reasoning: The paragraph is centrally about how the company oversees vendor cybersecurity — conducting risk assessments, requiring controls, and monitoring compliance — making Third-Party Risk the clear category. All language is generic process description ('periodic risk assessments,' 'appropriate cybersecurity controls,' 'monitoring vendor compliance') that any ERM professional could write; no domain-specific terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: About vendor cybersecurity oversight - risk assessments of vendors, requiring controls, monitoring compliance. This is centrally about third-party risk management.

Category: Third-Party Risk (TP) - vendor oversight is the central topic.

Specificity: Let me check for facts.
- "Third-Party Risk Management program" - could be firm-specific as a named program? It's fairly generic though.
- "periodic risk assessments of vendors" - generic process
- "requiring vendors to implement appropriate cybersecurity controls" - generic
- "monitoring vendor compliance" - generic

All of this is generic language. No domain terms that pass the ERM test - "risk assessments of vendors", "cybersecurity controls", "cybersecurity requirements" are all things an ERM professional would say. No firm-specific facts, no verifiable claims.

This lands at Level 1 - Generic Boilerplate.


content_category: Third-Party Risk

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph addresses two topics: engaging third-party consultants (RMP per Rule 3) and establishing dedicated processes for third-party cybersecurity risk oversight (TP). The explicit mention of 'separate processes and procedures to oversee and identify cybersecurity risks associated with third parties' signals a dedicated vendor oversight program, tipping the balance toward TP as the central topic. The language is entirely generic—'risk assessment,' 'processes and procedures,' 'third-party consultants'—all of which any ERM professional would use, with no domain terms, firm-specific facts, or verifiable claims.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

Content: mentions third-party consultants for risk assessment/management, and separate processes for third-party cyber risks. The paragraph has two parts: (1) engaging third-party consultants (which per Rule 3 = RMP), and (2) processes to oversee third-party risks (which = TP). It's a short paragraph split between RMP and TP.

The second clause is about managing third-party cyber risks, which is TP. The first clause is about using consultants for their own risk program (RMP). It's genuinely split. The TP portion ("established separate processes and procedures to oversee and identify cybersecurity risks associated with third parties") is slightly more specific/distinctive. But it's close.

Looking at this more carefully, the first sentence about engaging consultants for risk assessment is RMP since those third parties are serving the company's program, while the second sentence about oversight processes for vendor cybersecurity risks is clearly TP. The text is roughly balanced between both categories, but the TP portion is more distinctive as a dedicated topic, so I'm leaning toward classifying this as Third-Party Risk. Though Rule 3 suggests the consultant engagement might pull it toward RMP, the emphasis on third-party risk oversight processes seems to be the main point here.

Everything in this paragraph is generic boilerplate—no specific details about what consultants do, what risks they assess, or how the oversight processes actually work. Just standard compliance language.


content_category: Board Governance

fact: Technology Committee of the Board oversees cybersecurity risks

category_confidence: high

reasoning: The paragraph describes the board's oversight structure and delegation of cybersecurity risk oversight to the Technology Committee, squarely answering the BG question. The Technology Committee is a named non-generic board-level committee (not every company has one), making this firm-specific at Level 3.

thinking:
Classify this paragraph.

Category: Board Governance - describes board oversight structure, delegation to Technology Committee, reporting.

Specificity: "Technology Committee" - is this firm-specific? It's a named non-generic committee. Yes, not every company has a "Technology Committee" of the board. That's firm-specific (Level 3).

No verifiable facts (no numbers, dates, certifications, named individuals, named firms).


content_category: Risk Management Process

reasoning: The paragraph describes risk assessment methodology (identifying threats, assessing likelihood/damage, evaluating sufficiency of controls), directly answering what the cybersecurity program does → RMP. All language is generic risk management vocabulary that any ERM professional would use; no cybersecurity domain terms, firm-specific facts, or verifiable claims are present → Level 1.

thinking:
Classify this paragraph.

Content: Describes risk assessment process - identification of threats, likelihood assessment, sufficiency of existing controls. This is about what the cybersecurity program does → RMP.

Specificity: Let me scan for facts.
- "periodic risk assessments" - generic
- "identification of reasonably foreseeable internal and external risks" - generic risk management language
- "likelihood and potential damage" - generic
- "sufficiency of existing policies, procedures, systems, and safeguards" - generic

ERM test: Could a non-security ERM professional write this? Yes, absolutely.

The language here is purely generic risk management terminology with no cybersecurity-specific expertise evident, so this lands at Level 1.


content_category: Strategy Integration

reasoning: The paragraph contains a backward-looking materiality assessment ('have not materially affected the company, including our business strategy, results of operations, or financial condition'), which is SI per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present; the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. A cross-reference to Item 1A risk factors
2. A materiality assessment statement

The materiality assessment "have not materially affected the company, including our business strategy, results of operations, or financial condition" is a backward-looking SI assessment per Rule 5.

The cross-reference portion points to Item 1A, which per Rule 5 would be N/O. But the paragraph also contains a substantive materiality conclusion, which is SI.

Specificity: The materiality statement is a negative self-assertion ("have not materially affected") - per the rules, this is NOT externally verifiable.

The statement contains no domain-specific terminology or company-specific facts, so this falls into Level 1 complexity.


reasoning: The paragraph states a materiality conclusion ('have not materially affected, or are reasonably likely to materially affect, our business strategy, results of operations, or financial condition'), which is the SEC Item 106(b)(2) assessment → SI. Despite mentioning 'fiscal year 2023,' this is a reporting period anchor for a negative self-assertion (no material impact), which is not externally verifiable; the cross-reference to Item 1A and speculative disclaimer add no specificity above Level 1.

thinking: SI materiality assessment paragraph.


reasoning: The paragraph centrally addresses dependence on third-party service providers and the cyber risks they pose, with BHE's monitoring of those risks — making Third-Party Risk the primary topic. The language is entirely generic ('continuously monitors,' 'significant financial, operational, or reputational impact') with no domain terminology, firm-specific details, or verifiable claims.

thinking:
Classify this paragraph.

Content: About third-party service provider risks and monitoring. Central topic is third-party cyber risk.

Category: Third-Party Risk - it's centrally about how third-party risks are managed/monitored.

Specificity: "continuously monitors the risks associated with its service providers" - generic. No domain terms, no firm-specific facts, no verifiable claims. This is generic language about relying on third parties and monitoring them.

Level 1.


reasoning: The paragraph centrally addresses how third-party cyber risks are managed — vendor security assessments, remediation/termination actions, and contractual security provisions — making Third-Party Risk the clear category. Despite mentioning a 'third-party information risk management program,' this is a descriptive phrase rather than a distinctively named program, and terms like 'security risk assessment,' 'security controls,' and 'security and privacy provisions' are generic enough that a non-security ERM professional managing vendor risk would naturally use them, keeping this at Level 1.

thinking:
Classify this paragraph.

Content: Describes a third-party information risk management program, vendor security assessments, remediation/termination actions, and contractual security provisions. Central topic is managing third-party cyber risks.

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

Specific facts:
- "third-party information risk management program" — named internal program? It's somewhat generic but has a specific name. I'd say it's borderline firm-specific.
- "periodic security risk assessment" — domain term? "security risk assessment" passes ERM test as it's specific to security.

- "security and privacy provisions" — generic
- "remediate the identified deficiencies or termination" — generic process

I'm reconsidering whether "third-party information risk management program" is truly a distinctive named program or just a descriptive phrase. It lacks the kind of specific identifier that would make it firm-specific, so I'm leaning toward treating it as descriptive rather than a named program.

Looking at the domain-specific language, "security risk assessment" and "security controls" are borderline—they're slightly more specific than generic "risk assessment," but an ERM professional managing vendor risk would use similar phrasing. The overall language feels like standard third-party risk management boilerplate that could come from any ERM framework, so I'm settling on this as Level 1 generic language.


reasoning: This is a brief introductory sentence stating the company places importance on identifying and mitigating cybersecurity threats — a generic statement about risk management intent without any domain-specific terms, firm-specific facts, or verifiable claims. It borders on None/Other as a section header but does reference cybersecurity risk management goals, so RMP is marginally appropriate.

thinking: Simple introductory statement.


content_category: Incident Disclosure

fact: CDK identified as the third-party provider involved in the incident

fact: Incident occurred in June 2024

fact: Incident response plan includes identification, categorization, escalation and reporting processes

reasoning: The paragraph describes the company's incident response plan but pivots to disclosing a real cybersecurity incident involving CDK in June 2024, including its operational disruption and materiality assessment, making the incident frame dominant (Rule 4). Specificity reaches Level 4 because CDK is a named third-party firm and June 2024 is a specific date—both externally verifiable claims tied to a well-documented real event.

thinking:
Let me analyze this paragraph carefully.

Content category: This paragraph covers multiple topics - incident response plan (RMP), an actual incident (ID), and a materiality assessment (SI). Let me determine which is primary.

The paragraph starts with describing the incident response plan, then describes an actual incident (CDK incident in June 2024), then assesses materiality. The actual incident and its impact assessment take up roughly half the paragraph. The incident is a real event with specific details.

The materiality statement "did not materially impact our financial condition or results of operations" is a backward-looking SI assessment per Rule 5. But the dominant frame is the incident itself - what happened, how they responded.

The incident and response form the core narrative here, with the materiality conclusion woven in. Looking at the structure, the incident description and the company's response to it drive the paragraph forward, so I'm categorizing this as ID.

