reasoning: The paragraph's primary function is stating a business impact assessment — both backward-looking ('have not had a material impact') and forward-looking ('are not reasonably likely to materially affect') — which aligns with Strategy Integration under Rule 5. The description of 'directed attacks' is generic boilerplate that any company could use and fails the ERM test. The cross-reference to Risk Factors and the negative assertions about business impact are self-reported claims without external verifiability, yielding Generic Boilerplate specificity.


content_category: Strategy Integration

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph answers the question 'Does cybersecurity materially affect business outcomes?' by stating a backward-looking negative conclusion ('we do not believe there are currently any risks... reasonably likely to materially affect'), which is a Strategy Integration assessment per Rule 5. The second sentence is a cross-reference to Item 1A. The paragraph contains no specific facts—only generic materiality language and opinion language ('we do not believe')—warranting Generic Boilerplate.

provider: minimax

stage: benchmark


content_category: None/Other

reasoning: The paragraph describes the general threat landscape (ransomware, denial-of-service, nation-state actors) and asserts the importance of cybersecurity, but does not describe any specific cybersecurity activities, governance structures, or assessments the company actually performs. It contains no board oversight description, no named management roles, no specific program activities, no vendor oversight details, no incident disclosure, and no actual materiality determination—only speculation about potential impact. All language is generic boilerplate applicable to any company's cybersecurity risk disclosure.


content_category: Risk Management Process

fact: NIST CSF

fact: HIPAA

fact: SOC 2 Type II

fact: SOX ITGC

category_confidence: high

reasoning: The paragraph describes what the cybersecurity program does—specifically, using industry frameworks (NIST CSF, HIPAA, SOC 2 Type II, SOX ITGC) as guides to assess, identify, and manage cybersecurity risks—making it primarily about the risk management process. The specificity is Domain-Adapted because the named frameworks (SOC 2 Type II, SOX ITGC, HIPAA) are cybersecurity-specific terminology that a generic enterprise risk management professional would not naturally use, demonstrating cybersecurity domain expertise rather than generic program language.


specificity_confidence: medium

reasoning: The paragraph describes risk monitoring and review activities (continuous evaluation, tracking risk assessments and incidents) and mentions use of the Ontrack software solution. While Ontrack is a named tool, the paragraph describes general risk management activities rather than cybersecurity-specific expertise or verifiable claims. The language ('continuously performed,' 'monitor and track') is generic process description applicable to any enterprise risk function, with no cybersecurity domain terminology (no SIEM, SOC, EDR, vulnerability scanning, threat hunting, etc.) and no firm-specific organizational facts or verifiable claims.


content_category: Board Governance

reasoning: The paragraph describes the Audit Committee's (a Board-level committee) oversight role over the cybersecurity program and how information flows from management to the board (annual assessments, quarterly updates). This is clearly Board Governance. For specificity, the paragraph uses only generic governance language ('enterprise risk management program,' 'likelihood of occurrence and potential monetary impact') that any company could use—it fails the ERM test as a non-security ERM professional would naturally employ the same terminology. No domain-specific cybersecurity terms, firm-specific roles, or verifiable claims are present.


content_category: Management Role

fact: Vice President of Information Systems and Architecture (VP of IT)

reasoning: The paragraph's central subject is the VP of IT role — its responsibilities, qualifications, and reporting line to the CEO — making this Management Role. The only firm-specific fact is the VP-level title; certifications are referenced generically without being named, and the board reporting is generic governance boilerplate rather than specific oversight structure.


content_category: Incident Disclosure

fact: Retained a professional cybersecurity investigation firm to conduct full forensic analysis of the incident

reasoning: The paragraph describes a real 2019 ransomware incident with timeline, impact, remediation, and investigation findings, making Incident Disclosure the correct category. Specificity is Level 4 because the claim of engaging a professional cybersecurity investigation firm for forensic analysis is independently verifiable through company records or the firm's own documentation — one verifiable fact anywhere in the paragraph is sufficient to reach Level 4.


reasoning: The paragraph describes the Board's oversight role and expertise composition—pure board governance language. For specificity: the expertise topics listed (accounting, corporate governance, technology, ESG, cybersecurity) are generic board qualifications present in most public company disclosures. No named committees, no specific cybersecurity practices, no verifiable facts. The language would fit any company's 10-K boilerplate on board oversight.


reasoning: This paragraph primarily answers 'How has/does cybersecurity affect the business or finances?' through both a backward-looking negative assertion (no material incidents) and a forward-looking materiality statement (reasonably likely to materially affect us), which maps directly to Strategy Integration per Rule 5. The specificity is Generic Boilerplate because the paragraph contains no verifiable facts, domain-specific terminology, or firm-specific details—all statements are generic boilerplate that any public company could make, including the negative incident assertion (which is self-reported and unverifiable per Rule 6), vague 'investment' language without amounts, and generic references to 'internal controls and processes.'


reasoning: The paragraph describes the board's delegation of cybersecurity oversight to the Audit Committee, which is a governance structure question (Board → Committee). However, the content uses only generic governance language ('risk oversight function,' 'delegated,' 'oversees management's implementation') with no cybersecurity domain terminology, no firm-specific roles or committees beyond the standard Audit Committee, and no verifiable facts.


fact: CISO has 27 years of cybersecurity experience

fact: CISO has 17 years of experience in the oil and gas industry

fact: CISO graduated from FBI's CISO Academy in Quantico, Virginia

fact: Fewer than 400 CISOs globally have graduated from the FBI's CISO Academy

fact: Cybersecurity Team is part of the Company's Information Technology department

fact: CISO reports to Vice President and Chief Information Officer

fact: Named Cybersecurity Executive Committee

reasoning: This paragraph is primarily about management organization for cybersecurity — describing the CISO's role, specific qualifications, experience levels, and reporting structure — making it a Management Role disclosure. The specificity level is Quantified-Verifiable because the CISO's 27 years of cybersecurity experience, 17 years in oil and gas, and the 'fewer than 400 CISOs globally' credential are all externally verifiable facts that establish the highest specificity threshold.


reasoning: The paragraph describes board oversight structure—how the Audit Committee reports to the full Board, that the Board receives regular briefings from management, and that board members get presentations from the CTO and security staff. These are all generic governance mechanics present at any public company. No specific security tools, named frameworks, hard numbers, or firm-specific organizational details are present; 'regularly' is soft language and 'Chief Technology Officer' is a generic executive title. The paragraph is pure boilerplate.


reasoning: The paragraph describes the Board's oversight function of cybersecurity risks, including briefing frequency (quarterly reports), the Director of IT's presentation role, an escalation process for incidents, and third-party testing. This is classic board governance language describing how the board oversees cybersecurity. For specificity: while 'Director of IT' is mentioned, Director-level titles without a security qualifier do not meet the firm-specific threshold per the rules. The domain terms used ('cybersecurity risk', 'high-severity incidents', 'third-party technology experts') are generic ERM vocabulary that any enterprise risk professional would use — they don't demonstrate cybersecurity domain expertise beyond the topic itself. No verifiable facts or firm-specific distinguishing details are present, resulting in Generic Boilerplate.


reasoning: This paragraph is a cross-reference to Item 1A risk factors, quoting two risk factor headings without providing any substantive cybersecurity disclosure about board oversight, management organization, program activities, third-party oversight, incident details, or business impact. Per Rule 6, when no actual cybersecurity measure, process, or assessment is described and the paragraph merely points elsewhere, the category is None/Other. The paragraph contains no specific facts—it only references risk factor descriptions with no firm-specific details or verifiable claims.


fact: tabletop exercises to simulate responses to cybersecurity incidents

fact: analysis of risks and development of detection, mitigation and remediation strategies

reasoning: The paragraph describes specific cybersecurity activities (tabletop exercises, risk analysis, detection/mitigation/remediation strategy development) performed by the Breach Response Team, which answers what the cybersecurity program does. This is RMP. The specificity is Domain-Adapted because the paragraph demonstrates cybersecurity domain expertise — specifically using tabletop exercises to simulate cybersecurity incident responses with detection/mitigation/remediation framing — language a non-security ERM professional would not naturally use for general business continuity purposes.


fact: December 2021 - first incident date

fact: March 2024 - second incident date

fact: approximately two weeks - disruption duration for first incident

fact: within one week - restoration time for second incident

fact: Canadian subsidiary - entity affected in second incident

fact: freight shipments, customs brokerage functions, and distribution activities - specific business functions impacted

reasoning: Paragraph is clearly Incident Disclosure as it describes two specific cybersecurity incidents with dates, scope, and impact. Specificity is Level 4 due to hard verifiable facts including exact incident dates (December 2021, March 2024), specific durations ('approximately two weeks,' 'within one week'), and a named subsidiary entity.


reasoning: The paragraph is primarily a materiality assessment — stating that cybersecurity threats have not materially affected and are not reasonably likely to materially affect business strategy, results of operations, or financial condition — which is the core question Strategy Integration answers. The specificity is Generic Boilerplate because the paragraph contains no domain expertise terms (ERM-test-passing security vocabulary), no firm-specific facts (no named roles, committees, or programs), and no verifiable claims (the negative assertion about not experiencing incidents is not independently verifiable). The language is entirely speculative/disclaimer content: 'cannot eliminate all risks,' 'could have a material impact,' and a cross-reference to Item 1A.


