reasoning: The paragraph describes a component of the cybersecurity program (incident response planning), making it RMP. The language—'incident detection, containment, response and remediation' and 'security incident response plan'—is standard boilerplate; 'incident response plan' is explicitly a commonly-confused L1 term, and the overall phrasing does not demonstrate domain expertise beyond what any ERM professional would write.

thinking:
Classify this paragraph.

Content: describes having "a defined procedure for timely incident detection, containment, response and remediation, including a written security incident response plan"

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

Specificity: "incident detection, containment, response and remediation" - generic IR lifecycle terms. "security incident response plan" - generic. Let me apply the ERM test. "incident detection, containment, response and remediation" - these are standard IR lifecycle phases but would an ERM professional naturally use "containment"? Actually, containment is fairly specific to incident response in cybersecurity.

But "incident response plan" is listed as commonly confused L1, so even though "containment" is somewhat domain-specific, the overall message is just boilerplate about having an incident response plan. I'll classify this as L1.


content_category: Incident Disclosure

fact: July 10, 2024 — date unauthorized occurrences detected

fact: July 10, 2024 — date threat actor was ejected

fact: incident response plan activated

fact: leading external cybersecurity specialists engaged

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes an actual cybersecurity incident — detection, containment, remediation, and investigation — making it clearly Incident Disclosure. Specific dates (July 10, 2024 for both detection and ejection) are externally verifiable facts tied to a real event, elevating to Quantified-Verifiable.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking: Incident disclosure with specific dates and details.


content_category: Management Role

fact: Security team led by Chief Information Security Officer (CISO)

reasoning: The paragraph's primary purpose is describing who leads the security team and what their responsibilities are (risk assessments, security controls, incident response coordination), making it about management's organizational role. The CISO title is a firm-specific named role elevating specificity to Level 3, while the listed activities (risk assessments, security controls, incident response) are generic enough to fail the ERM test for Level 2 on their own.

thinking:
Classify this paragraph.

The paragraph describes the security team led by the CISO and what they oversee. Let me apply the person-removal test: remove CISO and team references. What remains? "cybersecurity risk assessments, implementation of security controls, coordination of incident response efforts." These are activities but they're generic. The primary focus is on describing who leads the team and what they oversee - this is about the role/organization.

Actually, the grammatical subject is "Our security team, led by our CISO" and the content describes what they oversee. Applying the person-removal test: remove "security team, led by our CISO" - what remains is "cybersecurity risk assessments, implementation of security controls, coordination of incident response efforts." These are generic program activities but they're tied to describing the role's responsibilities.

The paragraph centers on who's accountable rather than what the activities accomplish. The CISO is a firm-specific named role at VP-level or above, which signals Level 3. While the activities themselves are fairly generic—risk assessments and incident response are standard L1 terms—the emphasis on the CISO's specific responsibilities and domain awareness around security controls pushes this toward Level 3.


content_category: Board Governance

reasoning: The paragraph primarily answers how the board oversees cybersecurity — describing the full board's responsibility, the absence of regular reporting, and conditions under which management would escalate, making it Board Governance. No domain-specific terminology (everything is generic ERM language), no firm-specific facts (no named roles above VP, no named committees, no named third-party firm), and no verifiable claims, so it remains Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: The board oversees risk, management determined regular cyber reports aren't necessary, but would report material changes, and consults with third-party IT firm.

Category: This is about board oversight structure and how information flows (or doesn't) to the board. BG.

Specific facts: "third-party IT firm" - not named, not firm-specific. "full board of directors" - generic. No domain terms that pass ERM test. No firm-specific facts. No verifiable claims.

This is pretty generic - Level 1.


fact: Chief Information Security Officer (CISO)

fact: Chief Technology Officer (CTO) provides oversight

fact: Chief Operations Officer (COO) provides oversight

fact: CISO has over 25 years' experience in cybersecurity

type: quantified

reasoning: The paragraph describes the CISO's responsibilities, qualifications, and reporting structure under CTO/COO oversight — person-removal collapses it, confirming MR. The 'over 25 years' experience' claim is a verifiable lower bound, elevating to Level 4.

thinking:
Classify this paragraph.

Category: This is about management roles - CISO, CTO, COO responsibilities and qualifications. Person-removal test: remove names, titles, qualifications, experience → left with generic "assessing and managing cybersecurity risks" and "prevention, detection, mitigation, and remediation of cybersecurity incidents" — collapses to near-nothing. → MR

Specificity:
- CISO, CTO, COO → named_role (firm-specific)
- "over 25 years' experience" → quantified, verifiable (lower bound)

- The domain terminology around prevention, detection, mitigation, and remediation is borderline, but the concrete experience requirement pushes this to Level 4.


content_category: Risk Management Process

reasoning: Per Rule 3, third parties hired to serve the company (assessors, testers) are RMP, not TP. The paragraph describes using external consultants to 'assess, test, or otherwise assist' with the company's own cybersecurity controls. No domain-specific terminology, firm-specific facts, or verifiable claims are present—language is entirely generic.

thinking:
Classify this paragraph.

This is a short paragraph about using external consultants/third-party experts to assist with cybersecurity controls. It's a bullet point from a list (ends with "and").

Category: This describes using third parties as part of the company's own program (assessors, testers serving the company) → RMP per Rule 3.

Specificity: No domain terms that pass ERM test, no firm-specific facts, no verifiable claims. "external consultants", "third-party experts", "cybersecurity controls" - generic language.

So this lands at Level 1 specificity.


specificity_confidence: medium

reasoning: The paragraph describes the operational impact and recovery from a real cybersecurity incident (system shutdown, manufacturing disruption, delayed order fulfillment, and full IT restoration), clearly answering 'what happened?' → Incident Disclosure. Despite being detailed in narrative, there are no specific dates, named third parties, hard numbers, named tools, or domain-specific security terms — the language describes business operations disruption in general terms any business professional would use, keeping it at Level 1.

thinking: Incident disclosure - describes operational impact and recovery from a real cybersecurity incident.


category_confidence: medium

reasoning: The paragraph describes reviewing and updating systems/processes to safeguard against threats, which is a program activity (RMP). Third-party consultants are mentioned as serving the company (Rule 3 → RMP). All language is generic ('review and update systems, processes and procedures,' 'third party consultants') with no domain terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Content: Reviews and updates systems/processes to safeguard against threats, acknowledges limitations, mentions third-party consultants review attacks.

Category: This is about what the cybersecurity program does (reviewing/updating systems, processes, procedures) with a disclaimer about limitations. Third-party consultants are mentioned but as serving the company (Rule 3 → RMP). This is RMP.

Specificity: Let me scan for facts.
- "regularly review and update systems, processes and procedures" → generic, any ERM professional could say this
- "third party consultants" → unnamed, not firm-specific
- No domain terms that pass the ERM test

- No verifiable facts present, so this lands at Level 1 - Generic Boilerplate.


fact: firewalls

fact: vulnerability and patch management processes

fact: periodic phishing tests

fact: access controls

reasoning: The paragraph describes what the cybersecurity program does — risk assessments, technical controls, training — making it squarely RMP. Third-party assistance is mentioned but not the central topic. Multiple domain-specific terms (firewalls, IDS/IPS, vulnerability/patch management, phishing tests) pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Category: This describes what the cybersecurity program does - risk assessments, access controls, firewalls, IDS/IPS, vulnerability/patch management, tools, business continuity, employee training. Third-party mentioned but not central. → RMP

Specific facts:
- access controls - generic
- firewalls - domain term
- intrusion detection and prevention systems (IDS/IPS) - domain term
- vulnerability and patch management - domain term
- phishing tests - domain term
- security awareness training - borderline, but phishing-based training is domain-specific

No firm-specific facts (no named roles, no specific committees). No verifiable claims.

The specificity level here is Domain-Adapted, meaning the paragraph uses industry terminology and established security practices without introducing company-specific details or measurable claims.


reasoning: The paragraph lists what the cybersecurity program does (risk assessments, offsite backups, external providers, awareness training), making it squarely RMP. Despite listing several activities, none employ domain-specific cybersecurity terminology that passes the ERM test — risk assessments, backup storage, external service providers, and awareness training are all generic process descriptions any ERM professional would use.

thinking:
Classify this paragraph.

Content: Describes cybersecurity program activities - risk assessments, offsite backup, external service providers, training. This is about what the program does → RMP.

Specific facts:
- "risk assessments" - L1, generic
- "offsite backup storage" - this is a domain term, passes ERM test? Hmm, backup storage is pretty generic IT. Not really cybersecurity-specific.
- "external service providers to assess, test or otherwise assist with aspects of our security controls" - generic
- "cybersecurity awareness training" - L1, generic
- "Cadiz Inc." - company name, not a specificity marker

- "security controls" is borderline. An ERM professional might say "internal controls." "Security controls" is slightly more domain-adapted but it's pretty borderline.

Looking at the language overall, this reads as process-level description without real cybersecurity domain expertise. Risk assessments, backup, external providers, awareness training—these are all foundational concepts that don't demonstrate specialized knowledge. I'm settling on L1 - Generic Boilerplate.


reasoning: The paragraph describes a key element of the cybersecurity program (risk assessments to identify material risks), answering 'what does the program do?' → RMP. The language is entirely generic — 'risk assessments designed to help identify material risks' would work for any enterprise risk domain and contains no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes a key element of the cybersecurity risk management program - risk assessments to identify material risks. This is about what the program does → RMP.

