reasoning: The paragraph's central topic is managing cybersecurity risks from IT vendors and service providers, including assessments and remediation tracking, making it Third-Party Risk. The language—'vendor risk management policy,' 'pre-onboarding security assessments,' 'third-party security controls'—describes processes any ERM professional could articulate without cybersecurity domain expertise; no named frameworks, firm-specific facts, or verifiable claims elevate it above Level 1.

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

Specific facts: "IT vendor risk management policy" - firm-specific named program? It's a generic policy name. "third-party risk management program" - generic. "pre-onboarding security assessments" - this is a domain term (security assessments of vendors). "annual re-assessments" - generic cadence. "third-party security controls" - domain term.

Actually, let me apply the ERM test. "pre-onboarding security assessments" - would a non-security ERM professional say this? They might say "pre-onboarding assessments" but "security assessments" specifically... it's borderline. "third-party security controls" - this is somewhat domain-specific.

The language here is mostly standard ERM vocabulary applied to vendors, even though terms like "security assessments" and "security controls" hint at domain specificity. But these are broad enough that any ERM professional could use them across different risk areas, so I'm classifying this as Level 1 - Generic Boilerplate.


content_category: Board Governance

fact: CISO briefs the full Board

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes how the board receives cybersecurity briefings (from the CISO annually, and from external experts periodically), which directly answers how the board oversees cybersecurity. The CISO role is a firm-specific fact elevating to Level 3, but the rest (annual cadence, external expert presentations) is generic governance language.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

Content: Board receives briefings from CISO annually, board members get presentations from external experts for continuing education.

Category: Board Governance - describes how the board oversees cybersecurity (briefing frequency, information flow to board).

Specific facts:
- CISO (firm-specific named role)
- Annual briefing cadence (generic)

Specificity: Firm-Specific (Level 3) due to CISO mention.


content_category: Third-Party Risk

fact: Dedicated department within its Enterprise Risk Management division for third-party risk

fact: Bank's Information Technology Department collaborates on third-party cybersecurity evaluation

specificity_confidence: medium

reasoning: The paragraph's central topic is how the company manages cybersecurity risks from third-party service providers (vendors), making it Third-Party Risk. The mention of a dedicated department within the Enterprise Risk Management division and coordination with the Bank's Information Technology Department are firm-specific organizational details that distinguish this company's structure, reaching Level 3.

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

Specific facts:
- "dedicated department within its Enterprise Risk Management division" - firm-specific organizational structure
- "bank operations technology, payroll and benefits administrators, and professional service providers" - specific team composition by department type
- "Bank's Information Technology Department" - named department

This is clearly Third-Party Risk as the central topic is managing vendor/supplier cybersecurity risks.

For specificity - the mention of a "dedicated department within its Enterprise Risk Management division" is a firm-specific organizational claim. The specific types of third parties listed are illustrative but not particularly firm-specific. "Information Technology Department" is generic.

The dedicated department within the Enterprise Risk Management division is the key firm-specific detail here, so this clearly qualifies as Level 3.


content_category: Management Role

fact: CISO role identified as part of management team

fact: Core Cybersecurity Management Team (CCMT) — named non-generic committee

fact: CCMT composed of CISO, Chief Legal Officer, and Chief Financial Officer — specific team composition

fact: CIRP (Cyber Incident Response Plan) — named internal program

reasoning: The paragraph is about how management is organized to handle cybersecurity — identifying who comprises the CCMT, their responsibilities, and their role in incident communications — making it Management Role per the person-removal test (removing the named roles and committee leaves only generic responsibility language). Specificity is Firm-Specific due to the named CISO role, the specifically named CCMT committee with its defined composition, and the named CIRP program, but no externally verifiable claims push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes management's role in cybersecurity, specifically the Core Cybersecurity Management Team (CCMT) composed of CISO, Chief Legal Officer, and CFO. Describes their oversight of CIRP and incident response communications.

Category: This is about management's organizational role - who comprises the team, what they're responsible for. The person-removal test: remove CISO, CLO, CFO, CCMT - what remains? Generic responsibilities about planning, identification, assessment, mitigation, and communications. The paragraph is primarily about WHO is responsible and HOW management is organized → MR.

Now I'm identifying the firm-specific elements: the CISO role, the CCMT as a named committee, and CIRP as a proprietary incident response program all represent Level 3 specificity. The specific team composition of CISO, Chief Legal Officer, and CFO is what distinguishes this from generic cybersecurity governance structures. No independently verifiable facts are present.


content_category: Strategy Integration

reasoning: The paragraph makes both a backward-looking materiality assessment ('not aware of any cybersecurity threats or incidents... that have had a material impact') and a forward-looking SEC 106(b)(2) statement ('reasonably likely to materially affect us'), both triggering SI under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present — the cross-reference to Item 1A is boilerplate, and the negative assertion about no material incidents is not externally verifiable.

thinking: Materiality assessment paragraph.


fact: Cybersecurity incident in August 2023 affecting information systems and causing temporary operational disruptions

category_confidence: medium

reasoning: The paragraph mentions a real incident (August 2023) but its primary purpose is the backward-looking materiality assessment: 'prior cybersecurity incidents...have not materially affected us,' which is a SI conclusion per Rule 5. The specific date 'August 2023' tied to a real cybersecurity event is externally verifiable, elevating to Level 4.

thinking:
Let me analyze this paragraph.

It describes a past incident (August 2023), states no material effect, includes forward-looking disclaimer, and cross-references Risk Factors.

Category: This is mixed. It mentions a real incident (August 2023), makes a materiality assessment ("have not materially affected us"), and includes disclaimer/cross-reference. The materiality assessment is a backward-looking SI statement. The incident is real but briefly described. The dominant frame is the materiality assessment - "have not materially affected us" is a SI conclusion per Rule 5.

Actually, let me reconsider. The paragraph opens with incident disclosure (real event in August 2023), then pivots to a materiality assessment.

The materiality conclusion is really the crux of this - the incident gets mentioned mainly to support the "have not materially affected" finding, which makes this a Strategy Integration statement under Rule 4. And the specific date of August 2023 tied to an actual event gives me Level 4 specificity since it's verifiable.


content_category: None/Other

reasoning: This paragraph is a cross-reference directing readers to Item 1A for risk factor disclosures, with no substantive cybersecurity content 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 risk factors with materiality language.


fact: Chief Information Officer (CIO) role leading cybersecurity program

fact: CIO has more than 30 years of experience in information technology

type: quantified

fact: CIO held roles in financial services, banking, healthcare, and hospitality sectors

fact: Team holds Certified Information Systems Security Professional (CISSP)

fact: Team holds Certified Information Security Manager (CISM)

fact: Team holds Microsoft Certified Cybersecurity Architect Expert

fact: Team holds Security+ certification

fact: Team holds Certified Information Systems Auditor (CISA)

fact: Team holds Master's in Cybersecurity

fact: Team holds Graduate Certificates in Enterprise Cybersecurity and Data Science

reasoning: The paragraph focuses on management's organizational role — the CIO's qualifications, experience, and team certifications — collapsing to near-nothing under the person-removal test, making it MR. Specificity reaches Level 4 via multiple externally verifiable claims: 'more than 30 years of experience' (a verifiable lower bound) and named certifications (CISSP, CISM, CISA, Security+, Microsoft Certified Cybersecurity Architect Expert) checkable against issuing bodies.

thinking:
Classify this paragraph.

Category: This is about management's organization for cybersecurity - the CIO's role, qualifications, experience, and team composition/certifications. Person-removal test: remove CIO details, team certifications → almost nothing remains. → MR

Specificity:
- CIO (named role, firm-specific)
- "more than 30 years of experience" → verifiable lower bound
- CISSP, CISM, Microsoft Certified Cybersecurity Architect Expert, Security+, CISA → verifiable certifications
- Master's in Cybersecurity → verifiable
- Sectors: financial services, banking, healthcare, hospitality

- The verifiable certifications and "more than 30 years" of experience push this to Level 4.


fact: SOC 2 report required from vendors

type: framework

fact: ISO 27001 (Information and Security Certification) report required from vendors

fact: Information security posture assessment during vendor onboarding

fact: Reviews of third-party hosted applications focused on sensitive data sharing

reasoning: The paragraph's central topic is managing cybersecurity risks of third-party service providers—vendor onboarding, security requirements imposed on suppliers, and ongoing due diligence—making it Third-Party Risk. Specificity reaches Level 2 via domain terms like SOC 2 and ISO 27001 as specific evidence types required from vendors, which passes the ERM test, but no firm-specific facts (no named roles, committees, or individuals) push it to Level 3.

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

Specific facts:
- SOC 2 (domain/framework)
- ISO 27001 (domain/framework)
- Vendor onboarding and due diligence process details
- Security requirements imposed on suppliers

This is clearly Third-Party Risk as central topic. Level 2 at minimum for SOC 2 and ISO 27001 references. These are "aligned with" not "maintain certification" so Domain-Adapted level for frameworks. But wait - they mention requiring vendors to provide SOC 2 or ISO 27001 reports, which shows domain knowledge about what evidence to look for.

I don't see any firm-specific details like named executives or committees, and there aren't verifiable claims that would push this higher. This lands at Level 2 - Domain-Adapted.


content_category: Risk Management Process

fact: NIST Cybersecurity Framework alignment

fact: third party security operation center (SOC)

fact: multi-factor authentication

fact: email filtering

fact: firewalls

fact: encryption of information

fact: malware defenses

fact: partitioning (network segmentation)

reasoning: The paragraph describes what the cybersecurity program does — controls, tools, defenses, assessments, and training — squarely answering the RMP question. Rich in domain terminology (SOC, MFA, IDS/IPS, firewalls, encryption, malware defenses, NIST CSF) but lacks firm-specific facts (no named roles, committees, or teams) and no verifiable claims ('generally aligned with' NIST CSF is aspirational, not a held certification).

thinking:
Let me analyze this paragraph.

