content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the Audit and Risk Committee's oversight responsibilities for cybersecurity risks, with the committee as the grammatical subject, fitting Board Governance. After filtering, no IS-list facts remain: 'Audit and Risk Committee' is a standard governance committee variant (the codebook explicitly lists 'Audit Committee' as NOT specific), and all other elements are generic governance language.

provider: z-ai


reasoning: The paragraph's primary focus is board oversight of cybersecurity risks. While management is the grammatical subject of two sentences, their role is purely to provide information TO the board for oversight purposes. The disambiguation rule specifies that board oversight with management mentioned in service of that oversight constitutes Board Governance.


content_category: Risk Management Process

reasoning: The paragraph describes Garmin's internal cybersecurity risk management program, including risk assessment, identification, and management processes, which clearly fits Risk Management Process. For specificity: NIST Cybersecurity Framework is named (Sector-Adapted baseline), but no IS-list facts exist—'in-house cybersecurity experts' is generic (not a specific title like CISO), 'product development and technology management teams' are generic business functions (not a specific composition like 'Legal, Compliance, and Finance'), and 'third-party providers' are unnamed. Annotators A and C correctly identified Sector-Adapted; Annotator B erroneously counted generic team references as firm-specific facts.


content_category: Management Role

reasoning: The paragraph focuses on the CDIO's role, responsibilities, background, and qualifications, with the management role as the grammatical subject throughout. All annotators correctly identified this as Management Role.


reasoning: The paragraph describes the company's internal cybersecurity processes including assessments, audits, exercises, penetration testing, and training programs. Annotator B incorrectly counted 'Cyber Incident Response Plan' as a specific fact, but per the NOT list, generic program names without unique identifiers (like the IS-list example 'Cyber Incident Response Plan (CIRP)') do not qualify. After filtering, zero IS-list facts remain, making this Generic Boilerplate.


reasoning: The paragraph primarily describes internal cybersecurity processes (application design, backup systems, monitoring, detection, anti-malware, training, audits, and a trained response group) across three of five sentences. The Head of IT mention at the end is secondary attribution within the process context, not the dominant focus.


content_category: Third-Party Risk

reasoning: The paragraph is entirely focused on vendor/third-party qualification and assessment processes, with requirements imposed ON vendors as the central topic. Annotators A and C correctly identified this as Generic Boilerplate; Annotator B erroneously counted generic program names ('pre-engagement process', 'Risk Dependency Assessment', 'tier levels', 'Critical Vendors') as specific facts, but none have unique identifiers or appear on the IS-list.


reasoning: The grammatical subjects are the audit committee and Board of Directors throughout (sentences 1, 2, and 4), with the ISO/CISO appearing only in sentence 3 as actors reporting TO the board/committee. The paragraph describes oversight (receiving reports, incident escalation to the board) rather than operational processes, making Board Governance the correct category per the codebook's 'oversight vs operations' test.


reasoning: The paragraph focuses on the VP of IT's cybersecurity oversight role, qualifications, and supporting team, with management roles as the grammatical subject. The specificity is Firm-Specific because while the VP of IT role and 'over 20 years' experience are specific facts, only the years of experience counts as a QV-eligible fact—need two for Quantified-Verifiable.


reasoning: The paragraph describes internal processes for identifying, assessing, monitoring, and mitigating cybersecurity risks. The term 'Management' is generic (not a named cybersecurity-specific role like CISO), and the content focuses entirely on process activities rather than any individual's identity, qualifications, or reporting structure. Applying the disambiguation test: removing 'Management is responsible for' leaves a coherent process description, confirming RMP.


reasoning: The disambiguation rule explicitly states that board/committee 'receiving briefings' constitutes Board Governance. Although 'Management' is the grammatical subject, the Audit Committee is receiving updates on cybersecurity incidents—an oversight action. The communicative purpose is to describe the board's oversight mechanism for staying informed about incidents.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment process using the MLPS framework, including how IT systems are stratified by risk and assessed for effectiveness. This is clearly about the company's own internal processes.


