I'm noticing the paragraph includes specific threat terminology like "denial of service attacks" and "cyber intrusions," but it's really just laying groundwork without describing actual processes or controls. The definition of information security itself is broad and foundational rather than substantive, which makes this feel like introductory material that's borderline between not offering enough detail or barely meeting the threshold. I'm going back and forth on this classification. The paragraph mentions specific threat types like denial of service attacks and cyber intrusions, which suggests some cybersecurity awareness, but it's really just defining what information security is in generic terms without describing any actual measures or processes the organization uses. I think None/Other is the right call here since there's no substantive disclosure of their cybersecurity program—just contextual framing and a dictionary-style definition.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not experienced a cybersecurity threat or incident that resulted in a material adverse impact'), which is an SI assessment per Rule 5. The cross-reference to Risk Factors is secondary. No domain terms, firm-specific facts, or verifiable claims are present; the negative materiality assertion is a self-reported claim about absence.

thinking:
Materiality assessment + cross-reference.

First sentence: "have not experienced a cybersecurity threat or incident that resulted in a material adverse impact" — this is a backward-looking materiality conclusion → SI per Rule 5.

Second sentence: cross-reference to Risk Factors → N/O element.

Primary: SI (the materiality assessment is the substantive content).

Specificity: The negative materiality assertion is not externally verifiable. No domain terms, no firm-specific facts beyond the filing context. Level 1.


reasoning: The paragraph opens with a backward-looking materiality assessment ('have not materially affected') and forward-looking SEC 106(b)(2) language ('reasonably likely to materially affect'), making SI the primary category per Rule 5. The remainder is generic speculation ('could have a material adverse effect' type language) and a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: SI - materiality assessment statement plus cross-reference.


fact: Vice President of Information Systems leads cyber risk management program

fact: VP of Information Systems reports directly to CFO

reasoning: The paragraph primarily answers how the board oversees cybersecurity: Audit Committee oversight, Board of Trustees updates, reporting flows from VP of IS to committees, and incident escalation procedures. While the VP of IS role is mentioned, the bulk of the content describes the oversight chain. Specificity is Firm-Specific due to the VP of Information Systems title (VP-level with IT portfolio) and the specific reporting line to CFO.

thinking:
Let me analyze this paragraph.

Category: This describes the governance chain from VP of IS → CFO → Audit Committee → Board. It's about oversight structure - how information flows to the board, committee oversight, reporting lines. The primary question answered is "How does the board oversee cybersecurity?" Even though it mentions the VP of IS role, the bulk is about board/committee oversight. → Board Governance

Specific facts:
- "Vice President of Information Systems" — named role (VP-level with IT portfolio) → firm-specific
- "Chief Financial Officer" — generic role, every company has one → not firm-specific
- "Audit Committee" — generic, every company has one → not firm-specific

- "Board of Trustees" — generic governance structure → not firm-specific
- VP of IS reports directly to CFO — this is the firm-specific reporting line detail
- "response plan" — generic term

The VP of Information Systems title with its IT portfolio scope is what pushes this to Level 3, since that's the only firm-specific element that distinguishes their governance structure.


reasoning: The paragraph is centrally about how BioMarin manages cybersecurity risks from third-party service providers—onboarding assessments, contract renewal reviews, and contractual obligations—making Third-Party Risk the clear category. The language is entirely generic process description (risk assessments, vendor management, contractual obligations) that any ERM professional could produce without cybersecurity domain knowledge, yielding Level 1.

thinking:
Classify this paragraph.

Content: About third-party vendor cybersecurity risk management - onboarding assessments, contract renewal assessments, vendor management process, contractual obligations. Central topic is third-party risk management.

Category: Third-Party Risk (TP) - this is centrally about how third-party cyber risks are managed.

Specificity: Let me scan for facts.
- "research collaborators, contract research organizations, contract manufacturers, suppliers, and distributors" - these are specific types of third parties but fairly generic
- "cybersecurity risk assessments at the time of onboarding and upon contract renewal" - process description, generic

- "contractual obligations related to cybersecurity" - also generic

There's no domain-specific terminology, no company-specific details, and no verifiable claims here—just standard vendor risk management language. This rates as Level 1.


reasoning: The paragraph's primary assertion is a materiality conclusion — 'we have not had any material incidences involving cybersecurity attacks' — which is a backward-looking assessment of business impact, triggering SI under Rule 5. The remainder is generic speculation ('could have a material adverse effect') and a cross-reference to Risk Factors. No domain terms pass the ERM test, the date is a reporting-period anchor not a cybersecurity fact, and the negative self-assertion is not externally verifiable, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph states "As of December 28, 024, we have not had any material incidences involving cybersecurity attacks" — this is a negative assertion about material incidents, which per Rule 5 is SI (backward-looking assessment).