Content: Describes their cybersecurity program - multi-layered approach, NIST CSF alignment, controls, automated tools, third-party SOC, defenses (MFA, access controls, email filtering, firewalls, IDS/IPS, encryption, etc.), regular assessments, training.

Category: This is clearly about what the cybersecurity program does → Risk Management Process.

Specificity: Let me scan for facts:
- "aligned with the National Institute on Standards and Technology Cybersecurity Framework" → NIST CSF → domain term/framework (Level 2)

- "third party security operation center" → SOC → domain term (Level 2)
- "multi-factor authentication" → domain term (Level 2)
- "firewalls" → domain term (Level 2)
- "intrusion prevention and detection systems" → IDS/IPS → domain term (Level 2)
- "encryption" → domain term (Level 2)
- "malware defenses" → domain term (Level 2)
- "email filtering" → domain term (Level 2)
- "partitioning" (network segmentation concept) → domain term (Level 2)

The paragraph is packed with standard cybersecurity controls and terminology but lacks any firm-specific details like named leadership roles, committee structures, or concrete implementation specifics.

The claim about NIST CSF alignment is framed as an aspiration rather than a verified certification, which keeps it at Level 2. Overall, this reads as domain-adapted language without crossing into verifiable facts or proprietary information.


fact: CISO role manages cybersecurity program

fact: Cybersecurity subcommittee reviews program

fact: Board enterprise risk committee approves program

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

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

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

fact: CISO reports to Senior Vice President – Enterprise Risk Officer

fact: SVP Enterprise Risk Officer reports to CEO

reasoning: The paragraph's primary content is the CISO's qualifications, credentials, and reporting lines; applying the person-removal test leaves only a brief program mention, so MR wins over RMP. Specificity reaches Level 4 due to the CISM certification (verifiable via ISACA registry) and 'more than 20 years of experience' (a verifiable lower bound).

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CISO's role, qualifications, certifications, experience, and reporting lines. Using the person-removal test: remove all person-specific content (CISO title, 20 years experience, MBA, CISM certification, reporting lines) — what remains? "manages cybersecurity program which aligns to industry standards... includes identification, evaluation, and prioritization of security risks, as well as response to security incidents." Some program description remains but the bulk is about the CISO's role and qualifications. This is primarily MR.

Now I'm breaking down the specific elements that make this person-focused. The CISO title is a named role, the 20+ years is a quantified credential, the MBA with IT focus is specific to this individual, CISM is a verifiable certification, and the reporting structure to the Senior Vice President and Board committees are all organizational relationships tied to this person. The majority of the text centers on who this person is rather than what the program does, confirming this is MR.


fact: Chief Security and Trust Officer

fact: Reports to Executive Vice President, Operations

fact: Over 25 years of experience in information technology and information security

reasoning: The paragraph describes the CSTO's reporting line, responsibilities, and qualifications; while it mentions program activities (protecting IT environment, incident response), the person-removal test shows these are generic — the paragraph's primary purpose is establishing who is responsible and their credentials, making it MR. Specificity reaches Level 4 because 'over 25 years' is a verifiable lower-bound claim checkable against the individual's career history.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes a named role (Chief Security and Trust Officer), their reporting line, responsibilities, and qualifications. Using the person-removal test: remove the role, reporting line, qualifications → what remains? "implement policies and procedures designed to protect our IT environment and our products and services from cybersecurity threats, and to promptly respond to cybersecurity incidents in accordance with our incident response policies and procedures." That's a program description but it's fairly generic. The paragraph is split between MR (role, reporting line, qualifications) and RMP (what the program does). The person-specific content (title, reporting line, 25 years experience) is substantial. The program description is generic.

So this is clearly MR—the focus is on the individual's title, their position in the organizational hierarchy, and their extensive background rather than on what the security program itself entails. The specificity here comes from the named role at VP+ level, the explicit reporting structure, and the quantified experience threshold of over 25 years, which pushes this to Level 4. The incident response language is boilerplate, but the person-specific details dominate.


content_category: Incident Disclosure

fact: June 21, 2023 — date Umpqua Bank was informed of the incident

fact: June 22, 2023 — date email sent to affected customers

fact: August 2023 — U.S. mail notice sent

fact: MOVEit — named filesharing software involved

fact: Umpqua Bank — named subsidiary

fact: 429,252 affected customers

fact: Names and social security numbers or tax identification numbers compromised

reasoning: This paragraph describes a real cybersecurity incident (the MOVEit Vendor Incident) with timeline, scope, data types compromised, and remediation steps — classic Incident Disclosure. Multiple verifiable facts including specific dates (June 21-22, 2023), the named MOVEit software, and the precise count of 429,252 affected customers push this to Level 4.

thinking: Incident disclosure with specific dates, named entities, and quantified details.


reasoning: The paragraph is predominantly forward-looking risk disclaimer language ('could disrupt,' 'could damage,' 'could have a material adverse effect') — pure speculation that appears in virtually every 10-K. The opening sentence references processes but only as a lead-in to the disclaimer; no substantive cybersecurity measure is described. The 'material adverse effect' language is speculative ('could have'), not an actual materiality assessment, so it fails the SI materiality rule. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: This paragraph is speculative risk language about potential adverse effects, not an actual materiality assessment.


fact: Chief Security Officer (CSO) role

fact: CSO reports to the CFO

fact: Current CSO has served since 2018

fact: Responsible for cybersecurity, product security, and corporate/physical security programs

reasoning: The paragraph focuses on the CSO's role, responsibilities, qualifications, reporting line to CFO, and career history — classic Management Role content that collapses under the person-removal test. Specificity reaches Level 4 due to verifiable claims: serving since 2018 (specific date checkable) and 'over 14 years' of experience (a lower-bound quantity that could be verified against a resume).

thinking:
Classify this paragraph.

Category: This is about the CSO role, responsibilities, qualifications, reporting lines. Person-removal test: remove CSO title, qualifications, experience, reporting line → almost nothing remains. → MR.

Specific facts:
- CSO (Chief Security Officer) — named_role (firm-specific, VP-level equivalent)
- Reports to CFO — other_specific (firm-specific reporting line)
- Served since 2018 — specific_date (verifiable)

- Over 14 years of global executive cybersecurity experience — quantified (verifiable, lower bound)
- Product security, corporate/physical security programs — other_specific

Level 4 due to "since 2018" and "over 14 years."


fact: Director of IT Infrastructure and Security (director-level with security qualifier)

fact: Over 30 years of experience (Director)

fact: Over 19 years of experience (VP of IT)

fact: GIAC Security Essentials certification

fact: GIAC Certified Enterprise Defender certification

fact: GIAC Certified Incident Handler Certification

fact: GIAC Certified Windows Security Administrator certification

fact: GIAC Critical Controls Certification

fact: Certified Information Systems Security Professional (CISSP) certification

fact: Masters of Business Administration

fact: Defense Industrial Base environment experience

reasoning: The paragraph is overwhelmingly about management roles—titles, qualifications, certifications, experience, and reporting lines (Director → VP of IT). The person-removal test leaves almost nothing substantive. Specificity is Level 4 due to multiple verifiable claims: specific named certifications (five GIAC certs, CISSP) checkable against certification bodies, and quantified lower-bound experience figures (over 30 years, over 19 years).

thinking:
Classify this paragraph.

Category: This is about management roles - the IT Security team leadership, their qualifications, certifications, experience, and reporting lines. The person-removal test: remove all person-specific content and very little remains beyond "Our IT Security team is responsible for leading enterprise-wide cybersecurity strategy, policy, standards and processes. Team members are afforded opportunities to attend external training." That's minimal. → MR

Specificity: Let me list facts:
- "Director of IT Infrastructure and Security" - named role with security qualifier at director level → firm-specific
- "over 30 years of experience" → verifiable (lower bound)

- "Defense Industrial Base environment" → other_specific
- Multiple GIAC certifications including Security Essentials, Certified Enterprise Defender, Certified Incident Handler, Certified Windows Security Administrator, and Critical Controls Certification → all verifiable
- "Vice President of Information Technology" → VP-level IT role → firm-specific
- "over 19 years of experience" → verifiable
- "Masters of Business Administration" → verifiable
- CISSP certification → verifiable

This is clearly Level 4 - the paragraph is packed with specific credentials, named positions, quantifiable experience, and industry-recognized certifications across multiple team members.


reasoning: The paragraph is centrally about assessing and managing cyber risks associated with third-party vendors, including their control environments and information security practices, making Third-Party Risk the primary category. The language is entirely generic ERM-level ('assess vendor control environments,' 'evaluate risks,' 'managing the cyber risks') with no domain-specific terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: About vendor due diligence process within the ISP (Information Security Program), assessing vendor control environments, evaluating risks of vendor access, managing cyber risks of third-party vendors, reviewing their information security practices.

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

Specificity: Let me scan for facts.
- "ISP" - this is a named internal program reference (Information Security Program) → firm-specific? It's a generic acronym but refers to their specific program. Hmm, "ISP" alone is pretty generic.