reasoning: The paragraph centrally describes vendor oversight processes including due diligence, monitoring, and recertification of third-party cybersecurity controls, making Third-Party Risk the correct category. However, after filtering out NOT-list items (company self-references and generic program names), no IS-list facts remain, so specificity is Generic Boilerplate.


category_confidence: medium

reasoning: The paragraph primarily describes the company's information security program, including framework adoption (NIST CSF, PCI DSS), SOC operations, and security exercises. While CIO and CISO are mentioned, they serve as attributions for process oversight rather than the primary focus. Applying the disambiguation test: removing role mentions leaves a coherent process description, confirming Risk Management Process as the dominant communicative purpose.


reasoning: Annotator B correctly identified that the paragraph contains no IS-list facts. Annotators A and C erroneously counted operational team names ('CIRT' and 'Cyber Security Watch Team') as specific facts, but the IS list only includes board committees, team compositions, and programs with unique identifiers—not operational team names. After filtering out all NOT-list items, zero IS-list facts remain.


content_category: None/Other

reasoning: The paragraph contains only generic IT-dependence language stating the company has IT systems, transmits data electronically, and faces cyber risks—without describing any actual cybersecurity activities, processes, governance, or strategy. This matches the codebook's explicit None/Other criteria for paragraphs that 'only establish that the company has IT systems and data without describing any program, process, or strategy.'


reasoning: The paragraph's dominant communicative purpose is describing the company's internal cybersecurity risk management processes (business application design, backup systems, monitoring, anti-malware, training, audits, response activities). The Head of IT department is mentioned only in the final two sentences as part of the process structure, not as the primary focus. Applying the disambiguation test: removing the role mention leaves a coherent process description, confirming RMP. Annotators B and C erred by treating the brief management attribution as the primary content when it is incidental to the extensive process description.


reasoning: The paragraph describes the company's internal cybersecurity processes, including framework oversight by the IT team, risk assessment activities, and employee training programs. All three annotators correctly identified this as Risk Management Process. For specificity, after filtering strictly: 'Software Engineer' is NOT on the IS list (which specifies CISO, CTO, CIO, VP of IT/Security, etc.); 'IT Team' is a generic department name, not a specific composition; 'cybersecurity risk management program' is a generic program name without unique identifier. Zero IS-list facts remain, so Generic Boilerplate is correct. Annotators B and C applied the codebook correctly; Annotator A erroneously counted generic roles as specific facts.


reasoning: The grammatical subject is 'Senior management,' which is responsible for creating and recommending risk appetite metrics. The Board is mentioned only as the recipient of management's recommendations, not as the active subject performing oversight actions. Annotators A and B correctly applied the codebook; Annotator C erred by treating the Board's passive involvement as the primary focus.


reasoning: The paragraph describes the company's internal cybersecurity approach and monitoring processes, which aligns with Risk Management Process. After filtering NOT-list items (unnamed consultant, approximate experience duration), no IS-list facts remain, resulting in Generic Boilerplate specificity.


reasoning: This paragraph contains only generic IT-dependence language ('we rely on our IT systems'), hypothetical forward-looking impact statements ('could disrupt our business'), boilerplate materiality language, and a cross-reference to Risk Factors. Per the disambiguation rules, when a paragraph 'only establishes that the company has IT systems and data without describing any program, process, or strategy,' it qualifies as None/Other. Annotators B and C correctly applied this rule; Annotator A erred by treating generic risk disclosure language as substantive Strategy Integration content.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, including ERM integration, IT security team reviews, and penetration testing. Board oversight is mentioned as one component of the process, but the dominant communicative purpose is describing how the company assesses and manages risks, not board governance activities. The disambiguation rule explicitly states: 'We conduct quarterly risk assessments; the board is informed' → RMP (process is primary content).


reasoning: The paragraph describes the company's internal cybersecurity risk posture (or lack thereof), including reliance on third parties, absence of internal processes, and basic incident response reporting structure, which fits Risk Management Process.