For specificity, "June 2024" and "CDK" are both verifiable details tied to a real event—those are Level 4. The process terms like "identification, categorization, escalation and reporting" are generic enough to stay at L1, and the materiality statement about not impacting financial condition is a negative assertion about the incident's impact rather than the absence of incidents themselves.


content_category: None/Other

reasoning: This is a standard forward-looking statements disclaimer with no substantive cybersecurity content. Pure legal boilerplate → None/Other, Generic Boilerplate.


fact: Threat intelligence briefings from government and industry entities

fact: CISO role

fact: CISO reports to the Chief Executive Officer

fact: FedEx Executive Committee oversees business risk including cybersecurity

fact: DTRC (named committee in incident communication chain)

fact: CyTOC (named committee in incident communication chain)

reasoning: The paragraph primarily describes how cybersecurity information flows upward through the governance chain (CISO → CEO → Executive Committee → Board), making it a Board Governance paragraph about oversight structure. Specificity is Firm-Specific due to named committees (DTRC, CyTOC, FedEx Executive Committee) and the CISO-to-CEO reporting line, but no externally verifiable quantified claims push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes CISO participation in threat intelligence briefings, reporting line (CISO → CEO), Executive Committee oversight, and incident response communication processes.

Category: This touches multiple areas. The CISO reporting to CEO and Executive Committee oversight could be BG or MR. The threat intelligence briefings and incident response plan communication processes are about how information flows. The paragraph describes governance chain (CISO → CEO → Executive Committee → Board). Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. But there's also management organizational content. The primary focus seems to be about how information flows upward - oversight structure. I'll go with BG.

Actually, I'm seeing this is more mixed than I initially thought. There's the RMP activity with threat intelligence briefings, the MR element of the CISO reporting directly to the CEO, the BG aspect of Executive Committee oversight with cybersecurity as a standing agenda item, and then the RMP and BG components of how incident response plans get communicated up the chain. The dominant thread here is really the governance structure and information flow from threat intelligence up through the CISO to the CEO and Executive Committee and Board. That governance chain and oversight mechanism points to BG as the primary category.

Looking at the specificity markers: CISO is a firm-specific role, the reporting line to the CEO is a firm-specific organizational fact, and then there are the named committees—DTRC and CyTOC—which are clearly FedEx-specific. The threat intelligence briefings and incident response plan are domain terms, though incident response plans can sometimes get confused with L1 activities. Since I'm seeing firm-specific roles, firm-specific committee names, and no quantified facts, this lands at Level 3.


fact: material cybersecurity incident occurred in third quarter of fiscal year 2023

fact: personal information of a significant number of individuals was accessed by unauthorized third-party

fact: recorded expenses for investigation and remediation; details in Note 15. Commitments and Contingencies

reasoning: The paragraph's primary frame is a real cybersecurity incident—describing the timeline (Q3 FY2023), attack vector (zero-day in a file transfer app, likely MOVEit), scope (personal information accessed), and remediation expenses—making it Incident Disclosure per Rule 4 despite secondary materiality assessments. Specificity reaches Level 4 because 'third quarter of fiscal year 2023' is a specific, externally verifiable timeframe tied to a publicly known incident, and the zero-day/file-transfer-application details are independently confirmable.

thinking:
Incident disclosure with strategy integration elements. Let me classify.

The paragraph describes a real incident (Q3 FY2023, zero-day vulnerability in third-party file transfer app), mentions expenses, and includes materiality assessments. The dominant frame is incident disclosure combined with materiality assessment.

Category: The paragraph primarily describes what happened (a material cybersecurity incident) and its aftermath. But it also contains materiality assessments ("immaterial", "material cybersecurity incident", "not aware of any other cybersecurity incidents that have had a material effect").

Per Rule 4, mixed with incident frame dominant → ID. But there's also SI content. The paragraph starts with the incident, describes it, then transitions to materiality assessments and forward-looking disclaimers.

The incident description is substantial but the materiality conclusions are equally prominent. I'm weighing whether the incident itself or the materiality assessment dominates—the paragraph opens with what happened and uses that as the organizing principle, even though it spends considerable space on materiality conclusions and disclaimers. The incident frame is what anchors everything, so I'm classifying this as ID.

Now I'm looking at the specificity markers here. The timeframe is pinned to a concrete moment—third quarter of fiscal year 2023—and references a zero-day vulnerability in a third-party vendor's file transfer application, which points to a real, publicly documented event. There's also a cross-reference to Note 15 and acknowledgment that this was previously disclosed. All of this ties to verifiable facts, which puts this at Level 4 specificity.


reasoning: This paragraph describes regulatory context (financial privacy laws, SEC disclosure rules) and cross-references another section — it does not disclose any substantive cybersecurity program details, governance structure, or incident. The SEC rule effective date is a public regulatory fact, not a company-specific cybersecurity disclosure, so specificity remains Level 1.

thinking: Regulatory context and cross-reference paragraph.


reasoning: This paragraph describes the regulatory environment (financial privacy laws, SEC disclosure rules) and cross-references another section of the filing. It does not disclose any substantive cybersecurity measures, governance structures, or incident information — it merely notes that regulations exist. N/O with Generic Boilerplate as no cybersecurity program details are provided.


fact: vulnerability scanning

fact: penetration testing

reasoning: The paragraph describes what the cybersecurity program does—risk assessments, scanning, testing—answering the RMP question. Vulnerability scanning and penetration testing are domain-specific security practices that pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Describes what the cybersecurity risk management program includes - risk assessments, vulnerability scanning, penetration testing, third-party assessments. This is about what the program does → RMP.

Specific facts:
- vulnerability scanning → domain_term
- penetration testing → domain_term

These pass the ERM test. No firm-specific facts or verifiable claims.

Level 2.


fact: CSIRPs (Cyber Security Incident Response Plans) — named internal program with distinguishing acronym

fact: Incident response lifecycle phases: detection, analysis, containment, eradication, recovery, post-incident review

specificity_confidence: medium

reasoning: The paragraph describes what the incident response plans do — their phases and activities (detection through post-incident review) — making it primarily about program activities (RMP). The Audit Committee notification is subordinate context about escalation. Specificity reaches Firm-Specific due to 'CSIRPs' as a named internal program with a company-specific acronym, plus domain-adapted IR lifecycle terminology.

thinking:
Classify this paragraph.

Content: Describes CSIRPs (Cyber Security Incident Response Plans) - detection, analysis, containment, eradication, recovery, post-incident review, notice to stakeholders including Audit Committee.

Category: This describes what the incident response plans DO - the activities and phases. The mention of Audit Committee is subordinate (notification pathway). Primary question answered: "What does the cybersecurity program do?" → RMP.

Specific facts:
- "CSIRPs" - named internal program (Firm-Specific)

- The incident response lifecycle phases are standard domain terminology, while CSIRPs itself is the firm-specific element that drives the classification to Level 3.


reasoning: The paragraph contains a backward-looking materiality assessment ('has not experienced a cybersecurity threat that has materially affected the company'), which is SI per Rule 5, alongside a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present — the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Cross-reference + negative materiality assertion.

The first sentence is a cross-reference to Item 1A → N/O. The second sentence is "has not experienced a cybersecurity threat that has materially affected" → SI (backward-looking materiality assessment per Rule 5).

The SI sentence is a substantive materiality conclusion, so this isn't N/O. Category = SI.

Specificity: "has not experienced a cybersecurity threat that has materially affected" is a negative self-assertion, not externally verifiable. No domain terms, no firm-specific facts. Level 1.


reasoning: This is a cross-reference to Item 1A Risk Factors with speculative 'may be materially affected' language — not an actual materiality assessment but generic risk disclaimer language every 10-K includes. No substantive cybersecurity disclosure is present. No domain terms or firm-specific facts elevate specificity.

thinking: Cross-reference to Item 1A with speculative "may be materially affected" language.


fact: ransomware incident

fact: August 2020 discovery date

fact: engaged third-party forensics experts and outside counsel

fact: did not pay ransom

fact: no employee data or other personal information was accessed

reasoning: The paragraph describes an actual ransomware incident — its timeline, scope, response, and outcome — making it clearly Incident Disclosure. The specific date 'August 2020' is an externally verifiable fact tied to a real event, elevating specificity to Quantified-Verifiable.

thinking: Incident disclosure with specific details.


reasoning: The paragraph is centrally about how the company oversees third-party cybersecurity risks—diligence, contractual protections, and monitoring—making Third-Party Risk the clear category. The mention of 'security rating services' passes the ERM test as a cybersecurity-specific oversight mechanism (e.g., BitSight/SecurityScorecard), elevating specificity to Level 2, though no firm-specific or verifiable details are present.

thinking:
Classify this paragraph.

Content: About overseeing third-party cybersecurity risks - vendor diligence, contractual protections, third-party risk monitoring security rating services.

Category: This is centrally about managing third-party cyber risks → Third-Party Risk.

Specificity: "third-party risk monitoring security rating services" - does this pass the ERM test? A non-security ERM professional wouldn't naturally reference "security rating services" - this is a cybersecurity-specific concept (like BitSight, SecurityScorecard). That's domain knowledge. The rest is fairly generic (diligence, contractual protections).

So this lands at Level 2 - it has some cybersecurity-specific terminology mixed in with broader risk management concepts, making it moderately specialized rather than purely generic.


reasoning: The paragraph describes the Board's oversight awareness and responsibilities regarding cybersecurity risks, squarely answering how the board oversees cybersecurity. It contains no domain-specific terminology, firm-specific facts, or verifiable claims—just generic governance language any company could write.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity risks → Board Governance. Generic statements about board awareness and oversight responsibilities.

