reasoning: This paragraph describes generic IT infrastructure and data handling needs without addressing any of the six substantive cybersecurity disclosure questions — no governance, management, risk processes, third-party oversight, incidents, or strategy integration. It contains no domain-specific cybersecurity terms, only general business IT language any company could use.

thinking: Generic description of IT systems and data handling, no cybersecurity-specific content.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph concludes with a materiality assessment stating cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition — this is the SEC Item 106(b)(2) formula, making SI the primary category per Rule 5. No domain terms pass the ERM test (confidentiality agreements/framework are generic business concepts), and the negative materiality assertion is not externally verifiable, leaving specificity at Level 1.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. Plans to establish confidentiality framework
2. Confidentiality agreements for cybersecurity
3. Materiality assessment statement

The materiality assessment at the end is a clear SI statement per Rule 5 - "not aware of any material risks from cybersecurity threats, that have materially affected or are reasonably likely to materially affect the Company, including our business strategy, results of operations, or financial condition."

This is the SEC Item 106(b)(2) language - a backward and forward-looking materiality assessment → SI.

The materiality statement itself is a negative self-assertion that isn't externally verifiable, and the rest of the language is too generic—just "confidentiality framework" and "confidentiality agreements" without any domain-specific terms that would satisfy the ERM test. This lands at Level 1.


content_category: Management Role

fact: CFO has been responsible for oversight function for three years

type: quantified

fact: CFO has worked in financial services for more than 30 years

fact: CCO has been responsible for oversight functions for three years

fact: Current CCO has been serving since April 2025

fact: CCO has worked in financial services for more than 35 years

reasoning: The paragraph focuses on who (CFO, CCO) is responsible for cybersecurity risk management, their qualifications, and experience—person-removal leaves no substantive program description, confirming MR. Multiple quantified claims (years of experience with lower bounds, specific start date of April 2025) are externally verifiable, driving Level 4.

thinking:
Classify this paragraph.

Category: This is about management roles - CFO, CCO, their responsibilities, qualifications, experience. Person-removal test: remove all person-specific content and nothing substantive about cybersecurity program remains. → MR

Specific facts:
- CFO (named role) → firm-specific
- CCO (named role) → firm-specific? Actually CFO and CCO are generic roles every company has. But wait - in cybersecurity context, CFO/CCO having cybersecurity oversight responsibility is somewhat firm-specific since not every company assigns cyber oversight to CFO/CCO.

Actually, per the rules, generic governance roles like CFO and CCO aren't firm-specific even if the cybersecurity oversight assignment is unusual. The quantified facts though—three years as CFO oversight, more than 30 years in financial services, three years CCO oversight, April 2025 start date, more than 35 years in financial services—these are all verifiable, person-specific metrics.


content_category: Risk Management Process

reasoning: The paragraph describes what the cybersecurity program does—risk assessments, security controls, incident response, external service providers—making it RMP. All language is generic ERM-transferable ('assessments designed to help identify material cybersecurity risks,' 'security controls,' 'external service providers') with no domain terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Content: Describes cybersecurity risk management program integration with ERM, includes assessments, team responsibilities, security controls, incident response, external service providers.

Category: Risk Management Process - describes what the program does.

Specificity: Let me check for specific facts.
- "integrated into overall enterprise risk management program" - generic
- "assessments designed to help identify material cybersecurity risks" - generic process
- "security controls" - generic
- "response to cybersecurity incidents" - generic
- "external service providers" - generic

This is all generic ERM-style language. No domain terms that pass the ERM test, no firm-specific facts, no verifiable claims.

Level 1.


content_category: None/Other

reasoning: This paragraph is introductory risk-framing that describes general reliance on systems and the threat landscape but does not answer any of the six substantive cybersecurity disclosure questions—no program activities, governance structure, management roles, or incident details are described. As None/Other, specificity is Generic Boilerplate; the mention of 'nation-state actors' is common boilerplate in 10-K risk framing and no substantive cybersecurity measures are disclosed.

thinking:
Classify this paragraph.

This is generic risk description language - no specific cybersecurity measures, no specific facts about the company's program. It talks about reliance on systems, third parties, and general threat landscape.

Category: None/Other - this is general risk context, not answering any of the six substantive questions. Actually, let me reconsider - it mentions third parties and cybersecurity risks but doesn't describe any measures or processes. It's generic risk framing.

This could be RMP or N/O. It doesn't describe what the program does, how the board oversees, etc. It's just setting context about risk exposure. N/O.

Now checking the specificity level - there's minimal domain-specific language here, mostly boilerplate risk language. The reference to "nation-state actors" shows some cybersecurity awareness, which pushes it slightly above pure generic language, but the rest remains standard SEC filing language without firm-specific details or verifiable claims. Actually, this paragraph doesn't substantively address any of the key questions—it's just risk context and threat landscape framing without discussing actual security measures or processes. That makes it N/O, which means it defaults to Generic Boilerplate and Level 1 specificity.


reasoning: This paragraph states a generic business fact about collecting and storing information without describing any cybersecurity program, governance, or risk management activity. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

This is a simple statement about collecting and storing information - no cybersecurity measures, no specific program details, no governance structure.


content_category: Third-Party Risk

fact: SOC reports of providers reviewed

fact: complementary controls implemented alongside SOC report reviews

reasoning: The paragraph's central topic is oversight of third-party service providers—security assessments before engagement, ongoing monitoring, and SOC report reviews—making TP the primary category. The final sentence is a materiality assessment (SI), but it is subordinate to the TP framing. Specificity reaches Level 2 via 'SOC reports' and 'complementary controls,' which demonstrate security-domain knowledge beyond generic ERM language, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

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

Wait, let me check Rule 5 for the last sentence: "We have not encountered cybersecurity challenges that have materially impaired our operations or financial standing." This is a backward-looking materiality assessment → SI. But the majority of the text is about third-party risk management.

The central topic test: most of the paragraph answers "How are third-party cyber risks managed?" The last sentence is SI but it's one sentence out of five. TP wins.

Looking at the specificity level now. The disclosure mentions SOC reports and complementary controls, which are domain-specific security terms that demonstrate some technical depth. However, there are no named individuals, committees, or firm-specific details - just generic practices like annual assessments. The materiality statement at the end is a broad assertion without supporting evidence. This lands at domain-adapted specificity rather than firm-specific.


category_confidence: medium

reasoning: The paragraph describes third-party consultants and providers as part of the company's cybersecurity program; per Rule 3, third parties hired to serve the company are RMP, not TP. No domain terms pass the ERM test, no firm-specific facts (providers are unnamed), and no verifiable claims, leaving this at Level 1.

thinking:
Classify this paragraph.

This is about third-party cybersecurity partners/consultants as part of the company's risk management. The central topic is about third parties serving the company (assessors, consultants) → per Rule 3, third parties hired to serve the company → RMP.

Specificity: No domain terms beyond generic "cyber risk advisory." No firm-specific facts (no named roles, no named firms, no specific committees). "Industry recognized cybersecurity providers" is unnamed. This is generic boilerplate.


fact: insider threat controls to identify, assess, and address potential risks from within

fact: controls and tools to alert on suspicious or unusual insider activity

fact: controls to prevent data loss and external sharing of company information (DLP)

reasoning: The paragraph describes specific cybersecurity program activities — insider threat detection, monitoring for suspicious insider activity, and data loss prevention — making it RMP. Insider threat programs and DLP controls are cybersecurity domain concepts that pass the ERM test, but no firm-specific facts or verifiable claims are present, so it stays at Level 2.

thinking:
Classify this paragraph.

Content: Describes insider threat controls - identifying, assessing, addressing internal risks, tools for alerting on suspicious activity, data loss prevention, external sharing controls.

Category: This is about what the cybersecurity program does - insider threat controls, DLP, monitoring. → RMP

Specificity: Let me check for domain terms. "Insider threat controls" - this is a cybersecurity domain concept. "Data loss prevention" (implied by "prevent data loss and external sharing") - DLP is a domain term. "Insider activity" monitoring. These pass the ERM test - an ERM professional wouldn't naturally discuss insider threat programs or data loss prevention controls.

The language uses domain-specific terminology like insider threat detection and DLP concepts, though it avoids naming specific tools or roles, so this lands at Level 2.


content_category: Incident Disclosure

fact: DSCP (named internal program for incident reporting)

fact: Form 8-K filed on February 29, 2024

fact: MOVEit Cybersecurity Incident (named real-world incident)

fact: PBI (named third-party firm involved in investigation)

fact: Approximately 2.5 million to 2.7 million policyholders/customers affected

fact: Social security numbers exposed to threat actor

reasoning: The paragraph primarily describes a real cybersecurity incident (MOVEit), including investigation details, scope, and response, making it Incident Disclosure under Rule 4 since the incident frame dominates over the closing materiality assessment. Specificity is Level 4 due to multiple externally verifiable facts: a specific filing date (February 29, 2024), a named third-party firm (PBI), a named real-world vulnerability (MOVEit), and a quantified impact (2.5-2.7 million affected individuals).

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses:
1. Procedures in the DSCP for reporting/responding to incidents
2. A specific incident - MOVEit Cybersecurity Incident disclosed in Form 8-K on February 29, 2024
3. Investigation with PBI
4. Specific numbers: approximately 2.5-2.7 million policyholders affected
5. Social security numbers exposed
6. No material impact on information systems or business operations
7. Materiality assessment conclusion

This is a mixed paragraph. It describes a real incident (what happened, scope, investigation) AND concludes with a materiality assessment.