But looking at the language more closely, everything here is standard risk management terminology. "Vendor due diligence," "control environments," "vendor access risks," and "information security practices" are all generic concepts that any organization would use. "ISP" is just a common acronym—every company has an information security program, so it's not really a distinguishing identifier. The whole passage lacks any firm-specific details or domain-specific terminology that would indicate this is about a particular organization's unique practices.

This is Level 1 boilerplate.


fact: CISO leads the dedicated cybersecurity team

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

fact: CISO has over 20 years of information technology and cybersecurity experience

fact: CISO experience spans financial services and defense industries

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

fact: incident response process

reasoning: The paragraph primarily answers how management is organized for cybersecurity—CISO qualifications, team composition, and reporting lines to CEO and Audit Committee—making it MR despite the incident response process mention. 'Over 20 years' of experience is a verifiable lower bound (≥20), elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CISO's qualifications, team composition, and what happens when risks are identified. The person-removal test: remove CISO, qualifications, team composition → "When credible risks are identified, we invoke our incident response process to track and manage the details, quickly manage exposures, assess potential customer impact, and facilitate consistent reporting." That's a substantive process description but the paragraph leads with and emphasizes the CISO and team. It's roughly split. The primary question answered is "How is management organized?" with significant RMP content. Actually, the first two sentences are purely MR (CISO qualifications, team composition).

The third sentence covers what the team does when risks surface—invoking incident response procedures and reporting up to the CEO and Audit Committee—which blends RMP and BG elements, but the overall emphasis remains on how the management structure is organized and who's leading it. The specific details I'm noting are the CISO's background with a technical degree and two decades in IT and cybersecurity across financial services and defense, the composition of the team with security engineers and detection specialists, and the formal incident response process tied to executive reporting.


reasoning: The paragraph's core claim is a materiality assessment — 'no material incidents incurred to-date' — which is a backward-looking negative assertion mapping to SI under Rule 5. The 'could materially affect' language is generic speculation (every 10-K says this) and the Item 1A cross-reference is N/O, but the materiality conclusion dominates. No domain terms passing the ERM test, no firm-specific facts, and the negative assertion about no material incidents is not externally verifiable, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

The paragraph states: no material incidents to date, acknowledges ongoing threats, says cybersecurity threats "could materially affect" business, and cross-references Item 1A.

Category: The key statement is "there have been no material incidents incurred to-date at the Company" - this is a negative assertion about materiality, which per Rule 5 is SI (backward-looking assessment). The "could materially affect" is speculation (not SI), and the cross-reference is N/O. But the materiality assessment ("no material incidents") drives SI.

Wait - Rule 5 says "Have not experienced any material cybersecurity incidents" → SI (negative assertion). This matches.

The "no material incidents" claim is just a bare negative assertion with no external verification possible, and there's nothing here that would qualify as domain-specific or firm-specific detail. This is generic boilerplate language at Level 1.


fact: CIO role

fact: CSO role (peer to CIO)

fact: CIO reports to CFO

fact: CIO appointed in March 2022

fact: Nearly 20 years of experience in managing IT functions

reasoning: The paragraph describes the CIO's reporting line, responsibilities, and qualifications — squarely answering how management is organized for cybersecurity → MR. The specific appointment date of March 2022 is an externally verifiable fact (checkable against company announcements), elevating to Level 4.

thinking:
Classify this paragraph.

This is about the CIO role, reporting line, responsibilities, and qualifications. Primary question: "How is management organized to handle cybersecurity?" → Management Role.

Specific facts:
- CIO (named role, firm-specific)
- CSO (named role, firm-specific)
- Reports to CFO (reporting line)
- Appointed March 2022 (specific date, verifiable)
- Nearly 20 years of experience (soft number - "nearly" is hedged... but it sets a rough threshold. Actually "nearly 20" is soft - not a hard lower bound.

The "nearly 20 years" phrasing is vague and hedged, so that's soft data. But the March 2022 appointment date is concrete and verifiable, which pushes this to Level 4.


reasoning: This paragraph describes the CHRO's career history and HR responsibilities with no cybersecurity content whatsoever. As a None/Other paragraph, specificity is Generic Boilerplate.

thinking: This paragraph is about a CHRO's background - not cybersecurity content.


fact: Company's disclosure committee responsible for detecting and reporting cybersecurity incidents

fact: Audit committee responsible for review of IT governance and data security

fact: General counsel and chief compliance officer receive complaint submissions

fact: In 2022, developed an enhanced Employee Self Service portal

reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the governance chain from the Board to the audit committee, disclosure committee, and complaint reporting procedures — classic Board Governance. Specificity reaches Firm-Specific due to the named disclosure committee with a cybersecurity-specific mandate, the general counsel/chief compliance officer receiving submissions, and the specifically dated (2022) Employee Self Service portal, which are facts distinguishing this company's structure.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity governance structure including disclosure committee, Board oversight, audit committee responsibility, briefings, complaint reporting procedures, and an Employee Self Service portal.

Category: This is primarily about oversight structure - Board, audit committee, disclosure committee. The main question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- "disclosure committee" - this is a named committee but generic
- "audit committee" - generic, every company has one
- "Board of Directors receives briefings" - generic
- "general counsel and chief compliance officer" - generic roles

- "in 2022, we developed an enhanced Employee Self Service portal" - specific date tied to a concrete program they built
- "independent organization specializing in those services" - unnamed third party

The 2022 date is firm-specific since it marks when they launched this particular portal. The Employee Self Service portal itself is a named internal program, though the third-party provider remains unidentified. These are self-reported claims about their own initiatives rather than externally verifiable facts.

The disclosure committee is also a named governance structure, though disclosure committees are fairly standard at public companies. Still, it's specific to their organizational setup, so this lands at Level 3 for firm-specific details.


fact: Operational Risk Committees (named management committee)

fact: Enterprise Risk Management Committee chaired by Chief Risk Officer

fact: Information Security and Data Management Committee chaired by SHUSA's Chief Technology Officer

fact: SHUSA's Head of Technology & Operations chairs Operational Risk Committees

fact: Chief Technology Officer (CTO)

fact: Chief Risk Officer (CRO)

fact: Committee membership includes CEO, heads of businesses, second LOD representatives, and Internal Audit

fact: second LOD (line of defense)

reasoning: The paragraph's primary content is management committee structure and membership — naming specific committees (Operational Risk Committees, ERM Committee, Information Security and Data Management Committee), their chairs, and membership composition — making MR the best fit per Rule 1 (management-level committees about structure/membership → MR). The brief board mention at the end is subordinate. Specificity is Firm-Specific due to multiple named non-generic committees and VP+ roles (CTO, CRO, Head of Technology & Operations) that distinguish this company's organizational structure.

thinking:
Let me analyze this paragraph.

Category: This describes governance structure including management committees and board oversight. It mentions management committees (Operational Risk Committees, Enterprise Risk Management Committee, Information Security and Data Management Committee) with their chairs and members, plus a brief mention of board experience. The primary question answered is about governance structure - how risks are identified, escalated, and overseen. It's a governance-chain paragraph describing oversight structure from management committees up to the board.

The paragraph covers both management committee structure (MR) and board oversight (BG). The bulk of content is about management committees (their names, who chairs them, membership). But the governance-chain paragraph rule says these default to BG when describing oversight structure.

However, the management committees here are the central topic - their structure, membership, chairs. The board mention is brief at the end. Re-reading the paragraph, it starts with the governance model for risk escalation, then dives into management committee details, then briefly touches on board experience. Since the majority of the content focuses on management committee structure and membership, I'm categorizing this as MR.

Let me double-check the rule though. Governance-chain paragraphs default to BG when describing oversight structure, but become MR only when management's organizational role—responsibilities, qualifications, committee membership—is the primary content. Here, committee membership and structure of management committees clearly dominate, so MR is the right call.

Looking at specificity: the paragraph names specific committees like "Operational Risk Committees" and "Enterprise Risk Management Committee," identifies named roles like "SHUSA's Head of Technology & Operations" and "Chief Risk Officer," and mentions "Information Security and Data Management Committee" and "SHUSA's Chief Technology Officer." These are firm-specific details, though some roles like CEO are more generic. The second part of the specificity analysis appears to be cut off.

Pulling together the firm-specific facts—the named committees, named roles, and specific membership details—this clearly lands at Level 3, Firm-Specific.


reasoning: The paragraph contains the materiality assessment 'we have not experienced any recent material cybersecurity incidents' and forward-looking language about potential material effects on 'business strategy, results of operations, or financial condition,' both triggering SI under Rule 5. No domain terms pass the ERM test, no firm-specific facts, and the negative assertion about no material incidents is not externally verifiable, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: Discusses limitations of policies, states no recent material incidents, mentions risks, references other casino companies' incidents, and points to Risk Factors section.

Category: The key statement is "we have not experienced any recent material cybersecurity incidents" - this is a negative assertion about materiality. Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI. The rest is speculation ("could materially affect") and a cross-reference. The SI materiality assessment is present.

Specificity: "we have not experienced any recent material cybersecurity incidents" - negative self-assertion, NOT externally verifiable.

The reference to other casino companies' incidents is vague and unnamed, and the pointer to Item 1A doesn't add specificity. There are no domain-specific details or company-specific facts here, so this falls into Level 1.


fact: Cross-functional effort involving end-user, Legal, Privacy and Information Security teams

reasoning: The paragraph is centrally about how the company manages cybersecurity risks from third-party service providers — vendor assessments, risk identification, due diligence, and ongoing monitoring — making Third-Party Risk the clear category. The specific enumeration of departments involved (end-user, Legal, Privacy, Information Security) constitutes a firm-specific team composition, elevating to Level 3, though no verifiable/quantified claims are present.

thinking:
Classify this paragraph about Gilead's third-party risk management.