Specificity: No domain terms beyond generic "cybersecurity threats." No firm-specific facts. No verifiable claims. → Level 1, Generic Boilerplate.


fact: Technology Steering Committee (named management-level committee)

reasoning: The paragraph describes the governance chain from board to Audit Committee to management's Technology Steering Committee for cybersecurity oversight, making BG the primary fit. The Technology Steering Committee is a named non-generic committee that elevates specificity to Level 3; the Audit Committee is generic and does not count.

thinking:
Classify this paragraph.

Category: This describes board oversight structure - Board → Audit Committee → Technology Steering Committee. The governance chain is the focus. BG.

Wait - "management's Technology Steering Committee" - this is a management-level committee. Per Rule 1, management-level committees → MR if about structure/membership, RMP if about activities. But the paragraph's primary purpose is describing the oversight structure (governance chain), so BG.

Specific facts:
- "Audit Committee" - generic, every company has one → not firm-specific
- "Technology Steering Committee" - this is a named non-generic management committee → firm-specific (Level 3)

- The Technology Steering Committee is the firm-specific element that determines the overall classification.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers — vendor oversight including initial assessments, additional reviews, and contractual requirements — making TP the clear category. Despite the detailed process description, no domain-specific terminology (fails ERM test — 'assess', 'mitigate', 'risk assessment' are generic ERM language), no firm-specific facts, and no verifiable claims are present, keeping this at Level 1.

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


reasoning: This paragraph describes hypothetical risks and potential adverse effects ('could expose', 'may also cause') without disclosing any actual cybersecurity measures, processes, or assessments — pure risk speculation that any 10-K might contain. No domain terms, firm-specific facts, or verifiable claims elevate specificity beyond boilerplate.

thinking: Risk speculation paragraph - "could expose", "may also cause" - no actual measures described.


reasoning: The paragraph's central statement is a backward-looking materiality assessment ('no cybersecurity incident during the year ended December 31, 2024, resulted in... a material impact on the firm's strategy, financial condition or results of operations'), which maps to SI under Rule 5. No domain terms passing the ERM test, no firm-specific facts, and the negative assertion about no material incidents is not externally verifiable; the date is merely a reporting period anchor, not a cybersecurity fact.

thinking:
Let me analyze this paragraph.

Content: States they've been targeted by attacks, notes no material incident in 2024, references Risk Factors for more info.

Category: The key statement is "no cybersecurity incident during the year ended December 31, 2024, resulted in... a material impact on the firm's strategy, financial condition or results of operations." This is a backward-looking materiality assessment → Strategy Integration per Rule 5.

The cross-reference at the end is N/O but the materiality assessment dominates.

Specificity: "no cybersecurity incident...

Now I'm checking whether this actually contains verifiable facts or just self-assertions. The materiality claim is negative and unverifiable, the date is just a reporting period marker, and there's no domain-specific language or firm details that would elevate this beyond generic boilerplate. This is Level 1.


reasoning: The paragraph contains only generic speculation about cybersecurity threats ('could be severely disrupted', 'could have a material impact') and a cross-reference to Item 1A — no substantive cybersecurity measures, assessments, or program details are disclosed. Per Rule 5, 'could have a material impact' is speculation (not an assessment), and the cross-reference points elsewhere. None/Other paragraphs receive Generic Boilerplate.

thinking:
This paragraph discusses potential impacts of cybersecurity threats in general terms and cross-references Item 1A for more detail on material effects.

Category: The paragraph speculates about potential impacts ("could be severely disrupted", "could have a material impact") and cross-references Item 1A. Per Rule 5, "Could have a material adverse effect" is speculation, not SI. The cross-reference to Item 1A is N/O. No substantive cybersecurity measures are described. → None/Other

Specificity: N/O always gets Generic Boilerplate.


reasoning: The paragraph describes program activities (incident response plan/policy, mandatory annual employee training) — answering what the cybersecurity program does → RMP. All terms used (incident response plan, annual training, compliance programs) are generic ERM language with no domain-specific, firm-specific, or verifiable facts.

thinking:
Classify this paragraph.

Content: describes incident response plan/policy and mandatory annual cybersecurity training for employees.

Category: Risk Management Process - describes what the cybersecurity program does (incident response planning, employee training).

Specificity: Let me check for specific facts.
- "incident response plan" and "incident response policy" - these are generic terms, fail ERM test (any ERM professional would say this)
- "annual data protection and cybersecurity training" - generic cadence + generic practice
- "compliance programs" - generic

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

This rates as Level 1 - it's entirely generic language without any distinguishing details.


reasoning: The paragraph describes how material cybersecurity matters are escalated from senior management to the Audit Committee for oversight, answering the board governance question about information flow. No domain terms, firm-specific facts, or verifiable claims are present—'Audit Committee' and 'senior management' are generic to every public company.

thinking:
Classify this paragraph.

This describes how material cybersecurity matters flow from senior management to the Audit Committee for oversight. The primary question answered is "How does the board oversee cybersecurity?" — information flow to the board/committee.

Category: Board Governance

Specific facts: "Audit Committee" is generic (every company has one), "senior management" is generic. No domain terms, no firm-specific facts, no verifiable claims.

Specificity: Generic Boilerplate (Level 1)


reasoning: This paragraph states a backward-looking conclusion that cybersecurity has not materially affected the company, triggering the SI materiality rule. The reporting period date is contextual framing, not a cybersecurity fact, and the negative assertion about no material incidents is not externally verifiable, so specificity remains Level 1.

thinking: Materiality assessment - negative assertion about no material incidents.


fact: attack vectors

fact: reported vulnerabilities

fact: continuous cyber monitoring

fact: IT Steering Committee

reasoning: The paragraph primarily describes what the cybersecurity program does—risk assessment methodology, ERM integration, monitoring activities, and quarterly update content—making it RMP. The person-removal test confirms: removing the IT Steering Committee reference leaves substantial program description. Specificity reaches Level 3 via the named 'IT Steering Committee' (a non-generic named committee), with domain terms like 'attack vectors' and 'vulnerabilities' also present.

thinking:
Let me analyze this paragraph.

Category: This describes what the cybersecurity program does - risk assessment, monitoring, ERM integration, quarterly updates. There's mention of the IT Steering Committee and roles, but the primary content is about program activities. Person-removal test: remove the IT Steering Committee reference and there's still substantial program description. → RMP

Specific facts:
- "IT Steering Committee" — named committee → firm-specific
- "third-party cybersecurity vendor" — generic, not firm-specific
- "quarterly updates" — generic cadence
- "continuous cyber monitoring" — domain term? Let me check ERM test... "continuous monitoring" is used in ERM contexts too.

The cybersecurity-specific language like "attack vectors," "vulnerabilities," and "threat analysis" are domain terms that still pass the ERM test since risk management uses similar concepts. The named IT Steering Committee is what makes this firm-specific, pushing it to Level 3 specificity.


content_category: Management Role

fact: CISO role responsible for cybersecurity strategy

fact: CISO leads strategy centrally at Roivant and the majority of Vants (firm-specific organizational structure)

fact: CISO has previous leadership positions specializing in safeguarding healthcare data across health technology companies

reasoning: The paragraph describes the CISO's responsibilities and qualifications; applying the person-removal test leaves no substantive program description, so this is MR. Specificity reaches Level 3 via the named CISO role and firm-specific organizational detail (Roivant and its Vants), but lacks verifiable claims like certifications or specific years of experience to reach Level 4.

thinking:
Classify this paragraph.

Category: This is about the CISO's role and qualifications. Person-removal test: remove CISO, experience, qualifications → nothing remains. → MR.

Specific facts:
- CISO (named_role) → firm-specific
- Healthcare data safeguarding experience across health technology companies → other_specific (firm-specific background)
- "Roivant and the majority of our Vants" → firm-specific organizational structure

No verifiable numbers or certifications. Level 3.


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


reasoning: The paragraph's primary content is identifying management roles (Senior Director of IT, CEO, General Counsel, CFO) and listing their cybersecurity responsibilities—hiring, budgets, incident escalation—making it fundamentally about who is organized to handle cybersecurity (MR). No domain terms pass the ERM test (all language is generic risk management), the named titles are either generic (CEO, CFO, General Counsel, Audit Committee) or below the firm-specific threshold (Senior Director of Information Technology lacks a security qualifier), and no verifiable facts appear, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

Category: This describes management roles and responsibilities. The paragraph names specific roles (Senior Director of IT, CEO, General Counsel, CFO) and describes their responsibilities. Using the person-removal test: remove all person-specific content and what remains? "cybersecurity risk assessment and management processes are implemented and maintained," "hiring appropriate personnel, integrating cybersecurity risk considerations into the Company's overall risk management strategy, communicating key priorities, approving budgets, helping to prepare for cybersecurity incidents, approving cybersecurity processes, reviewing security assessments." These are responsibilities tied to the roles.

The core issue here is that this is really about organizational structure and accountability — who holds which positions and what they're accountable for. Looking at the specificity: the titles mentioned (Senior Director of Information Technology, CEO, General Counsel, CFO, Audit Committee) are all standard corporate roles that any company would have, not unique to this firm. The responsibilities themselves — cybersecurity risk assessment, incident preparation, budget approval, security reviews — are generic industry practices without any firm-specific details or verifiable facts that would distinguish them.


reasoning: The paragraph states a backward-looking materiality conclusion ('not aware of any risks from cybersecurity threats that have materially affected the Company, including our business strategy, results of operations or financial condition'), which is an SI assessment per Rule 5. However, specificity remains Level 1: the negative assertion about no material impact is not externally verifiable, the 'could' speculation is generic boilerplate, and the cross-reference to Item 1A adds no substantive content.

thinking: Materiality assessment paragraph.


fact: Information Security Officer

fact: Chief Information Officer

reasoning: The paragraph describes what specific management roles (ISO, CIO) are responsible for — mandatory training obligations — making it primarily about role responsibilities (MR). The ISO and CIO are firm-specific leadership titles at VP+ level, elevating specificity to Level 3.

thinking:
Classify this paragraph.