The incident details clearly dominate here—the MOVEit breach, the investigation scope, and the number of affected policyholders are the main focus, with the materiality conclusion serving as a brief wrap-up. So this falls under the Incident Disclosure category. I notice "DSCP" is a named internal reference worth flagging.

Looking at specificity, I've got multiple concrete anchors: the exact filing date of February 29, 2024, the named MOVEit incident, PBI as the firm, a quantified range of 2.5 to 2.7 million affected individuals, and specific data types like social security numbers. That's clearly Level 4 specificity—multiple verifiable facts throughout.


reasoning: The paragraph describes third-party consultants and external service providers hired to support the company's own cybersecurity program (risk assessment, security controls, incident response), making this RMP per Rule 3 rather than TP. The language is entirely generic—'security controls,' 'risk assessment process,' 'external service providers'—all terms an ERM professional would naturally use, with no named entities, domain-specific tools, or firm-specific details.

thinking:
Classify this paragraph.

This describes third-party involvement in the company's cybersecurity program - a third-party consultant overseeing risk assessment, security controls, incident response, and external service providers supporting security measures.

Category: This is about third parties hired to serve the company (assessors, consultants) → per Rule 3, this is RMP, not TP. Third parties hired to serve the company = RMP.

Specificity: Let me check for specific facts.
- "third-party security expert consultant" - generic, unnamed
- "risk assessment process" - generic ERM language

- "security controls" - domain term? An ERM professional might use this. Borderline but fairly generic.
- "maintenance of security controls" - slightly domain-adapted
- "coordination of responses to cybersecurity incidents" - generic
- "external service providers" - generic

The language is quite generic overall, with "security controls" being the only borderline term that an ERM professional might use. I'll classify this as Level 1.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing processes to identify, assess, and manage cybersecurity risks, making it RMP. The language is entirely generic ERM boilerplate ('identify, assess and manage material risks') with no cybersecurity domain terms passing the ERM test; the data type enumeration (clinical trial data, IP) describes business context rather than security expertise.

thinking:
Classify this paragraph.

Content: Describes information security processes to identify, assess, and manage material risks from cybersecurity threats. Lists what's protected (networks, services, hardware, software, data types).

Category: This is about what the cybersecurity program does - "What does the cybersecurity program do?" → RMP. It's describing processes to identify, assess, and manage risks.

Specificity: Let me scan for facts.
- "identify, assess and manage material risks" → generic ERM language, L1
- "third party hosted services" → generic
- "clinical trial data" → this is somewhat firm-specific (indicates a biotech/pharma company) but it's really just describing data types they protect.

Now I'm checking whether "clinical trial data" qualifies as a domain term or firm-specific cybersecurity fact. It's not a cybersecurity domain term, and while it hints at the company's industry, it's just listing what data types they protect rather than revealing anything cybersecurity-specific. The whole paragraph reads like standard boilerplate language about protecting various assets. There are no domain terms that meet the ERM threshold, no firm-specific cybersecurity facts, and nothing verifiable here. This is Level 1 - Generic Boilerplate.


reasoning: The paragraph's central topic is how the company manages cybersecurity risks from third parties (vendors, CROs, service providers), making Third-Party Risk the clear category. The language is entirely generic ('comprehensive, risk-based approach to identifying and overseeing cybersecurity risks') with no cybersecurity domain terms passing the ERM test, no firm-specific facts, and no verifiable claims, keeping it at Level 1.

thinking:
Classify this paragraph.

Content: About managing third-party cybersecurity risks - vendors, CROs, service providers. Central topic is third-party risk management.

Category: Third-Party Risk (central topic is how third-party cyber risks are managed)

Specificity: "CROs" (Contract Research Organizations) - this is somewhat specific to pharma/biotech but is it a domain term? It's more of an industry term than a cybersecurity domain term. The paragraph says "comprehensive, risk-based approach to identifying and overseeing cybersecurity risks" - generic. No domain-specific cybersecurity terms that pass the ERM test. No firm-specific facts. No verifiable claims.

So "CROs" is industry-specific rather than cybersecurity-specific, and the rest relies on generic language about third-party risk management. This falls into Level 1 - Generic Boilerplate.


content_category: Board Governance

reasoning: The paragraph describes the Board's and Audit Committee's oversight of cybersecurity risks and how information flows to the board via the CFO — classic Board Governance. No domain-specific terminology (all language passes the ERM test as generic), no firm-specific facts (Audit Committee and CFO are present at every public company), and no verifiable claims, yielding Level 1.

thinking:
Classify this paragraph.

Category: This describes board/committee oversight of cybersecurity. The Audit Committee oversees cyber risks, receives updates from CFO. This is Board Governance.

Specific facts:
- "Audit Committee" - every company has this, NOT firm-specific
- "Chief Financial Officer" / "CFO" - generic role, not firm-specific (not a security-specific VP+ role)
- "enterprise risk management program" - L1 term
- "identify, prioritize, assess, manage, and mitigate" - generic ERM language

- No domain-specific terminology or firm-specific details present. No verifiable claims that would elevate this beyond Level 1.


reasoning: The paragraph's central topic is overseeing and managing risks from third-party service providers, making TP the clear category. The language is entirely generic — 'security assessments,' 'ongoing monitoring,' 'compliance with our cybersecurity standards' — all terms any ERM professional could produce without cybersecurity domain knowledge, yielding Level 1.

thinking:
Classify this paragraph.

Category: Third-Party Risk - central topic is managing third-party cyber risks.

Specificity: Let me check for specific facts.
- "security assessments of all third-party providers" - this is generic process description
- "ongoing monitoring" - generic
- "compliance with our cybersecurity standards" - generic

No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims. This is generic boilerplate about third-party risk management.

Wait - "security assessments" - would a non-security ERM professional use this? Yes, they would say "security assessments" in many contexts.

"Data breaches" is common language too. Nothing here passes the ERM test. Level 1.


reasoning: This paragraph is pure speculative risk language ('may be unable to', 'could expose', 'could have a material adverse effect') describing hypothetical consequences of breaches without disclosing any actual cybersecurity measures, processes, or incidents. It reads as boilerplate risk factor language found in Item 1A, not substantive Item 1C disclosure. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: Speculative risk language, no actual incident, no measures described.


fact: threat intelligence analysis

fact: system scans

specificity_confidence: medium

reasoning: The paragraph primarily describes cybersecurity program activities—employee training, system scans, and threat intelligence—with third-party contractual requirements as a secondary topic (one sentence), so RMP wins over TP per Rule 3. 'Threat intelligence analysis' and 'system scans' pass the ERM test as cybersecurity-specific practices, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: employee training program (annual), managed service providers, third-party IT/cybersecurity providers for system scans and threat intelligence, contractual requirements for third parties.

Category: This touches RMP (training, system scans, threat intelligence), and TP (contractual requirements for third parties). The majority of content is about the program activities - training, leveraging MSPs, system scans, threat intelligence. The third-party contractual requirements are one sentence. RMP wins.

Wait - let me reconsider. There's a mix. The paragraph has three sentences: (1) employee training - RMP, (2) leveraging third-party providers for scans/threat intel - RMP (third parties hired to serve the company), (3) contractual requirements on third-party providers - TP.

By Rule 3, third parties hired to serve the company fall under RMP, while contractual requirements imposed on vendors are TP. Since the contractual piece is just one of three sentences and not the central focus, RMP is the stronger category. Looking at specificity, "threat intelligence analysis" and "system scans" are solid domain terms that pass the ERM test, though "managed service providers" is more generic IT terminology and "annual training" is fairly standard language. The contractual requirements language is also generic. So I'm seeing Level 2 domain specificity overall.


reasoning: The paragraph describes how the Audit Committee reports cybersecurity risk information to the Board and the Board's annual review cadence — squarely about board oversight structure. All elements (Audit Committee, Board, 'at least annually') are generic governance constructs with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes Audit Committee reporting to Board, Board review of material cyber risks annually. This is about oversight structure → Board Governance.

Specific facts:
- "Audit Committee" — generic, every company has one → NOT firm-specific
- "Board of Directors" — generic
- "at least annually" — generic cadence
- "prevent, detect and mitigate" — generic process language, not domain-specific

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

Level 1.


reasoning: The paragraph describes how management is organized to handle cybersecurity—CEO direction, MIS consultant and MIS supervisor roles, and reporting lines—making it primarily about management's organizational role (MR). No domain terms pass the ERM test (prevention, detection, mitigation, remediation are generic risk language), no VP-or-above security titles are present (MIS consultant and MIS supervisor are below VP level without a security qualifier), and no verifiable claims exist, leaving specificity at Level 1.

thinking:
Classify this paragraph.

Content: Describes management roles (CEO, MIS consultant, MIS supervisor) and their responsibilities regarding cybersecurity. The paragraph is about who manages cybersecurity and reporting lines.

Category: Management Role - it's about how management is organized, roles, responsibilities, reporting lines.

Specificity: Let me check for specific facts.
- "CEO" - generic role, every company has one
- "MIS consultant" - this is a somewhat unusual role title but not VP+ level
- "MIS supervisor" - again, below VP level, no security qualifier

- The paragraph uses generic process terms like prevention, detection, mitigation, and remediation that any ERM professional would reference, with no domain-specific language or firm-specific details. The IT titles mentioned are below VP level without security qualifiers, so they don't meet the threshold for firm-specific information. There are no named individuals or verifiable claims here.