Specificity: "risk assessments designed to help identify material risks from cybersecurity threats to our critical systems, and information" - this is generic process description. No domain terms that pass the ERM test, no firm-specific facts, no verifiable claims. Level 1.


fact: hardening our environment, systems and infrastructure

reasoning: The paragraph primarily describes program activities — internal audits, cyber readiness evaluation, environment hardening, and employee training — making it RMP. The 'no material cybersecurity risks' statement is about risk identification rather than a business/financial materiality assessment per Rule 5. Specificity reaches Level 2 via 'hardening,' a security-specific term an ERM professional would not naturally use; the rest is generic process language.

thinking:
Classify this paragraph.

Content: Internal audits, cyber readiness evaluation, no material risks identified, hardening environment, employee training.

Category: The paragraph describes what the cybersecurity program does - audits, evaluations, hardening, training. This is RMP.

Wait - "have not identified any material cybersecurity risks" - is this an SI materiality assessment? It's about risks not incidents. Rule 5 examples focus on "materially affected business strategy/results/financial condition" and "material cybersecurity incidents." This says "not identified any material cybersecurity risks" which is a conclusion about risk status but the paragraph is primarily about program activities. The materiality statement is secondary.

The main content is RMP. Looking at the specificity, "hardening" stands out as a domain-specific term that an ERM professional wouldn't naturally use outside of cybersecurity - that's Level 2. The rest like internal audits, cyber readiness, and employee training are generic program descriptions without firm-specific facts or verifiable claims.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is managing cybersecurity risks of vendors and service providers, making Third-Party Risk the best fit. The language ('due diligence, oversight and identification of cybersecurity risks') is entirely generic and could be written by any ERM professional — no domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: About managing third-party cybersecurity risk - vendor due diligence and oversight.

Category: This is centrally about third-party risk management → Third-Party Risk.

Specificity: "due diligence, oversight and identification of cybersecurity risks associated with vendors and service providers" — this is generic language any ERM professional could write. No domain terms, no firm-specific facts, no verifiable claims.

Level 1.


content_category: Strategy Integration

reasoning: The paragraph states a backward-looking materiality conclusion ('did not identify any...threats that materially affected...business strategy, results of operations, or financial condition') and a forward-looking one ('reasonably likely to materially affect'), squarely fitting the SI materiality rule. Specificity remains Level 1: 'In 2024' is a reporting period, the negative assertion is not externally verifiable, and the remaining text is boilerplate disclaimer and cross-reference with no domain terms or firm-specific facts.

thinking:
Strategy Integration - materiality assessment statement.

Specificity: "In 2024" is a reporting period, negative self-assertion not verifiable. The cross-reference to Item 1A is N/O material. No domain terms, no firm-specific facts, no verifiable claims.

Level 1.

Wait - "In 2024, we did not identify any privacy or cybersecurity threats that materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial condition" — this is a materiality assessment → SI.

Specificity: negative self-assertion, not verifiable. No domain terms. Level 1.


fact: cybersecurity insurance

reasoning: The paragraph describes maintaining cybersecurity insurance to cover incident-related costs, which directly addresses how cybersecurity affects the business financially → Strategy Integration. The mention of cybersecurity insurance is a domain-specific concept but no firm-specific details (coverage amounts, insurer names) elevate it beyond Level 2.

thinking: Cybersecurity insurance coverage description.


fact: threat detection

fact: continuous system monitoring

reasoning: The paragraph describes what the cybersecurity program does—evaluation, monitoring, threat detection, assessments—using employees and contracted third parties who serve the company (Rule 3 → RMP, not TP). 'Threat detection' and 'continuous system monitoring' pass the ERM test as security-domain concepts, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Describes using employees and third-party firms for security program evaluation, monitoring, threat detection, assessments. Also mentions requiring third parties to notify of incidents.

Category: The paragraph describes what the cybersecurity program does - using employees and third parties for monitoring, threat detection, assessments. Third parties are mentioned but as part of the internal program (hired to serve the company). The last sentence about requiring notification could be TP-adjacent, but overall this is about the company's security operations. RMP.

Specificity: Let me check for domain terms. "continuous system monitoring," "threat detection" - do these pass the ERM test? "Threat detection" is somewhat domain-specific.

"System monitoring" is generic, and "cybersecurity assessments" is too broad. But "threat detection" stands out as distinctly security-focused—an ERM professional would more likely say "risk identification" instead. I'll mark that as a domain-specific term, putting this at Level 2.


fact: Threat intelligence from partners on tactics, techniques, and procedures (TTPs)

fact: Phishing exercises for employees

fact: Third-party service provider for monitoring and detection of cybersecurity environment

fact: IT security assessment of critical third-party vendors

fact: Cybersecurity incident response plan ("CIRP") — named internal program with distinguishing acronym

reasoning: The paragraph describes program activities — threat intelligence, phishing exercises, monitoring/detection, vendor assessments, and an incident response plan — answering 'what does the program do?' → RMP. Third-party risk is present but as one component among several. The named 'CIRP' acronym is a firm-specific identifier elevating to Level 3, supported by multiple domain terms (TTPs, phishing exercises, threat intelligence).

thinking:
Let me analyze this paragraph.

Content category: This describes what the cybersecurity program does - threat intelligence, training, phishing exercises, monitoring, vendor assessments, incident response plan. Multiple activities. Third-party is mentioned but as part of a broader program description. RMP.

Specific facts:
- "threat intelligence" - domain term
- "tactics, techniques, and procedures" (TTPs) - domain term
- "phishing exercises" - domain term
- "monitoring and detection" - could be generic
- "cybersecurity incident response plan ("CIRP")" - named internal program with acronym → firm-specific

- Third-party vendor security assessments are part of the RMP framework, and "IT security assessment" is standard domain terminology. The CIRP with its specific acronym stands out as a firm-specific named program at Level 3 specificity.


reasoning: The paragraph states a backward-looking and forward-looking materiality conclusion ('have not materially affected... business strategy, results of operations, or financial condition' and 'reasonably likely to materially affect'), triggering 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, and the cross-reference to Item 1A adds no substance.

thinking:
This is a materiality assessment statement plus a cross-reference.

Category: The paragraph states a conclusion about whether cybersecurity has affected business outcomes - "have not materially affected... business strategy, results of operations, or financial condition" and "are reasonably likely to materially affect." This is SI per Rule 5.

Specificity: This is a negative self-assertion ("not aware of any risks," "have not experienced any cybersecurity incidents") - not externally verifiable. The cross-reference to Item 1A is N/O content. No domain terms, no firm-specific facts, no verifiable claims.

So this lands at Level 1 - it's a boilerplate materiality statement without substantive disclosure.


reasoning: The paragraph's central topic is reliance on a third-party accounting firm's cybersecurity protections and the evaluation of providers' security posture as part of engagement decisions, making vendor oversight the primary subject (TP). No domain-specific terminology (fails ERM test—'cybersecurity protections and procedures' is generic), no firm-specific cybersecurity facts (the third-party firm is unnamed, no named roles), and no verifiable claims, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Small company, minimal IT, outsourced bookkeeping to third-party accounting firm, relies on third party's cybersecurity protections, consideration of protections is part of management's decision to engage providers.

Category: This is about how they manage third-party cyber risks - vendor oversight is central. The paragraph describes their reliance on and evaluation of third-party cybersecurity. This fits Third-Party Risk.

Specificity: No domain terms that pass ERM test. No named roles at VP+. No verifiable facts. The content is generic - "outsourced bookkeeping to a third-party accounting firm" is somewhat firm-specific in describing their unique situation... but it's not a named firm or specific role.

The language around vendor oversight is pretty standard boilerplate. Though they do describe a specific company situation—small size, minimal IT resources, complete outsourcing of bookkeeping—these are operational facts rather than cybersecurity-specific details. No domain terminology, no firm-named vendors, no concrete security measures mentioned. This lands at Level 1 - Generic Boilerplate.

The core topic here is their reliance on third-party protections and how they evaluate providers when making engagement decisions, which clearly points to Third-Party Risk rather than RMP.


reasoning: The paragraph describes how a board-level Committee receives cybersecurity reports from management, which is about information flow to the board (oversight structure) → Board Governance. No domain-specific terminology, firm-specific facts, or verifiable claims are present; 'the Committee' without further specification and generic language about 'periodic reports' and 'cybersecurity incidents' remain at Level 1.

thinking:
Classify this paragraph.

This is about how the Committee (board-level) receives reports from management about cybersecurity risks and incidents. This describes the oversight structure and information flow to the board → Board Governance.

Specificity: No domain terms beyond generic "cybersecurity risks" and "cybersecurity incidents." No named roles, no firm-specific facts, no verifiable claims. This is generic boilerplate.


fact: ransomware attack

fact: In 2021, the Bank was the target of a ransomware attack

fact: Bank was sued in a purported class action lawsuit currently in process of settlement

reasoning: The paragraph's primary content describes a real 2021 ransomware incident—its nature, resulting class action lawsuit, and settlement status—making Incident Disclosure the dominant frame per Rule 4, though it also contains a materiality assessment (SI). Specificity reaches Level 4 because the 2021 ransomware attack is a specific dated real event and the class action lawsuit/settlement are independently verifiable via court records.

thinking:
Let me analyze this paragraph.