Then it has speculative language about future risks and a cross-reference to Risk Factors.

The primary content is the materiality assessment — "have not had any material incidences" → SI.

Specificity: The negative self-assertion "have not experienced any material cybersecurity incidents" is NOT externally verifiable per the rules.

The date itself is just a reporting period marker with no domain-specific or company-specific details — that's Level 1 classification.


reasoning: The paragraph describes what the cybersecurity program does (asset identification, assessment, monitoring, classification) making it RMP. The language is entirely generic — 'identify, assess, monitor, classify risks and inform mitigation efforts' could describe any enterprise risk domain and passes the ERM test as non-domain-specific.

thinking:
Classify this paragraph.

This describes elements of a cybersecurity risk management program - asset identification, assessment, monitoring, classification. These are program activities.

Category: Risk Management Process

Specificity: Let me check for domain terms. "Asset identification, assessment, monitoring, and classification procedures" - is this domain-adapted? The ERM test: would a non-security ERM professional use "asset identification... and classification procedures"? Asset classification is somewhat security-specific but "identification, assessment, monitoring" are generic. Actually, asset classification in cybersecurity context is somewhat domain-specific but this is borderline. The phrase is quite generic - "evaluate cybersecurity risks and inform mitigation efforts" is standard ERM language.

The language here is boilerplate without specific frameworks, tools, or company details, so this rates as Level 1 specificity.


reasoning: The paragraph describes incident response escalation processes, team designation, and reporting requirements — applying the person-removal test, substantive process description remains after removing the CFO reference, pointing to RMP over MR. Specificity stays Level 1 because 'incident response' is on the commonly-confused list, CFO and Audit Committee are generic governance roles (not firm-specific), and no domain terms pass the ERM test — the language is entirely generic process description any ERM professional could produce.

thinking:
Classify this paragraph.

The paragraph describes incident response processes, escalation, a cybersecurity incident response team, and reporting to the audit committee. The primary question answered is about how the cybersecurity program works (incident response processes) but also touches on governance (reporting to audit committee) and management organization.

Let me apply the "what question" test. The paragraph describes: escalation processes, incident response team composition, and reporting to audit committee. This is primarily about the incident response process structure - who's involved and how it flows. It's a governance-chain paragraph. The purpose seems to be describing the oversight/response structure.

Actually, looking more carefully: the paragraph describes incident response processes (RMP activity) but frames it through organizational structure (who is on the team, reporting lines).

Applying the person-removal test, if I strip out the team composition and reporting lines, the core process description remains intact—escalation, mitigation, remediation, and audit committee reporting all stay substantive. That confirms this is fundamentally about the incident response process itself, so RMP is the right classification. The team structure and reporting lines are supporting details that contextualize how the process operates, not the main point. The CFO being part of the incident response team is a specific composition detail, which could count as firm-specific, but the overall language here is generic process description—"incident response" itself is on the commonly-confused list for Level 1. Looking at the actual terms used like "escalate," "mitigate," and "remediate," these are all standard boilerplate that any ERM professional would write. I'm settling on Level 1 for this section since there aren't any domain-specific terms that pass the ERM test.


reasoning: The paragraph is split between describing consultants hired to serve the company's program (RMP) and requirements imposed ON those service providers—certification of security capabilities, maintaining security measures, and breach reporting obligations—which tilts the central topic toward Third-Party Risk per Rule 3. Specificity is Level 1 because the language ('risk assessment processes,' 'appropriate security measures,' 'monitoring and testing safeguards,' 'promptly report any suspected breach') is entirely generic and would work identically in any non-cyber vendor risk context, failing the ERM test.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party service providers in two contexts: (1) consultants helping with risk assessment, policy design, monitoring/testing - these are third parties hired to serve the company → RMP per Rule 3; (2) requirements imposed on third-party providers regarding security measures and breach reporting → TP per Rule 3.

The paragraph is split. First half: consultants assisting with cybersecurity program (RMP). Second half: requirements imposed on third-party providers (TP). The TP content about requiring certifications, security measures, and breach reporting is substantial. But the first part is also substantial.