content_category: Third-Party Risk

fact: Chief Information Security Officer (CISO)

reasoning: Paragraph centers on third-party vendor oversight processes (pre-engagement assessments, post-engagement monitoring), which is the core TP question. Specificity is elevated to Level 3 by the named CISO role (a firm-specific cybersecurity leadership position), but lacks Level 4 verifiable claims such as specific numbers, named third parties, or hard dates.


reasoning: This paragraph is a closing/aspirational statement that references risk management strategies without actually describing any specific cybersecurity processes, governance activities, or incident information. It answers none of the six substantive questions substantively — it's generic boilerplate that could appear in virtually any risk management section. No specific facts, domain terms, or verifiable claims are present.


fact: Types of third-party providers: software application providers, hosting companies, and contract research organizations

fact: Contract research organizations (CROs) are specific to biotech/pharma industry operations

fact: Vendor management process involves different levels of assessment

fact: Cybersecurity assessment methods: security questionnaires and contractual cybersecurity obligations

reasoning: This paragraph centrally addresses third-party vendor risk management, describing requirements imposed on providers (security questionnaires, contractual cybersecurity obligations) which maps to TP per Rule 3. The specificity reaches Level 3 because the vendor types — particularly contract research organizations (CROs) — are distinctive to a biotech company like Vera Therapeutics, distinguishing this from generic vendor oversight language any company could write. No hard numbers, named third parties, or certification claims elevate it to Level 4.


fact: CTO Vaidhunathan Raghavan previously served as General Manager of Technology at Wayfair

fact: CTO holds Master of Science in Electrical Engineering from University of Minnesota

fact: VP of IT and Security Brendan Hamilton previously worked as VP at international bank with cybersecurity supervisory responsibility

fact: VP Brendan Hamilton holds Certified Information Systems Security Professional (CISSP) certification

reasoning: This paragraph is about Management Role because it describes the specific individuals responsible for cybersecurity risk assessment and management, including their qualifications, prior experience at named companies, and professional certifications. It achieves Level 4 specificity because the CISSP certification and MS in Electrical Engineering are externally verifiable credentials, and the named prior employers (Wayfair, international bank) provide independently checkable employment history.


fact: penetration testing

fact: third party frameworks

reasoning: The paragraph primarily describes what the cybersecurity program does—assessing risks, developing policies and practices, and engaging third-party services for penetration testing and audits—making Risk Management Process the appropriate category. The specificity level is Domain-Adapted because references to 'penetration testing' and 'third party frameworks' demonstrate cybersecurity domain expertise (specific evaluation methodology) that a non-security ERM professional would not naturally use, while lacking firm-specific distinguishing facts such as named leadership, specific committee structures, or verifiable claims.


reasoning: The paragraph describes the company's third-party supplier risk assessment process—specifically that IT suppliers handling personal information or customer data are assessed periodically. This directly addresses how the company manages third-party cyber risks. However, the paragraph lacks any firm-specific identifiers (no named committees, titles, or programs), no domain expertise beyond generic 'risk assessments' and 'due diligence procedures' (which any ERM professional could write), and no verifiable quantifications—making it Level 1 Generic Boilerplate.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity threat information, with a quoted risk factor excerpt. It contains no substantive cybersecurity disclosure about the company's actual governance, management structure, risk management processes, or any actual incidents—it merely points elsewhere. The quoted language is hypothetical ('are or were compromised,' 'could experience') rather than describing actual events. As a cross-reference paragraph, it is None/Other. It contains no domain-specific terminology, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


fact: Vice President and Chief Information Officer

fact: Director of Information Security

fact: Director of Information Security chairs the Information Security Committee

fact: Executive Information Security Oversight Committee comprised of VP/CIO, Senior Vice President, CFO, Chief Legal Officer and Secretary, and Senior Vice President, Chief Human Resources Officer

fact: VP/CIO has 27 years of technology leadership experience

fact: VP/CIO holds Doctor of Business Administration

fact: Director of Information Security has 27 years of experience in infrastructure and security operations

fact: Director of Information Security holds degree in Information Technology Management

reasoning: The paragraph primarily describes management organization for cybersecurity — specific roles (VP/CIO, Director of Information Security), their qualifications and credentials, committee structure (Information Security Committee and Executive Information Security Oversight Committee), and composition (named senior leadership positions). This directly answers 'How is management organized?' The named non-generic committees and firm-specific leadership roles with specific credentials (27 years experience, degree titles) distinguish this company's cybersecurity governance structure from any other public company.


fact: NIST Framework (cybersecurity-specific standard)

reasoning: The paragraph primarily describes what the cybersecurity program does—using the NIST Framework as its foundation and employing various security tools and policies to prevent, identify, escalate, investigate, resolve, and recover from vulnerabilities and incidents. This operational description of the security program maps to Risk Management Process. Specificity is Domain-Adapted because the reference to the NIST Framework demonstrates cybersecurity domain expertise (a non-security ERM professional would not naturally reference NIST CSF as their framework), which elevates it above generic boilerplate.


reasoning: This paragraph answers the question 'what has been the business/financial impact of cybersecurity incidents?' — making it Strategy Integration under Rule 5's materiality assessment category (specifically, the negative backward-looking form: 'have not materially affected'). It contains no cybersecurity domain expertise, no firm-specific organizational facts, and no externally verifiable claims — only a self-reported negative assertion about absence of material incidents and a cross-reference to Item 1A.


fact: Global Director of IT (firm-specific role title)

fact: Over 30 years of experience in information technology roles

fact: Over 20 years of experience as an IT Director

fact: Over 10 years of experience in risk management (CFO)

reasoning: The paragraph is primarily about management organization for cybersecurity — identifying specific roles (Global Director of IT, CEO, CFO), their cybersecurity responsibilities, and individual qualifications. This answers 'how management is organized' rather than describing governance chain (BG) or program activities (RMP). The specificity reaches Level 4 because it contains quantified verifiable claims: 'over 30 years of experience,' 'over 20 years of experience as an IT Director,' and 'over 10 years of experience in risk management' — all specific lower-bound numbers that could be independently confirmed against resumes or LinkedIn profiles.


reasoning: The paragraph describes specific leadership roles (Senior Director of IT, General Counsel) and their cybersecurity responsibilities, making Management Role the appropriate category. However, the paragraph contains no firm-specific identifiers (Senior Director of IT lacks a security qualifier and General Counsel is a generic executive title), no domain expertise terms (all described responsibilities are generic governance activities any company could claim), and no verifiable claims. It describes organizational structure without any specific facts that would distinguish this company's cybersecurity governance from any other.


reasoning: The paragraph directly addresses third-party vendor cybersecurity oversight through due diligence, periodic reviews, and contractual requirements for incident reporting and insurance coverage, making Third-Party Risk the appropriate category. However, the specificity level is Generic Boilerplate because all content consists of generic business practices any company could describe—there are no named frameworks (e.g., SOC 2, NIST CSF), no specific tools or practices mentioned, no named vendors or assessors, no verifiable metrics, and no firm-distinguishing details. The language passes the ERM test: any enterprise risk management professional could write this about non-cyber vendor risk as well.


reasoning: The paragraph's central topic is third-party service provider cybersecurity oversight—due diligence, selection criteria, and ongoing monitoring—which directly answers 'How are third-party cyber risks managed?' This is TP. However, specificity is Generic Boilerplate because the paragraph contains only generic third-party risk management language ('policies and processes,' 'due diligence,' 'adequate safeguards') that any ERM professional could write without cybersecurity domain expertise. No domain-specific security terminology, firm-specific identifiers, or verifiable claims are present.


reasoning: This paragraph is a cross-reference directing readers to the Risk Factors section for cybersecurity threat information. It contains no substantive cybersecurity disclosure—no description of governance, management roles, program activities, or any actual cybersecurity measures. Per Rule 6, because no actual cybersecurity measure/process/assessment is described, it falls under None/Other. The specificity is Generic Boilerplate since there are no domain-specific terms, firm-specific facts, or verifiable claims—only boilerplate cross-reference language.


reasoning: The paragraph describes management's involvement and oversight role in cybersecurity (policies, incident response testing, vendor engagement for penetration tests, incident response team participation). This answers 'how is management organized to handle cybersecurity?' — fitting Management Role. However, all content is generic boilerplate: no named roles above VP-level, no specific titles, no numbers, no named programs, committees, or certifications. The language ('overseeing preparation,' 'testing of incident response plans,' 'engagement of vendors to conduct penetration tests') uses generic cybersecurity terminology any company could claim, with no firm-specific or externally verifiable facts.


reasoning: The paragraph describes that the company has 'experienced attempts to compromise our systems' including phishing attacks, malware infections, and unauthorized access attempts—this references real past events, making Incident Disclosure the primary category despite the lack of confirmed successful breaches. Specificity is Level 1 because while the paragraph mentions threat types (phishing, malware), these are generic domain terms that appear in virtually every cybersecurity disclosure and do not demonstrate specialized domain expertise; there are no quantified facts, named individuals, specific dates, or other verifiable claims.