Content: Describes a 2021 ransomware attack, resulting lawsuit, and materiality assessment. Mixed content - incident disclosure and strategy integration.

The paragraph has:
1. Reference to cyber attacks experienced
2. Specific 2021 ransomware incident description
3. Lawsuit and settlement status
4. Materiality assessment ("has not identified other known risks from previous cybersecurity threats that have materially affected or are reasonably likely to materially affect")
5. Forward-looking risk language

Per Rule 4: What happened (timeline, scope, response) → ID.

Now I'm looking at how the business and financial impact frames interact with the incident narrative. The paragraph opens with the 2021 ransomware attack as the anchor point, then moves into the lawsuit and settlement details, before concluding with the materiality assessment and forward-looking statements. The incident itself dominates the opening, but the materiality language—particularly the statement about not identifying other material risks from past cybersecurity threats—carries significant weight in establishing the company's risk posture. This feels like incident framing in the first half, shifting toward strategic impact language in the second half, with the incident serving as the foundation for the materiality claim. The specifics here are concrete—a dated 2021 ransomware attack, a class action lawsuit with settlement details, and materiality language—all verifiable through court records and company disclosures. This confirms Level 4 classification.


content_category: None/Other

reasoning: The paragraph is a forward-looking disclaimer about threat severity combined with a cross-reference to Item 1A Risk Factors, containing no substantive cybersecurity disclosure. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

This is a brief paragraph that says threats are severe and cross-references Item 1A Risk Factors. No substantive cybersecurity disclosure - it's a disclaimer plus cross-reference.


reasoning: The paragraph's most substantive claim is the negative assertion 'did not experience any cybersecurity incident during 2024,' which per Rule 5 is a backward-looking assessment of whether cybersecurity affected the business → SI. The first sentence is generic commitment language. No domain terms pass the ERM test, no firm-specific facts, and the negative incident assertion is a self-reported claim about absence that is not externally verifiable, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Two sentences. First about commitment to staying updated on regulations/best practices. Second states no cybersecurity incidents in 2024.

Category: The first sentence is generic commitment language. The second sentence is a negative assertion about incidents. Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI. Here it says "did not experience any cybersecurity incident during 2024" which is a negative assertion about incident history - this is SI.

But the first sentence is about board commitment to staying updated - could be BG. The second sentence is SI per the materiality rule. The SI assertion is a conclusion about whether cybersecurity affected business outcomes.

Actually, looking at Rule 5 more carefully, the negative assertion about not experiencing cybersecurity incidents during 2024 is clearly SI - it's a substantive disclosure about incident history, even though it's self-reported and not externally verifiable. The first sentence's generic commitment language is less concrete, so the negative assertion dominates here as the more meaningful content.

Breaking down the specificity: "Board of Directors" is just generic institutional language, "during 2024" is just the reporting period, and the core claim about no incidents is an unverifiable self-assertion. There are no firm-specific facts or verifiable claims present, so this lands at Level 1 - pure generic boilerplate.


fact: NIST framework referenced as basis for cybersecurity program

type: framework

fact: ISO framework referenced as basis for cybersecurity program

fact: Confidentiality, integrity, and availability (CIA triad)

reasoning: The paragraph describes what the cybersecurity program does—framework adoption, annual risk assessments, and a company-wide risk management approach—making it RMP. References to NIST and ISO as named standards and the CIA triad demonstrate domain knowledge beyond generic ERM language, but the paragraph only claims alignment rather than certification, keeping it at Level 2.

thinking:
Classify this paragraph.

Category: Describes what the cybersecurity program does - framework adoption, risk assessments, risk management approach. This is RMP.

Specific facts:
- NIST framework (domain_term/framework)
- ISO framework (domain_term/framework)
- "Annual technology and cybersecurity risk assessments" - "annual" is generic cadence
- "confidentiality, integrity, and availability" - CIA triad is a domain concept

NIST and ISO are named standards → domain terms (Level 2). "Aligned with" not "certified" so not Level 4.

Specificity: Domain-Adapted (Level 2)


fact: SVP, Engineering is primarily responsible for cybersecurity

fact: VP, Technology & CISO is primarily responsible for cybersecurity

fact: VP, Technology & CISO has prior head of security and CISO positions at both public and private companies

reasoning: The paragraph focuses on who in management is responsible for cybersecurity, their team structure, and qualifications — classic MR content. Specificity is Firm-Specific due to named VP-or-above roles (SVP Engineering, VP Technology & CISO) but lacks verifiable quantities (no years of experience, no certifications, no named individuals).

thinking:
MR - about management roles, responsibilities, qualifications.

Facts: SVP Engineering (named role), VP Technology & CISO (named role), experience description for CISO.

No verifiable numbers. The CISO role is firm-specific. Experience description is qualitative not quantified.


reasoning: The paragraph answers how the board oversees cybersecurity, describing Board and Audit Committee oversight roles and briefing cadences, making it Board Governance. All elements are generic — 'Audit Committee,' 'independent directors,' 'at least quarterly/annually' are standard governance language found at every public company, with no domain-specific terms, firm-unique facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: Board of Directors oversight, audit committee oversight of cybersecurity. This is about how the board oversees cybersecurity → Board Governance.

Specific facts:
- "at least once a year" for board discussion - generic cadence
- "audit committee" - every company has this, not firm-specific
- "at least quarterly" - generic cadence
- "comprised entirely of independent directors" - standard requirement

No domain terms that pass the ERM test. No firm-specific facts (audit committee is generic). No verifiable facts.

Wait - "Dropbox's business strategy" is just a company name reference, not a specific fact.

This is Level 1 - Generic Boilerplate.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for materiality discussion, containing no substantive cybersecurity disclosure itself. Per Rule 5, cross-references like 'risks that may materially affect us, see Item 1A' are N/O. No specific facts elevate specificity above Level 1.

thinking: Cross-reference to Item 1A with materiality language.


fact: World Gold Council provides reports to the Board

fact: Sponsor's officers report to the Board

reasoning: The paragraph describes how the Board of Directors receives cybersecurity-related reports from the Sponsor's officers and service providers, directly answering the board oversight question → Board Governance. The mention of 'World Gold Council' as a named organization providing reports is a firm-specific fact elevating to Level 3.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - how the board oversees cyber risks. This is Board Governance.

Specific facts:
- "Board of Directors" - generic, not firm-specific
- "Sponsor's officers" - somewhat specific to trust structure
- "World Gold Council" - named organization, firm-specific
- "annual due diligence" - generic cadence
- "service providers" - generic

The World Gold Council is a named entity specific to this company's structure. That's firm-specific.

Specificity: Firm-Specific (Level 3) due to "World Gold Council" being a named organization specific to this trust.


reasoning: The paragraph answers how the board oversees cybersecurity, describing its oversight role and candidly noting the lack of relevant expertise among board members — squarely Board Governance. No domain-specific terminology (ERM fails the ERM test), no firm-specific facts (Board is generic), and no verifiable claims, keeping this at Level 1.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity risks → Board Governance. The paragraph describes the board's oversight role and notes lack of expertise.

Specificity: No domain terms beyond generic "cybersecurity risks" and "enterprise risk management." No firm-specific facts (Board is generic). No verifiable claims. This is Level 1.


fact: penetration testing firms

fact: threat intelligence service providers

fact: eradication and recovery (incident response phase)

reasoning: The paragraph describes third-party providers hired to serve the company's cybersecurity program (assessors, pen testers, threat intel providers), which per Rule 3 maps to RMP rather than TP. Domain terms like penetration testing, threat intelligence, encryption/authentication, and eradication/recovery pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Lists third-party service providers used for security functions and cybersecurity risk management. The focus is on what third parties do for the company (assessors, pen testers, threat intel providers) - these are third parties hired to serve the company → RMP per Rule 3.

Wait, let me re-read. It describes both outsourced business functions AND third parties that help manage cybersecurity risks. Per Rule 3, third parties hired to serve the company → RMP.

The last sentence fragment "Response, eradication and recovery, Post-incident analysis and future preparations" seems like a truncated list item.

Now I'm checking the specificity level. The paragraph uses domain-specific terms like penetration testing, threat intelligence, encryption and authentication technology, and incident response concepts, but these are all standard cybersecurity terminology rather than company-specific facts. There are no verifiable claims or firm-specific details, so this lands at Level 2.


reasoning: The paragraph's heading and content center on whether cybersecurity risks have materially affected the company, concluding with a negative assertion ('we did not experience any cybersecurity incidents'), which per Rule 5 is a backward-looking materiality assessment → SI. For specificity, the date 'March 31, 2025' merely anchors a negative self-assertion which is not externally verifiable, there are no domain terms passing the ERM test, and no firm-specific facts, so it remains Level 1.

thinking:
Let me analyze this paragraph.

Content category: The paragraph states a conclusion about whether cybersecurity has affected business outcomes - "we did not experience any cybersecurity incidents" and discusses potential impacts. The heading is "Material Impact of Cybersecurity Risks." Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI (negative assertion). This fits Strategy Integration.