Looking more closely, the opening sentences describe how they use consultants to support their own risk assessment and program implementation—that's clearly RMP. But then the final sentence shifts to what they require of those third-party providers themselves, which is TP. The paragraph genuinely blends both perspectives: their use of third parties as part of their program, and their governance requirements imposed on those same vendors. The requirements on service providers—certification, security measures, breach reporting—push this toward Third-Party Risk, though it's genuinely close to a 50/50 split. Looking at the specificity now, the language stays pretty generic: "risk assessment processes," "cybersecurity policies," "monitoring and testing safeguards"—nothing that really requires security expertise to write. This reads like Level 1 content.


fact: VP Security role

fact: IT Risk and Compliance Team

reasoning: The paragraph describes organizational structure—Internal Audit's role, the IT Risk and Compliance Team's function, and its reporting line to the VP Security—answering how management is organized for cybersecurity. VP Security (VP-level role) and the named IT Risk and Compliance Team are firm-specific facts elevating to Level 3.

thinking:
Classify this paragraph.

Content: Describes Internal Audit performing audits and IT Risk and Compliance Team monitoring IT systems controls, reporting to VP Security.

Category: This is about management organization - specifically team structure and reporting lines. The IT Risk and Compliance Team reports to VP Security. This is about how management is organized. But let me apply the person-removal test: remove "VP Security" and "IT Risk and Compliance Team" - what remains? "performs audits" and "monitors certain IT systems controls integrated into our larger internal control environment." Some process description remains but it's thin. The primary content is about organizational structure (who does what, reporting lines). → MR.

The paragraph is fundamentally about how the organization structures its cybersecurity oversight, with the VP Security role and IT Risk and Compliance Team being firm-specific identifiers that confirm this is management reporting structure rather than generic process description. The specificity level is firm-specific due to the named roles and teams involved.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not identified any cybersecurity threats that have materially affected...') and a forward-looking assessment ('reasonably likely to materially affect'), making it SI under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present — the negative self-assertion about no material incidents is not externally verifiable, and the rest is generic disclaimer language and a cross-reference to Risk Factors.

thinking: SI materiality assessment + cross-reference to risk factors.


fact: Chief Information Officer leads the information technology team

fact: Cybersecurity governance committee

fact: Committee comprised of CFO, Chief Legal Officer, CIO, Head of Internal Audit, and senior IT team members

reasoning: The paragraph primarily describes who is responsible for cybersecurity and how they are organized — the CIO-led IT team, reporting lines to senior management/board, and the cybersecurity governance committee's membership and responsibilities. This is management organizational structure (MR). The cybersecurity governance committee is a non-generic named committee with specific composition (CFO, CLO, CIO, Head of Internal Audit), making it Firm-Specific, but no externally verifiable claims push it to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes management organization - roles, committee membership, reporting lines. The cybersecurity governance committee membership is detailed. There's some RMP content (developing policies, monitoring compliance) but the primary focus is on WHO is responsible and HOW they're organized. Person-removal test: remove CIO, CFO, CLO, Head of Internal Audit, team composition → the remaining is generic program description. But actually there's substantial organizational structure here. The paragraph is primarily about roles and committee structure → MR.

Wait, let me re-check. The paragraph describes:

1. IT team led by CIO with experience
2. IT team expertise and responsibilities (executing program, communicating with governance bodies)
3. Cybersecurity governance committee membership and responsibilities

This is about organizational roles and committee structure → MR.

Specificity:
- CIO (Chief Information Officer) → named_role, firm-specific
- CFO, CLO, Head of Internal Audit → these are generic governance roles... but wait, CFO/CLO are generic. However, the cybersecurity governance committee is a named non-generic committee → firm-specific
- "cybersecurity governance committee" → named_committee, firm-specific
- Committee composition: "Chief Financial Officer, Chief Legal Officer, Chief Information Officer, Head of Internal Audit and senior members of our information technology team" → specific

The committee's composition is defined by these specific executive roles and IT leadership positions.


fact: CISSP certification

fact: CISM certification

fact: CISA certification

fact: Previous cybersecurity leadership positions at Fortune 500 companies and U.S. Defense contractors

reasoning: The paragraph describes the management team's responsibilities, qualifications, and experience — primarily answering 'who handles cybersecurity and what qualifies them,' making it MR. Named certifications (CISSP, CISM, CISA) are independently verifiable via their issuing bodies, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Category: This is about management's role - their responsibilities, qualifications, experience. The person-removal test: remove names, titles, qualifications, experience → "monitors prevention, detection, mitigation and remediation... primary responsibility for cybersecurity risk management program... supervises internal and external consultants." Some program description remains but the primary focus is on who the team is and what qualifies them. It's MR.