reasoning: This paragraph is a negative assertion about material cybersecurity incidents combined with speculative forward-looking language ('may, from time to time, experience threats') and a risk factor cross-reference. Under Rule 5, negative assertions about whether cybersecurity has affected business outcomes are Strategy Integration, but the specificity is Level 1 because there are no domain-specific terms (the language is generic enough for any public company), no firm-specific facts (no named roles, committees, or programs), and no verifiable claims (the negative assertion about not having incidents is not independently verifiable).


reasoning: The paragraph describes the composition and qualifications of the management team responsible for cybersecurity policies, which directly answers 'How is management organized to handle cybersecurity?' — fitting Management Role. However, it contains no specific verifiable facts: it references 'individuals with either formal education or relevant experience' (a generic qualification framework) and 'periodic training...including certifications' (no named certification, no specific cadence, no named roles like CISO or specific committee). The language describing team composition and training is standard boilerplate that could appear in any company's disclosure.


reasoning: This paragraph describes the board's cybersecurity oversight structure—specifically the annual reporting cadence and incident update process—which directly answers how the board oversees cybersecurity (Board Governance). The paragraph contains no cybersecurity domain expertise beyond generic risk management language ('annual reports,' 'material cybersecurity incidents') that any ERM professional could write, no firm-specific details, and no verifiable claims, resulting in Generic Boilerplate specificity.


fact: internal and external penetration test

fact: at a minimum, on an annual basis

reasoning: The paragraph primarily describes what the cybersecurity program does—oversight, annual information systems audits, internal and external penetration testing, and risk assessments triggered by specific events. While it mentions the Enterprise Risk Management Committee's composition, the substantive content focuses on program activities (testing, auditing, assessing) rather than governance structure or management roles. Specificity is Domain-Adapted because 'internal and external penetration test' is a cybersecurity-specific practice that a general ERM professional would not naturally reference; the paragraph demonstrates awareness of distinct testing modalities. No firm-specific facts (the named C-suite titles exist at every bank, and third-party 'expert consulting firms' is generic), and no externally verifiable claims.


reasoning: The paragraph describes the board's oversight structure for cybersecurity—specifically that the Audit Committee handles cybersecurity oversight and the General Counsel manages cybersecurity risks. This is a governance-chain description (Board → Committee → Officer), making Board Governance the primary category. The specificity is Generic Boilerplate because the paragraph contains no firm-specific facts (Board, Audit Committee, and General Counsel are generic roles that exist at every company), no named individuals, no domain-specific terminology (the ERM test: 'policies, practices and risks' works for any risk category), and no quantifiable claims. The language is entirely generic governance boilerplate.


fact: information security program

fact: periodic testing

fact: cybersecurity-related issues

fact: information security

fact: technology risks

fact: cybersecurity incidents

fact: third-party consultants

fact: external legal counsel

reasoning: This paragraph primarily describes the cybersecurity oversight structure flowing from the Board's Audit Committee down through the COO to operational management—a governance-chain description that Rule 1 classifies as Board Governance. The specificity is Domain-Adapted (Level 2) because the paragraph uses cybersecurity domain terminology (information security program, periodic testing, cybersecurity incidents) that demonstrates expertise in how cybersecurity oversight functions operate, rather than generic enterprise risk management language.


reasoning: This paragraph is a forward/backward-looking materiality assessment — it asserts that no cybersecurity threats have materially affected the company (negative assertion) and speculates about future potential impact. Per Rule 5, this is Strategy Integration (assessing whether cybersecurity affects business outcomes). The paragraph contains no domain-specific terminology, no firm-specific roles or programs, and no verifiable claims — it is standard SEC boilerplate that appears in virtually every 10-K.


reasoning: This paragraph describes board-level cybersecurity oversight—specifically how the board delegates to the Audit Committee and what the Audit Committee oversees. It answers the BG question about oversight structure. However, the paragraph contains only generic governance language (board of directors, Audit Committee, risk oversight function) that appears identically in virtually every 10-K filing. No named individuals, no specific practices, no distinguishing identifiers, and no domain-specific expertise beyond the generic mention of 'cybersecurity risk.'


reasoning: The paragraph describes a standard board-to-management oversight structure (board has 'ultimate oversight'; management 'presents to the board') without naming any specific committee, role, or process that would distinguish this company's cybersecurity governance from any other public company. All language is generic boilerplate that any company could use. No firm-specific titles, named committees, or verifiable claims are present.


fact: ISO 27001 certification

fact: online training modules

reasoning: This paragraph describes cybersecurity program activities (control testing, employee training, third-party assessments, certification) — clearly answering 'what does the cybersecurity program do?' → RMP. The paragraph demonstrates cybersecurity domain expertise through the reference to ISO 27001 certification and specific training delivery mechanisms (online training modules), which pass the ERM test. However, 'second ISO 27001 certification' is ambiguous (could mean second certification cycle, second scope, or second facility) and lacks external verifiability in this context, so it does not elevate to Level 4.


fact: over 25 years of work experience in various roles in information technology and cybersecurity

reasoning: The paragraph is primarily about management's organizational role and individual qualifications for overseeing cybersecurity, answering 'How is management organized to handle cybersecurity?' through specific named roles (Senior Director of IT, CFO) and their credentials. The specificity reaches Level 3 due to the firm-specific leadership title (Senior Director of Information Technology) and the specific experience claim (25+ years in IT and cybersecurity), which collectively distinguish this company's cybersecurity leadership structure.


reasoning: The paragraph describes requirements imposed on third-party service providers (certification, security measures, breach reporting) — central to Third-Party Risk management. However, it contains no firm-specific facts, verifiable claims, or domain-expertise terms beyond generic cybersecurity vocabulary. 'Risk assessment processes,' 'security measures,' and 'safeguards' are generic terms that any ERM professional would use without specialized cybersecurity knowledge, failing the ERM test for Level 2.


fact: Mr. Lee

reasoning: This paragraph describes how cybersecurity information flows to the board and its Audit Committee, answering 'How does the board oversee cybersecurity?' The named individual Mr. Lee elevates the paragraph to Firm-Specific, as the identification of a specific person responsible for board briefings distinguishes this from generic governance language.


fact: Head of IT with over thirty years of experience in life sciences industry

reasoning: The paragraph's primary focus is describing a named management role (Head of IT), their strategic responsibilities for the IT organization, their qualifications (30 years of experience in life sciences), and their cybersecurity activities. While it mentions cybersecurity activities like reviewing threat intelligence, the core subject is the management role itself—answering 'who manages cybersecurity and what are their credentials.' The over-30-years experience in life sciences industry is a firm-specific fact distinguishing this company's cybersecurity leadership.


reasoning: This paragraph contains two materiality assessments—one backward-looking ('have not materially affected') and one forward-looking ('not reasonably likely to materially affect')—making Strategy Integration the correct category per Rule 5 (SI materiality rule). The paragraph contains no specific facts whatsoever: no domain expertise terms (the ERM test passes—the language is identical to what a financial risk manager would use), no firm-specific identifiers (no named roles, committees, or programs), and no verifiable claims (no numbers, named third parties, or specific dates tied to actual incidents).


fact: Information security certifications as part of expertise profile

fact: Prevention, detection, mitigation, and remediation as domain terminology

reasoning: The paragraph primarily describes WHO is responsible for cybersecurity (management including CCO) and their qualifications/expertise, fitting the MR category over RMP (activities). The expertise language includes domain-specific terms ('information security' certifications) that pass the ERM test—these are cybersecurity-specific credentials beyond what a generic ERM professional would reference—elevating specificity to Level 2, though the CCO role itself is standard across regulated entities and does not distinguish the firm.


reasoning: The paragraph centers on the Principal Accounting Officer's role—receiving reports, working with the incident response team, and assessing materiality—which directly answers how management is organized to handle cybersecurity. The paragraph contains only generic cybersecurity terms ('incident response,' 'vulnerability management') that any public company could use without demonstrating cybersecurity domain expertise, and no firm-specific or externally verifiable facts about BOLT's cybersecurity structure.


fact: IT Security Steering Committee (named committee)

fact: Led by Chief Financial Officer

fact: VP of Software Engineering (named title, firm-specific)

fact: Director of Information Systems and Security (firm-specific Director-level security title)

fact: Collectively over 40 years of experience (specific hard number, externally verifiable)

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity through a governance chain (committee leadership, committee membership, team composition) — fitting Management Role. The specificity is driven by the named IT Security Steering Committee (firm-specific), the specific VP and Director titles (firm-specific security roles), and the verifiable claim of 'over 40 years of collective experience' — a hard number that sets a lower bound checkable against actual resumes.


reasoning: This paragraph is entirely speculative risk language ('could result,' 'if...do not effectively resolve') describing potential future impacts of cybersecurity incidents rather than describing the company's actual cybersecurity governance, management structure, or program activities. The reference to 'business continuity plans' is conditional and hypothetical, not a description of an existing measure. It cross-references Item 1A Risk Factors and makes no substantive disclosure about how the company actually manages cybersecurity — only what might happen if things go wrong. No domain expertise terms, firm-specific facts, or verifiable claims are present.