Content: About ISO and CIO completing mandatory training for securing information assets.

Category: This is about management roles and their training responsibilities. The person-removal test: remove ISO and CIO titles → "completing additional mandatory training to understand processes, procedures, and technical requirements for securing information assets" — this describes a training requirement, but it's specifically about what these roles must do. It's about the responsibilities of these named roles. MR.

Specific facts:
- "Information Security Officer" — firm-specific named role (VP+ or Director with security qualifier? ISO is a security-specific role, I'd count it as firm-specific)

- "Chief Information Officer" — firm-specific named role (CIO is VP+ level)

Specificity: Firm-Specific (Level 3)


fact: December 2022 - specific date of cybersecurity incident

fact: containment protocols

fact: forensics experts

reasoning: The paragraph describes a real cybersecurity incident — data extraction discovered in December 2022, investigation launched, containment and remediation steps taken — making it Incident Disclosure. The specific date 'December 2022' is an externally verifiable fact tied to a real event, elevating specificity to Quantified-Verifiable.

thinking: Incident disclosure - describes a real event in December 2022.


reasoning: The paragraph describes the audit committee's oversight of cybersecurity risk management, its reporting relationship to the board, and how it receives updates — all answering how the board oversees cybersecurity → BG. All elements are generic governance structures (audit committee, board of directors, CFO, periodic updates) that exist at virtually every public company; no domain terms pass the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Category: Board Governance - describes audit committee oversight of cybersecurity, reporting to board, receiving updates. This is about how the board oversees cybersecurity.

Specific facts:
- "audit committee" - generic, every company has one → not firm-specific
- "Chief Financial Officer" - generic role → not firm-specific
- "periodic updates" - generic cadence

No domain terms that pass the ERM test. No firm-specific facts. No verifiable facts.

This is generic boilerplate about board oversight.


fact: Vendors categorized into tiers based on risk of activities

fact: Vendor due diligence questionnaires assessing cyber and information security control environment

fact: Formalized vendor incident response procedures

reasoning: The entire paragraph is about managing third-party/vendor cybersecurity risk — tiering, due diligence, incident response procedures for vendors — making TP the clear category. The paragraph uses domain terms like information security control environment and vendor due diligence questionnaires focused on cyber controls, showing some domain knowledge beyond generic ERM language, but lacks firm-specific identifiers (no named tools, named roles, or specific quantities).

thinking: Vendor oversight is the central topic here.


reasoning: This is a SPAC with no business operations and no cybersecurity program, fitting the N/O rule for no-operations companies. No domain terms, firm-specific facts, or verifiable claims are present—the negative incident assertion is a self-reported claim about absence and doesn't qualify as verifiable.

thinking: SPAC with no operations, no cybersecurity program.


fact: CIO

fact: Management committee on cybersecurity

fact: Audit and Finance Committee

reasoning: The paragraph primarily answers how information flows to the board — quarterly enterprise risk briefings and periodic cybersecurity-focused briefings to the Audit and Finance Committee and Board — making it Board Governance. Specificity reaches Level 3 via firm-specific roles (Senior Director, Information Protection & Compliance; CIO) and a named management committee on cybersecurity, which distinguish this company's governance structure.

thinking:
Classify this paragraph.

Category: This describes how information flows from management to the board. The primary question answered is "How does the board oversee cybersecurity?" — it's about briefing frequency, scope, and how information reaches the board/committee. This is Board Governance.

Specific facts:
- "Audit and Finance Committee" — named committee but this is a standard board committee, not firm-specific
- "quarterly briefings" — generic cadence
- "Senior Director, Information Protection & Compliance" — this is a Director-level title with a security qualifier → firm-specific
- "CIO" — VP-level role → firm-specific

- "management committee on cybersecurity" — named committee → firm-specific

Specificity: Level 3 (Firm-Specific)


reasoning: The paragraph describes general reliance on technology infrastructure and enumerates potential cybersecurity threats (ransomware, hacker attacks, AI-driven threats) but does not disclose any specific cybersecurity program, governance structure, incident, or materiality assessment—it is threat-landscape context and risk-factor framing without substantive disclosure answering any of the six category questions. None/Other paragraphs receive Generic Boilerplate per the rules.

thinking:
Let me analyze this paragraph.

Content: Describes reliance on technology infrastructure, defines cybersecurity threats broadly, mentions evolving sophistication. This is general risk description language, not describing specific processes, governance, or incidents.

Category: This reads like risk factor language - describing potential threats and vulnerabilities. No specific program, governance, or incident details. It's general context about cyber risk. No materiality assessment conclusion. This is essentially background/risk context without substantive cybersecurity disclosure of any specific category. → None/Other

Specificity: mentions "ransomware" (domain term), "AI and machine-learning technologies" used by threat actors.

Now I'm checking whether these specific threat types meet the ERM test - "ransomware" clearly qualifies as a concrete threat category, while "insider risk" sits in a gray area. The CIA triad language is standard domain terminology. But stepping back, this whole section is really just framing the threat landscape and their technology dependence without actually describing what measures they've implemented or how they're governing these risks. It's contextual background rather than substantive disclosure, so I'm categorizing it as None/Other.


fact: CISO role

fact: Security Steering Committee

fact: CTO role in cybersecurity review

fact: CSIRT (Computer Security Incident Response Team)

fact: PSIRT (Product Security Incident Response Team)

fact: incident handling lifecycle

fact: key risk indicators

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity—describing who (CISO, Security Steering Committee, CEO, CTO) reviews policies and how the CISO is informed, making it MR. The person-removal test leaves some process description but the core framing is about management's information flow. Specificity reaches Level 3 via firm-specific elements: CISO, Security Steering Committee, and named teams CSIRT and PSIRT, with domain terms like incident handling lifecycle providing Level 2 support.

thinking:
Let me analyze this paragraph.

Category: This describes how management (CISO, Security Steering Committee, senior executives) is organized to handle cybersecurity. But it also describes processes - how the CISO monitors incidents via CSIRT/PSIRT communications. Let me apply the person-removal test: Remove CISO, CEO, CTO, Security Steering Committee. What remains? "review and manage cybersecurity policies and processes" and "processes... informed about and monitors prevention, detection, mitigation, and remediation of cybersecurity incidents, include prompt communication from the CSIRT and PSIRT describing the severity and impact of the incident and status throughout the incident handling lifecycle and routine monitoring of key risk indicators."

There's substantial process description remaining, but the core focus is on how management gets informed and organized around cybersecurity - the information flow to the CISO and committee is what's being defined here. This is fundamentally about the management role and governance structure, so it maps to Management Role. For specificity, I need to flag the CISO as a named role and the Security Steering Committee as a named committee since they're firm-specific entities.

Now looking at the next chunk - CSIRT and PSIRT are both domain terms and firm-specific named teams, with PSIRT being particularly specific to this organization. The CEO and CTO are generic roles that appear everywhere, while "key risk indicators" and "incident handling lifecycle" are domain terminology. The presence of these named teams and the CISO pushes this to at least Level 3, and without any verifiable numbers or certifications mentioned, Level 3 is the appropriate classification.


fact: phishing attack

fact: April 28, 2023 - date incident identified

fact: $54,300 payment to unauthorized payee

type: quantified

fact: June 29, 2023 - date funds recovered

reasoning: The paragraph describes a real phishing incident with timeline, scope, investigation, and remediation — squarely Incident Disclosure. Specific dates (April 28, 2023; June 29, 2023) and a precise dollar amount ($54,300) are externally verifiable facts, driving Level 4.

thinking: Incident disclosure - describes a real phishing attack with specific dates, amounts, and outcomes.


reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing delegation to the Audit Review Committee (a board-level committee variant of the standard Audit Committee) and its review responsibilities — squarely Board Governance. The language uses only generic ERM terms ('cybersecurity risks, controls and procedures,' 'internal controls over financial reporting') with no domain-specific security terminology, no firm-specific facts beyond a standard audit committee renaming, and no verifiable claims.

thinking:
Classify this paragraph.

Category: This describes board/committee oversight of cybersecurity. The ARC (Audit Review Committee) is a board-level committee. The paragraph answers "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- "Audit Review Committee of the Board of Directors (the 'ARC')" - this is a named committee, but it's essentially an Audit Committee variant. The rules say "Audit Committee" is not firm-specific since every company has one. However, "Audit Review Committee" with the specific abbreviation "ARC" is a slightly distinctive name.

The ARC is fundamentally a standard audit committee, so despite the specific naming, it doesn't qualify as firm-specific. The language around cybersecurity risks, controls, and internal controls over financial reporting is all standard ERM terminology without any distinguishing characteristics. This falls into Level 1 - Generic Boilerplate.


reasoning: The paragraph is centrally about managing third-party cybersecurity risk—due diligence, evaluating practices, and imposing contractual requirements on vendors—making TP the clear category. The language is entirely generic (due diligence, contractual commitments, cybersecurity measures); no domain-specific terms pass the ERM test, and there are no firm-specific or verifiable facts.

thinking:
Classify this paragraph about third-party service provider due diligence.