This is Level 1 - Generic Boilerplate.


reasoning: The paragraph's central assertion is that no cybersecurity incidents have materially affected business strategy, results of operations, or financial condition — a backward-looking materiality assessment triggering SI under Rule 5. Specificity remains Level 1: 'Business Continuity and Incident Response programs' fail the ERM test (generic terms), the negative materiality assertion is not externally verifiable, and the cross-reference to Item 1A adds no substantive content.

thinking:
Let me analyze this paragraph.

Content: States no material incidents, mentions business continuity and incident response programs, cross-references Item 1A.

Category: The key sentence is "we have not experienced any cybersecurity incidents that have been determined to affect us materially, our business strategy, results of operations, or financial condition" — this is a materiality assessment (SI per Rule 5). The rest is a cross-reference and brief mention of programs.

Specificity: "Have not experienced any material cybersecurity incidents" → SI (negative assertion per Rule 5). But per specificity rules, negative self-assertions are NOT externally verifiable.

The references to business continuity and incident response programs are just generic boilerplate without any firm-specific details or verifiable facts, so they don't meet the ERM test. The cross-reference to Item 1A is just a pointer to other content. This lands at Level 1.


fact: nation-state threat actor

fact: rotation of credentials

fact: Azure environment

fact: February and April 2025 Microsoft notification of unauthorized activity

fact: Microsoft notified the Company about unauthorized activity

reasoning: The paragraph's framing question is whether cybersecurity has materially affected the business—it delivers the SEC-required materiality assessment ('not aware of any risks...that have materially affected or are reasonably likely to materially affect'), making SI the primary category, with the incident introduced subordinately via 'For example.' Specificity reaches Level 4 due to verifiable facts: specific dates (February and April 2025), named firm (Microsoft), and named system (Azure) tied to a real incident that could be independently confirmed.

thinking:
Let me analyze this paragraph carefully.

Content category: This paragraph contains multiple elements:
1. Generic cyber resilience language
2. A materiality assessment ("not aware of any risks...that have materially affected or are reasonably likely to materially affect")
3. An actual incident disclosure (February and April 2025, Microsoft notification, nation-state threat actor, Azure environment)

The incident disclosure is specific and detailed - it describes a real event with dates, what happened, and response. The materiality assessment is also present. Per Rule 4, mixed with incident frame dominant → ID. But actually, the paragraph seems split. Let me look at text volume.

The first half is about materiality and strategy integration, while the second half describes an actual incident with substantial detail and specific dates, actors, and response measures. The incident frame appears dominant in the latter portion, though the materiality assessment is also a central element. Looking more carefully, the paragraph seems to be primarily making a materiality assessment and then providing the incident as context or supporting example.

The "for example" framing suggests the incident illustrates the risk rather than being the primary disclosure. The materiality statement says "not aware of any risks...that have materially affected," then introduces the incident as an example of the type of risk, implicitly suggesting that even this incident didn't materially affect them. Given that the materiality assessment frames the paragraph and the incident serves as supporting context, SI seems appropriate here, though the incident description is quite detailed and takes up significant text. The paragraph structure moves from generic intro to cyber resilience measures to the materiality assessment, then a hypothetical risk, and finally a substantial incident disclosure with specific details.

But I'm second-guessing myself—the incident is a real disclosure, not just a hypothetical. The "for example" framing doesn't change that it's disclosing actual unauthorized activity in their Azure environment by a suspected nation-state actor. Looking at text volume, roughly half the paragraph is SI/generic and half is ID. When genuinely split like this, the category with the most text should win. Let me count more carefully to determine whether ID should take precedence here. the incident as supporting detail. Looking at the specificity markers—nation-state threat actor, incident response plan, enhanced credential rotation, Azure environment, the February and April 2025 dates, and Microsoft as the notifier—these are concrete, verifiable details tied to an actual event. The specific dates and named entities (Microsoft, Azure) make this clearly Level 4 material.


fact: Incident occurred in 2023

fact: Sphere 3D Corp. named as the company involved in the email exchange

fact: 26 BTC transferred to threat actor's wallet

fact: Value of approximately $560,000 at the time

fact: Gryphon engaged with US Federal law enforcement

fact: Business email compromise attack impersonating Sphere 3D CFO

reasoning: This paragraph describes an actual cybersecurity incident — a business email compromise resulting in theft of cryptocurrency — with timeline, scope, and remediation details, making it clearly Incident Disclosure. Multiple verifiable facts elevate to Level 4: 26 BTC stolen, ~$560K value, named third parties (Sphere 3D Corp., Gryphon), and engagement with US Federal law enforcement.

thinking:
Incident disclosure - describes a real cybersecurity event.

Specific facts: "2023" date, "Sphere 3D Corp." named firm, "26 BTC" quantified, "approximately $560,000" quantified, "Gryphon" named firm, "US Federal law enforcement" specific entity.


reasoning: The paragraph's core purpose is a materiality assessment: stating that no cybersecurity incidents materially affected the company's business strategy, results of operations, or financial condition during fiscal year 2025 — this is a backward-looking SI conclusion per Rule 5. Specificity remains Level 1 because the negative materiality assertion is not externally verifiable, the fiscal year reference is a reporting period rather than a cybersecurity fact, and no domain terms passing the ERM test are present.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. "Despite our efforts... breaches in data security and lapses in data privacy, which occur from time to time" - acknowledges past minor incidents
2. "During fiscal year 2025, the Company did not experience any cybersecurity incidents that have materially affected or are reasonably likely to materially affect the Company, including its business strategy, results of operations, cash flow or financial condition."

This is a materiality assessment - stating a conclusion about whether cybersecurity has affected business outcomes. Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI.

The language here is too generic to be verifiable—"data privacy," "data security," and "cybersecurity incidents" are all boilerplate terms without domain-specific details or firm-specific facts that would pass the ERM test. This is Level 1 generic boilerplate.


fact: CIO holds primary responsibility for the cybersecurity program

fact: More than 20 years of experience in information and operational technology

reasoning: The paragraph centers on the CIO's role, qualifications, and responsibility for the cybersecurity program, making it MR. The person-removal test leaves only generic language about evaluating risk postures and safeguarding assets. Specificity reaches Level 4 because 'more than 20 years of experience' is a verifiable lower bound.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CIO's role, qualifications, and responsibility for the cybersecurity program. It also mentions the IT team's activities. Using the person-removal test: remove "CIO, with more than 20 years of experience" - what remains? "The IT team continuously evaluates risk postures and safeguards critical cyber assets. Their efforts are designed to provide resilience against both common and sophisticated cyber threats." This is fairly generic. But the primary focus is on the CIO's role and responsibility - MR.

Specific facts:
- CIO (named role, VP-level equivalent) → Firm-Specific

- The experience metric is quantified and verifiable, though it's a lower bound rather than exact
- IT team reference lacks sufficient firm-specific detail

Specificity: Level 4 due to the measurable experience threshold.


reasoning: The entire paragraph is about assessing third-party vendors' data protection practices, making vendor oversight the central topic → Third-Party Risk. The language is entirely generic ('formal, documented process,' 'assess data protection practices,' 'sensitive information') — any ERM professional could write this without cybersecurity domain knowledge, and there are no firm-specific or verifiable facts.

thinking:
Classify this paragraph.

Content: Describes a process for assessing third-party vendors' data protection practices.

Category: This is about vendor oversight - assessing third-party vendors. Is TP the central topic? The entire paragraph is about assessing third-party vendors. Yes → Third-Party Risk.

Specificity: "formal, documented process to assess data protection practices of third-party vendors" - this is generic. No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims.

So this lands at Level 1 - it's too generic and lacks the specificity needed for higher classification.


reasoning: The paragraph describes how the Board delegates cybersecurity oversight to the Audit Committee, directly answering how the board oversees cybersecurity → Board Governance. No domain terminology, firm-specific facts, or verifiable claims are present; 'Audit Committee' is a generic governance body every public company has, and the language ('evaluates our cybersecurity program, risks and corresponding mitigations') is standard ERM vocabulary.

thinking:
Classify this paragraph.

Category: Board delegates oversight to Audit Committee - this is about board/committee oversight structure → Board Governance.

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

Specificity: Level 1 - Generic Boilerplate.


fact: Email spoofing incident occurred in May 2014

fact: Scammer pretended to be one of the Company's subsidiaries

fact: No money was sent to the scammer's bank account (outcome)

reasoning: Describes a real cybersecurity incident (email spoofing in May 2014) with specific timeline, nature, and outcome, making it Incident Disclosure. The specific date 'May 2014' is a verifiable claim tied to a real event, elevating to Quantified-Verifiable.

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


reasoning: The paragraph describes the information flow chain from monitoring through management to the Audit Committee and Board, with quarterly briefings — this is oversight structure, defaulting to BG per Rule 1. No domain terms pass the ERM test (monitoring, cybersecurity team, incident notification are all generic), Audit Committee is not firm-specific, and 'at least quarterly' is a generic cadence, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes monitoring (third-party + internal team), notification chain (management → Audit Committee → Board), and quarterly briefings.

Category: This describes the oversight/information flow chain from monitoring up to the Board. The governance chain (Board → Committee → Management) is described. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. The paragraph answers "how does the board oversee cybersecurity?" — information flows to the board via quarterly briefings, Audit Committee notified of material breaches. BG.