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

Specificity: Let me scan for facts.
- "external risk management software program" - generic, not named
- "vendor security assessment process" - domain term? The ERM test: would a non-security ERM professional say "vendor security assessment"? Possibly, but "IT security, privacy, business continuity" mentions IT security specifically

- "cross-functional effort involving our end-user, Legal, Privacy and Information Security teams" - specific team composition → firm-specific

Domain terms: "IT security" - borderline, "vendor security assessment" - could be L1
- "controls for IT security, privacy, business continuity" - this is fairly generic process description

Firm-specific: "cross-functional effort involving our end-user, Legal, Privacy and Information Security teams" - specific team composition by department → Level 3

No verifiable claims (no numbers, no named products, no certifications).


reasoning: The paragraph's primary purpose is stating a materiality assessment conclusion ('not aware of any material risks... that have materially affected or are reasonably likely to materially affect'), which is the SEC Item 106(b)(2) formula → Strategy Integration. The remaining sentences are generic speculation ('could materially adversely affect') and a cross-reference. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: SI materiality assessment paragraph.


fact: ISC (Information Security Committee) named as management committee

fact: CIO identified as ISC member

fact: Director of IT Security, Risk and Compliance identified as ISC member

fact: Combined 20 years of risk management experience

fact: Threat assessments

fact: Vulnerability management

reasoning: The paragraph identifies specific management roles (CIO, Director of IT Security, Risk and Compliance) as members of the ISC, along with their qualifications — applying the person-removal test leaves little substantive content, confirming MR. The 'combined 20 years' is a hard number that could be verified against resumes, elevating to Level 4.

thinking:
Classify this paragraph.

Content: Describes ISC committee members (CIO, Director of IT Security), their combined experience, and areas of expertise.

Category: This is about management roles - who the members are, their titles, qualifications. The person-removal test: remove CIO, Director of IT Security, their experience → little remains. → MR

Specific facts:
- "ISC" - named committee (firm-specific)
- "CIO" - named role (firm-specific)
- "Director of IT Security, Risk and Compliance" - named role with security qualifier (firm-specific)

- "combined 20 years of risk management experience" - quantified, verifiable fact that pushes this to Level 4
- "threat assessments," "vulnerability management" - domain-specific terms
- "incident response" - L1 per rules
- "cybersecurity insurance" and "end user awareness" - borderline domain language


reasoning: This 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 paragraph pointing to Item 1A.


reasoning: The paragraph is centrally about managing third-party security risks in the acquisition context—due diligence, testing, remediation requirements, and contractual protections—making Third-Party Risk the clear category. Despite describing a concrete process, the vocabulary (due diligence, vulnerability, remediation, contractual protections) is standard business/ERM language that a non-security professional would naturally use; no cybersecurity-specific domain terms pass the ERM test, keeping specificity at Level 1.

thinking:
Classify this paragraph.

Content: About third-party security risks, specifically acquisition target security due diligence. This is centrally about how they manage third-party cyber risks → Third-Party Risk.

Specific facts:
- "security due diligence process for each acquisition target" - this is a firm-specific process description
- "independent testing of the target technology" - could be domain (penetration testing adjacent)
- "contractual protections and liability parameters" - generic

This is about vendor/third-party oversight as the central topic, specifically acquisition targets. → TP

Specificity: Let me check for domain terms, firm-specific facts, verifiable claims.

The language here uses some security-adjacent terminology like "independent testing" and "vulnerability remediation," but these terms are fairly standard across both security and broader enterprise risk contexts. The overall process—testing technology, identifying issues, requiring fixes—shows some domain familiarity, though it's not particularly specialized or technical in its presentation.


fact: Risk Committee (named committee providing assurances to management and Board)

fact: Incident Management and Information Security Plan (named internal program)

reasoning: The paragraph describes the Risk Committee's oversight role in providing assurances to management and the Board regarding cybersecurity risk identification and controls, which is governance-chain content → BG. Specificity reaches Level 3 due to the named 'Risk Committee' (non-generic committee) and the named 'Incident Management and Information Security Plan' (firm-specific program identifier).

thinking:
Classify this paragraph.

The paragraph describes the Risk Committee providing assurances to management and the Board about risk identification and cybersecurity controls. It mentions the "Incident Management and Information Security Plan."

Category: This is about oversight structure - the Risk Committee's role in providing assurances to management and Board. The Risk Committee here seems to be a board-level committee (provides assurances to "management and the Board"). This is Board Governance.

Wait - "Risk Committee provides assurances to management and the Board" - this suggests it's a committee that reports to both management and the Board. It could be a board-level committee.

Since the Risk Committee provides assurances directly to the Board, it's clearly part of the governance oversight structure. The "Risk Committee" is a named, non-generic committee specific to this firm, and the "Incident Management and Information Security Plan" is a named internal program, so both elements point to firm-specific details rather than generic governance concepts.


reasoning: The paragraph primarily answers what the cybersecurity program does — ERM integration, annual risk assessments, and security approach reviews — making it RMP. The Audit Committee mention is subordinate context for the ERM process, not a description of board oversight structure. All terminology (risk assessment, incident response, business continuity management, ERM) fails the ERM test — a non-security risk professional would naturally use this same language, yielding Level 1.

thinking:
Let me classify this paragraph.

Content: Describes ERM integration, Audit Committee oversight of ERM, and annual security assessments.

Category: This is primarily about what the cybersecurity program does - risk assessment methodology, ERM integration. The Audit Committee mention is brief. The bulk is about the risk management process. → RMP

Specific facts:
- "Audit Committee of the Board" - generic, every company has this → not firm-specific
- "ERM" integration - generic ERM language
- "incident response, business continuity management" - these are L1 terms per the rules

- "risk universe" and "digital innovation and transformation company" are also standard ERM terminology without domain-specific cybersecurity depth

The language here is what you'd find in any ERM framework - "assess our approach to information and physical security, risk management, incident response, business continuity management, and personal data privacy and protection" are all process-level terms without specialized content. This is Level 1 - Generic Boilerplate.


reasoning: This paragraph describes hypothetical cybersecurity risks using speculative language ('could prevent', 'could severely harm') without disclosing any actual cybersecurity measures, processes, or materiality assessments. It fails the SI materiality rule ('could...severely harm' is generic risk speculation every 10-K includes) and contains no substantive cybersecurity disclosure, making it None/Other with no specific facts.

thinking:
Classifying this paragraph.

This is generic risk language about what could happen - hypothetical threats. "Could prevent", "cause", "could severely harm" - all speculative. No actual measures, no program details, no materiality assessment conclusion.

This is None/Other - pure speculation about potential risks without any cybersecurity measures described.


fact: Chief Information Officer identified as responsible for cybersecurity

reasoning: The paragraph primarily answers who in management is responsible for cybersecurity — the CIO and their team — along with qualifications and supervisory scope, making it MR. The CIO is a firm-specific VP-level role, but 'many years of experience' is a soft number (not verifiable), and no domain terms pass the ERM test, capping specificity at Level 3.

thinking:
Classify this paragraph.

Category: The paragraph describes management's role - CIO responsibilities, team composition, qualifications. Person-removal test: remove CIO, qualifications, experience → "team responsible for assessing and managing material risks... has primary responsibility for overall cybersecurity risk management program and supervises internal personnel and retained external consultants." Some program description remains but the primary focus is on WHO is responsible and their qualifications. This is MR.

Specific facts:
- "Chief Information Officer" - named_role (CIO is a firm-specific VP+ level role)
- "many years of experience" - soft, not quantified

- No domain-specific terms that would trigger the ERM test; the language around cybersecurity and IT functions is too generic to qualify. Specificity lands at Level 3 given the firm-specific CIO designation.


fact: October 11, 2023 announcement of cybersecurity incident

fact: Disruption lasted approximately three days

fact: Backlog fulfilled within one week

fact: Notified relevant law enforcement

fact: No material financial impact to business

reasoning: The paragraph describes a real cybersecurity incident with timeline, scope, response, and resolution — squarely Incident Disclosure. The specific date (October 11, 2023), quantified disruption duration (approximately three days), and recovery timeline (one week) are externally verifiable facts, driving Level 4. The final sentence about no material financial impact is a Strategy Integration-adjacent assessment but the incident narrative clearly dominates.

thinking: Incident disclosure with specific details.


fact: CRO role with cybersecurity oversight responsibility

fact: CIO role leading IT strategy

fact: CISO role implementing cybersecurity risk management strategy

fact: RGA's Executive Committee (CRO and CIO are members)

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

fact: CRO has more than 30 years of experience

fact: CRO served as Global Chief Risk Officer

reasoning: The paragraph describes qualifications, career history, and responsibilities of CRO, CIO, and CISO — squarely Management Role per the person-removal test (removing person-specific content leaves almost nothing). Specificity is Quantified-Verifiable due to 'over 15 years' and 'more than 30 years' being verifiable lower-bound experience claims.

thinking:
Management Role - describes qualifications and responsibilities of CRO, CIO, CISO.