Specific facts:
- CISSP certification → verifiable via (ISC)²

- CISM and CISA certifications are also named and verifiable through ISACA, while claims like "decades of experience" and references to "Fortune 500 companies" or "U.S. Defense contractors" lack the specificity needed for verification. Since the certifications are explicitly called out as verifiable, this lands at Level 4.


reasoning: The paragraph makes two explicit materiality assessments — a backward-looking conclusion ('have not identified material risks… that have materially affected us') and a forward-looking SEC 106(b)(2) statement ('reasonably likely to materially affect us') — squarely placing it in Strategy Integration. No domain terms, firm-specific facts, or verifiable claims are present; the cross-references to Risk Factors are generic pointers, leaving specificity at Level 1.

thinking:
This paragraph contains two materiality assessments and a cross-reference.

First sentence: backward-looking negative assertion about material impact → SI
Second sentence: forward-looking "reasonably likely to materially affect" → SI (SEC Item 106(b)(2))
Third sentence: cross-reference to Risk Factors → N/O

The dominant content is SI - two materiality assessments.

Specificity: No domain terms, no firm-specific facts, no verifiable claims. The cross-references to specific risk factor titles could be considered firm-specific. But these are just risk factor headings being referenced. Actually, the negative assertion "have not identified material risks" is not verifiable.

The "reasonably likely to materially affect" language is standard SEC boilerplate, so this is essentially Level 1 disclosure language overall.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers—vendor reviews, contractual obligations, assessments, inspections, questionnaires, and annual re-assessments—making Third-Party Risk the primary category. All language (vendor management, security assessments, contractual obligations, on-site inspections, questionnaires) passes the ERM test as standard risk management vocabulary any non-security professional would use, with no cybersecurity-specific domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes vendor management processes for cybersecurity - reviewing practices, contractual obligations, security assessments, on-site inspections, questionnaires, annual re-assessments. This is centrally about how third-party cyber risks are managed → Third-Party Risk.

Specificity: Let me scan for facts.
- "vendor management processes" - generic
- "reviewing cybersecurity practices" - generic
- "contractually imposing obligations" - generic
- "security assessments" - could be domain but pretty generic

- "on-site inspections" - generic
- "written questionnaires" - generic
- "annual re-assessments" - generic cadence

All of this is standard vendor management language that any ERM professional would recognize - nothing here demonstrates domain-specific cybersecurity knowledge. This is Level 1 - Generic Boilerplate.


fact: dedicated monitoring platform providing real time threat detection and mitigation

fact: prevention, detection, mitigation, and remediation of cybersecurity incidents

reasoning: The paragraph starts with management responsibility (CCO) but the person-removal test leaves substantial program content: third-party IT provider, dedicated monitoring platform with real-time threat detection, and incident monitoring processes — pointing to RMP. Specificity reaches Level 2 via domain terms like 'real time threat detection' and 'dedicated monitoring platform,' which pass the ERM test, but no firm-specific or verifiable facts elevate it further.

thinking:
Let me analyze this paragraph.

Content: Describes management's responsibility for cybersecurity, third-party IT provider, monitoring platform, and how management stays informed about incidents.

Category: This touches MR (management responsibility, CCO role) and RMP (monitoring platform, threat detection). Let me apply the person-removal test. Remove CCO reference - substantial content remains about the program activities (monitoring platform, real-time threat detection, prevention/detection/mitigation/remediation processes). So RMP.

Wait, but the paragraph starts with management responsibility and the CCO. Let me re-read. The paragraph describes: (1) management/CCO responsible for assessing risks, (2) third-party IT provider provides cybersecurity resources, (3) dedicated monitoring platform with real-time threat detection, (4) how management monitors incidents through notifications and communications.

Now I'm applying the person-removal test more carefully. If I strip out the CCO and management titles, what's left is the third-party IT provider, the monitoring platform with real-time threat detection, and the incident notification process—that's clearly substantial program description, pointing to RMP. Looking at the specific elements: the CCO is a named senior role, the monitoring platform and threat detection are domain-specific terms, and the team composition across risk, legal, IT, and compliance is firm-specific. The CCO appears to be a VP-level or equivalent officer role, which the rules flag as potentially person-focused.

But I need to reconsider whether CCO itself is firm-specific. The rules explicitly list CISO, CTO, CIO, and VP/SVP/EVP of IT as firm-specific cybersecurity roles. CCO—Chief Compliance Officer—isn't a cybersecurity-specific title; it's more of a generic governance role like General Counsel or CFO. Those generic corporate officer roles aren't considered firm-specific under the rules. So CCO probably shouldn't count as firm-specific either, even though it's a C-level position.