reasoning: The CEO is the grammatical subject throughout the paragraph ('CEO plays a pivotal role,' 'They provide comprehensive briefings'). The Audit Committee is the object receiving briefings, not the subject taking oversight actions. Per the disambiguation rules, when a named executive's role and reporting function is the focus, this is Management Role.


reasoning: The paragraph focuses on the qualifications and experience of the CIO and VP of Information Security, which are management roles. Two annotators correctly identified this as Quantified-Verifiable because the text contains multiple hard verifiable facts: 'nearly 30 years of experience', 'more than 20 years of experience', and 'CISSP' certification. These meet the QV threshold of 2+ facts (years of experience and named certifications both count as QV-eligible per the disambiguation rules). Annotator C incorrectly stopped at Firm-Specific, failing to count the years of experience toward the QV threshold.


reasoning: The paragraph describes the company's participation in Liberty's processes for assessing, identifying, and managing cybersecurity risks, which is the company's own risk management process delivered via a services agreement with a related entity. Liberty is a parent/affiliate, not an external vendor being overseen, so this does not qualify as Third-Party Risk under the disambiguation rule that third parties supporting internal processes fall under RMP.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including firewall solutions, antivirus/patch systems, internal cloud infrastructure, and backup procedures. All three annotators correctly identified this as Risk Management Process.


reasoning: The paragraph describes the company's internal enterprise risk management process with cybersecurity as a risk category, board review cadence, and management monitoring—clearly fitting Risk Management Process. The text contains no genuine IS-list facts: 'enterprise risk management committee' is a lowercase descriptive phrase (not a capitalized proper noun like 'ERM Committee'), and all other elements are generic governance terminology.


reasoning: The paragraph describes Centuri's internal cybersecurity risk management processes, including quarterly reviews, framework adoption, risk assessments, and a risk register, with third-party engagements as a minor component of internal practices.


reasoning: The paragraph states what data the company collects and that IT system security is important, but does not describe any actual cybersecurity activities, processes, or governance. Per the disambiguation rule, paragraphs that only state the company has IT systems and collects data without describing what it DOES about them are None/Other.


reasoning: The paragraph describes the company's internal cybersecurity monitoring, training, access controls, and AI guidelines, which are classic Risk Management Process activities. All three annotators correctly identified this category.


reasoning: This paragraph is pure forward-looking risk factor language describing hypothetical consequences of hypothetical cybersecurity failures. It contains no substantive disclosure of actual programs, processes, governance, incidents, or strategies. The disambiguation rule explicitly states that paragraphs establishing only that the company has IT systems and data without describing any program, process, or strategy should be classified as None/Other. Annotator C correctly identified this as boilerplate; Annotators A and B erred by treating generic risk language as Strategy Integration, which requires 'actual discussion' of business/financial impact, not hypothetical scenarios.


specificity_confidence: medium

reasoning: The paragraph describes the company's cybersecurity risk management structure and reliance on external parties, with vendor oversight (SOC 2 reviews) as a component rather than the central topic. It contains the firm-specific fact that the company has no employees (a headcount of 0), which qualifies as an IS-list fact. Annotators A and B correctly identified the category but missed the headcount fact; Annotator C correctly identified the headcount fact but misapplied the category test by treating vendor oversight as the central topic when the paragraph is primarily about the company's overall risk management structure.


reasoning: The grammatical subject is 'our approach to cybersecurity risk management' (an internal process), not the Board. The paragraph describes the company's risk management approach with board oversight mentioned secondarily, matching the disambiguation rule: 'We conduct quarterly risk assessments; the board is informed' → RMP (process is primary content).


reasoning: The paragraph's dominant communicative purpose is describing the incident response team composition, which is an element of IR planning. The CEO mention is incidental—brief, without qualifications or reporting structure—and CEO is a generic C-suite role on the NOT list. Applying the disambiguation test: removing the CEO mention leaves a coherent process description about the cross-functional incident response team.


reasoning: Annotator C correctly applied the disambiguation test: the paragraph's dominant communicative purpose is describing the company's cybersecurity program implementation, monitoring, incident response, and reporting processes. The IT Engineer and Cybersecurity Council are mentioned as actors, but the primary content is process description, not management identity/qualifications/reporting structure. Removing role mentions leaves a coherent process description about implementing protection programs, deploying multidisciplinary teams, monitoring threats, and reporting to committees.