reasoning: This paragraph is a generic value statement expressing the company's commitment to cybersecurity without describing any specific governance structure, management role, process, or activity. It contains no domain-specific expertise language, no firm-specific facts, and no verifiable claims. It is indistinguishable from boilerplate that could appear in any company's cybersecurity disclosure.


reasoning: The paragraph's central question is how third-party cybersecurity risks are managed — describing reliance on the Adviser's personnel to identify and oversee third-party cyber threats, which is the central topic for TP category. However, the paragraph contains no specific facts: 'suppliers, vendors, and service providers' is a generic listing, the Adviser's personnel (risk management, legal, IT, compliance) are generic roles without names or titles that would distinguish this firm, and no specific cybersecurity tools, frameworks, or vendor oversight mechanisms are mentioned. The language reads as boilerplate that any company relying on an external adviser could use.


reasoning: This paragraph answers the question 'Has/does cybersecurity affect business outcomes?' via a negative backward-looking assertion ('have not materially affected') and a forward-looking belief ('are not reasonably likely to materially affect'), making it Strategy Integration per Rule 5. For specificity: the paragraph contains only negative self-assertions (not externally verifiable per Rule 4 Level 4 examples), subjective beliefs ('we believe'), and a cross-reference — no specific facts, domain expertise, or verifiable claims survive the specificity filters.


reasoning: This paragraph is primarily about materiality assessments — whether cybersecurity incidents have materially affected or are reasonably likely to affect financial condition, results of operations, and business strategy — making it Strategy Integration. It contains no specific verifiable facts, no firm-specific identifiers, and only generic cybersecurity domain language ('security breaches,' 'cyber-based attacks,' 'information systems') that any company could use; the negative assertions about material impact are self-reported claims that cannot be independently verified.


fact: Senior Director - Information Security (title)

fact: over 15 years' experience in information technology and cybersecurity

fact: over 15 years' experience in auditing information security

fact: completed CISO Academy Workshop

fact: BA in math and computer science from Ohio Wesleyan University

fact: Information Systems Auditor certification

reasoning: This paragraph is about the Senior Director - Information Security and describes their qualifications, experience, education, and certifications — fitting the Management Role category. The specificity is Quantified-Verifiable (Level 4) because the paragraph contains multiple externally verifiable facts: specific experience counts ('over 15 years'), a named university degree, a named professional certification (Information Systems Auditor), and a specific training program (CISO Academy Workshop), all of which could be independently confirmed.


fact: Enterprise Risk Management Committee ("ERMC")

fact: "TISC" (Tompkins Information Security Committee)

fact: "Director of Enterprise Risk Management"

fact: "Chief Risk Officer"

fact: "Audit and Risk Committee"

fact: quarterly reporting cadence

reasoning: This paragraph describes the cybersecurity governance chain and oversight structure — the ERMC (a management-level committee) reviewing cybersecurity information and reporting to the Audit and Risk Committee (a board-level committee) on a quarterly basis. The primary question answered is 'How does the board oversee cybersecurity?' through its committee structure and information flow. Specificity is Firm-Specific because it names internal committees (ERMC, TISC), specific leadership titles (Director of Enterprise Risk Management, Chief Risk Officer), and the board committee to whom they report.


reasoning: This paragraph makes a generic aspirational statement about cybersecurity being important to operational strategy but provides no substantive disclosure on any of the six required topics — no governance structure, no management roles, no program activities, no materiality conclusion, no incident details. It contains no domain-specific technical language, no firm-specific facts, and no verifiable claims, making it pure boilerplate at Level 1.


reasoning: This paragraph states a negative conclusion about cybersecurity threats affecting the business (no material threats identified) and discusses insurance coverage—classic Strategy Integration framing under Rule 5 (assessments about whether cybersecurity has/will affect business outcomes). The specificity is Generic Boilerplate because the sole 'fact' is a negative self-assertion about the absence of incidents, which Rule 5 explicitly states is NOT externally verifiable. The insurance reference uses vague qualifiers ('certain liabilities,' 'certain disruptions') without verifiable specifics like coverage amount or named insurer. No hard numbers, named individuals, specific dates, or other verifiable claims are present—only generic disclaimers common to any risk section.


fact: penetration testing of our customer facing domains

fact: quarterly cybersecurity briefings with outside counsel

fact: annual assessment of our overall cybersecurity program

fact: implementation of the CIS Critical Security Controls

fact: written incident response plan

fact: simulated incidents

reasoning: The paragraph primarily describes what the cybersecurity program does (third-party engagements for testing/assessments, incident response plan and testing, CIS Controls implementation), making RMP the central topic. Third-party content here describes engagements BY third parties to serve the company rather than requirements imposed ON vendors, so it remains RMP rather than TP. The specificity is Domain-Adapted because the paragraph demonstrates cybersecurity domain expertise through specific practices (penetration testing, simulated incidents, CIS Critical Security Controls) that an ERM professional would not naturally use without cybersecurity-specific knowledge. No firm-specific identifiers or externally verifiable claims are present.


reasoning: This paragraph's primary purpose is stating a conclusion about business outcomes — specifically that cybersecurity risks have not materially affected (backward) and are not reasonably likely to materially affect (forward) the company — which maps directly to SI under Rule 5. The paragraph contains no domain-specific cybersecurity terminology (passes the ERM test: 'assess risks' and 'evaluate' work for any risk category), no firm-specific facts, and no externally verifiable claims; it is entirely composed of generic boilerplate and self-reported negative assertions about incident absence.


reasoning: This paragraph describes the board's delegation of cybersecurity oversight to the audit committee—textbook Board Governance content. For specificity, the language contains only generic governance roles (board of directors, audit committee) that exist at every public company and uses boilerplate terms ('risk oversight function,' 'risk management program') that any ERM professional could write; no domain-specific security terminology, firm-specific facts, or verifiable claims are present, resulting in Level 1 Generic Boilerplate.


reasoning: The paragraph describes cybersecurity measures in generic, boilerplate language (safeguarding systems, networks, data from unauthorized access, disruption, or misuse) without describing any specific process, framework, tool, or activity that would differentiate it from any other company's disclosure. While RMP is the appropriate category for content about what cybersecurity measures do, this paragraph contains no specific facts whatsoever—only aspirational language about protecting digital assets and information.


reasoning: This paragraph is a negative assertion about the absence of material cybersecurity incidents affecting the business, which constitutes an assessment of whether cybersecurity has impacted business outcomes—fitting the SI category under Rule 5. The paragraph contains no domain-specific cybersecurity terminology, firm-specific details, or verifiable claims; it is entirely generic boilerplate language that could appear in any company's disclosure.


reasoning: This paragraph does not describe any actual cybersecurity program, governance structure, or risk management measures. It is pure risk acknowledgment language about an early-stage company's vulnerability and lack of resources, combined with a negative assertion about past incidents. Per the SI materiality rule, speculative language about potential 'material adverse consequences' does not constitute an actual assessment. The paragraph contains no domain-specific cybersecurity terminology, no firm-specific cybersecurity facts, and no externally verifiable claims—it is standard SPAC boilerplate.


fact: Information security risk committee (management-level committee)

fact: Chaired by Chief Information Security Officer (CISO)

fact: Comprising employees and executive management

fact: Monthly internal reporting to senior leadership and executive team

reasoning: The paragraph primarily describes organizational structure for cybersecurity management—an information security risk committee chaired by a named role (CISO) with specific membership composition and reporting cadences. Per Rule 2, removing person-specific content (CISO title, committee membership) still leaves substantive process content, but the paragraph's grammatical focus on WHO manages (committee, CISO) and how organized (monthly reporting, committee composition) points to Management Role as the primary category. The named committee and CISO title constitute firm-specific facts elevating specificity to Level 3.


fact: Senior Vice President – Technology Solutions (firm-specific title at VP level with security/IT portfolio)

fact: More than 25 years of experience in aggregate (quantified verifiable claim)

fact: More than ten years with the Company (quantified verifiable claim)

reasoning: This paragraph primarily describes the board's cybersecurity oversight structure, with the audit committee as the central governance body responsible for oversight and the management reporting chain flowing from the SVP through the President to the audit committee semi-annually, making it Board Governance. The paragraph contains quantified verifiable facts—specifically the SVP's 'more than 25 years of experience' and 'more than ten years with the Company'—which are externally verifiable through employment records and could be confirmed or refuted by outside parties, elevating it to Level 4 despite the surrounding governance boilerplate.


reasoning: This paragraph is a pure cross-reference directing readers to Item 1A Risk Factors for cybersecurity information. It contains no substantive disclosure about any of the six substantive categories—it does not describe governance, management roles, risk processes, third-party oversight, incidents, or business impact. No specific facts are present.


fact: Two members of the audit committee have obtained certifications in cybersecurity oversight

reasoning: The paragraph is fundamentally about board-level oversight structure—describing which board committee (audit committee) oversees cybersecurity, the reporting cadence (quarterly from CIO/CISO, twice yearly from CRO), and board member expertise (two members with cybersecurity certifications). The specificity is driven by the firm-specific fact that two audit committee members hold cybersecurity oversight certifications, distinguishing this company's board composition from peers.