Category: This is centrally about managing third-party cyber risks - due diligence, evaluating practices, contractual requirements. → Third-Party Risk

Specificity: "due diligence", "contractual commitments", "cybersecurity measures" - generic language. No domain terms that pass ERM test, no firm-specific facts, no verifiable claims. → Level 1


fact: phishing tests

fact: penetration tests

fact: Corporate Controller involved in risk-related activities

reasoning: Person-removal test: removing the Corporate Controller and VP of IT titles still leaves a substantive description of centralized risk management, third-party penetration/phishing testing, and process implementation — so RMP wins over MR. Specificity reaches Firm-Specific due to the VP of Information Technology role (VP-level IT title), with domain terms like penetration testing and phishing tests supporting Level 2 as a floor.

thinking:
Let me analyze this paragraph.

Content: Describes centralized IT/risk management, mentions Corporate Controller and VP of IT roles, third-party phishing/penetration tests, implementing new processes from test results.

Category: This is primarily about how management is organized (centralized function, specific roles involved) AND what the program does (penetration testing, implementing new processes). The person-removal test: remove "Corporate Controller and Vice President of Information Technology" - we still have centralized risk management, third-party phishing/penetration tests, implementing new processes. Substantive program description remains → RMP.

Actually, let me reconsider. The first sentence is about organizational structure (MR-ish), but the second and third sentences are about program activities.

The RMP category wins out based on text volume. Looking at specificity, I see firm-specific details like the VP of IT role, domain terminology around phishing and penetration testing, and a concrete year when the tests occurred. That points to Level 3.

But I need to check whether "2023" is actually verifiable—it's just a year without external confirmation, and "a third party" remains unnamed. Without those qualifying verification facts, this stays at Level 3 due to the VP of Information Technology title alone.


fact: SOC (System and Organizational Control) type reports required from service providers

reasoning: The paragraph primarily answers what the cybersecurity program does — deploying software, conducting internal audits, and requiring vendor SOC reports — making it RMP. The third-party SOC requirement is one component of the broader program description, not the central topic (Rule 3). Specificity reaches Level 2 because SOC reports are a domain-specific assurance mechanism that passes the ERM test; the rest ('industry standards,' 'sophisticated software,' 'internal audits') is generic language any business professional could write.

thinking:
Classify this paragraph.

Content: Describes their cybersecurity program - built on industry standards, deployed software, internal audits, require service providers to provide SOC reports.

Category: The paragraph describes what the program does (risk assessment, tools, vendor requirements). The main question answered is "What does the cybersecurity program do?" → RMP. There's a TP element (requiring SOC reports from service providers), but TP is not the central topic - it's one component among several program activities.

Specific facts:
- "SOC" type reports - this is a domain term (SOC reports are specific to cybersecurity/audit domain, passes ERM test)

- Internal audits and "industry standards" are too generic to pass the ERM test, but the SOC reports reference demonstrates domain-specific knowledge that a non-security professional wouldn't naturally use in this context.

Specificity: Level 2 (Domain-Adapted) based on the SOC reports reference.


reasoning: SPAC with no operations and no cybersecurity program, explicitly stating they have not adopted any program — fits the N/O rule for no-operations companies. No specific facts of any kind are present.


reasoning: This is a backward-looking materiality assessment stating that cybersecurity risks have not materially affected business strategy, operations, or financial condition — directly triggering the SI materiality rule. No specific facts elevate specificity; the negative self-assertion about no material impact is not externally verifiable.

thinking: SI materiality rule applies.


fact: Fortra, LLC identified as the third-party vendor involved

fact: GoAnywhere managed file transfer as a service (MFTaaS) named as the affected system

fact: Incident occurred in fiscal 2023

fact: zero-day vulnerability exploited by threat actor

fact: Protected health information (PHI) as defined by HIPAA was accessed

fact: Personally identifiable information (PII) was accessed

fact: Notifications provided to State Attorneys General

reasoning: This paragraph describes a real cybersecurity incident — the Fortra/GoAnywhere MFTaaS breach — with timeline, scope, cause, and response details, making it clearly Incident Disclosure. Specificity is Quantified-Verifiable due to multiple externally verifiable facts: Fortra, LLC as the named vendor, GoAnywhere MFTaaS as the named product, the well-documented zero-day vulnerability, and fiscal 2023 timing — all independently confirmable via public breach disclosures and news reporting.

thinking: Incident disclosure - describes a real cybersecurity incident with specific details.


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

thinking: Simple cross-reference paragraph.


reasoning: The paragraph describes engaging external experts (assessors, consultants, auditors) to evaluate and test the company's risk management systems — these are third parties hired to serve the company, making this RMP per Rule 3, not TP. Despite mentions of 'threat assessments' and 'proactive detection tools,' the language remains at a level any ERM professional could produce — no specific tool categories (SIEM, EDR), no named frameworks, no firm-specific or verifiable facts, keeping this at Level 1.

thinking:
Classify this paragraph.

Category: The paragraph describes engaging external experts to evaluate/test risk management systems, including audits, threat assessments, and security enhancements. It also mentions using advanced technology solutions. The external experts here are hired to serve the company (assessors, consultants, auditors) → RMP per Rule 3.

Specificity: Let me scan for facts.
- "cybersecurity assessors, third-party legal consultants, and auditors" — generic unnamed entities
- "audits, threat assessments, and consultations on security enhancements" — "threat assessments" passes ERM test as domain term

- "proactive detection tools" — cybersecurity-specific language suggesting active threat hunting rather than reactive response, but lacks concrete tool names
- "aligned with industry standards" — generic

"Threat assessments" could appear in general risk discussions, but "proactive detection tools" is distinctly cybersecurity-focused. The phrase implies understanding of active monitoring versus passive response, though it remains vague without specific tool categories. Overall, this leans toward domain-specific language but isn't consistently detailed enough. The language here is borderline—"proactive detection tools" and "identify threats within its environment" do signal some cybersecurity awareness, but they're vague enough that an ERM professional could use similar phrasing without deep domain knowledge. I'm settling on Level 1 because the entire passage relies on generic risk management language without anything specific enough to demonstrate real cyber expertise.


category_confidence: low

reasoning: This fragment lists oversight duties (policy implementation oversight, promoting corporate commitment) that describe a governance oversight role, defaulting to BG given the 'oversight' framing, though without surrounding context it could be MR. No domain terms, firm-specific facts, or verifiable claims are present—entirely generic language that any ERM professional could write.

thinking:
Classify this paragraph.

This is a short fragment listing oversight duties - appears to be continuation of a list about cybersecurity responsibilities. Items b and c describe oversight of policy implementation and promoting corporate commitment.

Category: This describes oversight responsibilities. Without more context, these look like they could be board governance or management role duties. The items are about "oversight of implementation" and "promoting commitment" - these are generic oversight/governance activities. Given this appears to be a continuation of a list (starting at b.), it's describing someone's responsibilities. Without knowing who, but given it's about oversight structure, likely BG or MR. The language "oversight of continued and consistent implementation" and "promoting overall corporate commitment" sounds like governance oversight duties.

The "oversight" framing pushes me toward Board Governance, though I recognize the ambiguity - this could just as easily describe management responsibilities. The specificity here is minimal: no domain-specific terminology, no firm-specific details, no verifiable claims. This is purely generic language, so it rates as Level 1.


fact: phishing simulation testing (mimicking harmful phishing attempts)

fact: information security and data privacy training for employees

reasoning: The paragraph describes program activities — employee security training and phishing simulations — which are cybersecurity operations (RMP). The third-party vendor is hired to serve the company, not a vendor oversight topic. Phishing simulation is a domain-specific security practice passing the ERM test, elevating to Level 2, but no named vendors, named roles, or verifiable claims push it higher.

thinking:
Classify this paragraph.

Content: Employee security training, phishing simulations by third-party vendor, monthly cadence, reporting results to management.

Category: This describes what the cybersecurity program does - training and phishing simulations. The third-party vendor is hired to serve the company (assessor/tool), so per Rule 3 → RMP.

Specificity: Let me scan for facts.
- "information security and data privacy training" - generic
- "phishing attempt each month" - "each month" is a cadence but also specific
- "phishing simulation" - domain term (simulated phishing is a specific security practice)

- "third-party vendor" - unnamed, not firm-specific

The phishing simulation and testing language is a domain-specific practice that an ERM professional wouldn't typically use, but there are no firm-specific facts here—no named roles, vendors, or programs, and nothing verifiable. This lands at Level 2 - Domain-Adapted.


fact: malware detection training

fact: phishing simulations

reasoning: The paragraph describes program activities (security awareness training, phishing simulations, disaster recovery exercises) — answering what the cybersecurity program does → RMP. Terms like 'malware detection' and 'phishing simulations' pass the ERM test as cybersecurity-specific practices, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Security awareness program details - trainings on data protection/malware detection, phishing simulations, disaster recovery exercises. This is about what the program does → RMP.

Specific facts:
- "malware detection" - domain term (ERM test: specific to cybersecurity)
- "phishing simulations" - domain term (specific to cybersecurity)
- "disaster recovery exercises" - this is borderline, commonly used in ERM... but in context with other terms it's part of a broader program description. Actually "disaster recovery" fails the ERM test per the rules.

So domain terms: malware detection, phishing simulations. These pass the ERM test.