Specificity: Let me scan for facts.
- "As of March 31, 2025" - a specific date, but it's anchoring a negative assertion ("we did not experience any cybersecurity incidents"). Per the rules, negative self-assertions are NOT externally verifiable.

The date itself doesn't add verifiable substance to a negative claim. "Proactive risk management processes" is just generic language without domain specifics or firm-specific details, and there are no verifiable claims that would elevate this beyond boilerplate. This lands at Level 1 - Generic Boilerplate.


fact: Chief Information Security Officer (CISO) prepares and presents reports to the board committee

reasoning: The paragraph describes the governance chain from senior management through the CISO to the Audit Committee, answering how the board oversees cybersecurity — the CISO report to the Audit Committee is the core content. Specificity is Firm-Specific due to the CISO role; 'Audit Committee' and 'quarterly' are generic, and 'enterprise risk assessment' fails the ERM test (it IS ERM language).

thinking:
Classify this paragraph.

The paragraph describes how cybersecurity risks flow from senior management up to the Board's Audit Committee. It mentions the CISO reporting to the Audit Committee quarterly. The primary question answered is "How does the board oversee cybersecurity?" — information flow to the board via CISO reports to Audit Committee.

Category: Board Governance (describes oversight structure and how information flows to the board)

Specific facts:
- "chief information security officer" (CISO) — named_role, firm-specific
- "Audit Committee" — NOT firm-specific (every company has one)

- "quarterly basis" — generic cadence, not specific
- "enterprise risk assessment" — ERM term, not domain-specific

The CISO reference pushes this to Level 3 classification.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for materiality discussion, with no substantive cybersecurity disclosure of its own. Per Rule 5, cross-references like 'risks that may materially affect us, see Item 1A' are N/O. No specific facts elevate specificity above Level 1.

thinking: Cross-reference to Item 1A risk factors, no substantive cybersecurity disclosure here.


reasoning: The paragraph makes a backward-looking materiality assessment ('no cybersecurity impact on our results of operations or financial condition') → Strategy Integration. No domain terms, firm-specific facts, or verifiable claims; the negative assertion about no incidents is not externally verifiable → Generic Boilerplate.

thinking:
Classify this paragraph.

This states "we have not experienced a cybersecurity threat or incident" and "no cybersecurity impact on our results of operations or financial condition" - this is a materiality assessment (backward-looking negative assertion). Then generic forward-looking speculation.

Category: Strategy Integration (SI) - it's stating a conclusion about whether cybersecurity has affected business outcomes.

Specificity: The negative assertion "have not experienced" is not externally verifiable. No domain terms, no firm-specific facts, no verifiable claims. Level 1.


reasoning: The paragraph describes cybersecurity program activities — incident response operations, annual security training, and ongoing security awareness education — which are program processes rather than management organizational structure (person-removal test: substantive content remains). No domain terms pass the ERM test ('incident response plan,' 'security awareness' are standard ERM vocabulary), no firm-specific facts, and no verifiable claims, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

Category: The paragraph discusses senior leadership monitoring cybersecurity incidents and employee training. The first sentence describes management's participation in cybersecurity processes. The second and third sentences describe employee training programs. This is primarily about what the cybersecurity program does (training, incident response operation) rather than who the managers are. Using the person-removal test: remove "members of senior leadership" and the paragraph still describes incident response plans, training programs, and security awareness education. → RMP.

Specificity: Let me scan for facts:
- "incident response plan" — commonly confused, stays L1
- "annual information security and privacy training" — generic process description, L1

- "security awareness education via informational emails, talks and presentations, and resources available on our intranet" — also a process description, fairly generic

No domain terms that pass the ERM test, no firm-specific facts, and no verifiable claims. This is Level 1.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by listing program components (risk assessments, security team, training, incident response plan, third-party risk management). All terms used are standard ERM language — risk assessments, security controls, incident response plan, cybersecurity awareness training, third-party risk management — none pass the ERM test as domain-specific vocabulary, resulting in Level 1.

thinking:
RMP - describes what the program does. Let me check specificity.

Looking for domain terms: "risk assessments," "security controls," "incident response plan," "cybersecurity awareness training," "third-party risk management process."

ERM test: "risk assessments," "security controls" - security controls passes ERM test as it's domain-specific. Actually, "security controls" is borderline. "Incident response plan" is listed as commonly confused L1. "Cybersecurity awareness training" - this is generic. "Third-party risk management process" - generic.

Actually, let me re-examine.

Going through each term, I'm noticing that "risk assessments," "incident response plan," "cybersecurity awareness training," and "third-party risk management process" are all standard L1 language. Even "security controls" is fairly generic despite being somewhat domain-specific. This whole paragraph reads like boilerplate that any ERM professional could produce without much thought.


reasoning: The paragraph describes general IT infrastructure and business systems (cloud technologies, licensed software) without addressing any cybersecurity-specific question — no risk management, governance, or incident content. As None/Other, specificity defaults to Generic Boilerplate.

thinking:
Classify this paragraph.

This is about general IT systems and technology, not cybersecurity. No cybersecurity measures, processes, or assessments described.


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

thinking: Cross-reference to Item 1A Risk Factors → None/Other


fact: CIO (Chief Information Officer) coordinates the cybersecurity program

fact: CIO coordinates with CEO, CFO, and General Counsel

fact: CIO's team is deployed to address cybersecurity threats

reasoning: The paragraph primarily answers how management is organized: CIO coordinates with CEO/CFO/GC, CIO's team is deployed, and the management team monitors and reports to the Board. While program activities are mentioned (monitoring prevention/detection/mitigation/remediation), the grammatical subjects are consistently roles and teams describing organizational structure. CIO is a firm-specific role (VP-equivalent IT leadership), elevating to Level 3, but no verifiable claims push it to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes how management is organized - CIO coordinating with CEO/CFO/GC, team deployment, reporting lines. But it also describes program activities (implement program, monitor prevention/detection/mitigation/remediation). Let me apply the person-removal test: remove CIO, CEO, CFO, GC titles and team references. What remains? "implement a program designed to protect information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents in accordance with incident response and recovery plans" and "monitors the prevention, detection, mitigation and remediation of cybersecurity threats and incidents in real time." There's still substantive program description, but the paragraph is primarily about WHO does WHAT - the organizational structure.

The grammatical subjects are all people and roles, so this is clearly about management responsibility. The core question being answered is how the organization structures its cybersecurity oversight - the CIO coordinates with other C-suite executives, deploys teams, and the management structure reports to the Board. Since CIO qualifies as a firm-specific role under the rules, while CEO, CFO, and General Counsel are generic governance titles, this is management responsibility.

Looking at the specificity markers: the incident response and recovery plans are generic L1 content, the prevention-detection-mitigation-remediation framework is standard process language, but "in real time" suggests a firm-specific operational claim about their 24/7 capabilities. The CIO being firm-specific pushes this to 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 receive Generic Boilerplate.

thinking: Cross-reference to Item 1A Risk Factors, no substantive cybersecurity content.


fact: CFO and CCO provide updates to the Board on cybersecurity

fact: GC Advisors' cybersecurity program (named affiliated entity)

reasoning: The paragraph describes how the Board provides strategic oversight and receives periodic cybersecurity updates, squarely answering the BG question. CFO and CCO are generic governance roles (not firm-specific), but 'GC Advisors' is a named affiliated entity specific to GBDC's structure, elevating to Firm-Specific. No verifiable claims or domain terms beyond generic oversight language.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - BG. Board receives updates from CFO/CCO about cybersecurity program.

Specific facts:
- CFO and CCO named as roles reporting to board (but these are generic governance roles - CFO, CCO exist at every company)
- "GC Advisors" - named entity, firm-specific
- Board receives periodic updates - generic cadence

Wait - CFO and CCO are generic roles per the rules. But "GC Advisors' cybersecurity program" names a specific entity. That's firm-specific.

The "GC Advisors" reference makes this Level 3 firm-specific, since it's a named entity unique to this company rather than a generic governance structure.


reasoning: The paragraph is an introductory commitment statement, a cross-reference to Item 1A risk factors, speculative 'could negatively impact' language, and a generic definition of cybersecurity threats — none of which constitute substantive cybersecurity disclosure answering any of the six category questions. While it names specific system types (POS software, accounting software), no actual cybersecurity measures, governance structures, or program activities are described, keeping this as N/O with Generic Boilerplate.

thinking:
Analyzing this paragraph from Nathan's Famous (NATH) 10-K Item 1C.

What question does it answer? It's a general statement about commitment to security, references Item 1A risk factors, and defines cybersecurity threats. It contains a cross-reference and general acknowledgment of risks. The "could negatively impact our brand, business, results of operations and financial condition" is speculative (every 10-K says this), not a materiality assessment.

There's mention of specific systems: "accounting software, point-of-sale software, and back-of-house software" - these are somewhat specific to the company but are they domain terms or firm-specific? Point-of-sale software is a domain term in retail/restaurant context.

The rest reads as boilerplate risk language. This looks like a commitment statement with risk acknowledgment and cross-references, but without describing actual cybersecurity measures or governance structures—so it's likely N/O rather than RMP.


reasoning: This is a concluding summary sentence that name-drops several topics (third-party assessments, certifications, reporting structure) without actually describing any of them — no substantive cybersecurity disclosure is provided. All language is generic promotional boilerplate ('unwavering dedication to safeguarding sensitive information') with no domain terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

This is a summary/concluding statement about cybersecurity governance. It mentions third-party assessments, industry certifications, and organizational reporting structure but in a very high-level, non-specific way.