reasoning: This paragraph describes CEPO's unique position as a blank-check company with no operations and no independent cybersecurity program — it explicitly states they have no personnel or processes of their own for cybersecurity protection. While it touches on cybersecurity risk, it does not answer any of the six substantive questions (board governance, management role, risk management process, third-party risk management, incident disclosure, or strategy integration). Instead, it serves as a contextual explanation for why substantive cybersecurity disclosure is limited, making it None/Other. No domain terminology, firm-specific facts, or verifiable claims are present — only generic statements about blank-check company structure and third-party reliance.


reasoning: The paragraph describes board and Audit Committee oversight structure—information flow from management regarding cybersecurity risks and incidents. It contains no domain-specific security terminology (no tools, frameworks, or practices), no firm-specific details (Board and Audit Committee exist at every public company), and no verifiable facts (reports are described as 'regular' without specifics). This is standard governance boilerplate.


reasoning: The paragraph's central topic is third-party cybersecurity risk management, describing that the company has processes to oversee third-party risks. However, the content contains no domain-specific expertise (no mention of specific security tools, frameworks, or practices that would pass the ERM test), no firm-specific facts (no named roles, committees, or specific programs), and no verifiable claims (the quantity 'several' is soft/hedged). The language is entirely generic boilerplate about engaging 'third-party consultants' and having 'processes and procedures' — terms any ERM professional could use without cybersecurity expertise.


reasoning: The paragraph describes third-party vendor cybersecurity oversight (TP), stating the Sponsor conducts risk assessments of vendors with network access. However, it contains no specific facts that elevate it above boilerplate — 'rigorous,' 'robust,' and 'align with our cybersecurity standards' are generic descriptors without domain-specific terminology, firm-specific identifiers, or verifiable claims. The language would apply equally to any regulated entity's vendor risk management program.


reasoning: This is a risk factor section header (appears to be Item 1A risk factor title rather than substantive Item 1C cybersecurity disclosure) that describes potential consequences in speculative 'could' language without describing any actual cybersecurity governance, program activities, or incidents. No substantive cybersecurity disclosure is present.


fact: Mr. Tao — named individual

fact: more than 20 years of professional experience — verifiable lower bound

reasoning: The paragraph describes a named individual's qualifications and experience, which directly answers how management is organized and who holds key roles — Management Role. The phrase 'more than 20 years' provides a hard, verifiable lower bound, elevating this to Level 4 despite the paragraph's brevity.


reasoning: The paragraph describes how the board (specifically the audit committee) receives cybersecurity updates from the executive team — a classic board governance question. However, specificity is Level 1 because all elements are generic: 'audit committee' is a standard governance role at every public company, 'executive team' is a generic term, and 'regular updates' provides no specific cadence or firm-unique detail. The language demonstrates awareness that cybersecurity oversight exists, but no domain expertise or firm-specific facts.


fact: Director of Information Security and Privacy (leadership title)

fact: CISSP certification (Certified Information Systems Security Professional)

fact: CCSP certification (Certified Cloud Security Professional)

reasoning: The paragraph's primary focus is describing the cybersecurity leadership structure — the Director of Information Security and Privacy role, their decades of experience, and their certifications. While a substantial list of security activities follows (penetration testing, phishing campaigns, vulnerability scanning, etc.), the grammatical subject and lead content establish organizational structure around named leadership. The CISSP and CCSP certifications are externally verifiable credentials — they can be confirmed through (ISC)² certification registries — making this Quantified-Verifiable level. The Director of Information Security and Privacy title is also firm-specific, distinguishing this company's leadership structure.


reasoning: This paragraph is a simple cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk information. It contains no substantive disclosure about any cybersecurity topic — no governance, management organization, program activities, third-party oversight, incidents, or business impact. The entire paragraph is a pointer to another section.


fact: January 18, 2023 (specific incident date)

fact: ransomware attack (specific threat type)

fact: fewer than 300 restaurants closed (specific quantifiable impact)

fact: closed in one market for one day (specific scope)

fact: personal information of former and current employees was affected (specific data type)

fact: no evidence that customer databases were accessed (specific negative finding)

reasoning: This paragraph describes a specific cybersecurity incident—the January 18, 2023 ransomware attack—with concrete details including the exact date, a verifiable number of affected restaurants (fewer than 300), the duration (one day in one market), and the scope of data accessed (former/current employee personal information, no customer data). The specificity level is QV because the date and restaurant count are hard facts that could be independently verified through external sources such as news reports or public statements.


reasoning: The paragraph describes JLL's use of third-party consultants as part of the cybersecurity program (testing and advisory services for risk identification and incident response). Per Rule 3, third parties hired to serve the company are part of the RMP, not TP. The paragraph contains no firm-specific facts (no named vendors, specific tools, or quantified details), no verifiable claims, and the language used ('assessing, identifying and managing material risks,' 'testing and advisory services') is generic domain boilerplate that any company could use — failing the ERM test for domain expertise.


reasoning: The paragraph describes the board's oversight structure for cybersecurity—Audit Committee designation, reporting lines from the CFO, and annual Board updates—but all terms are generic governance language (Audit Committee, independent directors, CFO) that exist at every public company. No named individuals, no distinguishing committee identifiers, no specific cadence (only 'regular' and 'at least annual'), and no cybersecurity domain expertise shown—only standard ERM oversight language any business professional could write. This is identical boilerplate to hundreds of other Item 1C disclosures.


reasoning: The paragraph is a speculative disclaimer about future cybersecurity incidents that redirects readers to Item 1A Risk Factors. It contains no substantive cybersecurity disclosure about actual incidents, governance, processes, or business impact. It qualifies as None/Other. No domain terms, firm-specific facts, or verifiable claims are present — purely boilerplate speculation.


reasoning: The paragraph provides generic definitional context about information security rather than describing any specific governance, management organization, program activities, or business impact. It contains no firm-specific facts, named individuals, named programs, or domain-specific security practices beyond basic threat categories.


reasoning: The paragraph contains a backward-looking negative assertion ('have not, as of the date of this 2024 10-K, experienced a cybersecurity threat or incident that resulted in a material adverse impact') which maps to SI per Rule 5. However, this negative self-assertion is not externally verifiable — you cannot independently confirm the absence of something — and the forward-looking disclaimer is pure boilerplate present in virtually every 10-K. No domain expertise terms, firm-specific facts, or verifiable claims are present, yielding Generic Boilerplate.


reasoning: The paragraph centers on third-party service provider cybersecurity oversight — describing contract review processes and security amendments — which squarely fits TP as the central topic. However, the paragraph contains only generic operational language ('implementing processes,' 'actively reviewing,' 'upon renewal') with no domain-specific terminology, firm-specific identifiers, or verifiable claims; specificity is Generic Boilerplate.


reasoning: The paragraph's substantive content is a backward-looking negative assertion ('To date... have not materially affected') about cybersecurity's impact on business outcomes, which qualifies as Strategy Integration per Rule 5. The opening sentence is generic speculative language ('could materially impact') and the cross-reference to Item 1A is N/O context. There are no specific facts present—no domain terminology (fails the ERM test), no firm-specific details, and the negative assertion about past incidents is not independently verifiable—resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes the Board's oversight role and the structure of board-level review/approval of cybersecurity matters, which directly answers 'How does the board oversee cybersecurity?' — making it Board Governance. The paragraph contains no specific facts: it uses only generic governance language ('the Board will oversee,' 'a dedicated committee of the Board or an officer appointed by the Board'), no named committees or individuals, no technical security terminology (all terms pass the ERM test as generic risk management language), and no verifiable or firm-specific details.


reasoning: The paragraph describes elements of the cybersecurity risk management program (asset identification, assessment, monitoring, classification procedures), which maps to Risk Management Process. However, the language is entirely generic — 'asset identification,' 'assessment,' 'monitoring,' and 'classification procedures' are standard ERM terms that any risk management professional could use regardless of cybersecurity expertise. No specific security tools, named frameworks, firm-specific roles, or verifiable claims are present. This is pure boilerplate describing the general function of a cybersecurity program without demonstrating how this company actually operates it.


reasoning: The paragraph primarily answers 'How does cybersecurity affect the business or finances?' through its opening assertion that cybersecurity risks 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 a direct SI materiality statement per Rule 5. The specificity is Generic Boilerplate because the paragraph contains only standard business and cybersecurity terminology (cybersecurity threats, preventative actions, controls) with no firm-specific facts (no named roles, committees, or programs), no domain expertise beyond generic ERM-level language, and no verifiable claims.


reasoning: The paragraph describes board-level oversight of cybersecurity risk through the Board and Audit Committee—a classic Board Governance framing. No specific facts elevate this above generic boilerplate: 'Board' and 'Audit Committee' are generic governance roles present at every public company, and the language ('oversees processes,' 'may review measures,' 'identify and mitigate') contains no domain-specific terminology, named programs, leadership roles, or verifiable claims. A non-cybersecurity ERM professional would write identical language about financial or operational risk.