No firm-specific facts or verifiable details present, so this lands at Level 2.


reasoning: The paragraph centers on dependence on third-party IT service providers and the vendor management process for mitigating cybersecurity risk, including obtaining reports from vendors handling sensitive data — making third-party oversight the central topic. The language is entirely generic ERM vocabulary ('vendor management process,' 'risk mitigation strategy,' 'obtain reports') with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

The paragraph discusses third-party IT systems, vendor management, and obtaining reports from vendors about cybersecurity. The central topic is how they manage third-party cyber risks - vendor management process, obtaining reports from vendors handling sensitive data.

Category: Third-Party Risk - vendor oversight is the central topic here.

Specific facts: Let me scan for anything above Level 1.
- "hosted architecture" - generic IT term
- "vendor management process" - generic ERM language
- "obtain reports from our vendors handling sensitive data as to their efficacy and efficiency in managing cybersecurity issues" - this is a process description but fairly generic

- No domain-specific terminology that meets the ERM threshold, no firm-specific details, and no verifiable claims present.

Level 1 - Generic Boilerplate.


reasoning: The paragraph centrally addresses processes to manage security risks at third-party vendors and in third-party technology, with listed measures (vendor security assessments, insurance company risk assessments) all oriented toward third-party oversight. Specificity remains Level 1 because the measures described ('security assessments,' 'risk assessments,' 'security solution') are generic process descriptions without domain-specific terminology, named entities, or verifiable claims.

thinking:
Classify this paragraph.

Content: About third-party vendor security measures - security solution for customer data, security assessments of vendors, risk assessments by insurance company. Central topic is third-party risk management.

Category: Third-Party Risk - the paragraph is centrally about managing third-party cyber risks (vendor assessments, customer data protection, insurance company assessments).

Wait, let me reconsider. The paragraph mentions processes to oversee third-party vendors AND lists security measures. The central topic is third-party risk management.

The key phrase here is about processes designed to oversee and reduce the impact of security incidents at third-party vendors, which confirms this is Third-Party Risk. The supporting details—vendor security assessments and insurance company risk evaluations—reinforce this classification. Looking at the specificity, most of these are generic process descriptions without concrete details, though the insurance company assessment adds a bit more substance.

None of the language contains domain-specific terminology that would meet the ERM test. "Security assessments" and "risk assessments" are standard boilerplate without named frameworks or verifiable claims. This lands squarely at Level 1 - Generic Boilerplate.


fact: Security Operations Center (SOC)

fact: 24x7 security operations

reasoning: The paragraph describes specific security tools and operations (SOC, SIEM, real-time monitoring) that constitute program activities, making it RMP. The '24x7' operational claim is a firm-specific distinguishing detail per the guidelines, elevating beyond the domain terms (SOC, SIEM) to Level 3.

thinking:
Classify this paragraph.

Content: Describes specific security operations - 24x7 SOC and SIEM systems for monitoring and threat response. This is about what the cybersecurity program does → RMP.

Specific facts:
- "24x7 Security Operations Center (SOC)" - "SOC" is a domain term, "24/7" is a firm-specific operational claim
- "Security Information and Event Management (SIEM)" - domain term

24/7 security operations is listed as firm-specific. SOC and SIEM are domain terms.


fact: CISO role

fact: CIO role

fact: Chief Legal Officer role

fact: CISO reports to CIO

fact: over 30 years of experience in cybersecurity and intelligence

fact: Department of Defense experience

fact: CIO Program Certificate from College of Information and Cyberspace, National Defense University

fact: CISSP designation

fact: CIPP designation

reasoning: The paragraph primarily describes management organization: CISO role, reporting line to CIO, team oversight, and extensive qualifications — classic MR content. While some program activities are mentioned, the person-removal test leaves little substance. Specificity is QV due to multiple externally verifiable facts: 'over 30 years' experience (lower bound), CISSP and CIPP certifications (verifiable via registries), and a named credential from National Defense University.

thinking:
Let me analyze this paragraph.

Category: This is about management roles - CISO, CIO, reporting lines, qualifications, team composition. The person-removal test: remove names, titles, qualifications → what remains? "We have a team... who lead our enterprise-wide cybersecurity strategy, risk management, cyber defense, software security, security monitoring and other related functions." That's some program description but the bulk is about who leads it and their qualifications. MR.

Specificity: Let me list facts:
- CISO (firm-specific role)

- CIO (firm-specific role)
- Chief Legal Officer (named role)
- "over 30 years of experience" → verifiable lower bound
- "Department of Defense" → named organization, verifiable
- "defense contracting community" → somewhat specific
- "publicly traded companies" → general
- "CIO Program Certificate from the College of Information and Cyberspace, National Defense University" → verifiable credential from named institution
- CISSP designation → verifiable via (ISC)²
- CIPP designation → verifiable

Multiple verifiable facts → Level 4.

Domain terms: cyber defense, software security, security monitoring → these pass ERM test as domain terms.


fact: CIO role leading cybersecurity program

fact: CISO role leading cybersecurity program under CIO

fact: Both CIO and CISO have over 20 years of experience managing and securing global enterprises

fact: Enterprise Risk Management (ERM) process integration

reasoning: This is a governance-chain paragraph describing oversight from CISO/CIO through the Audit Committee to the Board, with ERM integration — the default for such paragraphs is BG per Rule 1, though MR and RMP content are also present. Specificity reaches Level 4 because 'over 20 years of experience' is a lower-bound quantified claim verifiable against the officers' professional histories.

thinking:
Let me analyze this paragraph.

Content category: This touches multiple categories - MR (CIO, CISO roles, experience), BG (Board delegates to Audit Committee, receives updates), and RMP (integration into risk management). Let me apply the person-removal test and see what dominates.

The paragraph has three sentences:
1. CIO/CISO leadership, 20+ years experience → MR
2. Board delegates to Audit Committee, CISO/CIO updates annually → BG
3. Integration into risk management via quarterly reviews, budget planning, ERM → RMP

The content splits fairly evenly across all three categories. The governance-chain structure—Board delegating to Committee, which oversees the Officer leading the Program—would normally default to BG, but the substantial focus on qualifications and program integration pulls this toward a hybrid classification. The first sentence emphasizes who leads and their credentials, the second describes the oversight structure, and the third shows how cybersecurity fits into the broader risk management framework. I'm looking at the word counts for each sentence to help settle this. The first sentence about the CIO and CISO is substantial management content, the board oversight is moderate, and the ERM integration adds another significant piece. Given the governance-chain default rule applies here, I'll stick with BG, though I'm not entirely confident since the management structure really does anchor the paragraph. Now checking the specificity - the named roles like CIO and CISO are firm-specific, and the "over 20 years" is a quantified detail, but the Audit Committee reference is generic since every company has one.


fact: IT Lead has 5 years of experience in cybersecurity risk management oversight

reasoning: The paragraph describes who manages cybersecurity (IT Lead) and their qualifications; person-removal test collapses it, confirming MR. '5 years of experience' is a hard number verifiable against a resume, elevating to Level 4. 'About 15 years' for the external agency is hedged and fails the hard-number test.

thinking:
Let me analyze this paragraph.

Content: Describes who implements cybersecurity risk management (IT Lead), their experience, and external agency assistance.

Category: This is about management's organizational role - who is responsible, their qualifications. The person-removal test: remove IT Lead, 5 years experience, external agency details - very little substantive program description remains. → MR

Specific facts:
- "IT Lead" - this is below VP level, not a security-specific title at VP+ level. Not firm-specific per the rules.
- "5 years of experience" - quantified, verifiable

- "external agency with about 15 years of expertise" - the "about" qualifier makes this a soft number, not verifiable
- "cybersecurity risk assessment and management processes" - generic, L1

The only hard verifiable fact here is the 5 years of experience; the external agency's expertise is hedged with "about," and "IT Lead" is too generic and below the VP threshold to count as firm-specific.


fact: penetration testing (external and internal)

fact: emulate tactics and techniques of cyber threat actors

fact: remediate identified vulnerabilities across a wide range of severities

reasoning: The paragraph covers three components of the cybersecurity program—penetration testing, third-party vendor oversight, and cybersecurity insurance. Per Rule 3, third-party risk mentioned as one component of a broader internal program points to RMP rather than TP. Specificity reaches Level 2 via domain terms like penetration testing and vulnerability remediation, which pass the ERM test, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: penetration testing, vulnerability remediation, third-party risk management policies, cybersecurity insurance.

Category: This covers multiple topics - penetration testing (RMP), third-party oversight (TP), and cybersecurity insurance (SI). The penetration testing is RMP, the third-party policies are TP, and insurance is SI. Let me assess which dominates by text volume.

- Penetration testing + vulnerability remediation: ~1 sentence
- Third-party risk policies: ~2 sentences
- Cybersecurity insurance: ~1 sentence

- Third-party risk gets the most text, but it's close with RMP. The paragraph starts with pen testing (RMP), then moves to third-party oversight (TP), then insurance (SI). The TP content is about requirements imposed ON vendors (onboarding assessments, contractual terms, periodic assessments) - this is genuine TP per Rule 3. Looking at the actual distribution, RMP and TP are roughly equal in length, though TP edges out slightly. The third-party content focuses on vendor requirements and assessments, which is clearly TP material, but the penetration testing and vulnerability remediation form a substantive program description that might be the stronger signal here.

Actually, I need to reconsider what Rule 3 says about this situation. The paragraph describes multiple cybersecurity program components - pen testing, third-party oversight, and insurance - rather than having a single central topic. When the content is genuinely split across categories, the one with the most text should win. TP gets roughly two sentences while RMP gets about one and a half, making TP the largest component. But the paragraph opens with and frames around program activities, positioning third-party oversight as one element within the broader risk management program. Rule 3 specifically addresses this: when third parties are mentioned as one component of an internal program, it should be categorized as RMP. That's the better fit here.