Category: This doesn't answer any specific question deeply. It's a summary statement touching governance, third-party assessments, and certifications but none substantively. It's mostly a concluding flourish. The closest might be RMP or N/O. It does reference "cybersecurity governance," "third-party assessments," "industry certifications," "organizational reporting structure" — but all at a very superficial level.

Looking at this more carefully, it's really just boilerplate wrapping up the company's strategic approach without diving into any actual details. Rule 6 applies here—while it touches on substantive topics like third-party assessments and certifications, there's zero depth to any of it. This reads as pure promotional language, so I'm going with N/O. language ("unwavering dedication to safeguarding sensitive information and maintaining trust").

Specificity: No domain terms that pass the ERM test. "Third-party assessments," "industry certifications," "organizational reporting structure" — all generic. "Industry certifications" is vague. This is Level 1.

Wait, "industry certifications" — does this pass the ERM test? An ERM professional could say "industry certifications" about any field. It's not cybersecurity-specific. Same with "third-party assessments."

Level 1, Generic Boilerplate, N/O.

Actually, let me reconsider the category. This paragraph does make substantive references to cybersecurity measures (assessments, certifications, reporting structure). But it's so generic and summary-like... Rule 6 says "If any actual cybersecurity measure/process/assessment is described → relevant category." But nothing is actually DESCRIBED here — they're just listed as things the company has. I'll mark this as N/O since it's a concluding statement with no real disclosure.


fact: References the CIA triad: confidentiality, integrity and availability

reasoning: The paragraph describes the company's cybersecurity risk management processes, answering 'what does the program do?' → RMP. The only element elevating above Level 1 is the explicit reference to 'confidentiality, integrity and availability' (the CIA triad), an information security domain concept that passes the ERM test, though the rest is highly generic boilerplate.

thinking:
Classify this paragraph.

Content: "We have developed and implemented cybersecurity risk management processes intended to protect the confidentiality, integrity and availability of our critical systems and information."

Category: RMP - describes what the program does (risk management processes to protect systems).

Specificity: "confidentiality, integrity and availability" - this is the CIA triad, a fundamental infosec concept. Does it pass the ERM test? An ERM professional might use "confidentiality, integrity and availability" but it's actually the CIA triad which is a core cybersecurity/infosec concept. However, this phrase has become so commonplace in SEC filings that it's borderline.

The CIA triad is fundamentally a domain-specific concept from information security, so a general ERM professional would more likely just say "protect our systems and data" rather than invoking those three specific terms. Even though the language has become standard boilerplate in SEC filings, the ERM test is about what a non-security professional would naturally use, and that points toward Domain-Adapted classification. The rest of the sentence is quite generic—"risk management processes intended to protect"—but the CIA triad reference is the distinguishing factor here.


reasoning: The paragraph opens with a materiality assessment — risks have not materially affected and are not reasonably anticipated to materially affect the organization — which is a classic SI statement under Rule 5. The remainder includes a cross-reference to Item 1A and generic mentions of tabletop exercises and lessons learned, none of which contain domain terms passing the ERM test, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

The paragraph starts with a materiality assessment ("has not identified risks from cybersecurity threats... that have materially affected or are reasonably anticipated to materially affect"). This is a classic SI statement per Rule 5.

It also contains a cross-reference to Item 1A, and mentions tabletop exercises and lessons learned from prior incidents.

The dominant content is the materiality assessment statement. Per Rule 5, "Have not materially affected... or are reasonably anticipated to materially affect" → SI.

Specificity: Let me scan for facts.
- "tabletop exercises" — commonly confused list says these stay L1 without cybersecurity qualifier.

But when it says "tabletop exercises simulating potential cyber threats," that's with a cybersecurity qualifier, though it's still pretty generic ERM language even with that added context, so I'll mark it L1.
- "cybersecurity risk management practices" — generic
- No named roles, no specific facts, no verifiable claims.

The paragraph is fairly generic overall. No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims.

Specificity: Generic Boilerplate.


reasoning: The paragraph describes what the cybersecurity program does—risk assessment processes, safeguards, system tests, policy reviews—making it RMP. All language is generic ERM boilerplate ('processes for assessing, identifying, and managing risks,' 'physical, procedural, and technical safeguards') with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Category: This describes what the cybersecurity program does - processes for assessing, identifying, managing risks, safeguards, tests, policy reviews. The external IT consultant is mentioned but not central. → RMP

Specificity: Let me scan for facts.
- "processes for assessing, identifying, and managing cybersecurity risks" → generic ERM language → L1
- "physical, procedural, and technical safeguards" → generic → L1

- "tests on our systems" → generic → L1
- "routine review of our policies and procedures" → generic → L1
- "information technology consultant" → unnamed → L1

Everything here is generic language with no domain-specific terms, firm-specific details, or verifiable claims. Level 1.


reasoning: This paragraph is a forward-looking disclaimer about the impossibility of perfect security, combined with a cross-reference to Risk Factors. It contains no substantive cybersecurity disclosure—no measures, processes, or assessments are described. No specific facts elevate specificity above Level 1.

thinking: None/Other - this is forward-looking disclaimer/risk factor cross-reference with no substantive cybersecurity disclosure.


reasoning: The paragraph primarily answers how the board oversees cybersecurity—receiving periodic updates and incident notifications—making it Board Governance. Despite mentioning the IT department's responsibility, the dominant frame is the board's oversight role. No domain terms passing the ERM test, no firm-specific facts (only generic 'Board' and 'Information Technology department'), and no verifiable claims, leaving specificity at Level 1.

thinking:
Classify this paragraph.

Content: IT department oversight, Board receiving updates periodically, Board getting updates on material incidents.

Category: This describes how the board oversees cybersecurity (receives updates periodically, gets incident updates) and mentions IT department responsibility. The primary question answered is about board oversight structure. → Board Governance.

Specificity: Let me scan for facts.
- "Information Technology department" — generic, not firm-specific
- "Board receives information and updates periodically" — generic governance
- "cybersecurity and information security framework" — generic
- No domain terms that pass ERM test
- No firm-specific facts (no named roles at VP+, no named committees beyond generic Board)

- No verifiable claims either, so this lands at Level 1 — Generic Boilerplate.


reasoning: The paragraph describes how the cybersecurity program integrates into the broader ERM program, which is a program-level activity (RMP). The language is entirely generic—'common methodologies, reporting channels, and governance processes' could describe any risk domain's ERM integration, with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes ERM integration of cybersecurity program. This is about what the program does (RMP) - specifically ERM integration.

Specificity: "enterprise risk management program" - generic ERM language. No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims. This is pure boilerplate about integration.

Level 1.


reasoning: The paragraph centrally addresses third-party service provider cybersecurity risks, vendor onboarding/monitoring, and limitations of oversight over suppliers, making TP the clear category. No domain-specific terminology (ERM test fails for all terms used), no firm-specific facts, and no verifiable claims — entirely generic language about vendor risk and disclaimers.

thinking:
Classify this paragraph.

Content: About third-party service providers, vendor onboarding/monitoring, limitations of oversight. Central topic is third-party risk.

Category: Third-Party Risk - the entire paragraph is about managing third-party cyber risks.

Specificity: No domain terms that pass ERM test, no firm-specific facts, no verifiable claims. This is generic language about vendor risk. "onboarding and monitoring processes for third-party vendors" is standard ERM language. No specific practices, tools, or standards mentioned.

Level 1 - Generic Boilerplate.


fact: virtual Chief Information Security Officer (vCISO) role

reasoning: The paragraph's primary purpose is describing how third-party risk information flows to management and the Board via a quarterly summary, fitting BG's 'how information flows to the board' question, though there is significant overlap with Third-Party Risk as the subject matter. The 'virtual Chief Information Security Officer (vCISO)' is a firm-specific CISO-level role with a distinctive qualifier, elevating specificity to Level 3.

thinking:
Let me analyze this paragraph.

Category: This describes how third-party risk information flows to the board and management via the vCISO's quarterly summary. The central topic is third-party risk reporting. But what question does it answer?

It's about oversight of third-party risk - the vCISO compiles a summary presented to board and management. This is about how information flows upward (governance chain). The purpose is describing oversight structure for third-party risk.

BG vs TP: The paragraph is about third-party risk reporting to the board. Third-party risk is the subject matter, but the paragraph is about the governance/oversight mechanism.

Now I'm weighing whether this is governance-focused or third-party risk-focused. The paragraph describes a reporting mechanism for third-party risk, and while it's technically about governance structure, the specific focus is on how third-party cyber risks are managed through executive summaries to leadership. But looking at it again, it's really about the information flow to the board - that's the governance mechanism at play here, so this should be BG. Looking at the specific elements in the text, I'm seeing this genuinely straddles both categories—the vCISO's quarterly summary and board reporting points toward Board Governance, while the focus on managing third-party risk and enabling decisions about third-party engagements pulls toward Third-Party Risk. The paragraph's core purpose is describing how third-party risk information reaches leadership, so I'm leaning toward Board Governance, though I recognize the third-party risk management angle is equally central here.