Specific facts:
- CRO (named role)
- CIO (named role)
- CISO (named role)
- "over 15 years experience" - quantified, verifiable lower bound
- "more than 30 years of experience" for CRO - quantified, verifiable
- RGA's Executive Committee (named committee)
- Enterprise Risk Management program mention

Level 4 due to "over 15 years" and "more than 30 years" being verifiable lower bounds.


fact: Ransomware incident occurred in July 2018

fact: Ransomware - specific threat type

fact: Affected Dx information technology systems specifically

reasoning: The paragraph describes a real cybersecurity incident — ransomware in July 2018 — with timeline, scope, investigation findings, and materiality conclusion, making it Incident Disclosure. The specific date 'July 2018' is an externally verifiable fact (this was a widely reported incident), driving specificity to Quantified-Verifiable. The final sentence is a materiality assessment but the incident narrative dominates (Rule 4).


fact: NIST Cybersecurity Framework

fact: CIS Top 18 Critical Security Controls – Control Level Framework

fact: Phishing tests conducted at least quarterly on a global basis, with additional periodic phishing tests for high-risk employee groups

fact: Individualized, biannual employee information security assessments with tailored follow-on trainings

fact: Cyber incident response plan

reasoning: The paragraph answers 'what does the cybersecurity program do?' with a detailed bulleted list of program features including risk assessments, training, phishing tests, incident response, and third-party oversight — squarely RMP. Specificity is Domain-Adapted due to named frameworks (NIST CSF, CIS Top 18) and domain-specific practices (phishing tests, security assessments), but no firm-specific roles/committees or externally verifiable claims push it to Level 3 or 4.

thinking:
Let me classify this paragraph.

Content: Describes IDEXX's cybersecurity risk management program - frameworks used, controls, procedures, training, phishing tests, third-party assessments, incident response, insurance. This is primarily about what the program does → RMP.

Specific facts:
- NIST CSF (framework, domain term)
- CIS Top 18 Critical Security Controls (framework, domain term)
- Code of Ethics (firm-specific reference)
- Biannual employee information security assessments (specific cadence)

- Phishing tests at least quarterly on a global basis (domain term + specific cadence)
- Cyber risk insurance policy (SI-adjacent but minor)
- Third-party service provider cybersecurity risk assessments as part of procurement process

Now I'm evaluating specificity levels: NIST CSF and CIS Top 18 are named frameworks at Level 2, phishing tests and quarterly cadence are domain terms with measurable frequency, while biannual assessments represent a softer timeline that's harder to verify independently.

Looking at what might push toward Level 3 or 4—the individualized employee security assessments are program-specific but not firm-unique, and the cyber incident response plan is too generic. The quarterly phishing testing is borderline verifiable as a frequency, but there's no hard numerical target, named individuals, or certifications to anchor it. The cyber risk insurance policy feels tangential to the main security narrative.

Overall this reads as Level 2, grounded in recognized frameworks and standard practices rather than firm-specific innovations or measurable commitments.


fact: credit monitoring offered to current and former customers

fact: two years of identity protection services

reasoning: The paragraph describes ongoing remediation from an actual incident — law enforcement engagement, regulatory interaction, litigation defense, and customer identity protection services, all pointing to Incident Disclosure. The specific duration of 'two years' for identity protection services is a verifiable, quantified claim.

thinking: Incident disclosure - describes response to an actual incident (law enforcement engagement, offering identity protection/credit monitoring to customers).


reasoning: The paragraph is centrally about how the company manages cybersecurity risk from third parties—due diligence, security risk assessments, incident-triggered reassessments, and ongoing monitoring of third-party providers—making Third-Party Risk the clear category. Despite length, the language (due diligence review, risk assessment, additional controls, continuous monitoring) is process-level description any ERM professional could write; no domain-specific terms pass the ERM test, no firm-specific facts, and no verifiable claims are present.

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

Specific facts:
- "third party security risk assessment" - this is generic process language
- "due diligence review" - generic
- "cybersecurity team continuously monitors" - "cybersecurity team" is generic, continuous monitoring is domain-ish

Let me think about specificity. The paragraph describes vendor oversight processes. "Third party security risk assessment" - generic. "Continuously monitors and addresses cybersecurity threats and incidents at third-party service providers" - this is process description but fairly generic.

Actually, is there anything that passes the ERM test for Level 2? "Security risk assessment," "information assets," "cybersecurity threats and incidents" - these are fairly standard.

"Vulnerabilities" and "additional controls commensurate to the risk" are both process-level language. Even "third party security risk assessment" is just a standard ERM practice with "security" added on—a general risk professional would recognize it immediately. The whole section stays at Level 1 because it's all procedural: due diligence, assessments, monitoring, controls. Nothing here goes beyond what you'd expect from a standard risk management framework.


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

reasoning: The SVP IT is the grammatical subject, but the paragraph's substance describes program activities—monitoring information systems, deploying security measures, system audits, and incident response planning—so the person-removal test leaves substantive RMP content. The SVP IT title (VP-level with IT portfolio) is firm-specific, elevating to Level 3, but no verifiable claims (certifications, named tools, specific numbers) are present.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes monitoring, incident response, and the SVP IT's role. Using the person-removal test: remove "SVP IT" references - there's still content about monitoring information systems, deploying security measures, system audits, vulnerability identification, and incident response plan. So RMP.

Wait, but there's significant content about the SVP IT role. Let me re-read. The SVP IT is the grammatical subject but the content describes what the program does (monitoring, security measures, audits, incident response). Per Rule 2, this → RMP.

Specificity:

The SVP IT title itself is firm-specific since it's a VP-level IT role, which puts us at Level 3. The supporting details like security measures, system audits, and incident response plans are all generic operational concepts. There are no verifiable facts—no specific numbers, certifications, named firms, or dates to anchor this to anything concrete.


reasoning: The paragraph builds toward a backward-looking materiality conclusion ('has not identified any cybersecurity threats that have materially affected operations or financial position'), which is a clear SI assessment under Rule 5. While it also describes an Incident Response Team and materiality determination process (RMP-adjacent), the culminating purpose is the materiality assessment. Specificity remains Level 1 because the vocabulary is entirely generic ERM language—'Incident Response Team,' 'subject matter experts,' 'materially affected'—with no cybersecurity domain terms passing the ERM test and no firm-distinguishing facts.

thinking:
Let me analyze this paragraph.

Content: Describes an Incident Response Team, incident materiality determination process, and a negative materiality assertion.

Category: The paragraph has three parts:
1. Incident Response Team composition - RMP
2. Materiality determination process - could be RMP or SI
3. "has not identified any cybersecurity threats that have materially affected" - SI (backward-looking materiality assessment)

The materiality assessment is a clear SI statement per Rule 5. But there's also RMP content about the Incident Response Team. The paragraph is mixed. The materiality assessment and the process leading to it seem to be the main thrust - the IRT is mentioned to support the assessment process.

The materiality conclusion is really the focal point here, even though the paragraph opens with the assessment framework. The whole structure builds toward that negative materiality finding, which is fundamentally a Strategy Integration statement about how cybersecurity impacts the business.

Now I'm examining whether the Incident Response Team itself qualifies as firm-specific. It's a named internal program, but "Incident Response Team" is pretty generic—most banks have one. The composition detail about members from major business areas adds some specificity, but it's still fairly standard language that doesn't really distinguish this bank's approach.

Looking at the domain terminology, "incident response" is flagged as commonly confused and stays at Level 1. The cybersecurity language is generic, and the materiality determination is just standard SEC/legal phrasing. I'm settling on Level 1 for this—it's generic boilerplate without domain-specific terms that would pass the ERM test or truly firm-specific facts that rise above what any bank would say.


fact: Specific date: May 14, 2019

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

fact: Named incident: AMCA Incident

reasoning: The paragraph describes a real cybersecurity incident (the AMCA Incident) with timeline, named third party, and nature of the breach, making it Incident Disclosure. The specific date (May 14, 2019) and named external firm (AMCA/Retrieval-Masters Credit Bureau) are independently verifiable facts, elevating to Level 4.

thinking: Incident disclosure - specific date, named third party, real event.


fact: Chief Risk Officer role providing specialized expertise and oversight

reasoning: The paragraph describes the Chief Risk Officer's role within the ERM structure, making it primarily about a management-level leadership role and responsibilities (MR). The CRO is a C-suite title in a cybersecurity governance context, qualifying as firm-specific, but no verifiable claims (certifications, years of experience, named individual) elevate it to Level 4.

thinking:
Classify this paragraph.

Content: Describes a Chief Risk Officer role providing expertise in risk management. This is about a management role.

Category: Management Role - it's about a leadership role (CRO) and their responsibilities.

Specific facts:
- "Chief Risk Officer" - This is a named role at VP+ level. But wait - CRO is about broader risk management, not specifically cybersecurity. However, in the context of a cybersecurity filing (Item 1C), the CRO is being described as part of the governance structure. CRO is a C-suite role, so it's firm-specific.

- CRO is a C-level position whose responsibilities span risk management broadly, which could encompass cybersecurity as part of that portfolio. The named_role criteria specifically mention cybersecurity leadership roles like CISO, CTO, and CIO, but CRO isn't explicitly listed—though it's clearly C-suite. The real question is whether risk management responsibilities are broad enough to count as a role whose portfolio includes cybersecurity.

Since this appears in Item 1C (the cybersecurity disclosure section) and the CRO oversees enterprise risk management that includes cyber risk, I think it qualifies as firm-specific. However, ERM itself is a standard domain term that wouldn't be considered adapted terminology. So I'm settling on Level 3 based on the CRO title being a C-suite cybersecurity leadership role.


fact: cyber maturity assessment

reasoning: Category is RMP because external parties are hired to supplement the company's own cybersecurity capabilities (Rule 3: third parties serving the company → RMP, not TP). Specificity reaches Domain-Adapted via terms like 'managed services agreement for incident response,' 'firewall maintenance,' and 'cyber maturity' which pass the ERM test, but no firm-specific facts (unnamed parties) or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Describes engaging external parties for cybersecurity services (managed services for incident response, comprehensive assessment, firewall maintenance) and also describes vendor oversight of those third parties.