reasoning: The paragraph describes how cybersecurity findings flow to the Board's Enterprise Risk and Compliance Committee (ERC Committee), making Board Governance the primary category. However, this paragraph contains no specific facts—no named individuals, no cybersecurity domain terminology, no quantified claims, and no firm-specific organizational details beyond referencing a committee type that exists broadly across public companies. It is pure boilerplate about reporting structure with no elevatory content.


reasoning: This paragraph is a backward-looking negative assertion stating that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company—answering the SI question of whether cybersecurity affects business outcomes. It contains no domain terminology (would read identically in any ERM or non-cyber context), no firm-specific details (no named roles, committees, or programs), and no verifiable claims (no numbers, dates, named third parties, or specific certifications)—making it purely boilerplate.


category_confidence: low

reasoning: The paragraph is primarily a negative assertion that the company has experienced no material cybersecurity incidents and has not implemented specific policies—forward-looking disclaimers and what the company lacks, not substantive disclosure of what it does. No domain-specific security practices, tools, or frameworks are named; 'keeping up to date our information systems and educating our personnel' fails the ERM test as generic IT hygiene any company could claim. Zero specific facts appear; one verifiable negative assertion ('no material incidents') does not elevate specificity.


reasoning: This paragraph directly answers the question 'Has cybersecurity materially affected or will it materially affect the business?' through an explicit backward-looking assessment ('have not identified material risks...that have materially affected us') and forward-looking statement ('reasonably likely to materially affect us'), both of which are hallmarks of Strategy Integration per Rule 5. It contains zero specific facts—only standard SEC boilerplate language, cross-references to Risk Factors, and self-reported negative assertions (which are not externally verifiable per the specificity rules). The paragraph describes no cybersecurity measures, processes, or organizational specifics, making Generic Boilerplate the correct specificity level.


reasoning: The paragraph states a backward-looking assessment that cybersecurity has not materially affected the company's strategy, results, or financial condition — which qualifies as Strategy Integration per Rule 5. It contains no specific facts, domain terminology, firm-specific details, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph explicitly describes the Company's Third-Party Risk Management program and its activities (conducting vendor risk assessments, requiring vendor cybersecurity controls, monitoring vendor compliance), making Third-Party Risk the primary category. However, all described activities are generic boilerplate—no specific standards (SOC 2, NIST), no named assessors, no specific tools, and 'periodic' is a soft descriptor. This contains no domain-specific terminology beyond generic risk management language, no firm-specific identifiers, and no verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes what the cybersecurity program does (assess, identify, and manage risks) with policies and controls reviewed through assessments, making it clearly about risk management process. However, it contains no domain-specific terminology (no specific tools, frameworks, or security practices), no firm-specific facts (no named roles, committees, or team compositions), and no verifiable claims (no specific numbers, dates, or named assessors) — only generic ERM-style language that any company could use, yielding Level 1.


reasoning: This paragraph states Charles River's general cybersecurity philosophy—placing importance on identifying and mitigating threats to various assets. While it gestures toward a risk management purpose, it provides no concrete processes, practices, or specifics. The language ('identifying and mitigating potential cybersecurity threats') is fully swappable with generic ERM language for any risk category and demonstrates no cybersecurity domain expertise. No specific facts, firm-unique details, or verifiable claims are present.


reasoning: This paragraph is a protective disclaimer containing negative assertions ('have not identified,' 'cannot eliminate all risks') and a cross-reference to Risk Factors. It does not substantively answer any of the six category questions—no incident description, no governance oversight description, no management organization, no program activities, no third-party risk management, and no actual business impact assessment. The first sentence is a negative self-assertion (absence of material incidents) that fails the SI materiality rule, and the remainder is standard liability-limiting boilerplate with no domain expertise, firm-specific facts, or verifiable claims.


reasoning: The paragraph describes the board's oversight structure for cybersecurity risk, directly answering how the board oversees cybersecurity threats — clearly Board Governance. However, it contains only generic governance language ('board of directors,' 'audit committee,' 'executive officers') that any public company could use, with no cybersecurity domain expertise, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


fact: Chief Risk Officer designated as Chief Privacy Officer

fact: Chief Privacy Officer has held various leadership roles including over 13 years previously serving as Chief Financial Officer

fact: Chief Information Security Officer has over 20 years of work experience in cybersecurity at financial institutions

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity—specifically the roles, responsibilities, reporting relationships, and qualifications of the Chief Privacy Officer and CISO. The Chief Privacy Officer/CRO has dual oversight responsibilities and coordinates with the CISO, while the CISO handles day-to-day management of the Information Security Program. The specificity is elevated to Level 4 by the quantified verifiable credentials: over 13 years as CFO and over 20 years of cybersecurity experience at financial institutions—these are hard numbers about named roles that could be independently verified through public records or background checks.


reasoning: The paragraph primarily describes cybersecurity program activities—evaluating safeguards, managing risk assessments, monitoring/testing safeguards, and employee training—making RMP the fitting category. For specificity, the phrase 'IT leadership reports to our Chief Executive Officer' references only a generic role title without quantified detail, and all described processes use language any ERM professional would employ without cybersecurity domain expertise (no security-specific tools, standards, or architectural concepts). No firm-specific facts or verifiable claims are present, yielding Generic Boilerplate.


reasoning: This paragraph primarily answers 'How does cybersecurity affect the business or finances?' through a negative materiality assertion—that cybersecurity threats have not materially affected business strategy, results of operations, or financial condition—making it Strategy Integration. It contains no specific facts whatsoever: no named individuals, committees, security tools, quantified claims, or domain-specific terminology; only generic boilerplate language about not identifying material risks.


reasoning: The paragraph is a materiality assessment stating that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company—triggering Strategy Integration under Rule 5. The paragraph contains no specific facts, dates, numbers, or named entities; it is purely a generic boilerplate disclaimer with a cross-reference to Risk Factors.


fact: Incident occurred in Q3 FY2023

fact: Zero-day vulnerability in a third-party vendor's file transfer application

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

fact: Expenses recorded for investigation and remediation (referenced to Note 15)

fact: Company: MAXIMUS, INC. (MMS)

reasoning: This paragraph describes a specific real incident (Q3 FY2023 material cybersecurity incident involving a zero-day exploit of a third-party vendor's file transfer application, affecting personal information of a significant number of individuals) with verifiable details including the quarter of occurrence, technical nature of the attack vector, and reference to recorded expenses in financial disclosures, making it Incident Disclosure at Level 4.


reasoning: This paragraph describes the board's oversight structure for cybersecurity risks, specifically identifying the Board's overall responsibility and the Technology Committee's delegated oversight role with reporting to the Board — all of which answers the Board Governance question. However, the paragraph contains no firm-specific cybersecurity facts (no named cybersecurity officers, specific committee charters, or firm-distinguishing details), no domain expertise beyond generic risk management language, and no externally verifiable claims — making it purely structural governance boilerplate with no informative content about DexCom's actual cybersecurity posture.


reasoning: The paragraph describes the Audit Committee's oversight role over risk management including cybersecurity — clearly a Board Governance disclosure. However, it contains no specific facts: 'Audit Committee' is a generic governance structure found at every company, 'regular review' is a vague cadence, and the language about 'risk assessment and risk management policies' is generic ERM terminology that any business professional could write — it fails the ERM test for domain expertise. The paragraph is entirely boilerplate with no named individuals, dates, numbers, or firm-specific identifiers.


reasoning: This paragraph primarily explains the regulatory framework and SEC disclosure rules that apply to the company rather than describing how the company actually manages cybersecurity. It cross-references a section that would contain substantive information and describes SEC's enacted rules rather than BankPlus' own cybersecurity program, governance, or practices. No facts about the company's specific cybersecurity measures, leadership, or processes are provided.


fact: regularly scanning our environment for vulnerabilities

fact: performing penetration testing

fact: engaging third parties to assess the effectiveness of our technical cybersecurity practices

reasoning: The paragraph describes what the cybersecurity program DOES (risk assessments, vulnerability scanning, penetration testing, third-party assessments), making it a Risk Management Process disclosure. The specificity is Domain-Adapted because the language contains cybersecurity-specific terms ('scanning our environment for vulnerabilities,' 'performing penetration testing,' 'technical cybersecurity practices') that an ERM professional would not use when discussing non-cybersecurity risks — these demonstrate cybersecurity domain expertise beyond generic risk management language.


reasoning: This paragraph is a risk disclaimer combining a negative assertion about past incidents with forward-looking speculation about future cybersecurity threats. It contains no substantive description of the cybersecurity program (no risk assessment methodology, no specific policies or procedures, no tools or practices). The reference to 'various cybersecurity policies and procedures' is generic boilerplate that any company could state. The paragraph primarily cross-references Risk Factors rather than providing the Item 1C disclosure itself.


reasoning: The paragraph's primary function is stating a negative assessment about whether cybersecurity incidents affected business outcomes (no material impact on strategy, financial condition, or results of operations), which maps to Strategy Integration per Rule 5. The specificity is Generic Boilerplate because the paragraph contains only self-reported negative assertions about absence of incidents (not independently verifiable per Rule 5 guidance), no domain expertise terms, no firm-specific identifiers, and no hard numbers—it's generic forward-looking and risk-disclosure language found in virtually any public company's 10-K.