On specificity, the "virtual Chief Information Security Officer" is a firm-specific role with a distinctive qualifier that sets it apart from a standard CISO position, making it Level 3. The quarterly cadence and executive summary format are specific mechanisms but fairly standard, while third-party risk itself isn't a specialized domain term under the ERM framework.


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

thinking: Cross-reference to Item 1A, no substantive cybersecurity disclosure.


reasoning: The paragraph's central topic is how third-party cyber risks are managed—vendors, service providers, and external users—making it Third-Party Risk. The language is entirely generic ('comprehensive, risk-based approach to identifying and overseeing cybersecurity risks') with no domain terminology, firm-specific facts, or verifiable claims, keeping it at Level 1.

thinking:
TP - central topic is third-party risk management approach. But let me check specificity.

The paragraph says "comprehensive, risk-based approach to identifying and overseeing cybersecurity risks presented by third parties, including vendors, service providers and other external users." This is generic - no domain terms, no firm-specific facts, no verifiable claims.

"risk-based approach" - fails ERM test, generic.
"vendors, service providers and other external users" - generic.

Level 1.


fact: Vice President of IT and Digital

fact: CISO

reasoning: The paragraph describes how two named leadership roles (VP of IT and Digital, CISO) maintain their cybersecurity knowledge; applying the person-removal test, the remaining content ('processes to identify, prevent, mitigate and remediate') is generic boilerplate, so the paragraph collapses without the role-specific content → MR. Two VP-level or equivalent roles elevate specificity to Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph describes how the VP of IT and Digital and CISO stay informed about cybersecurity developments through third-party providers and seminars, and how this enhances their processes.

Category: This is about management roles - specifically how these officers maintain their knowledge. But applying the person-removal test: remove the VP of IT and Digital and CISO references. What remains? "Through third party service providers and attendance at seminars... regularly informed about the latest developments in cybersecurity... This ongoing knowledge acquisition enhances our processes to identify, prevent, mitigate and remediate cybersecurity threats." - This collapses to generic process language without substance.

The key here is that these are named leadership positions with specific IT responsibilities, which makes this firm-specific. There aren't any concrete metrics or external certifications mentioned, but the roles themselves and how they're structured are what anchor this to the organization. I'd categorize this as firm-specific at level 3.


reasoning: The paragraph describes general IT management services (operational review, strategic planning, technology road-mapping, IT policy handbook, SLA reporting) provided by a vCIO/MSP — none of which constitutes substantive cybersecurity disclosure. While placed in Item 1C, the content itself answers no cybersecurity-specific question. N/O paragraphs receive Generic Boilerplate.

thinking:
Classifying this paragraph about vCIO services for Lightbridge Corp.

This describes IT services provided by an external MSP (Managed Service Provider) - operational review, strategic planning, technology road-mapping, policy development, and reporting per SLA. This is general IT management services, not substantively about cybersecurity.

Category: This is about IT services from a third party, but the content is general IT (not cybersecurity-specific). It mentions operational review, strategic planning, technology road-mapping, IT policy handbook, SLA reporting. None of this is cybersecurity-specific. Could be Third-Party Risk or None/Other. Since it's describing what IT services are provided but not cybersecurity measures, and there's no substantive cybersecurity disclosure here, this leans toward None/Other.

Even though this appears in Item 1C context where cybersecurity disclosures belong, the actual content is just general IT management - there's no substantive cybersecurity substance here. The vCIO and MSP terminology describes outsourced IT management, but the specifics listed are operational and strategic IT work, not security measures. This falls under None/Other as generic boilerplate.


reasoning: This paragraph is essentially a risk factor discussion cross-referencing Item 1A, dominated by speculative 'could/may' language about potential adverse effects. While it briefly mentions generic measures taken (security technologies, internal controls, disaster recovery, insurance), the overwhelming purpose is forward-looking disclaimer about what might go wrong — it does not primarily answer any of the six substantive cybersecurity disclosure questions. Per Rule 5, 'could have a material adverse effect' is generic speculation, not a materiality assessment. None/Other paragraphs receive Generic Boilerplate.

thinking:
This is a risk factors paragraph from Item 1C, but it reads like typical Item 1A risk factor language - speculative, forward-looking, describing potential adverse effects.

Category: This is speculative risk language - "could have a material adverse effect" which per Rule 5 is NOT SI. It mentions some measures taken but mostly in a hedged, speculative context. The paragraph is primarily a risk factor discussion with "could" and "may" language throughout. It cross-references Item 1A. The cybersecurity measures mentioned are brief and generic. This is essentially a risk factor paragraph placed in Item 1C.

The measures listed—security technologies, internal controls, network resiliency, disaster recovery, remote work upgrades, and insurance—are too vague and generic to constitute substantive disclosure. The paragraph is dominated by speculative language about what could go wrong rather than describing actual cybersecurity practices, so this reads like N/O rather than substantive Item 1C disclosure. Looking at this next thinking, it seems to be a classification decision about whether something receives a "Generic Boilerplate" label. Since my current rewritten thinking already concluded this is a None/Other category with speculative language, this next chunk appears to be confirming that classification and assigning the specificity level.

I'll integrate this into the existing thought naturally:

Looking at this paragraph, it's primarily a risk factor discussion with speculative language—the measures mentioned are too generic and incidental to be the main focus. This gets classified as None/Other with Generic Boilerplate specificity.


reasoning: This paragraph is pure forward-looking risk speculation ('we may not be able to...', 'we may also incur...') without describing any actual cybersecurity measures, processes, or assessments — it reads as generic risk factor language. No domain terms, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph primarily describes board oversight responsibility for cybersecurity risk management with management's role subordinate to that structure, making BG the best fit despite the closing no-incidents assertion (which alone would be SI). All language is generic ERM vocabulary ('identifying, considering and assessing,' 'monitoring') with no domain terms, no firm-specific facts (only generic 'Board' and 'Management'), and the negative incident assertion is a non-verifiable self-report, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: Board oversight of risk management including cybersecurity, management responsibility for identifying/assessing risks, and a statement about no incidents in fiscal year 2024.

Category: The paragraph answers multiple questions. It mentions board oversight (BG), management responsibility (MR/RMP), and no incidents (SI per Rule 5 - negative assertion about material incidents... wait, it says "cybersecurity incidents" not "material cybersecurity incidents"). Let me re-read: "We have not experienced any cybersecurity incidents in fiscal year 2024." This is a negative assertion but doesn't use "material" - it's broader.

The last sentence is actually a stronger claim than what Rule 5 typically requires—it's asserting no incidents at all rather than no material ones. But looking at the overall structure, the governance and management responsibility content takes up most of the paragraph, so the primary focus is really on how the board oversees cybersecurity rather than the incident disclosure itself. The specificity is pretty thin too—just generic references to "board" and "management" with the reporting period and a blanket statement about no incidents.

There aren't any domain-specific terms that would indicate real expertise or firm-specific details. It's all standard risk management language without named roles, concrete facts, or anything that could actually be verified. This reads as generic boilerplate.


reasoning: The paragraph answers how the board oversees cybersecurity — describing awareness, management collaboration, and delegation to the Audit Committee — making it Board Governance. No domain terms, firm-specific facts, or verifiable claims are present; 'Audit Committee' is generic and exists at every public company, so specificity remains Level 1.

thinking:
Classify this paragraph.

Content: Board oversight of cybersecurity, delegation to Audit Committee. This is about how the board oversees cybersecurity → Board Governance.

Specific facts: "Audit Committee" - generic, every company has one. No domain terms, no firm-specific facts, no verifiable claims. This is generic boilerplate about board oversight.

Specificity: Level 1 - Generic Boilerplate.


reasoning: The paragraph states a backward-looking materiality conclusion ('did not identify any cybersecurity threats that have materially affected...') and a forward-looking materiality assessment ('reasonably likely to materially affect'), both triggering the SI materiality rule. No domain terms, firm-specific facts, or verifiable claims are present—the fiscal year reference is reporting context, and the negative assertion is not externally verifiable.

thinking: SI materiality rule applies here.


fact: Chief Information Officer (CIO) role supervising information security team

fact: Information Security Officer role

fact: Annual and ongoing company-wide information security awareness training

fact: Third-party vendor onboarding cybersecurity assessment

fact: Risk-based monitoring of third-party vendors

fact: Combined over 35 years of IT management experience

reasoning: Person-removal test: removing CIO, ISO, their qualifications, and team references leaves substantial program content (cybersecurity strategy implementation, security awareness training, third-party vendor oversight processes), pointing to RMP over MR. The third-party content is significant but not the central topic of the whole paragraph. Specificity reaches Level 4 due to 'combined over 35 years of IT management experience,' which is a verifiable lower-bound claim checkable against resumes.

thinking:
Let me analyze this paragraph.

Category: Mixed content - management roles (CIO, ISO), their responsibilities, qualifications, and third-party risk management. The person-removal test: removing CIO, ISO, their titles and experience leaves the third-party vendor processes and security awareness training. That's substantial RMP/TP content. But the paragraph also describes management organization. Let me weigh: CIO supervises team, ISO conducts training, combined experience, then third-party processes. It's split between MR and RMP/TP.

The first two sentences describe management roles and responsibilities. The third sentence is qualifications (MR).