Category: The paragraph describes third parties hired to serve the company (assessors, incident response, firewall maintenance) - per Rule 3, this is RMP. The vendor oversight portion at the end is about assessing these service providers, but the central topic is about the company's own cybersecurity program using external parties.

Specificity: Let me scan for facts:
- "managed services agreement with an external party for incident response" - domain term (managed services for IR)

- "comprehensive cybersecurity assessment" - generic
- "firewall maintenance and upgrade initiatives" - domain term (firewall)
- "cyber maturity" - domain term

The paragraph uses domain-specific language like firewall maintenance, incident response, and cyber maturity that demonstrates technical knowledge, though "incident response" alone is somewhat borderline. There are no firm-specific facts, named roles, named vendors, or verifiable claims present. This lands at Level 2 - Domain-Adapted.


fact: ransomware

fact: malware

fact: phishing

reasoning: The paragraph opens with a backward-looking materiality assessment ('have not had any material cybersecurity incidents') and mentions cybersecurity insurance, both SI indicators per Rule 5. Specificity reaches Level 2 via specific threat types (ransomware, malware, phishing) that pass the ERM test, but the negative assertion about no material incidents is not externally verifiable and no firm-specific facts qualify.

thinking:
Let me analyze this paragraph.

Content: It starts with a negative assertion about material incidents, then discusses risk factors (cyber-attacks, ransomware, malware, etc.), mentions security efforts, insurance, and cross-references to Risk Factors.

Category: The paragraph states "we have not had any material cybersecurity incidents" - this is a materiality assessment (SI per Rule 5). It also mentions cybersecurity insurance (SI). The cross-references at the end are N/O but they're not the main content. The middle discusses generic risk language. The dominant frame is the materiality assessment + insurance = Strategy Integration.

Now I'm checking the specificity of each claim. The materiality assertion as of December 31, 2023 is a negative self-assertion that can't be externally verified. The threat types mentioned—ransomware, malware, phishing, cyber-attacks, and cyber intrusions—are domain-specific terminology. The cybersecurity insurance reference is strategy integration content but not a domain term itself, and the cross-references to risk factor sections are just firm-specific citations rather than substantive content.

Since the only specific, verifiable elements are the domain terms for threat types, this disclosure qualifies as Level 2 - Domain-Adapted, with no firm-specific facts or verifiable information that would elevate it further.


reasoning: This is a backward-looking negative materiality assertion ('has not experienced any cybersecurity incidents that have had a material impact on its business strategy, financial condition, or results of operations'), which per Rule 5 is SI. No domain terms, firm-specific facts, or verifiable claims are present — the negative self-assertion about absence of incidents is not externally verifiable — so specificity remains Level 1.

thinking:
Negative materiality assertion → SI by Rule 5.

"have not experienced any material cybersecurity incidents" → SI (negative assertion).

Specificity: This is a self-reported negative assertion. Per the rules, "We have not experienced any material cybersecurity incidents" is NOT externally verifiable. No domain terms, no firm-specific facts. Level 1.


reasoning: The paragraph's central topic is managing cybersecurity risks from third-party providers — pre-acquisition diligence, contractual obligations, and monitoring — making it Third-Party Risk. The explicit reference to SOC Reports demonstrates domain knowledge (specific attestation type an ERM generalist wouldn't naturally cite), elevating to Level 2, but no firm-specific or verifiable facts push higher.

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

Specific facts:
- SOC Reports (domain term / framework reference)
- Pre-acquisition diligence, contractual obligations, performance monitoring (generic process descriptions)
- "System Organization and Control Reports (SOC Reports)" - this is a domain term that passes the ERM test (specific audit/attestation type)

The paragraph describes how they manage third-party cyber risks - vendor oversight is the central topic → TP.

SOC Reports is a domain term (Level 2). The mention of "key third-party financial systems" is somewhat specific but not firm-specific enough. No named roles, no verifiable claims.

Level 2.


fact: due diligence of service providers' information security programs prior to onboarding

fact: reassess vendors using a risk-based approach

fact: contractually require third-party service providers to implement and maintain appropriate security controls

fact: contractually restrict third-party ability to use data for purposes other than providing services

fact: service providers contractually required to notify promptly of information security incidents on their systems

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers — due diligence, contractual requirements, ongoing oversight — making Third-Party Risk the clear category. Specificity reaches Domain-Adapted due to references to information security programs, security controls, and incident notification requirements on third-party systems, which demonstrate cybersecurity domain knowledge beyond generic ERM language, but no firm-specific or verifiable facts elevate it further.

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


reasoning: The paragraph contains a backward-looking materiality assertion ('we have not experienced any material adverse events related to a security breach or cyber-attack'), which per Rule 5 qualifies as Strategy Integration. The rest is speculative about potential consequences of IT failures. No domain terms pass the ERM test (security breach, cyber-attack are generic), no firm-specific facts, and the negative self-assertion is not externally verifiable, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Discusses reliance on IT systems, claims appropriate precautions, states no material adverse events from breaches, and describes potential consequences of system failures.

Category: The paragraph contains "we have not experienced any material adverse events related to a security breach or cyber-attack" — this is a negative assertion about materiality, which per Rule 5 is SI. But let me consider the full paragraph. Most of the text is about IT system reliability and potential consequences (speculative). The materiality statement is present though.

Per Rule 5: "Have not experienced any material cybersecurity incidents" → SI (negative assertion).

The negative self-assertion "have not experienced any material adverse events" lacks external verification—there are no domain-specific terms that would pass the ERM test, just generic references like "security breach" and "cyber-attack." No firm-specific facts or named roles, so this lands at Level 1.


reasoning: The paragraph is centrally about managing third-party cybersecurity risk—vendor evaluation, contractual safeguards, review of internal control reports, and incorporating third-party risk into incident response plans—making TP the clear category. All language passes the ERM test (evaluating vendors' policies/procedures, contractual safeguards, internal control reports, incident response plans are standard risk management vocabulary), with no domain-specific cybersecurity terms, firm-specific facts, or verifiable claims, keeping it at Level 1.

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

Specific facts: "evaluate third-party service providers' cybersecurity policies, procedures, and practices annually" - generic process description. "contractual safeguards" - generic. "internal control reports" - this could be domain-adapted but "internal control reports" is borderline ERM language. "incident response plans" - commonly confused, stays L1.

Actually, let me reconsider. "internal control reports" could refer to SOC reports but it's not explicitly stated. The paragraph describes vendor oversight processes but uses fairly generic language. The ERM test: would a non-security ERM professional use this language? Mostly yes - evaluating vendors' policies, contractual safeguards, internal control reports, incident response plans. These are all general risk management concepts.

This is clearly third-party risk management based on the heading, and the language throughout is generic boilerplate without domain-specific terminology—just standard vendor oversight processes described in broad strokes.


reasoning: The paragraph describes developing/maintaining systems and monitoring/updating programs to mitigate cybersecurity incidents, which answers 'what does the program do?' → RMP, though the cross-reference to Item 1A and speculative language make category borderline with N/O. All language is entirely generic ('mitigate the impact,' 'monitor and update,' 'security measures') with no domain terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Describes mitigating cybersecurity incidents, monitoring/updating systems, mentions past occurrences causing adverse impacts, and cross-references Risk Factors.

Category: This is mostly generic language about having systems/programs plus a cross-reference to Item 1A. The cross-reference and speculative language ("could cause in the future") push toward N/O. But there is some substantive content about developing/maintaining systems and monitoring. However, it's extremely generic. The last sentence is a pure cross-reference. The mention of "have caused" past incidents is vague. Overall this is borderline RMP/N/O.

The paragraph does describe what their program does—mitigate, monitor, update—but it's so thin and generic that it barely qualifies as substantive. The language about developing and maintaining systems and continually updating them suggests RMP, yet there's no specificity whatsoever. No domain-specific terminology, no concrete examples—just vague references to mitigating cybersecurity incidents and monitoring systems.


fact: Since at least January 1, 2021 — specific date anchoring the no-material-incident assertion

reasoning: The paragraph makes two materiality assessments — a backward-looking statement that no incidents have materially affected the company and a forward-looking statement that material impact is not reasonably likely — squarely fitting the SI materiality rule. The specific date 'January 1, 2021' is a firm-specific anchoring detail, but the negative assertion about absence of incidents is not externally verifiable, so this stays at Level 3.

thinking: Materiality assessment paragraph.


fact: Board has not assigned cybersecurity oversight responsibility to any committee or subcommittee

reasoning: The paragraph answers how the board oversees cybersecurity — full board retains oversight, management provides updates at regular meetings — making it Board Governance. The explicit statement that oversight has NOT been delegated to any committee or subcommittee is a firm-specific organizational fact that distinguishes this company's governance structure, elevating to Level 3.

thinking:
Classify this paragraph.

Category: Board Governance - describes board oversight of cybersecurity, no delegation to committee, management reports to board.

Specific facts:
- "ERM program" - this is generic ERM language, not domain-specific
- "Board has not assigned that responsibility to any committee or subcommittee" - this is a firm-specific organizational fact
- "regularly scheduled Board meetings" - generic cadence

The statement that the Board has NOT delegated to any committee is a firm-specific organizational detail. It distinguishes this company.