reasoning: This is a standard forward-looking statement disclaimer that appears in SEC filings. It contains no substantive cybersecurity disclosure whatsoever — it is purely legal boilerplate about projections and risk factors. No cybersecurity measures, processes, or assessments are described.


reasoning: The paragraph directly answers how the company manages third-party cybersecurity risks through diligence, contractual protections, and security rating services — making TP the correct category. However, all described methods are generic vendor oversight practices with no specific details: no named vendors, specific tools, quantified thresholds, or domain-specific terminology that would elevate specificity beyond Level 1.


reasoning: This paragraph describes the board's oversight responsibilities (policy implementation and corporate commitment) in generic terms that any public company could use. The language ('continued and consistent implementation,' 'promoting overall corporate commitment') lacks any firm-specific details, named roles, domain terminology, or verifiable claims that would elevate specificity above Level 1.


reasoning: The paragraph describes how the company manages third-party cybersecurity risks through vendor risk assessments and contractual obligations, making Third-Party Risk the primary category. However, all content is generic boilerplate—the listed provider types (research collaborators, CROs, contract manufacturers) are standard in the pharmaceutical industry, and the assessment triggers (onboarding and contract renewal) are universal vendor management practices. No domain-specific terminology, firm-specific identifiers, or externally verifiable claims are present.


fact: GDPR

reasoning: This paragraph describes what the cybersecurity program does—its methodology for identifying, monitoring, and addressing threats, including third-party vendor scope—which maps to Risk Management Process. The paragraph references three named frameworks (ISO 27001, NIST 800-53, GDPR) that pass the ERM test—these are specific cybersecurity domain standards that demonstrate expertise beyond generic risk management language. No firm-specific facts (no named leadership, no specific tools, no organizational structure) and no quantified verifiable claims are present.


reasoning: This paragraph is a cross-reference to Item 1A plus a non-verifiable negative assertion about incident history; it answers no substantive cybersecurity question and contains no domain terms, firm-specific facts, or verifiable claims.


reasoning: This paragraph is a forward-looking risk factor that speculates about what cybersecurity incidents 'could' expose or 'may cause' — it describes threats and potential impacts but no actual cybersecurity measures, governance structure, or program activities. Per Rule 5's SI materiality exception, 'could have a material adverse effect' language is speculation present in every 10-K, not a substantive materiality assessment. The specificity is Level 1 because generic threat descriptions (computer viruses, hackers, employee misconduct) contain no domain-specific technical language, no firm-specific claims, and no verifiable facts — any public company could write this paragraph.


reasoning: This paragraph describes the regulatory framework governing cybersecurity disclosures (federal banking agency oversight, SEC rules with specific effective date of December 18, 2023, four-day disclosure timeline) and cross-references another section. It does not describe actual governance practices, management organization, or cybersecurity program activities—it merely explains what regulations apply. Since no substantive cybersecurity governance, management, risk management, or strategy content is provided, this is None/Other. The specificity date ('December 18, 2023') and timeframe ('four business days') are regulatory parameters, not facts about the company's cybersecurity posture.


reasoning: The paragraph is centrally about third-party service provider cybersecurity risks and mentions monitoring those risks, making TP the appropriate category. However, it contains no domain expertise (no specific security controls, tools, or practices), no firm-specific facts (no named roles, committees, or programs), and no verifiable claims (no numbers, certifications, or named third parties) — it is entirely generic boilerplate.


reasoning: The paragraph describes the Board's oversight role over cybersecurity risks, management reporting to the board, and periodic CIO sessions — all governance-chain content about how the board oversees cybersecurity (→ Board Governance). The language ('oversees,' 'regularly reviews,' 'policies and procedures,' 'management team') passes the ERM test — it is generic oversight language any ERM professional could write about any risk category. No cybersecurity-specific domain terminology, no firm-specific roles beyond generic titles, and no externally verifiable claims are present.


reasoning: The paragraph describes vendor management processes for cybersecurity risks—specifically reviewing provider practices, imposing contractual obligations, conducting assessments and inspections, and requiring questionnaires. This directly answers 'How are third-party cyber risks managed?' making it Third-Party Risk. The specificity is Generic Boilerplate because all content consists of generic process descriptions ("conducting security assessments," "requiring written questionnaires," "conducting annual re-assessments") that use vocabulary any ERM professional could apply to any risk domain—no domain-specific cybersecurity terms, no named frameworks, no firm-specific details, and no verifiable claims.


reasoning: This paragraph describes an actual cybersecurity incident at UNFI (unauthorized activity on IT systems in Q4 fiscal 2025, containment actions, and operational/financial impacts), making it Incident Disclosure. However, while the paragraph provides firm-specific context about what happened, all substantive claims are qualitative rather than quantifiable — 'reduced sales volume' and 'increased operational costs' lack specific dollar amounts or quantities that could be externally verified. The specificity is therefore Generic Boilerplate.


fact: Ransomware discovered on a server in August 2020

fact: Engaged third-party forensics experts and outside counsel for incident response

fact: Did not pay ransom because documents were backed up

fact: Investigation confirmed no employee data or personal information was accessed

fact: Implemented security enhancements during and after the incident

reasoning: The paragraph describes a specific real cybersecurity incident (ransomware in August 2020), including the nature of the threat, response actions taken (engaging forensics experts and counsel), the investigation's findings (no data accessed), and remediation measures. Per Rule 4, this is clearly Incident Disclosure as it focuses on what happened, the timeline, and the response. The August 2020 date and specific incident details (server, ransomware, forensics engagement) are externally verifiable claims, making this Level 4 specificity.


reasoning: The paragraph describes third-party vendor oversight requirements—security risk assessments for providers, remediation or termination based on risk, and contractual security provisions—which directly answers the TP question of how third-party cyber risks are managed. However, the paragraph contains no firm-specific identifying details (no named programs, tools, assessors, or specific practices), no verifiable claims (no certifications, specific numbers, or externally confirmable facts), and all described measures are generic third-party risk management practices that any company could state.


reasoning: The paragraph describes the Board's general awareness of cybersecurity risks and its oversight responsibilities, which directly answers the Board Governance question about how the board oversees cybersecurity. However, the paragraph contains no specific facts—only generic boilerplate language about board awareness and oversight that could appear in any public company's filing. There are no named committees, specific practices, quantified metrics, or any detail that would distinguish Greene County Bancorp's governance from any other reporting company.


fact: FedEx Executive Committee oversees business risk with cybersecurity threat risks as regular topic

fact: CISO reports to the Chief Executive Officer

fact: CyTOC (Cybersecurity Technical Oversight Committee) named as management body

fact: DTRC (Digital Technology Risk Committee) named as management body

fact: Incident response plan includes processes for communicating to Executive Committee, CyTOC, DTRC, and full Board of Directors

reasoning: The paragraph describes the governance chain for cybersecurity oversight at FedEx—how information flows from CISO through management committees (CyTOC, DTRC, Executive Committee) to the Board of Directors. This is classic Board Governance content explaining the oversight structure and reporting lines. Specificity is elevated to Firm-Specific by the presence of two named FedEx-specific committees (CyTOC, DTRC) that would not appear in any other company's filing, combined with the specific CISO-to-CEO reporting line and the named Executive Committee overseeing cybersecurity risk.


reasoning: The paragraph describes the board's oversight structure for cybersecurity—specifically identifying the Audit Committee and Technology Steering Committee as responsible for cybersecurity risk management oversight. While this is a Board Governance topic, it uses entirely generic language ('general oversight function,' 'overseeing processes,' 'cybersecurity threats') that any public company could use. There are no domain-specific security terms (no frameworks, tools, practices), no firm-specific identifiers (the committee name 'Technology Steering Committee' is fairly generic), and no verifiable claims. This reads as standard boilerplate with no informative specificity.


reasoning: This paragraph answers whether cybersecurity has materially affected the business (the company has not experienced material incidents), which is a backward-looking materiality assessment → Strategy Integration per Rule 5. The specificity is Generic Boilerplate because all claims are negative assertions about the absence of incidents, which cannot be externally verified; no domain-specific security terminology, firm-specific roles/programs, or quantifiable verifiable facts are present.


reasoning: The paragraph describes the oversight pathway from senior management to the Audit Committee for material cybersecurity matters, which is a board governance question. It contains no firm-specific facts (Audit Committee and senior management are generic governance structures that exist at every public company), no named individuals, no specific processes, and no cybersecurity domain expertise beyond the topic itself — making it Level 1 Generic Boilerplate.


reasoning: This paragraph describes the company's general reliance on technology infrastructure and outlines the broader cybersecurity threat landscape (types of attacks, threat actors, AI/ML trends), but it does not describe any specific cybersecurity program, process, or activity that the company undertakes. It describes WHAT the company relies on and WHAT threats exist in the abstract, not what the company DOES in response. There is no mention of risk assessment methodology, security tools, monitoring processes, or incident response capabilities—the actual mechanisms of a cybersecurity program.