Looking at the fourth sentence about third-party risk processes, I'm seeing the governance structure (CIO supervising, ISO coordinating) maps to management roles, while the actual activities—cybersecurity strategy, training, vendor oversight—are clearly RMP/TP content. When I strip away the people and titles, what's left is substantial: enterprise-wide security strategy, company-wide awareness training, and the entire third-party vendor management piece. This paragraph genuinely straddles both categories with meaningful content in each.

The structure moves from MR context into RMP substance—it's describing what the cybersecurity program does, with organizational roles providing the framework. The third-party content is prominent in the final sentence but doesn't dominate the whole paragraph. I'm settling on RMP as the primary classification, with third-party as a secondary component. The specificity of named roles like CIO and Information Security Officer, plus the detail about combined experience, anchors this in firm-specific governance, but the program activities themselves are what drive the RMP categorization.


reasoning: The paragraph describes how the audit committee oversees cybersecurity risks and how information flows from management to the committee to the board — squarely answering the board governance question. No domain-specific terminology, firm-specific facts, or verifiable claims are present; 'audit committee,' 'periodic presentations,' and 'when material' are all generic governance language.

thinking:
Classify this paragraph.

Category: Board Governance - describes board/committee oversight of cybersecurity, briefing frequency, how information flows to the board.

Specificity: Let me scan for facts.
- "audit committee" - generic, every company has one → not firm-specific
- "periodic presentations" - generic cadence
- "when material" - generic

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

Level 1.


fact: vendor qualification and management program for service providers handling protected health information, personal information, or regulated data

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers, including a vendor qualification program and reliance on providers for incident notification — squarely Third-Party Risk. The mention of a named internal program ('vendor qualification and management program') specific to providers handling PHI/PII gives it a firm-specific flavor, though it's borderline since the program name is somewhat generic. The confidentiality/integrity/availability triad is standard domain language but fails the ERM test as it's commonly used in general risk contexts. The specific scoping to PHI and regulated data distinguishes this company's program.

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


reasoning: The paragraph describes how the Board is informed about cybersecurity risk management and its oversight responsibility, making it Board Governance. All language is generic — 'Board,' 'executive officers,' 'risk management process,' 'cybersecurity threats' — with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity risks, how board is informed. This is Board Governance.

Specificity: No domain terms beyond generic "cybersecurity threats" and "risk management process." No firm-specific facts (Board and executive officers are generic). No verifiable claims. Level 1.


reasoning: The opening sentence is a backward-looking materiality assessment ('have not materially affected our business, strategy, results of operations or financial condition'), which per Rule 5 triggers SI. The remainder is generic speculation and 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 not externally verifiable.

thinking:
Let me analyze this paragraph.

"Such threats and breach attempts have not materially affected our business, strategy, results of operations or financial condition." → SI (backward-looking materiality assessment)

The rest is speculation ("could have a material adverse effect") and a cross-reference to Item 1A.

The primary content is the materiality assessment statement, making this SI.

Specificity: No domain terms, no firm-specific facts, no verifiable claims. The materiality statement is a negative self-assertion, not verifiable. This is Level 1.


reasoning: The paragraph's central statement is a backward-looking materiality assessment ('have not had a material impact on our operations, business strategy or financial results'), which maps to Strategy Integration per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present—only generic language about cybersecurity risks and a cross-reference to Risk Factors.

thinking:
Let me analyze this paragraph.

Content: This paragraph states that risks haven't had material impact (backward-looking materiality assessment), references Risk Factors, and mentions continuous enhancement.

Category: The key sentence is "To date, these risks, threats or attacks have not had a material impact on our operations, business strategy or financial results" — this is a backward-looking materiality assessment → Strategy Integration per Rule 5.

Specificity: Let me scan for facts:
- "have not had a material impact on our operations, business strategy or financial results" — this is a negative self-assertion about absence of material impact, not externally verifiable

- No domain terms, no firm-specific facts, no verifiable claims
- "cybersecurity program" — generic
- Cross-reference to Risk Factors — N/O element but not dominant

This is pretty much generic boilerplate with a materiality conclusion. Level 1.


fact: Active interactions with children's hospitals while assisting with insurance prior approvals identified as a specific risk context

reasoning: The paragraph contains both a backward-looking materiality conclusion ('have not identified risks...that have materially affected us') and a forward-looking SEC 106(b)(2) assessment ('reasonably likely to materially affect'), making it Strategy Integration under Rule 5. The mention of children's hospitals and insurance prior approvals as a specific risk context is firm-specific, distinguishing this company's posture, but there are no verifiable/quantified claims.

thinking:
Classify this paragraph.

The paragraph contains two materiality assessments plus a section header. The first sentence is a backward-looking materiality conclusion ("have not... materially affected"). The second is a forward-looking materiality statement ("reasonably likely to materially affect"). Both are SI per Rule 5. The "CYBERSECURITY GOVERNANCE" at the end is just a header.

Specificity: The mention of "active interactions with children's hospitals while assisting with insurance prior approvals" is firm-specific - it describes this company's particular risk context. No domain terms, no verifiable claims. Level 3.


reasoning: The paragraph frames the scope of cybersecurity risks the company recognizes (operational risks, IP theft, fraud, etc.) but describes no actual processes, measures, or program activities—it merely states they 'recognize the importance.' This is an introductory framing paragraph for RMP content, though N/O is defensible since no substantive measure is disclosed. All terminology (operational risks, intellectual property theft, data privacy, fraud) is standard business/ERM language that fails the ERM test, keeping specificity at Level 1.

thinking:
Classify this paragraph.

Content: Generic statement about recognizing importance of cybersecurity risks, listing risk types. No specific program details, no people, no processes described.

Category: This is a generic opening statement. It lists risk types but doesn't describe any process, governance, or program. It's essentially introductory boilerplate. However, it does mention "assessing, identifying, and managing material risks" which touches RMP territory, but it's extremely generic. The mention of "material risks" here is using "material" as an adjective, not making a materiality assessment. This is borderline N/O vs RMP.

The language here is all about recognizing importance rather than actually describing what they do—just saying they acknowledge the value of assessing and managing cybersecurity risks without disclosing any actual measures or programs. The risk types listed are generic enough that they could apply to any company, so this leans toward N/O despite the conceptual nod to risk management. I'm debating whether this is really a risk management process disclosure or just generic framing. The paragraph lists some business risks but doesn't describe any actual cybersecurity measures or assessments—it's more of an acknowledgment that these risks exist. I'm leaning toward RMP since it does identify the scope of risks they manage, even if superficially, though N/O is defensible. I'll go with RMP at low-moderate confidence.

Now looking at the specificity of the terms used—"operational risks," "intellectual property theft," "fraud," and the regulatory reference to Item 106(a)—these are general business and compliance terms rather than cybersecurity domain language. An ERM professional wouldn't consider these cybersecurity-specific terminology.

This is Level 1 generic boilerplate.


reasoning: The paragraph contains the SEC Item 106(b)(2) forward-looking materiality assessment ('not reasonably likely to materially affect us or our operations, business strategy, results of operations or financial condition'), making SI the primary category per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present—management's role is described generically and the cross-reference to Item 1A adds no substance—so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Management responsible for day-to-day risk management, statement that no known risks are reasonably likely to materially affect them, cross-reference to Item 1A.

Category analysis:
- "Management is responsible for day-to-day administration" → MR
- "We do not believe that there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us" → SI (this is the SEC Item 106(b)(2) forward-looking materiality assessment)
- Cross-reference to Item 1A → N/O

The materiality assessment is a clear SI statement per Rule 5. The management sentence is generic.

The cross-reference doesn't add substantive content, so the materiality conclusion is what matters here. The management responsibility language is boilerplate, and the negative self-assertion about cybersecurity risks lacks external verification or firm-specific details. This is clearly Level 1 generic boilerplate with no verifiable claims or domain-specific facts.


reasoning: The paragraph's central content is the SEC materiality assessment ('have not materially affected, or are reasonably likely to materially affect our business strategy, results of operations, or financial condition') plus insurance discussion, making it Strategy Integration. No domain-specific terms, firm-unique facts, or externally verifiable claims elevate it above Level 1.

thinking:
Let me analyze this paragraph.

Content: Mixed - mentions training programs briefly, then a materiality assessment, then insurance. The materiality statement ("have not materially affected, or are reasonably likely to materially affect our business strategy, results of operations, or financial condition") is a clear SI assessment per Rule 5. The insurance mention also fits SI. The program mention is brief.

Category: Strategy Integration - the materiality assessment is the core statement, plus insurance discussion.

Specific facts:
- "have not materially affected, or are reasonably likely to materially affect our business strategy, results of operations, or financial condition" → SI materiality assessment

- Insurance coverage for cybersecurity and references to prior immaterial incidents both support the SI classification, but there's no domain-specific language or firm-specific details that would elevate this beyond Level 1 disclosure.


reasoning: The paragraph contains the SEC Item 106(b)(2) materiality assessment ('have not materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition'), making Strategy Integration the primary category. No domain terms pass the ERM test ('controls,' 'detect, triage and eradicate,' and 'cyber insurance policy' are all general business language), no firm-specific facts, and no verifiable claims, yielding Level 1.

thinking:
Let me analyze this paragraph.