This is firm-specific information at the highest level of detail.


fact: Head of Global IT role leading cybersecurity

fact: IT Security Team as named team

fact: Acquisition due diligence on IT security systems of targets

fact: PCI, SOC1, SOC2 compliance experience

fact: CompTIA security certifications

fact: Over 20 years of combined infrastructure architecture experience

reasoning: The paragraph primarily describes who is responsible for cybersecurity (Head of Global IT, IT Security Team), their responsibilities, qualifications, and career background — classic Management Role content. Person-removal test confirms: removing the Head of Global IT's experience and team qualifications leaves only a thin acquisition due diligence process. Specificity reaches Level 4 via 'over 20 years of combined infrastructure architecture experience' (verifiable lower bound) and named CompTIA certifications (verifiable via issuing body).

thinking:
Let me analyze this paragraph.

Content: Describes the Head of Global IT role, IT Security Team responsibilities, acquisition due diligence process, and qualifications/experience of the Head of Global IT and team members.

Category: This is primarily about management roles - who is responsible (Head of Global IT), team composition (IT Security Team), their responsibilities, and qualifications. The person-removal test: removing person-specific content (Head of Global IT's experience, team certifications, qualifications) would leave some program description about acquisition due diligence, but the bulk is about roles and qualifications. → MR

Specific facts:

- "Head of Global IT" is a named leadership role with a "Global" qualifier that makes it firm-specific, even though it's not explicitly VP-level, it functions as a senior leadership position.
- "IT Security Team," CompTIA certifications, and the quantified infrastructure experience are all verifiable and firm-specific facts.
- PCI and SOC compliance standards, along with acquisition due diligence practices, are domain-specific credentials and activities that support the candidate's expertise.
- The key distinction is that "over 20 years combined experience" provides a measurable lower bound, while CompTIA certifications come from a named, verifiable organization.


reasoning: The paragraph opens with a backward-looking materiality assessment ('have not experienced a cybersecurity threat or incident that resulted in a material adverse impact') which triggers SI under Rule 5. The remainder is speculative risk language ('could have a material adverse effect') which alone would be N/O, but the SI assertion dominates. No domain terms, firm-specific facts, or verifiable claims are present — the negative assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: States no material incident to date, then speculative language about future risks.

Category: The first clause "have not experienced a cybersecurity threat or incident that resulted in a material adverse impact" is a materiality assessment (SI per Rule 5). The rest is speculative ("could have a material adverse effect" — NOT SI per Rule 5). The SI assertion is present though.

Specificity: "Have not experienced... material adverse impact" — this is a negative self-assertion, not externally verifiable. No domain terms, no firm-specific facts. Level 1.


fact: Chief Technology Officer (CTO) as first line of defense

fact: Technology Leadership Centre

fact: IT and cybersecurity teams at subsidiaries as first line

fact: Chief Risk Officer as second line of defense

fact: Risk Committee of the board of directors as second line

fact: Controlling Department as third line

reasoning: This is a governance-chain paragraph describing the three-lines-of-defense oversight structure spanning board committees and management roles, which defaults to Board Governance per Rule 1. Specificity is Firm-Specific due to multiple distinguishing organizational details: named roles (CTO, CRO), named teams (Technology Leadership Centre, Controlling Department), and a non-generic board committee (Risk Committee).

thinking:
Let me analyze this paragraph.

Category: This describes a governance structure with three lines of defense. It mentions board committees (Risk Committee, Audit Committee) and management roles (CTO, CRO). The primary question it answers is "How does the board oversee cybersecurity?" — but it's really about the overall governance model spanning board and management. The three lines of defense model is a governance-chain paragraph. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure.

Actually, this is describing the entire governance model - board AND management. The purpose is describing the oversight structure, so BG.

Now I'm identifying the specific entities mentioned: CTO and Technology Leadership Centre are firm-specific roles and teams, as are the Chief Risk Officer, Risk Committee, and Controlling Department. The Audit Committee is generic, but the three lines of defense framework itself is a standard ERM concept, not cybersecurity-specific, so it wouldn't meet the ERM test for categorization.


reasoning: The paragraph primarily describes how cybersecurity risks are integrated into the ERM process, including risk evaluation and audit planning — answering 'what does the program do?' rather than a governance question, making it RMP (ERM integration). All language (risk evaluation, risk-based audit plan, ERM process) is standard enterprise risk management vocabulary that any non-security ERM professional would use; VP of Internal Audit is not a cybersecurity-portfolio role, General Counsel and Audit Committee are generic, yielding no facts above Level 1.

thinking:
Let me analyze this paragraph.

Category: This describes how cybersecurity risks fit into the ERM process. The VP of Internal Audit and General Counsel facilitate ERM, cybersecurity is included in ERM, and internal audit uses ERM for audit planning. The primary question answered is "What does the cybersecurity program do?" — specifically how cyber risks are integrated into ERM. This is RMP (ERM integration).

Wait - let me reconsider. The paragraph mentions reporting to Audit Committee and approval by Audit Committee. But the main content is about the ERM process and how cybersecurity fits into it. The governance chain (internal audit → Audit Committee) is secondary.

Now looking at specificity: the Vice President of Internal Audit isn't necessarily a cybersecurity role since Internal Audit covers broader functions, the General Counsel is a standard position, and terms like "enterprise risk management," "Audit Committee," and "risk-based audit plan" are all generic governance language without firm-specific details. There's nothing here that would distinguish this company's approach from any other organization's standard ERM framework. This is Level 1.


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

reasoning: The paragraph describes the organization's general commitment to data protection, which is a high-level statement about the cybersecurity program's philosophy, fitting RMP as it answers 'what does the program do' even if only at a high level. The mention of 'confidentiality, integrity, and availability' is the CIA triad—a core information security concept that passes the ERM test—elevating specificity to Level 2.

thinking:
Classify this paragraph.

Content: Generic statement about valuing data protection, CIA triad mention, everyone responsible. No specific program details, no board oversight structure, no management roles.

Category: This is very generic. It mentions "Board of Directors" but only in the context of "everyone is responsible." It's not describing board oversight. It's a general introductory statement about cybersecurity commitment. Could be RMP as it's about the program philosophy, but it's so generic... It mentions "confidentiality, integrity, and availability" which is the CIA triad - that's a domain term.

The use of "confidentiality, integrity, and availability" signals domain-specific knowledge—a non-security professional wouldn't naturally reach for this terminology—which pushes it to Level 2 specificity. This is clearly RMP material since it's outlining the organization's foundational approach to protecting data.


fact: FFIEC framework referenced for program design

fact: NIST standards and guidelines referenced

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

reasoning: The paragraph primarily describes what frameworks the company uses to design its cybersecurity program (FFIEC, NIST) and mentions risk mitigation controls and processes, making it RMP. The named frameworks (FFIEC, NIST) and CIA triad demonstrate cybersecurity domain knowledge beyond generic ERM language, reaching Level 2, but there are no firm-specific facts (the 'Information Security Program' name is generic) or verifiable claims to push higher.

thinking:
Let me analyze this paragraph.

Content: Describes their Information Security Program's design referencing FFIEC and NIST frameworks, then has boilerplate about cyber threats, then a cross-reference to Risk Factors.

Category: This is about what the cybersecurity program does - framework adoption, risk mitigation controls. → RMP

Specific facts:
- FFIEC framework → named framework (domain term / framework)
- NIST → named framework
- "Information Security Program" → named internal program (firm-specific? It's a fairly generic name but it is their named program)
- Confidentiality, integrity, availability → domain terms but very basic

- FFIEC and NIST are standard industry frameworks, so they're Level 2 domain terms. The "Information Security Program" itself is generic without any firm-specific details like named teams or roles, so that's also Level 2. The main substance here is about their risk management program, though there's some boilerplate cross-referencing at the end.


fact: Risk Committee of the Board oversees cybersecurity

fact: Global Security Organization executes the strategy

fact: ERM Steering Committee receives reports

fact: CSO (Chief Security Officer) is an advisor to the Disclosure Committee

fact: Disclosure Committee meets quarterly

reasoning: The paragraph describes the governance chain from the Risk Committee of the Board down through senior executives and the Global Security Organization, with reporting flows to the ERM Steering Committee and Board — this is oversight structure, defaulting to BG per Rule 1. Multiple firm-specific named entities (Risk Committee of the Board, Global Security Organization, ERM Steering Committee, CSO) elevate specificity to Level 3, but no externally verifiable claims are present.

thinking:
Let me analyze this paragraph.

Category: This describes governance structure - how oversight flows from Board → Risk Committee → management. It mentions the Risk Committee of the Board, the Global Security Organization, ERM Steering Committee, CSO as advisor to Disclosure Committee. The primary question answered is "How does the board oversee cybersecurity?" but it also describes management organization. The governance chain (Board → Committee → Officer → Program) defaults to BG per Rule 1. But there's significant management organizational detail too. The paragraph starts with "overseen by senior executives" and "ultimately overseen by the Risk Committee of the Board" - this is governance chain. I'll go with BG.