Specific facts:

Looking at the language used here, everything reads as boilerplate. "Continuously monitored" is vague, the mention of third-party providers and internal teams is standard across most companies, and the governance structure with an Audit Committee and Board of Directors is generic. The quarterly cadence and "promptly notified" language are also typical corporate language. The paragraph doesn't include any specific domain terminology that would distinguish this company's cybersecurity approach — it's all standard governance language without concrete details about what's actually being monitored or how.


fact: May 2025 - specific date of incident detection

fact: Unauthorized changes to domain, DNS, and email configurations

fact: Administrative credentials retained by a former employee as attack vector

fact: Contained on the same day it was discovered

fact: Independent external assessment conducted

reasoning: The paragraph describes a real cybersecurity incident — unauthorized changes via former employee credentials in May 2025 — with timeline, scope, impact, and remediation details, clearly answering 'what happened?' → Incident Disclosure. 'May 2025' is a specific date tied to a real event that could be independently verified (e.g., via domain registration records or news), elevating to Level 4.

thinking:
Incident Disclosure - describes a real event with timeline, scope, and remediation.

Specific facts: "May 2025" specific date, "domain, DNS, and email configurations" domain terms, "former employee" context, "same day" containment timeline.

Level 4: "May 2025" is a specific date tied to a real incident, verifiable.


reasoning: The paragraph primarily answers how the board oversees cybersecurity — the board reviews risk factors including cybersecurity threats prior to SEC filings — making it Board Governance despite the SPAC context with no internal personnel. No domain terms, firm-specific facts, or verifiable claims elevate specificity above Level 1; 'board of directors' is generic governance language every company uses.

thinking:
SPAC with no operations, relying entirely on third parties. But it does describe board oversight of cybersecurity risk review before SEC filings.

Category: This is a SPAC with no personnel or processes. The paragraph describes board oversight (reviewing risk factors before SEC filings). It's primarily about board governance - how the board oversees cybersecurity. BG.

Wait - Rule 6 says SPACs with no program → N/O. But this paragraph does describe board activity (reviewing risk factors before filings). Let me think...

The paragraph says "we have no personnel or processes of our own" - this is a SPAC.

The board reviewing risk factors before SEC filings is minimal but arguably substantive governance disclosure, so BG seems more appropriate than N/O here. The specificity is generic - just "board of directors" with no named roles or firm-specific details, so that's Level 1.


reasoning: This paragraph describes general regulatory requirements (SEC rules, banking oversight) and provides a cross-reference to another section. It does not disclose any substantive cybersecurity measures, governance, or program details specific to the company. The SEC rule effective date is a public regulatory fact, not a company-specific cybersecurity disclosure.

thinking: Regulatory context and cross-reference, no substantive cybersecurity disclosure.


fact: CTO role in cybersecurity management

fact: CISO role in cybersecurity management

reasoning: The paragraph describes qualifications and experience of management personnel (internal working group, CTO, CISO), making it about who is responsible and what qualifies them → MR. CTO and CISO are firm-specific VP+ roles, but certifications are referenced generically ('certifications relevant to…') without naming any specific one, so specificity stops at Level 3.

thinking:
Classify this paragraph.

Content: Describes qualifications of internal working group members, CTO, and CISO - their experience, education, certifications. This is about WHO is responsible and what qualifies them → MR.

Specific facts:
- "internal working group" - named team (firm-specific? It's a generic name but refers to a specific team)
- CTO - named role (firm-specific, VP+ level)
- CISO - named role (firm-specific, VP+ level)
- "multiple decades of experience" - soft number, not verifiable
- "certifications relevant to management of cybersecurity" - no specific certifications named

- Specificity: Firm-Specific (Level 3) due to CTO and CISO roles being named, though the working group uses generic terminology and the experience metrics are vague without specific certifications listed.


reasoning: The paragraph opens with a negative assertion about incident history ('have not experienced any cybersecurity incidents to date'), which per Rule 5 is a backward-looking assessment of cybersecurity's impact on the business → SI. The remainder is generic speculative risk language ('could potentially lead to…'). No domain terms pass the ERM test, no firm-specific facts, and the negative self-assertion is not externally verifiable, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: States no incidents to date, acknowledges lack of formalized framework, then speculates about potential impacts.

Category: The first sentence is a negative assertion about incidents. The rest is speculative risk language. The materiality rule: "Have not experienced any material cybersecurity incidents" → SI. But this says "have not experienced any cybersecurity incidents to date" which is a backward-looking assessment. Then the rest is speculation ("could potentially lead to..."). The SI materiality rule says negative assertions like "Have not experienced any material cybersecurity incidents" → SI. This is similar. But wait - "could potentially lead to" is speculation, not an assessment. The first sentence is the assessment part.

The opening statement about no incidents follows the same pattern as the SI rule for negative self-assertions, making this SI. The acknowledgment of lacking a formalized framework adds a self-assessment element, but the speculative risk language that follows doesn't change the core categorization. The negative assertion about incidents is what drives the SI classification here.

Looking at specificity, the language is entirely generic—"formalized cybersecurity framework" and the incident statement are things any organization could say without revealing anything firm-specific. There are no domain-specific facts or externally verifiable details. This is Level 1 boilerplate.


fact: Vice President of Information Technology Services leads the cybersecurity program

reasoning: The paragraph primarily answers how the board oversees cybersecurity — audit committee oversight, board-level risk review, and information flow from senior leadership — making it Board Governance. The VP of Information Technology Services is a VP-level IT role qualifying as firm-specific, elevating specificity to Level 3.

thinking:
Classify this paragraph.

Category: This describes board/committee oversight of cybersecurity. The audit committee retains oversight, board oversees management's assessments, updates flow to audit committee and board. This is Board Governance.

But it also mentions "vice president of information technology services" - that's a named role. And "senior leadership" provides updates. The primary question answered is "How does the board oversee cybersecurity?" → BG.

Specific facts:
- "vice president of information technology services" — named role (VP-level IT role → firm-specific)
- "Audit Committee" — generic, every company has one → not firm-specific

- The VP of IT Services is a VP-level title whose portfolio includes IT, making it firm-specific per the rules. This lands it at Level 3.


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

reasoning: The paragraph describes the purpose and scope of the cybersecurity program (evaluating and improving security posture), answering 'what does the program do?' → RMP. The explicit invocation of the CIA triad (confidentiality, integrity, availability) is a domain-specific information security concept that passes the ERM test, elevating to Level 2, though the rest is generic boilerplate.

thinking:
Classify this paragraph.

Content: Generic statement about cybersecurity risk management being part of information security program, mentions CIA triad (confidentiality, integrity, availability).

Category: This is about what the cybersecurity program does at a high level → RMP. But it's extremely generic.

Specificity: "confidentiality, integrity, and availability" - this is the CIA triad, a foundational infosec concept. Does it pass the ERM test? An ERM professional wouldn't naturally use "confidentiality, integrity, and availability" as a specific grouping - this is the CIA triad from information security.

The CIA triad is borderline—it's become mainstream enough in risk management that some professionals would use it, but it's still fundamentally an infosec concept. I'll classify this as Level 2.


reasoning: The paragraph centers on the Board of Directors' role in developing and implementing a cybersecurity program post-acquisition, making BG the best fit despite the program not yet existing. No domain-specific terminology, firm-specific facts, or verifiable claims appear—language like 'cybersecurity and risk assessment policies and procedures' and 'measures to reduce these risks' is entirely generic ERM vocabulary, keeping specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: This is about a company that recently went through an acquisition, reshaped its board, and currently lacks formal cybersecurity policies. They plan to have the board develop a cybersecurity program. There's also a note about SEC transition guidance.

Category: This is primarily about the absence of a cybersecurity program and future plans. The board is mentioned as the entity that will develop the program. But the core message is about the current state - no formal policies, plans to implement them. This feels like a mix of BG (board will develop program) and N/O (no substantive program exists yet).

Per Rule 6: "SPACs and no-operations companies with no program → N/O." This company appears to be early-stage post-acquisition with no formal cybersecurity program.

But they do mention some investment in measures, so I need to reconsider whether there's enough substance here. The paragraph describes some risk reduction efforts and board-led implementation plans, but the dominant theme is still the absence of formal policies. The SI materiality rule doesn't really apply here since this isn't about anticipated data collection. Looking at the primary actor and focus, the board governance angle is strong—they're reshaping the board and tasking it with developing the program—but there's also a compelling case for N/O given the lack of an actual program in place.

The core question is how the board oversees cybersecurity, and the honest answer is it doesn't yet. They're in the implementation phase. So I'm leaning toward Board Governance as the category, though it's admittedly a weak fit. Now scanning for specificity: the acquisition reference is vague, the board and fiscal year are generic context, the SEC guidance is a standard citation, and there are no domain-specific terms, named roles, or frameworks mentioned. This lands squarely at Level 1—Generic Boilerplate.


reasoning: The paragraph's primary purpose is a backward-looking materiality assessment ('have not experienced a cybersecurity threat or incident that materially affected our business strategy, results of operations, or financial condition'), which is SI per Rule 5. The remainder is a cross-reference to Item 1A and generic forward-looking disclaimer. No domain terms, firm-specific facts, or verifiable claims are present—the negative materiality assertion is a self-reported claim about absence and not externally verifiable.

thinking:
Materiality assessment + cross-reference.

"have not...experienced a cybersecurity threat or incident that materially affected our business strategy, results of operations, or financial condition" → SI (backward-looking materiality assessment per Rule 5)

The cross-reference is secondary.