Now looking at the actual security capabilities mentioned: "real time threat detection" and "dedicated monitoring platform" both demonstrate domain knowledge and pass the ERM test. These push the specificity to Level 2 (Domain-Adapted).


reasoning: This is a forward-looking disclaimer about unpredictable future incidents plus a cross-reference to Item 1A Risk Factors — no substantive cybersecurity disclosure. No specific facts of any kind are present.

thinking: Forward-looking disclaimer with cross-reference to Item 1A.


reasoning: This is a backward-looking materiality assessment stating that cybersecurity has not materially affected business strategy, results, or financial condition — squarely SI under Rule 5. No specific facts elevate specificity: the negative assertion about no material incidents is a self-reported claim about absence, not externally verifiable.

thinking: Materiality assessment - negative assertion about incidents not materially affecting business.


reasoning: The opening sentence is a backward-looking materiality assessment ('has not identified any cybersecurity incidents which have materially affected...business strategy, results of operations or financial condition'), which is the SI trigger per Rule 5. The remaining sentences acknowledge the absence of specific policies and offer only vague statements about staying current and educating personnel—no domain terms, no firm-specific facts, no verifiable claims, keeping this at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph has three sentences:
1. "To date, the Company has not identified any cybersecurity incidents which have materially affected, or are reasonably likely to materially affect, the Company's business strategy, results of operations or financial condition." — This is a materiality assessment (SI per Rule 5).
2. "The Company has not implemented any specific policies with respect to monitoring and managing cybersecurity threats." — This is basically saying they have NO program.
3. "Moreover, the Company is aware of the evolution of cybersecurity risks and is taking proactive steps by keeping up to date our information systems and educating our personnel about these risks." — Generic statement about awareness.

The first sentence is a clear SI materiality assessment, but both the negative assertion about incidents and the claim about having no policies are self-serving statements that can't be externally verified. The third sentence is just boilerplate language about awareness and updates with no specific facts or domain expertise. This is Level 1 generic boilerplate.


reasoning: The paragraph centrally addresses how Cleco manages cybersecurity risks from third-party service providers, including contract amendments for security and confidentiality — making Third-Party Risk the primary category. The language is entirely generic process description ('implementing processes,' 'reviewing and updating contracts') without any domain-specific cybersecurity terms, named roles, or verifiable facts, keeping it at Level 1.

thinking: Third-party risk management is the central topic.


reasoning: The paragraph answers how the board oversees cybersecurity, describing the board's risk oversight function and delegation to the audit committee — classic Board Governance. All entities mentioned (board of directors, executive officers, audit committee) are generic governance structures present at every public company, with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity risks, board responsibility, audit committee involvement → Board Governance.

Specificity: Let me scan for facts.
- "board of directors" — generic, every company has one
- "audit committee" — generic, every company has one
- "executive officers" — generic
- No domain terms that pass the ERM test
- No firm-specific facts
- No verifiable claims

This is generic governance language. Level 1.


reasoning: The paragraph describes the company's cybersecurity program activities (assessments, policies, controls), answering 'what does the program do?' → RMP. All language ('assess, identify, and manage risks,' 'policies and controls,' 'internal and external assessments') is standard ERM vocabulary that passes no domain-expertise threshold, yielding Level 1.

thinking:
Classify this paragraph.

Content: "To assess, identify, and manage the risks of cybersecurity threats to our information system, we maintain a cybersecurity program, including policies and controls, which are regularly reviewed through internal and external assessments."

Category: This describes what the cybersecurity program does - RMP.

Specificity: Very generic language. "assess, identify, and manage risks" - standard ERM language. "policies and controls" - generic. "internal and external assessments" - generic. This is Level 1.


fact: Enterprise Risk and Compliance Committee (ERC Committee) of the Board of Directors

reasoning: The paragraph describes how cybersecurity findings flow to a board-level committee, which is information flow to the board → Board Governance. The named 'Enterprise Risk and Compliance Committee' is a non-generic board committee specific to Axon, elevating specificity to Firm-Specific.

thinking:
Classify this paragraph.

This is a short sentence about presenting findings to the ERC Committee of the Board. It describes how information flows to the board committee - that's Board Governance.

Specific facts: "Enterprise Risk and Compliance Committee" - this is a named committee. But is it firm-specific? It's a board-level committee with a specific name beyond generic "Audit Committee." Yes, this is a named non-generic committee.

"ERC Committee" abbreviation is firm-specific.

Specificity: Firm-Specific (Level 3).


reasoning: The paragraph states a backward-looking and forward-looking materiality conclusion ('have not materially affected or are reasonably likely to materially affect'), which is the SEC Item 106(b)(2) assessment → SI. The second sentence is a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present, so specificity remains Level 1.

thinking: Materiality assessment paragraph.