Now I'm identifying the firm-specific elements: the Risk Committee of the Board is a non-generic board committee, the Global Security Organization is a named team, the ERM Steering Committee is a management-level committee, and the CSO is a firm-specific role. The quarterly meeting cadence is standard, but most of these organizational names and titles are unique to this company.


fact: CIO role

fact: CISO role

fact: CIO has more than 30 years of experience

fact: CISO has more than 20 years of cybersecurity experience

fact: CIO prior roles at Aegon N.V., Citigroup, Inc. and JP Morgan Chase & Company

fact: CISO was SVP, CISO at Brighthouse Financial

fact: CISO was Technology VP & CISO for GE Healthcare

fact: CISO started career at Allstate Insurance Company

fact: Certified Information Systems Auditor (CISA)

fact: Certified Information Security Manager (CISM)

fact: Certified Information Systems Security Professional (CISSP)

reasoning: The paragraph is entirely about the qualifications, career history, and credentials of the CIO and CISO — classic Management Role content that collapses to nothing under the person-removal test. Specificity is Level 4 due to numerous verifiable claims: specific years of experience (30+, 20+), named prior employers (Aegon, Citigroup, JP Morgan Chase, Brighthouse Financial, GE Healthcare, Allstate), and named certifications (CISA, CISM, CISSP) all independently verifiable.

thinking:
Classify this paragraph.

Category: This is about management roles - specifically qualifications, career history, and credentials of the CIO and CISO. Person-removal test: remove all person-specific content and nothing substantive about cybersecurity programs remains. → MR

Specificity: Let me list facts:
- CIO with more than 30 years of experience → quantified, verifiable lower bound
- Prior roles at Aegon N.V., Citigroup, Inc., JP Morgan Chase & Company → named firms, verifiable

- CISO with more than 20 years of cybersecurity experience → quantified, verifiable
- Prior roles at Brighthouse Financial, GE Healthcare, and Allstate Insurance Company → named firms, verifiable
- Multiple relevant certifications including CISA, CISM, and CISSP → all verifiable

Level 4 easily.


fact: penetration testing

fact: information security risk assessments on third party service providers

fact: vendor management group

reasoning: While the first sentence describes an external penetration test (RMP), the bulk of the paragraph—four of five sentences—addresses vendor oversight: risk assessments on third-party providers, re-assessments, a monitoring program, and contractual requirements, making Third-Party Risk the central topic. Specificity reaches Firm-Specific due to the named 'vendor management group' and a described 'third party service provider monitoring program,' which are organizational details specific to this company, alongside domain terms like penetration testing and information security risk assessments.

thinking:
Let me analyze this paragraph.

Content: External penetration testing, vendor security assessments, vendor monitoring, contractual requirements.

Category: This covers both RMP (penetration testing) and TP (vendor management). The majority of the text is about third-party vendor oversight - vendor assessments, re-assessments, monitoring program, contractual terms. The first sentence is about pen testing (RMP), but sentences 2-5 are all about vendor/third-party management. TP is central topic → Third-Party Risk.

Specific facts:
- "penetration testing" → domain_term (L2)

- "vendor management group" is a named organizational unit, so I'll mark it as firm-specific
- "information security risk assessments" is too generic to flag
- "risk weighted basis" and "third party service provider monitoring program" are somewhat generic terms that many firms use, so they don't rise to the level of firm-specific identifiers
- "penetration testing" is a domain term

I'm settling on Level 3 specificity, with "vendor management group" as the key firm-specific reference since it's a named internal team.


fact: threat intelligence services

fact: Third-Party Risk Management program (named, capitalized internal program)

reasoning: The paragraph splits between threat intelligence (RMP) and vendor oversight (TP), but the majority of text describes requirements imposed on third parties and the company's Third-Party Risk Management program, making TP the central topic. The capitalized 'Third-Party Risk Management program' is a named internal program that elevates specificity to Firm-Specific, while 'threat intelligence services' is a domain term passing the ERM test.

thinking:
Classify this paragraph.

Content: Discusses threat intelligence services, third-party risk management program, vendor security controls and compliance assessment.

Category: The paragraph has two parts - threat intelligence (RMP) and third-party risk management (TP). The second half about the "Third-Party Risk Management program" and vendor requirements is substantial. Let me assess which is central. About half is threat intel (RMP), half is third-party oversight (TP). The TP content is slightly more prominent and is the concluding focus. But it's close. The third-party content describes requirements imposed ON vendors → TP. I'll say TP given the named program and central focus on vendor oversight.

Re-reading more carefully, the threat intelligence portion covers services from multiple organizations while the third-party risk management content—including the named program and vendor security control requirements—comprises roughly two-thirds of the paragraph, making TP the clear winner. The "Third-Party Risk Management program" is capitalized as a named internal program, which counts as firm-specific. This lands at Level 3.


reasoning: The paragraph is primarily speculative risk language ('may be insufficient', 'could result', 'may further expose') culminating in a cross-reference to Item 1A Risk Factors. While it briefly mentions 'regular testing of our cybersecurity incident response plan,' the dominant content is forward-looking disclaimers and a pointer elsewhere, making it N/O. N/O paragraphs receive Generic Boilerplate.

thinking:
This paragraph discusses cybersecurity threats and controls but primarily serves as a cross-reference to Item 1A Risk Factors. Let me analyze.

Content: Talks about sophistication of threats, AI risks, mentions testing of incident response plan, then cross-references Item 1A. The main thrust is speculative risk language ("may be insufficient", "could result", "may further expose") and a cross-reference.

Category: This is mostly speculative risk language + cross-reference. The "could materially and negatively impact" is speculation (every 10-K says this), not an assessment. The cross-reference points elsewhere. This is N/O per Rule 5 and Rule 6 - it's speculative without substantive measures described.

The mention of "regular testing of our cybersecurity incident response plan" and "controls and preventative actions" are buried within risk language rather than substantively describing the program itself. The paragraph's real purpose is addressing the threat landscape and directing readers to Item 1A, not detailing what the cybersecurity program actually does.

I'll classify this as N/O - primarily a risk factor cross-reference with speculative language, and "ransomware" being a domain term doesn't change that since N/O paragraphs default to Generic Boilerplate per the rules.


fact: Director - Information Systems (i.e. the Company's chief information officer)

reasoning: The paragraph describes board and committee oversight of cybersecurity risk, with the Audit and Compliance Committee as the supporting body, making Board Governance the clear category. The mention of the 'Director - Information Systems' explicitly equated to the CIO role elevates specificity to Firm-Specific, as CIO is a VP-equivalent title per the rules.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity risks, delegation to Audit and Compliance Committee, interaction with senior management. This is about how the board oversees cybersecurity → Board Governance.

Specific facts:
- "Audit and Compliance Committee" — this is a board-level committee, essentially a variant of Audit Committee (generic, every company has one) → borderline. "Audit and Compliance Committee" is slightly more specific than just "Audit Committee" but it's still a standard board committee. I'll consider it not firm-specific.

- "Director - Information Systems" is described as the Company's chief information officer, which qualifies as a CIO role. CIO is listed as firm-specific, so this counts as Level 3 (Firm-Specific).


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

fact: Chief Information Officer (CIO) receives cybersecurity reports from CSO

fact: Reporting line: CSO informs CIO and senior management team on cybersecurity risks and incidents

reasoning: The paragraph centers on the CSO's role—what they are informed about, what they stay current on, and who they report to (CIO and senior management). While some program activities are mentioned, they serve to describe the CSO's scope of responsibility and reporting lines, making MR the best fit. Specificity is Level 3 due to named VP+-level roles (CSO, CIO) and a firm-specific reporting chain.

thinking:
Classify this paragraph.

The paragraph describes the CSO's role - being informed about the program, staying current on developments, and informing the CIO and senior management. This is about management's organizational role and reporting lines.

Person-removal test: Remove CSO, CIO, senior management team references. What remains? "continually informed about the status of the program, including the effectiveness of the process and controls to monitor, prevent, detect, mitigate, and remediate cybersecurity incidents" and "latest developments in cybersecurity, including potential threats and innovative risk management techniques." Some program description remains but the paragraph is structured around the CSO's role and reporting lines.

So this is fundamentally about management organization - specifically how the CSO relates to the CIO and senior management through reporting lines. That makes it MR. The CSO and CIO are firm-specific named roles, and the reporting structure is also firm-specific, putting this at Level 3 specificity.


fact: ransomware mentioned as specific threat type

fact: denial-of-service mentioned as specific threat type

fact: nation state actors as advanced persistent threat actors

fact: defense industrial base as sector context

fact: 21st Century Security vision — named internal strategic initiative

reasoning: The paragraph primarily answers how cybersecurity fits into the company's business strategy — linking it to their '21st Century Security vision,' digital transformation, and commitment to being a leader in information security, making it Strategy Integration. The 'could materially adversely affect' language is speculative and does not constitute an SI materiality assessment. Specificity reaches Firm-Specific due to the named '21st Century Security vision' initiative, which is a distinguishing identifier for Lockheed Martin; domain terms like ransomware, denial-of-service, and nation state actors provide the Level 2 floor.

thinking:
Let me analyze this paragraph.

Category: It discusses cybersecurity's importance to the company, threat landscape, and potential business impact. It mentions "could materially adversely affect" which is speculation (not SI per Rule 5). It's mostly about why cybersecurity matters to the company and the threat environment. This is more of a general introduction/context-setting. It doesn't describe board oversight, management roles, specific processes, third-party management as central topic, or an actual incident. The "could materially adversely affect" is speculative, not an assessment. This feels like Strategy Integration in terms of how cybersecurity fits into business strategy ("21st Century Security vision", "digital transformation"), but also has threat landscape description.

The core focus is strategic positioning—how cybersecurity aligns with business vision and digital transformation efforts—rather than governance or risk management specifics. The threat landscape details and resource allocation support this strategic framing, making this Strategy Integration. The specific threat types mentioned (ransomware, denial-of-service, nation state actors) and references to the defense industrial base add domain-specific grounding to the strategic narrative.