Specificity: "have not experienced any material cybersecurity incidents" → negative self-assertion, NOT externally verifiable. No domain terms, no firm-specific facts beyond the materiality statement itself. This is generic boilerplate language.

Wait - the materiality conclusion is standard language.

This disclosure lacks any concrete details—no specific incidents mentioned, no named roles, no verifiable facts. It's purely generic language at Level 1.


reasoning: This paragraph is a cross-reference directing readers to Item 1A risk factors, with no substantive cybersecurity disclosure. No specific facts elevate specificity above Level 1.


reasoning: The paragraph is introductory framing about the importance of cybersecurity and the existence of threats, but does not answer any of the six substantive questions — no program activities, governance structure, management roles, or materiality assessment are described. The 'could materially adversely affect' language is generic speculation per Rule 5 (not SI), and no actual cybersecurity measures are disclosed (Rule 6: pure framing without measures → N/O). N/O paragraphs always receive Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Discusses cybersecurity threats (ransomware, DoS), mentions customers/suppliers face similar threats, says incident "could materially adversely affect" business. States cybersecurity is critical and they need to expend resources.

Category: The "could materially adversely affect" is speculation per Rule 5 (NOT SI). The paragraph is general framing about threats. No specific program activities, no board governance, no management roles. It's introductory/framing language. But it does mention specific threat types (ransomware, denial-of-service) which are domain terms.

This is mostly general framing about why cybersecurity matters and the threats they face, without describing any actual measures or programs they've implemented. The specific threat types mentioned don't change the fact that there's no substantive disclosure of governance, management, or what their cybersecurity program actually does—it's borderline N/O territory.


fact: penetration testing (internal and external)

fact: vulnerability scanning

reasoning: The paragraph describes program activities—employee training, penetration testing, vulnerability scanning, and remediation—answering 'what does the cybersecurity program do?' → RMP. Penetration testing and vulnerability scanning are domain-specific security practices that pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts push higher.

thinking:
Classify this paragraph.

Content: Training, penetration testing, vulnerability scanning, remediation process.

Category: RMP - describes what the cybersecurity program does (training, testing, scanning, remediation).

Specific facts:
- "penetration testing" - domain term
- "vulnerability scanning" - domain term
- "onboarding and at least annually thereafter" - cadence for training
- Third-party providers mentioned but generic

Specificity: Domain-Adapted (Level 2) - penetration testing and vulnerability scanning are domain terms passing ERM test.


fact: ransomware groups that steal data, encrypt systems, and demand a payment

reasoning: The paragraph opens with a backward-looking materiality conclusion ('no cybersecurity incidents have materially impacted the Company, including the Company's business strategy, results of operations, or financial conditions'), which is a classic SI assessment per Rule 5. The remainder is generic risk speculation. Specificity reaches Level 2 due to the mention of 'ransomware' as a specific threat type, which passes the ERM test, though the rest of the paragraph is boilerplate risk language.

thinking:
Let me analyze this paragraph.

Content: Starts with "To date, no cybersecurity incidents have materially impacted the Company, including the Company's business strategy, results of operations, or financial conditions." This is a materiality assessment → SI per Rule 5.

Then it discusses generic risks, third-party reliance, and limitations of controls. This is speculative/disclaimery language.

The opening sentence is a backward-looking materiality conclusion → SI. The rest is generic risk language. The SI assessment is the lead and frames the paragraph.

Specificity: "no cybersecurity incidents have materially impacted" → negative self-assertion, NOT externally verifiable.

Now I'm looking at the threat landscape discussion. Ransomware appears as a specific threat type in the ERM framework, and the language around "encrypt systems" and "critical information systems infrastructure assets" shows some domain-specific knowledge, so that's Level 2. But most of the surrounding language about security controls and risk-based approaches is still generic boilerplate, so this remains SI category with Level 2 specificity.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not...materially affected') and a forward-looking SEC 106(b)(2) assessment ('reasonably likely to materially affect'), making it Strategy Integration per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present — the negative self-assertion about no material incidents is not externally verifiable, and the cross-reference to Item 1A is boilerplate.

thinking: SI materiality assessment paragraph.


fact: Cyber Risk Committee comprised of CIO and other executive officers

fact: CIO role responsible for communicating significant IT activities

fact: virtual Chief Information Security Officer (third-party)

fact: CIO has more than twenty years of experience as an IT professional

fact: CIO since 2007

reasoning: The paragraph primarily describes management's organizational structure for cybersecurity: the Cyber Risk Committee, CIO's responsibilities and qualifications, and the virtual CISO engagement — answering 'how is management organized to handle cybersecurity?' rather than board oversight (no board exists). Specificity reaches Level 4 via 'more than twenty years of experience' (verifiable lower bound) and 'CIO since 2007' (specific verifiable date).

thinking:
Let me analyze this paragraph.

Content: No board/committees, relies on Manager's oversight, Cyber Risk Committee (CIO + executive officers), CIO role and experience, virtual CISO engagement.

Category: This describes governance structure (no board) and management organization. The paragraph covers: no board → management oversight structure → Cyber Risk Committee → CIO role/qualifications → virtual CISO. The primary question answered is about how management is organized to handle cybersecurity. BG vs MR: There's no board, so the governance chain goes through management. The paragraph is primarily about management's organizational role - CIO responsibilities, qualifications, committee membership. → MR.

The facts here are quite specific: the Cyber Risk Committee and CIO role are named positions within the firm, the CIO has more than twenty years of experience which gives us a verifiable lower bound, and there's a specific date of 2007 when the CIO took the role. The virtual CISO is also a named third-party role. These concrete details and dates push this to Level 4 specificity.


fact: Information Technology Committee reviews cybersecurity controls

fact: Chief Information Security Officer (CISO)

fact: Penetration test results reviewed by committee

fact: Cyberattacks, unauthorized access

reasoning: The paragraph describes how the Board and its Information Technology Committee oversee cybersecurity risk, including briefing cadence and information flow from the CISO—classic Board Governance. The named Information Technology Committee and CISO role are firm-specific facts elevating to Level 3; domain terms like penetration testing are present but no externally verifiable claims push it to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes board oversight structure and how information flows to the board. The Board reviews risks, the IT Committee reviews controls, and the CISO reports to them. This is primarily about the governance/oversight structure. Even though it mentions what the IT Committee reviews (cybersecurity controls), the frame is oversight. BG.

Specific facts:
- "Information Technology Committee" - named committee (firm-specific)
- "CISO" - named role (firm-specific)
- "penetration test results" - domain term

- "at least quarterly" briefings and "annual cybersecurity update to the full Board" establish reporting cadence but lack specific dates or numbers

Specificity: The named committee and role are firm-specific, and while the reporting frequency is mentioned, there are no verifiable facts like specific names, numbers, or certifications. Level 3.


fact: Ransomware attack in May 2020

fact: Ransomware attack (specific threat type)

fact: Cybercriminal removed a copy of a subset of data from self-hosted environment

reasoning: The paragraph describes a real cybersecurity incident — the May 2020 ransomware attack — including its nature (data exfiltration from self-hosted environment), ongoing legal consequences, and cross-references to financial statement notes, making it Incident Disclosure. The specific date 'May 2020' is an externally verifiable fact tied to a well-known public incident, elevating specificity to Level 4.

thinking:
Classifying this paragraph about Blackbaud's ransomware incident.

Category: This describes a real cybersecurity incident (May 2020 ransomware attack), its nature, and ongoing consequences. Primary question answered: "What happened?" → Incident Disclosure.

Specificity: Contains specific verifiable facts - "May 2020" date, "ransomware attack", data removal from "self-hosted environment", reference to Note 11. Named specific event details.


reasoning: The paragraph is headed 'Management's Role' and describes management's responsibilities (overseeing risk, resource allocation, evaluating effectiveness, ensuring alignment) in coordination with an external IT specialist; applying the person-removal test, no substantive program description survives — it collapses to generic oversight duties, so MR. No domain terms pass the ERM test ('incident response planning,' 'business continuity,' and 'risk management framework' are all commonly-confused generic ERM language), and there are no firm-specific facts or verifiable claims, yielding Level 1.

thinking:
Classify this paragraph.

Category: This describes management's role and responsibilities. Let me apply the person-removal test: remove all person-specific content - no names, no specific titles, no qualifications. What remains? "overseeing cybersecurity risk," "external IT specialist," "resource allocation, incident response planning, strategic integration," "evaluates effectiveness periodically," "alignment with business continuity." These are generic process descriptions but framed around management's organizational responsibility. The paragraph collapses to generic oversight language without specific program activities. But actually, the content describes what management DOES (oversees, evaluates, ensures alignment) - these are responsibilities.

No specific program activities survive the person-removal test. This is MR - the paragraph focuses on management's organizational role and how they coordinate with external IT, but doesn't describe concrete program activities. For specificity, I'm scanning for firm-specific facts: "external IT specialist" suggests they outsource IT, while "incident response planning," "business continuity," and "resource allocation" are all standard L1 concepts. The outsourcing detail is somewhat firm-specific, but it's still just describing a common practice rather than revealing unique operational details.

Nothing here passes beyond generic boilerplate - no domain terms survive the ERM test, and the commonly-confused items like "incident response planning" and "business continuity" confirm this is Level 1 language.


fact: System and Organization Controls (SOC) reports requested from vendors

reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity, including pre-engagement evaluation and requiring SOC reports — requirements imposed ON vendors, making this Third-Party Risk. SOC reports are a domain-specific attestation mechanism that passes the ERM test, elevating specificity to Level 2, but no firm-specific or verifiable facts push it higher.

thinking:
Classify this paragraph.