Looking at the specificity markers, "penetration testing" and "cyber threat actors" are solid domain terms that pass the ERM test, while "cybersecurity insurance," "onboarding risk assessments," and "cybersecurity-related contractual terms" are more general business language. The passage contains no firm-specific facts, named roles, committees, or verifiable claims, so this lands at Level 2 with penetration testing as the key domain term.


reasoning: The opening sentence states a materiality conclusion ('not reasonably likely to materially affect us or our business strategy, results of operations or financial condition'), which is an SI assessment per Rule 5. The remainder is a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

The first sentence is a materiality assessment: "We do not believe that there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us or our business strategy, results of operations or financial condition." This is a backward-looking/forward-looking materiality conclusion → SI per Rule 5.

The second sentence is a cross-reference to Item 1A risk factors.

The materiality assessment is the substantive content here → Strategy Integration.

Specificity: The materiality statement is a negative self-assertion ("no known risks reasonably likely to materially affect").

The cross-reference just points to Item 1A without adding substantive content—it's generic boilerplate language with no domain-specific terms, firm-specific facts, or verifiable claims. The real substance is in that first materiality conclusion, which is what qualifies as SI. This paragraph is essentially a materiality statement paired with a pointer elsewhere, and the specificity level is minimal—just Level 1 generic language.


fact: Formal Vendor Management Program (named internal program)

fact: CCDC (named committee involved in vendor program review)

reasoning: The paragraph is centrally about oversight of vendor/supplier cybersecurity risks—onboarding due diligence, requirements imposed ON vendors, and ongoing monitoring—making it Third-Party Risk. The named 'Vendor Management Program' and 'CCDC' committee are firm-specific identifiers that elevate specificity to Level 3.

thinking:
Classify this paragraph.

Category: This is centrally about how third-party/vendor cyber risks are managed - Vendor Management Program, vendor onboarding due diligence, requirements imposed ON vendors, ongoing monitoring of vendors. Central topic is vendor oversight → Third-Party Risk.

Specific facts:
- "Vendor Management Program" - named internal program → firm-specific
- "CCDC" - named committee → firm-specific
- "risk-based due diligence" - could be generic ERM language
- "cybersecurity requirements for vendors" - requirements imposed on vendors

- "ongoing monitoring, assessment, and contract review" - generic

The presence of the named Vendor Management Program and CCDC committee makes this firm-specific content, placing it at Level 3 specificity.


reasoning: Despite the heading referencing 'Management's Role,' the paragraph primarily answers how the Board oversees cybersecurity—briefing structure, Board participation in strategic decisions, annual review of cybersecurity posture—making it BG. All roles mentioned (CFO, Director of Internal Audit, Director of Information Technology) are either generic governance roles every company has or Director-level titles without a security qualifier, which per rules are not firm-specific. The cybersecurity language (emerging threats, incident reports, compliance) fails the ERM test, yielding Level 1.

thinking:
Let me analyze this paragraph.

Category: The heading says "Management's Role Managing Risk" but the content is primarily about how information flows to the Board and how the Board oversees cybersecurity. The Director of Internal Audit and CFO brief the Board, the Board participates in strategic decisions, conducts annual reviews. This is about Board oversight structure - BG.

Specific facts:
- Director of Internal Audit - this is a named role but not VP+ level, and no security qualifier
- CFO - generic governance role, every company has one

- Director of Information Technology - Director-level IT title without security qualifier, which per the rules means it's not firm-specific
- Board of Directors - generic governance body
- "Minimum frequency of once per year" - this is a specific cadence, but it's a generic control frequency, not a quantified fact that distinguishes this company
- The briefing topics themselves are generic boilerplate

None of these elements meet the threshold for firm-specific facts. The roles lack security qualifiers, the cadence is standard, and the Board structure is universal. Director of Internal Audit lacks the security qualifier too, so this entire paragraph qualifies as Level 1 Generic Boilerplate.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party vendors, including additional scrutiny for vendors handling sensitive data, making Third-Party Risk the clear category. The language is entirely generic — 'risk-based approach,' 'identifying and overseeing cybersecurity risks,' 'personally identifiable information,' and 'trade secrets' are all terms any ERM professional would use without cybersecurity domain expertise, yielding Level 1.

thinking:
Classify this paragraph.

Content: About third-party vendor management with cybersecurity risk focus. Central topic is managing vendor cyber risks. → Third-Party Risk

Specificity: "personally identifiable information" - this is a domain term but fairly generic. "trade secrets" - not really a cyber domain term. "risk-based approach" - generic. No firm-specific facts, no verifiable claims. The mention of PII and trade secrets as specific data types to scrutinize - PII is somewhat domain-relevant but also used broadly in ERM. Actually, PII is commonly used in general business/legal contexts too. This is pretty generic language about vendor oversight.

This lands at Level 1 - Generic Boilerplate, since the language is standard enough that any ERM professional could produce it without specialized knowledge.


fact: Outsources CIO function to external 'CIO firms'

fact: Uses a managed service provider for cybersecurity operations

reasoning: The paragraph is centrally about how the company oversees third-party service providers (due diligence, monitoring, communication protocols, scheduled meetings), making Third-Party Risk the clear category. The disclosure that the company outsources its CIO function to external 'CIO firms' and relies on a managed service provider for operations are firm-specific organizational facts that distinguish this company's posture, elevating specificity to Level 3.

thinking:
Classify this paragraph.

Content: About third-party service provider oversight - due diligence, monitoring of managed service provider and CIO firms, protocols for communication and incident response aligned with MSP operations, scheduled meetings with third-party providers.

Category: This is centrally about how they manage third-party cyber risks → Third-Party Risk.

Specific facts:
- "managed service provider" - this is a domain term (MSP)
- "CIO firms" - this is somewhat firm-specific, indicating they outsource CIO function
- "due diligence checks" - generic

- "incident response" - generic per the rules

Now I'm reconsidering whether "managed service provider" really qualifies as firm-specific. It's a standard IT infrastructure concept that an ERM professional would encounter regularly, so it's probably borderline at best. But "CIO firms" is different—that reveals this particular company outsources its entire CIO function to external firms, which is a meaningful firm-specific detail about their governance structure. That pushes the specificity to Level 3.


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

thinking: Cross-reference to Item 1A Risk Factors.


fact: Cybersecurity incident occurred on July 23, 2023

fact: $14.3 million of costs incurred in connection with the incident

fact: Forensic investigation conducted

reasoning: The paragraph describes an actual cybersecurity incident with timeline, scope, costs, and remediation steps, making it Incident Disclosure. The specific date (July 23, 2023) and dollar amount ($14.3 million) are externally verifiable hard facts, driving Level 4. The final sentence about no material impact to financial results is secondary to the incident narrative frame.

thinking: Incident disclosure with specific details.


fact: Information Technology Committee (named committee comprised of key members of senior management)

reasoning: The paragraph primarily answers how the board oversees cybersecurity — describing board involvement, update cadence, and approval responsibilities — making it Board Governance. The named 'Information Technology Committee' is a distinguishing, non-generic committee name that elevates specificity to Firm-Specific, but no externally verifiable facts are present.

thinking:
Let me classify this paragraph.

Category: This describes board oversight and a committee's role in cybersecurity. The IT Committee is "comprised of key members of senior management" - this is a management-level committee but the paragraph's primary focus is on board oversight (monthly updates to board, board reviews and approves). The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- "Information Technology Committee" - named committee, but is it firm-specific? It's comprised of senior management, so it's a management-level committee with a specific name → firm-specific
- "Monthly updates" - generic cadence, not firm-specific

- The board's review and approval of cybersecurity risk assessments, policies, and formalized reviews describes generic oversight activities rather than firm-specific practices.

The Information Technology Committee is a named non-generic committee → firm-specific (Level 3). There are no verifiable facts like specific numbers, dates, certifications, or named individuals, so the overall specificity level is Firm-Specific (Level 3).


reasoning: Blank check company explicitly states it has no operations and no cybersecurity threats, fitting the SPAC/no-operations N/O rule. No substantive cybersecurity disclosure or specific facts of any kind.

thinking: SPAC with no operations, no cybersecurity program.


reasoning: The paragraph's second sentence is a textbook SI materiality assessment — both backward-looking ('have not materially affected') and forward-looking ('are not reasonably likely to materially affect') — matching the Rule 5 SI pattern. The first sentence is a cross-reference to Risk Factors, but the materiality conclusion dominates. No domain terms, firm-specific facts, or verifiable claims are present, keeping specificity at Level 1.

thinking:
Two sentences: first is a cross-reference, second is a materiality assessment.

The second sentence is a clear SI materiality statement - backward-looking and forward-looking assessment that cybersecurity has not materially affected and is not reasonably likely to materially affect business.

Specificity: No domain terms, no firm-specific facts, no verifiable claims. The materiality statement is a self-reported negative assertion. Level 1.


reasoning: The opening sentence states a backward-looking materiality conclusion ('have not experienced a cybersecurity incident that has resulted in a material effect on our business strategy, results of operations or financial condition'), which is an SI assessment per Rule 5. The remainder is generic speculation ('may materially affect') and a cross-reference to Item 1A, neither of which override the SI lead. No domain terms passing the ERM test, no firm-specific facts, and the negative self-assertion is not externally verifiable, so specificity stays at Level 1.

thinking:
Let me analyze this paragraph.