reasoning: The paragraph follows the exact pattern from the disambiguation rules: named managers mentioned once at the beginning, followed by extensive process description. The role mention is incidental. Applying the test: removing the first sentence's role attribution, the remaining text (two full sentences describing threat identification, assessment methods, monitoring tools, audits, vulnerability assessments, and tabletop exercises) stands as a complete process description. The dominant communicative purpose is describing how the company identifies and assesses cybersecurity risks, not who holds which role.


reasoning: This paragraph is a cross-reference to Item 1A risk factor disclosures with only generic boilerplate language about risk management processes and board/management focus. It contains no substantive cybersecurity disclosure - no actual discussion of materiality, business impact, insurance, budget, or any specific program or process. The text appears to be a sentence fragment combining regulatory language with boilerplate, providing no meaningful content.


reasoning: This paragraph is generic IT-dependence language stating that operations rely on IT systems and a cyber-attack 'could' hypothetically disrupt business. The disambiguation rules explicitly classify this type of statement as None/Other: 'If the paragraph only establishes that the company has IT systems and data without describing any program, process, or strategy → None/Other.' This is forward-looking hypothetical risk language, not actual discussion of business/financial impact, insurance, budget, or materiality assessment.


reasoning: The paragraph describes the company's internal cybersecurity controls, processes, and monitoring strategies, which clearly falls under Risk Management Process. All three annotators correctly identified this category.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including identification, assessment, and mitigation of threats as part of ERM, which clearly falls under Risk Management Process. After filtering strictly, no IS-list facts remain: the team composition mentions generic job categories (cybersecurity/data privacy professionals) rather than specific departments, and all other elements are generic program names or unnamed entities.


content_category: Strategy Integration

reasoning: The paragraph's dominant communicative purpose is delivering a standalone materiality conclusion ("We have not identified risks...which have materially affected us") and discussing potential future material impacts, which aligns with Strategy Integration per the disambiguation rules. The brief mention of "cybersecurity risk management program and processes" is contextual, not a description of HOW risks are assessed or monitored.


reasoning: The paragraph's grammatical subject is the Board and Audit Committee overseeing cybersecurity risks, receiving periodic reports from management on risks and mitigation measures, which clearly aligns with Board Governance. After strict filtering, no IS-list facts remain: Board/Audit Committee are generic governance entities, Advisor/Sub-Advisor/Dealer Manager are organizational references not on the IS list, and 'incident response plan' is a generic program name without a unique identifier.


reasoning: The paragraph's first sentence (the substantive content) is entirely about evaluating third-party service providers for security capabilities and imposing breach reporting requirements on them. This is vendor oversight as the central topic, not vendors supporting an internal process. The tiebreaker 'Requirements imposed ON vendors → Third-Party Risk' applies. Annotator B correctly identified this; Annotators A and C incorrectly treated vendor evaluation as merely a component of internal processes when it is the paragraph's primary focus.


reasoning: The paragraph focuses on the CIO's identification, qualifications, experience, and reporting lines, with management roles as the grammatical subject throughout. Two QV-eligible facts (13 years of experience and 40 years of combined team experience) meet the Quantified-Verifiable threshold.


reasoning: The paragraph focuses on the qualifications, experience, and cybersecurity oversight responsibilities of a specific management role (Executive Vice President, Senior Operations Officer), making Management Role the correct category. The specificity is Quantified-Verifiable because the text contains two hard verifiable facts: 35 years of experience and 24 years in the role, which meet the QV threshold under the disambiguation rules.


reasoning: The paragraph describes the company's internal cybersecurity program measures including assessments, testing, and framework adoption. Annotator A correctly identified Sector-Adapted; Annotators B and C incorrectly counted Harley-Davidson as a 'named third-party firm' when it is a parent company/business partner, not a cybersecurity services firm like Mandiant, CrowdStrike, or Deloitte.