Content: About third-party risk management - evaluating third parties, requesting SOC reports from vendors. Central topic is third-party oversight.

Category: Third-Party Risk (requirements imposed ON vendors, central topic)

Specific facts:
- "System and Organization Controls reports" (SOC reports) - domain term (Level 2)

Specificity: Domain-Adapted (SOC reports is a domain term that passes the ERM test)


fact: Email spoofing incident on April 9, 2024

fact: 10:25 p.m. local Hong Kong SAR time detection

fact: Wire transfer of $30,825

fact: Payment wired on March 27, 2024

fact: Verified by April 11, 2024

fact: Remediation actions adopted as of April 12, 2024

fact: email spoofing

fact: $30,825 deemed unrecoverable based on conversations with bank and law enforcement

reasoning: This paragraph describes a real cybersecurity incident — an email spoofing attack resulting in a misdirected wire transfer — with timeline, scope, response, and remediation actions, making it clearly Incident Disclosure. Specificity is Quantified-Verifiable due to multiple externally verifiable facts: specific dates (April 9, March 27, April 11, April 12, 2024), a precise dollar amount ($30,825), and exact time of detection.

thinking: Incident disclosure with specific dates, amounts, and details.


fact: forensic investigation completed

fact: automated off-boarding and access-revocation processes

fact: 24/7 SIEM/SOC monitoring for identity and domain anomalies

fact: SIEM/SOC monitoring

fact: DNS and domain operations referenced as incident scope

fact: 24/7 security operations

reasoning: The paragraph describes remediation actions completed after a real cybersecurity incident (forensic investigation, access revocation, monitoring, training, stabilization), making Incident Disclosure the primary category despite the closing materiality sentence. Specificity reaches Firm-Specific due to the '24/7 SIEM/SOC monitoring' claim, which is a specific organizational fact about this company's operations, alongside multiple domain terms (SIEM/SOC, access-revocation, DNS). No externally verifiable claims (named firms, certifications, specific dates/numbers) push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes remediation actions after an incident (forensic investigation, automated off-boarding, SIEM/SOC monitoring, training, domain/DNS/email stabilization, quarterly reviews). Ends with a materiality statement.

Category: This references a real incident and describes what was done in response (remediation). The dominant frame is incident remediation. But the last sentence is a materiality assessment. The bulk is about what happened after an incident - remediation steps. This is Incident Disclosure (timeline, scope, response, remediation). The materiality statement at the end is secondary.

Now I'm looking at the specific language used throughout. There are several domain-specific terms like forensic investigation, automated off-boarding, and SIEM/SOC monitoring, with "24/7" being a firm-specific detail about their monitoring capabilities. The paragraph mixes technical remediation steps with a materiality conclusion that feels somewhat disconnected from the incident disclosure framing.


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

reasoning: The paragraph is an introductory framing statement about the company's cybersecurity measures and data protection, answering 'what does the program do?' at a very high level, making it RMP despite its thinness. The explicit invocation of 'confidentiality, integrity, and availability' — the CIA triad — is a foundational infosec domain concept that passes the ERM test, elevating specificity to Level 2.

thinking:
Classify this paragraph.

This is generic boilerplate about recognizing importance of cybersecurity. No specific measures, no domain terms, no firm-specific facts.

Category: This doesn't answer any of the six substantive questions. It's a generic introductory statement. But it does mention "confidentiality, integrity, and availability" - the CIA triad. Let me think... is that a domain term?

The CIA triad (confidentiality, integrity, availability) is a foundational cybersecurity concept. An ERM professional might use these words but the specific trio together is a security domain concept. Actually, "confidentiality, integrity, and availability" is the CIA triad which is a core infosec concept.

But the paragraph is really just a preamble with no actual description of processes, governance, or programs - it doesn't even finish explaining what measures they're developing. The CIA triad reference alone isn't enough to push this beyond generic boilerplate.

Looking at Rule 6, this barely qualifies as RMP since it mentions safeguarding systems and protecting data, but it's so thin that I'm borderline between RMP and N/O. I'll categorize it as RMP since there's at least a framing around having a cybersecurity program, though my confidence is moderate.

Now examining the specificity here—citing "confidentiality, integrity, and availability" demonstrates actual domain knowledge beyond generic "protect data" language. That's the CIA triad, a foundational infosec concept, so this warrants a Level 2 for specificity.


reasoning: The paragraph describes the board of directors and management intending to meet periodically to assess cybersecurity status, which is a minimal governance oversight statement. No domain terms, firm-specific facts, or verifiable claims are present—entirely generic language with no substantive detail.

thinking:
Classify this paragraph.

This is a vague statement about management and board meeting periodically to assess status. No substantive cybersecurity content.

Category: This could be BG (board oversight) but it's extremely vague. It mentions both management and board meeting to assess "the then-current status" - but of what? Given it's in Item 1C, presumably cybersecurity. "Fluid situation" suggests minimal program. This is a SPAC/no-operations type company (WORLDS INC/WDDD is a very small company).

The paragraph describes board oversight intention but is extremely generic.

I'm torn between N/O and BG here. The disclosure lacks any real substance about cybersecurity—it's just saying they'll meet periodically. But since it does describe a governance structure with board and management oversight, even if minimal, I'm leaning toward BG. The "fluid situation" language and overall vagueness point to a company with essentially no program in place, yet the intent to have board oversight is still there.

Going with BG for the governance structure, though it's clearly Level 1 with no specific details whatsoever.


fact: Steering Committee identified as the body overseeing cybersecurity program

reasoning: The paragraph describes how the Steering Committee oversees the cybersecurity program—monitoring effectiveness, receiving updates from management, and reviewing policies—which is governance oversight structure (BG). The named 'Steering Committee' as the cybersecurity oversight body is a firm-specific organizational detail, but the remainder is generic oversight language (monitoring, updates, reviews) that any ERM professional could write, keeping this at Level 3.

thinking:
Let me analyze this paragraph.

Category: The "Steering Committee" monitors the cybersecurity program, receives updates from management, reviews policies. This is about oversight structure. The Steering Committee seems to be a board-level or governance committee overseeing cybersecurity. But wait - is it a board committee or management committee? It says it "receives regular updates from management" which suggests it's above management - likely a board-level committee. This looks like Board Governance - describing how a committee oversees cybersecurity.

Actually, "Steering Committee" is ambiguous. It could be management-level. But the paragraph describes oversight activities (monitoring, receiving updates, reviewing policies).

Given the governance-chain rule, this defaults to Board Governance when describing oversight structure. Now I'm checking the specificity - "Steering Committee" is fairly generic on its own, not like a firm-specific name such as "Cybersecurity Committee" or "Technology Risk Committee." And "cyber incident response plan" is a domain term that stays at Level 1, so that doesn't add specificity here.

Looking at the rest of the language - "prevention, detection, mitigation, and remediation" are standard risk management terms that any ERM professional would recognize, not cyber-specific. "Third-party assessments" and "cyber threat trends" are also generic oversight language. This reads like boilerplate governance disclosure, mostly Level 1 content without firm-specific details that would elevate it. I'll classify this as firm-specific based on the named Steering Committee functioning as the cybersecurity oversight body.


fact: Head of Resources Management role involved in cybersecurity

fact: CCO (Chief Compliance Officer) involved in cybersecurity

fact: Head of Resources Management is also a member of the Board of Directors

fact: Head of Resources Management has more than 30 years of overall experience

fact: Head of Resources Management has more than 20 years directly assessing and managing cyber IT and HR systems

fact: CCO has more than 30 years of overall experience as a CPA

fact: CCO holds CPA credential

fact: CCO has more than 15 years managing information technology systems and databases

fact: CCO has 15-plus years supporting Adviser's and Administrator's resource management department

reasoning: The paragraph primarily describes who in management handles cybersecurity (Head of Resources Management, CCO), their qualifications, and experience—classic Management Role content. The final sentences touch on board updates but the bulk is management personnel. Specificity is Level 4 due to multiple verifiable lower-bound experience claims (30+, 20+, 15+ years) and the CPA credential, which is independently verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes management personnel (Head of Resources Management, CCO) involved in cybersecurity, their qualifications and experience, board members' backgrounds, and board receiving updates.

Category: This is primarily about management roles - who is responsible, their qualifications, experience. There's a brief mention of board updates at the end, but the bulk is about management personnel. By the person-removal test, removing names/titles/qualifications leaves very little. → Management Role.

Wait, the last two sentences are about Board governance. But the majority of text is about management roles and qualifications.

Now I'm looking at the specific credentials and experience metrics. The Head of Resources Management brings over 30 years of general experience plus more than 20 years specifically in cybersecurity assessment and management, while the CCO holds a CPA credential with over 30 years as a CPA and 15+ years managing IT systems. These are all quantified, verifiable benchmarks that establish their expertise in the role.


reasoning: This paragraph is an introductory commitment statement and general threat definition without describing any actual cybersecurity program, governance structure, or management role. The 'could negatively impact' materiality language is speculative (every 10-K says this), and no substantive cybersecurity measures or processes are disclosed. None/Other paragraphs receive Generic Boilerplate.

thinking:
Classify this paragraph.

Content: General commitment to cybersecurity, recognition of threats, definition of cybersecurity threats. No specific program details, no board governance, no management roles. Mentions "accounting software and back-of-house software" which is slightly specific but really just generic. The materiality language "could negatively impact" is speculative (every 10-K says this), not an assessment.