The first sentence is a backward-looking materiality assessment: "we have not experienced a cybersecurity incident that has resulted in a material effect on our business strategy, results of operations or financial condition" → SI per Rule 5.

The rest is speculation ("cannot guarantee", "may materially affect") and a cross-reference to Item 1A → N/O territory.

The SI materiality assessment is the lead sentence and makes a concrete conclusion. The rest is generic risk factor language. The SI assessment is the most substantive content here.

Category: Strategy Integration

Specificity: The negative assertion "have not experienced...

The temporal anchor "as of the date of this report" doesn't add verifiability to the negative claim itself. There are no domain-specific terms that would satisfy the ERM test, and beyond the generic risk language, there's nothing firm-specific here. The cross-reference to the risk factor is just pointing elsewhere.

Specificity: Generic Boilerplate (Level 1).


reasoning: This is a SPAC with no business operations and explicitly no cybersecurity program, fitting the N/O rule for no-operations companies. No domain terms, firm-specific facts, or verifiable claims are present—just generic disclosure of having nothing to disclose.


fact: penetration testing

fact: forensic analysis

fact: NIST framework

type: framework

fact: FRI's Global Corporate Continuity Program

reasoning: The majority of the paragraph addresses how FRI identifies, oversees, and mitigates cybersecurity risks from third parties (vendors, service providers, counterparties), making third-party risk the central topic per Rule 3. The third-party firms hired for assessments/pen testing serve the company (→ RMP element) but are subordinate to the dominant TP content. Specificity reaches Firm-Specific due to the named internal program 'Global Corporate Continuity Program,' which distinguishes this company's posture.

thinking:
Let me analyze this paragraph.

Content: after-action evaluation, third-party firms for assessments/pen testing/forensics, risk-based approach to third-party cyber risks, NIST framework, Global Corporate Continuity Program, diligence on third parties.

Category: The paragraph starts with after-action evaluation (RMP), then mentions third-party firms hired to assess (RMP per Rule 3), then shifts to managing third-party risks (TP). The bulk of the paragraph is about third-party risk management - vendors, service providers, etc. Third-party risk oversight is the central topic for most of the text. I'd say TP.

I'm identifying the key domain terms and named entities here: penetration testing and forensic analysis are domain-specific terms, NIST framework is a recognized framework, the Global Corporate Continuity Program is a firm-specific initiative, and FRI appears as a specific entity reference.


reasoning: This paragraph is a generic acknowledgment of cybersecurity importance with no substantive disclosure of any program, governance structure, or assessment — it could appear in any company's filing. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

This is generic acknowledgment of cybersecurity importance with no substantive disclosure. No specific measures, processes, or assessments described.


reasoning: The paragraph's central topic is managing third-party cybersecurity risks (due diligence, monitoring, partner standards), making TP the best fit. Every phrase ('comprehensive due diligence process', 'continuous monitoring', 'stringent standards') is generic language any ERM professional could write — no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: About managing third-party risks through due diligence, monitoring, and ensuring partners meet cybersecurity standards. Central topic is third-party risk management → TP.

Specificity: "comprehensive due diligence process", "continuous monitoring", "stringent standards" — all generic. No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims. → Level 1.


reasoning: The paragraph's central topic is oversight of third-party providers' cybersecurity — obtaining reports and monitoring compliance with standards — making TP the best fit. The language is entirely generic ('obtain reports,' 'ongoing monitoring,' 'compliance with our cybersecurity standards') with no domain terms passing the ERM test, no firm-specific details, and no verifiable claims.

thinking:
Classify this paragraph.

Content: About monitoring third-party providers' security - vendor oversight is the central topic → Third-Party Risk.

Specificity: "obtain reports to assess the security of their systems" - generic. "ongoing monitoring of all third-party providers" - generic. No domain terms that pass ERM test, no firm-specific facts, no verifiable claims. → Level 1.


reasoning: This paragraph is a generic definition of 'cybersecurity threat' mirroring SEC regulatory language; it discloses nothing about the company's program, governance, or incidents. No specific facts elevate specificity above Level 1.

thinking: Definitions paragraph.


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity through periodic discussions and annual reviews, squarely answering how the board oversees cybersecurity → Board Governance. All language is generic: 'Audit Committee' is not firm-specific, cadences are vague ('periodic', 'annual'), and terms like 'identify and detect threats' and 'response or recovery' fail the ERM test as they could apply to any enterprise risk domain.

thinking:
Classify this paragraph.

Category: This is about the Audit Committee's oversight of cybersecurity - board-level committee overseeing cyber risks. → Board Governance.

Specificity: Let me scan for facts.
- "Audit Committee" - generic, every company has one → not firm-specific
- "periodic discussions" - generic cadence
- "annual review" - generic cadence
- "identify and detect threats" - generic language
- "response or recovery situation" - generic

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

→ Generic Boilerplate


reasoning: This paragraph describes the company's IT landscape (accounting software, CRM, mobile app, POS, data warehouse) and notes that it collects confidential information — it is context-setting for cybersecurity but does not itself answer any of the six substantive cybersecurity questions. No cybersecurity measures, governance, incidents, or assessments are described. None/Other paragraphs receive Generic Boilerplate.

thinking:
Classify this paragraph.

This describes IT systems and data collection but in a general business context, not specifically about cybersecurity program activities. It lists systems (accounting software, CRM, mobile app, online ordering, POS, data warehouse) and mentions collecting confidential information.

This is more of a business context/IT landscape description. It doesn't answer any of the six cybersecurity questions directly. It's setting the scene for why cybersecurity matters but doesn't describe any cybersecurity measures, governance, or incidents.

Category: None/Other - it's describing the business IT environment, not cybersecurity measures. But wait - it's in Item 1C which is about cybersecurity. Let me reconsider.

Actually, the paragraph is purely about IT systems and data collection with no cybersecurity disclosure at all, so None/Other is the right call. Since Rule 6 specifies "only when no substantive cybersecurity disclosure," and there's nothing here about cybersecurity program, governance, or strategy, I should classify this as Generic Boilerplate under None/Other.


reasoning: The paragraph states a backward-looking materiality conclusion ('business strategy, results of operations, and financial condition have not, to date, been affected') and a negative incident assertion, both fitting SI under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present—negative self-assertions about absence of incidents are not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: States that business hasn't been affected by cybersecurity risks, no material incidents experienced. This is a materiality assessment - backward-looking conclusion about whether cybersecurity has affected business outcomes.

Category: Strategy Integration (Rule 5 - "Have not materially affected our business strategy, results of operations, or financial condition" → SI)

Specificity: "have not experienced any material cyber incidents" - this is a negative self-assertion, NOT externally verifiable. "During the reporting period" is generic. No domain terms, no firm-specific facts, no verifiable claims.

This falls into generic boilerplate territory - it's a standard disclaimer without substantive detail or evidence.


fact: Chief Information Officer oversees regular assessments of third-party providers

reasoning: The paragraph centrally addresses how third-party provider cybersecurity risks are managed (assessments before engagement, ongoing monitoring, compliance), making it Third-Party Risk. The CIO role is a firm-specific fact elevating specificity to Level 3, but no verifiable claims or domain-specific terminology beyond generic process descriptions are present.

thinking:
Classify this paragraph.

Category: This is about third-party risk management - vendor oversight, security assessments of third-party providers, ongoing monitoring. Central topic is third-party risk. → Third-Party Risk

Specific facts:
- "security assessments" - generic process
- "Chief Information Officer" - CIO is a named role at VP+ level → firm-specific
- "ongoing monitoring" - generic

No domain terms that pass the ERM test. "Security assessments of third-party providers" is generic. No verifiable facts.

The CIO reference qualifies as firm-specific information at Level 3.


reasoning: The paragraph centrally addresses how third-party/vendor cybersecurity risks are managed — vendor selection, due diligence, monitoring, and a vendor management policy — making Third-Party Risk the clear category. Despite mentioning a 'Cybersecurity Program Manager,' this title falls below the Director+ threshold for firm-specific roles, and the remaining language (vendor evaluation, due diligence, risk assessment, monitoring threats) is generic ERM vocabulary that would apply to any vendor risk domain, keeping this at Level 1.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party/vendor cybersecurity risk management - monitoring threats at third-party providers, vendor selection/renewal process, vendor management policy approved by Board annually, vendor risk evaluation criteria.

Category: This is centrally about how third-party cyber risks are managed → Third-Party Risk.

Specific facts:
- "Cybersecurity Program Manager" - named role (firm-specific, VP-level? No, "Program Manager" is not VP-level. But it's a specific named role with security qualifier... Let me check the rules. The rules say "cybersecurity leadership roles at VP level or above" or "Director-level titles WITH a security qualifier." "Cybersecurity Program Manager" is below Director level but has a security qualifier.

Actually, looking at the criteria more carefully, this title doesn't meet the threshold - it's below Director level and the rules specifically require Director+ with a security qualifier or VP+ for general IT roles. So "Cybersecurity Program Manager" wouldn't count as firm-specific under those standards.

Now examining the vendor management policy claim - while it mentions Board approval, which adds some specificity, "Board of Directors" itself is generic terminology. The policy and its annual review process are organizational details many companies have, so this doesn't rise to the level of firm-specific either. The supporting language like "cybersecurity threats," "vendor evaluation," and "due diligence" are all standard ERM terminology.

The "Cybersecurity Program Manager" title does have a security qualifier, but it's below the Director threshold required by the rules, so it doesn't meet the firm-specific criteria. Overall, this is Level 1 - the content describes generic vendor risk management processes using standard ERM language that any non-security professional would recognize.


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

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