Content: Discusses cybersecurity risks generally, mentions controls, cyber insurance, and a materiality assessment statement.

Category: The key sentence is "the risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have not materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition" — this is the SEC Item 106(b)(2) materiality assessment language. Per Rule 5, this is SI.

Specificity: Let me scan for facts.
- "cyber insurance policy" — this is a firm-specific fact about having cyber insurance...

Actually, while cyber insurance is mentioned, it's pretty standard across companies. The language around detection and response processes like "detect, triage and eradicate" is generic security terminology that doesn't really demonstrate domain expertise or verifiable claims. The materiality statement itself is just a self-assessment with no concrete supporting details. This reads like boilerplate risk disclosure without much substance.


fact: Company is not insured for damages from cybersecurity incidents

reasoning: While the first sentence is speculative disclaimer language ('could have a material adverse effect' — not SI per Rule 5), the second sentence makes a concrete claim about the company's lack of cybersecurity insurance, which is a business/financial posture fact falling under Strategy Integration. The no-insurance claim is firm-specific — it distinguishes this company's cybersecurity posture from peers — elevating specificity to Level 3.

thinking:
Classify this paragraph.

"Notwithstanding our efforts, we may not be successful in preventing or mitigating a cybersecurity incident that could have a material adverse effect on us. Nor are we insured for damages that could result from such an incident."

This is speculative/disclaimer language ("may not be successful", "could have a material adverse effect") plus a note about lack of insurance.

Category: The "could have a material adverse effect" is speculation per Rule 5 — NOT SI. The lack of insurance is a factual statement about their posture. But is "we are not insured" a strategy integration fact? It's about cybersecurity insurance which falls under SI.

The insurance statement is a firm-specific fact about their cybersecurity posture relating to business and financial strategy. The first sentence is pure disclaimer language, but the second sentence states a concrete fact about their insurance coverage. Since SI includes cybersecurity insurance disclosures, I'd classify this as SI based on the substantive insurance statement.

For specificity, "not insured for damages" is a factual claim about this company's insurance posture that distinguishes it from others. That's Level 3.


reasoning: The first sentence is a backward-looking materiality assessment ('have not materially impaired our operations or financial standing'), which is SI per Rule 5. The cross-reference to Item 1A is secondary. No domain terms, firm-specific facts, or verifiable claims are present — the negative assertion about no material impact is a self-reported claim not externally verifiable — so specificity remains Level 1.

thinking:
Classify this paragraph.

"We have not encountered cybersecurity challenges that have materially impaired our operations or financial standing." — This is a backward-looking materiality assessment → SI.

"For additional information regarding risks from cybersecurity threats, please refer to Item 1A" — cross-reference → N/O.

The first sentence is a materiality conclusion (SI per Rule 5). The cross-reference is secondary. Category: Strategy Integration.

Specificity: "have not materially impaired our operations or financial standing" — negative self-assertion, not externally verifiable. No domain terms, no firm-specific facts, no verifiable claims.

This lands at Level 1 — the lowest specificity tier.


reasoning: The paragraph primarily answers how the board oversees cybersecurity—approving investments, overseeing compliance, and ensuring legal counsel—making it Board Governance. No domain-specific terminology passes the ERM test (breach notification, compliance, and investments are standard governance language), no firm-specific facts or verifiable claims are present, yielding Level 1.

thinking:
Classify this paragraph.

The paragraph discusses the board approving cybersecurity investments based on management/vendor recommendations, compliance oversight by both management and board, and ensuring legal counsel for cybersecurity issues.

Category: This is about board oversight of cybersecurity - approving investments, overseeing compliance, ensuring legal counsel. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "breach notification requirements" - this is a legal/compliance term, not really a cybersecurity domain term that passes the ERM test. An ERM professional would know about breach notification.

- "cybersecurity technologies, training, and talent" - generic
- "external vendors and consultants" - unnamed, generic
- No named roles above generic (board, management), no specific facts, no domain terms that pass the ERM test.

This is Level 1 - Generic Boilerplate.


reasoning: The majority of the paragraph describes third parties hired to serve the company's security program (monitoring, assessment, remediation), which maps to RMP per Rule 3; only the final sentence addresses vendor oversight (TP), but it is not the central topic. The vocabulary is entirely generic—'identify, assess, and manage cybersecurity risks,' 'standards and best practices,' 'security reviews,' 'investigation and remediation'—all language an ERM professional could produce without cybersecurity domain expertise, keeping specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes partnerships with third-party cybersecurity companies, use of third-party providers for monitoring, and evaluation of third-party risk for critical suppliers.

Category: This is a mix of RMP and TP. The first three sentences describe third parties hired to serve the company (assessors, monitors) → RMP per Rule 3. The last sentence describes requirements imposed ON vendors/suppliers → TP. The majority of text is about third parties serving the company, but the last sentence shifts to vendor oversight. Let me weigh: 3 sentences about third parties helping the company (RMP) vs 1 sentence about evaluating third-party risk for suppliers (TP).

The paragraph centers on their relationship with third parties overall—using them for security monitoring and assessments falls under RMP, but the final sentence about evaluating supplier risk is clearly TP. Since Rule 3 treats third parties hired to serve the company as RMP, and the bulk of the content focuses on that dynamic, this leans RMP despite the TP element at the end. The language here is pretty generic—terms like "identify, assess, and manage cybersecurity risks" and "cybersecurity standards and best practices" are standard L1 boilerplate. Even "continuous monitoring" and "security controls" are borderline; an ERM professional might use them in any risk domain, not just cybersecurity. If I swapped out "cybersecurity" for another risk type, the whole thing would still work. This reads as Level 1 generic oversight language. The vocabulary here—"identify, assess, and manage risks," "standards and best practices," "security reviews," "monitoring," "investigation and remediation"—doesn't require any specialized cybersecurity knowledge, so this is clearly Level 1 generic boilerplate.


fact: SOC reports

fact: complementary controls

reasoning: The paragraph's central topic is oversight of third-party service providers—security assessments before engagement, ongoing monitoring, and SOC report reviews—making it Third-Party Risk. The final sentence is a backward-looking materiality assertion (SI-eligible), but it is a minor coda, not the primary content. Specificity reaches Level 2 via 'SOC reports' and 'complementary controls,' which are domain-specific audit/security terms that pass the ERM test, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content category: This is primarily about third-party risk management - vendor assessments, monitoring, SOC reports. The last sentence is a materiality assessment. But the central topic is third-party oversight, so TP.

Wait, let me re-read. The majority of text is about third-party risk management processes. The last sentence is a materiality statement (SI). But the central topic is TP.

Actually, the last sentence "have not encountered cybersecurity challenges that have materially impaired our operations or financial standing" is an SI materiality assessment. But the bulk is about third-party risk.

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

The specific language here shows domain expertise - SOC reports and complementary controls are audit and security terms that demonstrate real knowledge of vendor oversight practices. The materiality statement at the end is a backward-looking self-assertion about not experiencing material cybersecurity incidents, which fits SI per Rule 5, but the dominant focus remains third-party risk management.


reasoning: The paragraph centers on the CEO's expected cybersecurity responsibilities—leading risk assessment, monitoring incidents, and reporting to the Board—making it primarily about management's organizational role (MR). All language ('risk assessment and management processes,' 'incident response plan,' 'prevention, mitigation, detection and remediation') is generic ERM vocabulary that fails the domain-expertise test; CEO is not firm-specific; and no verifiable claims are present, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

Category: This describes the CEO's role in cybersecurity - responsibilities, reporting lines. The person-removal test: remove CEO and his role, what remains? Generic descriptions of cybersecurity processes ("risk assessment and management processes", "incident response plan") but these are described in the context of what the CEO does. The paragraph is primarily about the CEO's responsibilities and tasks. → MR

But wait - it also mentions reporting to the Board. However, the primary focus is on management's role (CEO's responsibilities).

Specificity:
- "Chief Executive Officer" - CEO is generic, every company has one. NOT firm-specific.

- The language throughout is boilerplate - "incident response plan," "risk assessment and management processes," "prevention, mitigation, detection and remediation" - all standard ERM terminology that appears in every governance document. None of these terms are firm-specific or verifiable claims about this particular company. This is clearly Level 1 disclosure.


reasoning: The paragraph describes how the company's cybersecurity program operates — by outsourcing IT management including cybersecurity to a third-party sub-contractor. Per Rule 3, third parties hired to serve the company are RMP, not TP. The language ('protection against, detection, and response to cyberattacks') is generic and fails the ERM test — swap 'cyberattacks' for 'fraud' and it reads identically. No domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: They use a third-party sub-contractor to manage all IT issues including cybersecurity.

Category: This is about how they manage cybersecurity through a third-party. The third party here is hired to serve the company (assessor/service provider), so per Rule 3, this could be RMP. But the central topic is that they outsource to a third party. Actually, the third party is hired to serve the company - per Rule 3, "Third parties hired to serve the company (assessors, pen testers) → RMP." So this is RMP.

The paragraph is quite brief and essentially describes their approach of outsourcing all IT and cybersecurity functions to an external contractor, which fits the RMP classification. Looking at the language used—"protection against, detection, and response to cyberattacks"—it's fairly generic and doesn't include domain-specific terminology or firm-specific details, so this lands at Level 1 specificity.