Category: This is introductory/general language. No substantive cybersecurity disclosure. Could be N/O or RMP. It mentions "devoting resources to secure our information technology systems" but that's very generic. Let me check - is there ANY actual cybersecurity measure described? "devoting resources" is extremely vague.

The paragraph names specific software types like accounting and back-of-house systems, but doesn't actually describe what the company does to protect them—it's just a commitment statement wrapped around threat recognition. The vague language about "devoting resources" doesn't constitute a real disclosure of cybersecurity measures or processes. This is a preamble, so I'm classifying it as None/Other.


fact: Technology Committee of the Board

fact: Information Security Policy (named governing policy)

reasoning: The paragraph describes how the Board and its Technology Committee oversee the information security program, approve policies, and engage in risk assessments — squarely Board Governance. The Technology Committee is a non-generic board-level committee, elevating specificity to Firm-Specific (Level 3).

thinking:
Classify this paragraph.

Category: This describes board-level oversight of cybersecurity. The Technology Committee of the Board is discussed in terms of its oversight role. This is Board Governance.

Specific facts:
- "Technology Committee of our Board" — named committee (firm-specific)
- "Information Security Policy" — named internal program (firm-specific)
- "risk assessments" — generic
- "mitigation plans" — generic

Specificity: The Technology Committee is a non-generic board committee (not Audit Committee), so firm-specific. The named "Information Security Policy" is a named policy but fairly generic.

I'd rate this as Level 3 specificity.


fact: IASME Cyber Essentials framework

type: framework

fact: UK government NCSC (National Cyber Security Centre)

fact: NIST framework

reasoning: The paragraph describes the company's risk assessment methodology and framework adoption (annual assessment, policies and controls), directly answering what the cybersecurity program does → RMP. Multiple named security frameworks (IASME Cyber Essentials, ISO 27001, NIST) pass the ERM test as domain-specific terms, but the company says 'based on' and 'understanding of' rather than claiming certification, so these remain Domain-Adapted rather than verifiable.

thinking:
Classify this paragraph.

Content: Describes annual IT security assessment based on IASME Cyber Essentials framework, references ISO 27001 and NIST, implements policies and controls.

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

Specific facts:
- "IASME Cyber Essentials framework" - named framework (domain term/framework)
- "UK government Cyber Security NCSC" - named entity
- "ISO 27001" - framework
- "NIST framework" - framework

- "annual IT Security assessment" - cadence

The paragraph references multiple frameworks but doesn't claim actual certification—it says they "follow an annual IT Security assessment based on" these standards rather than maintaining formal certifications. The mention of NCSC approval is about the framework itself, not the company's status. Since there's understanding of ISO 27001 without certification claims and multiple frameworks cited without firm-specific implementation details, this lands at Level 2 (Domain-Adapted).


fact: ISIRP (Information Security Incident Response Plan) - named internal program

fact: SOC reports (System and Organization Control reports) used for vendor security reviews

fact: data protection covenants in third-party provider agreements

fact: risk-based re-assessment of high inherent-risk third-party providers on an annual basis

reasoning: The paragraph centrally addresses how third-party cyber risks are managed — due diligence, contractual requirements, ongoing monitoring, and escalation — making TP the primary category. The named program 'ISIRP' is a firm-specific identifier, and SOC reports are domain terms passing the ERM test; the combination elevates to Firm-Specific.

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


fact: IT Risk Assessment reports

fact: Cybersecurity Risk Assessment reports

fact: Internal Vulnerability Reports

fact: Annual IT Program Status Report

reasoning: The paragraph describes how a board-level committee oversees cybersecurity risks, including what reports it receives and its decision-making role, clearly answering the Board Governance question. The named 'Risk Management Committee of the Board of Directors' is a non-generic committee name elevating to Firm-Specific, with domain terms like vulnerability reports and cybersecurity risk assessment providing Level 2 support.

thinking:
Classify this paragraph.

Category: Board Governance - describes board committee oversight of cybersecurity risks, what reports they receive, their responsibilities.

Specific facts:
- "Risk Management Committee of the Board of Directors" - named committee (firm-specific)
- "IT Risk Assessment" - domain term
- "Cybersecurity Risk Assessment" - domain term
- "Vulnerability Reports" - domain term
- "Vendor Management Risk Assessment" - could be domain
- "Annual IT Program Status Report" - specific report name
- "Quarterly Internal Vulnerability Reports" - specific cadence + domain term

- The named Risk Management Committee is firm-specific, while the specific report names demonstrate domain expertise. This lands at Level 3 specificity due to the committee designation, with the domain terminology at Level 2. There are no verifiable claims present.


fact: Forensic investigation completed on December 13, 2023

fact: Last confirmed unauthorized activity on November 20, 2023

fact: Malware deployed was not self-propagating

fact: Data exfiltration occurred

reasoning: This paragraph describes a real cybersecurity incident — forensic investigation findings, nature of the attack (non-self-propagating malware, data exfiltration), scope, and timeline — making it clearly Incident Disclosure. Specific dates (December 13, 2023 and November 20, 2023) are externally verifiable facts tied to the incident, elevating specificity to Level 4.

thinking: Incident disclosure - describes what happened in a real cybersecurity incident.


fact: Cybersecurity Committee

fact: Senior IT executive with ten years of cybersecurity experience

fact: Thirty-five years of experience in various technology domains

fact: Experience includes Fortune 500 and large semiconductor companies

fact: Domains: IT Infrastructure, Cloud, Cybersecurity, and Application Development

reasoning: The paragraph describes management responsibilities (executives, IT management, Cybersecurity Committee) and qualifications of a senior IT executive — person-removal test leaves only generic oversight language, confirming MR. Specificity reaches Level 4 due to hard numbers: 'ten years of cybersecurity experience' and 'thirty-five years of experience' are verifiable against a resume.

thinking:
Let me analyze this paragraph.

Content: Describes executives, IT management, and Cybersecurity Committee responsibilities, then describes a senior IT executive's qualifications.

Category: This is about management's organizational role - responsibilities and qualifications. The "Cybersecurity Committee" here seems management-level. Person-removal test: remove the senior IT executive's qualifications and experience - we lose the last sentence entirely. The remaining content describes responsibilities of management roles. This is MR.

Specific facts:
- "Cybersecurity Committee" - named committee (firm-specific)
- "senior IT executive" - not a VP+ title, but let me check...

The qualifications are concrete: ten years in cybersecurity and thirty-five years across technology domains like IT Infrastructure, Cloud, and Application Development, with experience at Fortune 500 and semiconductor companies. These hard numbers and domain specifics push this to Level 4 specificity.


fact: vulnerability management

reasoning: The paragraph describes the oversight structure: CEO directs the program and management updates the Audit Committee — a governance-chain paragraph that defaults to BG per Rule 1, as its purpose is explaining how cybersecurity information flows to the board. 'Vulnerability management' is a cybersecurity domain term that passes the ERM test, elevating specificity to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Describes oversight structure - CEO directs cybersecurity, management updates Audit Committee on cybersecurity topics.

Category: This is a governance-chain paragraph (Board → Committee → Officer → Program). Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. The primary question answered is "How does the board oversee cybersecurity?" - information flows to the board via Audit Committee updates.

But wait - it also says programs are under CEO direction. That's about management organization. However, the paragraph's purpose is describing the oversight structure flowing from CEO to Audit Committee.

The Audit Committee is a board-level committee, so the governance-chain default applies here. The paragraph is fundamentally about how the board receives cybersecurity information through its committee, making this Board Governance.

For specificity, "Chief Executive Officer" and "Audit Committee" are generic roles and structures every company has, so they don't count as firm-specific. "Vulnerability management" is a domain term that meets the ERM threshold, giving it Level 2 specificity, while "cybersecurity risks and mitigation strategies" remains too generic.


fact: Chief Information Security Officer (CISO) manages the cybersecurity program

reasoning: The paragraph is split between describing the cybersecurity framework (identify, assess, mitigate risks; establish policies and safeguards) and governance structure (CISO management, Audit Committee oversight). The first two sentences primarily answer 'what does the program do,' giving RMP a slight text-volume edge. The 'identify, assess and mitigate' language fails the ERM test (Level 1), but the CISO role is a firm-specific fact elevating specificity to Level 3. The Audit Committee is generic (every company has one) and does not count as firm-specific.

thinking:
Let me analyze this paragraph.

Category: This covers multiple topics - framework/program description, CISO mention, and Audit Committee oversight. The paragraph describes the framework (RMP), mentions CISO management (MR), and Audit Committee oversight (BG). The bulk of text describes the framework and oversight structure. The "what question" - it's split between "what does the program do" and "how does the board oversee." The framework description is generic ("identify, assess and mitigate"), and the governance chain (CISO → Audit Committee) is described. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure.

Looking at the breakdown more carefully, the paragraph is genuinely split between framework description in the first two sentences and governance oversight in the final two sentences. The framework content answers what the program does, while the CISO and Audit Committee portions address how the board oversees it. Since the text is fairly evenly distributed between these elements, I need to weigh which category dominates - the framework explanation takes up the first half, but the paragraph concludes with the governance structure.

Re-examining the specificity: the generic risk language fails the ERM test, the cybersecurity framework is vague, but the Chief Information Security Officer is a named firm-specific role at VP-equivalent level. The Audit Committee reference is standard boilerplate that every company includes. This tips the classification to Level 3 based on the CISO mention.


reasoning: The paragraph describes the findings of a forensic investigation into a real cybersecurity incident — timeline, nature of malware, exfiltration, and scope — making it clearly Incident Disclosure. Specific dates (December 13, 2023 and November 20, 2023) are externally verifiable facts tied to the incident, elevating to Level 4.


fact: cyber risk insurance

reasoning: The paragraph addresses how cybersecurity affects the business financially by noting the company carries cyber risk insurance, fitting the SI category's coverage of insurance and financial impact. 'Cyber risk insurance' is a domain-specific term passing the ERM test, but no firm-specific or verifiable details are provided beyond its existence.

thinking: Cybersecurity insurance mention with caveat about coverage limits.


fact: August 2021 cybersecurity incident

fact: January 2023 cybersecurity incident

fact: Cyber liability insurance referenced

fact: Cross-reference to Note 18 – Commitments and Contingencies

reasoning: The paragraph references two real cybersecurity incidents but its primary purpose is assessing their financial/business impact—lawsuits, costs, insurance coverage, and material adverse effect on financials—making the financial frame dominant (Rule 4 → SI). Specific dates (August 2021, January 2023) tied to publicly known, real incidents are externally verifiable, elevating to Level 4.

thinking:
Incident disclosure with financial impact discussion.

Specific dates: August 2021, January 2023 - specific dates tied to real incidents. This references real cybersecurity incidents with lawsuits, class actions, regulatory inquiries.

Category: This describes what happened (real incidents) AND business/financial impact. Rule 4: mixed with financial frame dominant → SI. Actually, let me re-read. The paragraph names real incidents but the bulk is about financial/business impact (lawsuits, costs, material adverse effect). The frame is financial impact. → SI.

Wait, Rule 4 says "Mixed with incident frame dominant → ID. Mixed with financial frame dominant → SI." The paragraph starts by referencing incidents but the main content is about costs, lawsuits, insurance, material adverse effect. Financial frame dominant → SI.

Actually, Rule 5 applies here too - the language about "may have a material adverse effect" and "we have incurred and may continue to incur significant costs" fits the SI criteria. The real incidents are mentioned, but the focus is on their financial consequences and business implications rather than the incidents themselves.

The specificity is strong: August 2021 and January 2023 are concrete dates tied to actual events, the lawsuits and class actions are verifiable facts, and there's a reference to cyber liability insurance details in Note 18. This pushes it to Level 4 - the dates and incident references are specific enough to be verifiable.


reasoning: This paragraph describes general IT dependency on systems and third-party technology without any substantive cybersecurity disclosure—no measures, processes, or governance structures are described. No specific facts elevate specificity above Level 1.

thinking:
Classify this paragraph.

This is generic language about IT dependency - no cybersecurity measures, no specific facts.


reasoning: The paragraph answers how the board oversees cybersecurity, describing delegation from the full Board to the Audit Committee for risk oversight including cybersecurity. No domain terms pass the ERM test ('risk assessment,' 'risk management' are generic), and all entities mentioned (Board, Audit Committee) are standard governance structures present at every public company.

thinking:
Classify this paragraph.

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

Specificity: Let me scan for facts.
- "Board of Directors" - generic
- "Audit Committee" - generic, every company has one
- No domain terms that pass ERM test - "risk assessment", "risk management", "cybersecurity" are generic
- No firm-specific facts, no named roles above generic

This is generic boilerplate about board oversight.


fact: monitoring and rating services for third parties

fact: posture and intelligence reviews of vendors

reasoning: The paragraph's central topic is how the company manages cybersecurity risk for third-party vendors — imposing requirements, conducting evaluations, and embedding controls in SLAs — making it Third-Party Risk. Terms like 'open-source intelligence risk assessments' and 'posture and intelligence reviews' pass the ERM test as cybersecurity-specific vocabulary, elevating to Domain-Adapted, but no firm-specific facts (named roles, committees, or programs) push it higher.

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

Specific facts: "monitoring and rating services", "open-source intelligence risk assessments", "posture and intelligence reviews" - these show domain knowledge. "service level agreements" with cyber controls embedded - this is about requirements imposed on vendors.

Domain terms: open-source intelligence (OSINT) risk assessments, posture reviews, monitoring and rating services - these pass the ERM test.

This is TP - requirements imposed on vendors, vendor oversight as central topic.

Specificity: Domain-Adapted (Level 2) - terms like "open-source intelligence risk assessments," "posture and intelligence reviews," "monitoring and rating services" demonstrate cybersecurity domain knowledge.


fact: management committee on cybersecurity (management-level cybersecurity committee)

reasoning: The paragraph describes who oversees cybersecurity policies (Senior Director and Head of IT, management committee on cybersecurity) and their responsibilities/reporting lines — squarely MR. The person-removal test leaves little substantive content. The 'management committee on cybersecurity' is a non-generic management-level committee qualifying as firm-specific, but the Senior Director and Head of IT title lacks a security qualifier at Director level and doesn't meet the firm-specific threshold. No domain terms pass the ERM test.

thinking:
Let me analyze this paragraph.

Content: Describes the Senior Director and Head of IT's role in overseeing cybersecurity, plus a management committee on cybersecurity. This is about management's organizational role and responsibilities.

Category: This is about management roles and responsibilities - who oversees what, reporting lines. MR.

Person-removal test: Remove "Senior Director and Head of IT" and their responsibilities - not much substantive program description remains. → MR confirmed.

Specific facts:
- "Senior Director and Head of Information Technology" - This is a Director-level title.

Now I'm checking whether the committee designation makes this firm-specific. The "Senior Director and Head of Information Technology" title itself isn't firm-specific since it lacks a security qualifier, but the "management committee on cybersecurity" does appear to be a named, non-generic committee focused on cybersecurity, which would qualify as firm-specific. The other elements like prevention, detection, mitigation, and remediation are just standard security processes, and "security team" is generic. I'm reconsidering whether the cybersecurity committee itself is truly firm-specific or just a standard governance structure that many organizations have. The language around incident prevention, detection, and mitigation is definitely generic ERM terminology, so the specificity here really hinges on whether naming an internal committee counts as firm-specific information. I think it does—it's an actual organizational structure they've established—so I'll classify this as Level 3.


fact: ransomware

fact: phishing attacks

fact: computer malware, viruses

reasoning: Though mostly risk-factor boilerplate, the paragraph does describe a cybersecurity measure ('continuously monitor and develop our information technology networks and infrastructure to help prevent, detect, address and mitigate...'), which per Rule 6 pushes it into RMP over N/O. Specificity reaches Level 2 via named threat types (ransomware, phishing attacks, malware/viruses) which are cybersecurity domain terms, though the overall paragraph is largely generic.

thinking:
This is a risk factor-style paragraph about IT dependence and cyber threats. Let me classify it.

Content: Describes general IT dependency, types of data stored, generic threats, and potential consequences. Ends with "could have a material adverse effect" which is speculation, not an assessment. Cross-references Item 1A.

Category: This is mostly generic risk language about potential cyber threats. No actual program description beyond very generic "continuously monitor and develop our information technology networks." The "could have a material adverse effect" is speculation per Rule 5. The cross-reference to Item 1A → N/O element. But there is some mention of monitoring/developing IT networks.

The paragraph leans toward risk disclosure rather than program substance—the monitoring sentence is brief and generic while the bulk focuses on vulnerabilities and consequences. The speculation language and Item 1A reference suggest this belongs in None/Other or RMP rather than a cybersecurity program category.

But Rule 6 pushes me toward RMP since there's at least some description of actual measures like monitoring and network development, even if it's boilerplate. The specific threat types mentioned—ransomware, phishing, malware—and the reference to non-public personally identifiable information do add some domain specificity, though I should verify whether that's enough to distinguish this from generic risk language.


reasoning: This is a general company description stating commitment to security without answering any of the six substantive cybersecurity questions. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: Simple classification task.


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

thinking: Materiality assessment paragraph.


reasoning: The paragraph describes how the Board delegates cybersecurity oversight to the Audit Committee and receives periodic management reports — squarely answering the board oversight question (BG). All elements are generic governance language (Board, Audit Committee, periodic reports, management updates) with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity, delegation to Audit Committee, reporting from management to committee. This is Board Governance.

Specific facts: "Audit Committee" is generic (every company has one), not firm-specific. No domain terms that pass ERM test. "periodic reports" is generic. No named roles beyond generic ones.

This is Level 1 - Generic Boilerplate.


reasoning: The paragraph makes two explicit materiality assessments — a backward-looking 'not aware of any material incidents' and a forward-looking 'not reasonably likely to materially affect' (SEC 106(b)(2) language) — squarely fitting Strategy Integration. No domain terms, firm-specific facts, or verifiable claims are present; negative self-assertions about absence of incidents are not externally verifiable, and the Item 1A cross-reference adds no substantive content.

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

1. "not aware of any cyber incidents that...have been material" → backward-looking SI assessment
2. "do not believe that risks...are reasonably likely to materially affect" → forward-looking SI assessment (SEC Item 106(b)(2))
3. Cross-reference to Item 1A

Category: Strategy Integration (two materiality conclusions)

Specificity: The negative assertions ("not aware of any material incidents", "not reasonably likely to materially affect") are self-reported claims about absence — not externally verifiable. The cross-reference to Item 1A is not a specific fact.

This is just generic boilerplate language with no domain-specific terminology, company-specific details, or claims that could be independently verified.