reasoning: This paragraph is purely a cross-reference with speculative 'may be affected' language pointing to Item 1A Risk Factors. It contains no substantive cybersecurity disclosure—no description of governance structure, management organization, program activities, or actual incident. Per Rule 6, pure speculation without measures or processes is N/O. No facts are present (no domain expertise terms used in context of describing a program, no firm-specific details, no verifiable claims).


reasoning: The paragraph describes board-level cybersecurity oversight structure (audit committee role, regular reporting cadence, incident escalation path to board), which is the core question of Board Governance. However, all facts are generic governance elements found in every public company—audit committee, Board of Directors, CEO, CFO, CISO, General Counsel—and no domain-specific terminology (no named frameworks, security tools, or specific practices) or firm-specific identifiers (named individuals, specific committee names, named programs) are present.


fact: Senior Vice President and Chief Information Officer (CIO) - VP-level title with cybersecurity relevance

fact: CIO has over 25 years of IT Risk Management experience

fact: Cybersecurity team has more than 30 years of collective information and product security experience

fact: Team composition includes early-career professionals with cybersecurity degrees and seasoned professionals with multiple cybersecurity-related certifications

reasoning: The paragraph is primarily about Management Role because it focuses on organizational structure: the CIO position (title, experience), the cybersecurity team's composition and collective experience level, and their responsibilities. While governance reporting to the Board is mentioned, the primary purpose is describing how management is organized. Specificity reaches Level 4 because the CIO's specific VP-level title, the quantified experience figures (over 25 years, more than 30 years collective), and the team's composition with distinct credential categories are externally verifiable facts about the organization's cybersecurity leadership.


reasoning: The paragraph describes the organizational structure for cybersecurity oversight — who bears responsibility (management, CCO), what third-party resources are engaged, and how information flows to management. This answers 'how is management organized to handle cybersecurity?' However, the paragraph contains no firm-specific identifiers (third-party IT provider is unnamed), no named individuals, no verifiable claims, and no domain expertise beyond generic cybersecurity terminology ('real time threat detection and mitigation'). All content is standard boilerplate that could appear in any company's 10-K Item 1C.


reasoning: This paragraph is a cross-reference/bridge statement that makes general observations about cybersecurity threats and redirects readers to Item 1A for substantive risk disclosures. The materiality language ('could have a material impact') is speculative boilerplate per Rule 5, not a stated conclusion about actual or reasonably likely effects. No substantive cybersecurity measures, processes, or assessments are described. The specificity is Generic Boilerplate because no domain expertise, firm-specific facts, or verifiable claims are present—only generic threat language that any public company could use.


fact: CISO role at Roivant

fact: Scope: cybersecurity strategy centrally at Roivant and the majority of our Vants

fact: CISO experience specializing in safeguarding healthcare data across health technology companies

reasoning: The paragraph centers on the CISO's role and qualifications—specifically who holds the position, their primary responsibilities, and career experience specializing in healthcare data protection. Per Rule 2, this is MR because the CISO is the grammatical and conceptual subject, with role responsibilities and credentials as the core content. The specificity is firm-specific because it names the CISO role at Roivant, references the company's unique 'Vants' subsidiary structure, and describes the CISO's specialized experience in healthcare data safeguarding—a detail that narrows identification to healthcare-focused firms. No verifiable quantified claims are present.


fact: Vice President, Information Security and Privacy

fact: Senior Vice President, Chief Strategy and Digital Officer

reasoning: The paragraph describes board-level oversight of cybersecurity (Audit Committee role, quarterly briefings, review scope), which directly answers 'How does the board oversee cybersecurity?' — making Board Governance the primary category. The two named officer roles (VP of Information Security and Privacy, and SVP Chief Strategy and Digital Officer) constitute firm-specific facts at Level 3, as they identify specific leadership roles with security-relevant portfolios. No domain expertise terms (security tools, frameworks, specific practices) are present that would elevate to Level 2, nor any externally verifiable claims for Level 4.


reasoning: This paragraph is a pure cross-reference directing readers to Item 1A for cybersecurity risk factors. It contains no substantive cybersecurity disclosure—no description of governance, management structure, security processes, or incident information. Under Rule 6, N/O applies when no actual cybersecurity measure, process, or assessment is described. No domain terminology, firm-specific facts, or verifiable claims are present, making this generic boilerplate.


fact: threat assessments

fact: proactive detection tools

fact: audits

reasoning: The paragraph describes the company's cybersecurity program activities—engaging external experts to evaluate and test risk management systems, conduct audits and threat assessments, and deploy proactive detection tools. Under Rule 3, external assessors hired to serve the company are classified as RMP, not TP. The paragraph contains domain-specific terminology ('threat assessments,' 'proactive detection tools,' 'security enhancements') that an ERM professional would not naturally use outside a cybersecurity context, indicating domain expertise beyond generic risk management language.


reasoning: The paragraph is clearly about third-party risk management as the central topic, describing their process for identifying, assessing, and mitigating third-party cybersecurity risks. However, the specificity is Level 1 because the description uses only generic ERM terminology ('initial assessment,' 'additional risk assessment,' 'contracting process') without demonstrating cybersecurity domain expertise — the assessment criteria ('network access, data access, information systems access') are standard risk categories any ERM professional would use. No firm-specific facts (no named programs, roles, or thresholds), no hard numbers, and no externally verifiable claims are present.


reasoning: The paragraph describes using a third party to assess cybersecurity processes and practices, which answers 'What does the cybersecurity program do?' — placing it in RMP. However, all language is generic: 'processes and practices for managing and mitigating cybersecurity risks' is interchangeable with any risk category language an ERM professional would use. No domain-specific security terminology (tools, frameworks, practices), no named assessors, no firm-specific details, and no verifiable claims are present. The paragraph provides no meaningful specificity beyond noting that third-party assessment exists.


reasoning: The paragraph's primary purpose is stating a negative assertion about cybersecurity's impact on business outcomes ('we are not aware of any risks...that have materially affected the Company'), which matches SI's backward-looking materiality assessment. The paragraph contains no specific facts—only boilerplate language including a negative self-assertion (which is not externally verifiable per Rule 5) and a cross-reference to Risk Factors.


fact: CISO (Chief Information Security Officer)

fact: Security Steering Committee

fact: CEO and CTO involvement

fact: CSIRT (Computer Security Incident Response Team)

fact: PSIRT (Product Security Incident Response Team)

reasoning: The paragraph describes management-level organizational structure — the CISO and Security Steering Committee (a named management committee, not board-level) overseeing cybersecurity alongside the CEO and CTO. It explains reporting relationships (CSIRT/PSIRT informing the CISO). The named roles and committee structure are firm-specific facts that distinguish this company's cybersecurity management organization.


fact: CIO and CISO lead the cybersecurity program

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

fact: Board of Directors delegates cybersecurity oversight to Audit Committee

fact: CISO and CIO report to Audit Committee at least annually

fact: Cybersecurity integrates into ERM via quarterly business reviews and annual budget planning

reasoning: The paragraph's dominant focus is the Board Governance chain (Board → Audit Committee → CISO/CIO), which frames the entire disclosure; the verifiable claim about 20+ years of experience for named roles (CIO, CISO) elevates specificity to Level 4.


reasoning: This paragraph is a negative assertion stating the absence of material cybersecurity incidents during 2023 — a forward/backward-looking assessment of business impact fitting Strategy Integration per Rule 5. However, it contains no specific facts: no hard numbers, no named individuals, no verifiable external claims, no domain terminology demonstrating cybersecurity expertise, and no firm-specific distinguishing details. The specificity level is therefore Generic Boilerplate.


fact: Fortra, LLC is the named third-party vendor that experienced a data security incident

fact: The incident involved GoAnywhere managed file transfer as a service system (MFTaaS)

fact: The threat actor exploited a zero-day vulnerability in Fortra's systems

fact: Affected data included protected health information (as defined by HIPAA) and personally identifiable information

fact: Outside experts were engaged to assist in investigating and responding to the incident

fact: Notifications were provided to data owners, affected individuals, and various State Attorneys General

reasoning: This paragraph describes a specific real-world incident (the Fortra GoAnywhere MFTaaS breach) with verifiable details: named vendor, named product, zero-day exploit method, HIPAA-defined data types, outside experts engaged, and regulatory notifications sent. The highest specificity comes from externally verifiable claims (named vendor, specific product, regulatory data categories, named response actions).


reasoning: The paragraph describes third-party cybersecurity risk management as its central topic, answering 'How are third-party cyber risks managed?' with a description of due diligence, evaluation of practices, and contractual requirements. However, the language consists entirely of generic vendor risk management terminology (due diligence, evaluating practices, contractual commitments) that any ERM professional could apply to any risk category — it does not demonstrate cybersecurity domain expertise. No firm-specific facts (no named vendors, specific contractual terms, or quantifiable metrics) are present, and no domain-specific security terminology appears that would elevate it beyond Level 1.


reasoning: The paragraph describes third-party IT service provider dependency and the company's vendor management process, directly answering how third-party cyber risks are managed. However, it contains no specific facts: no named vendors, no specific security requirements imposed, no specific evidence obtained, and no domain-specific terminology (like SOC 2, encryption standards, or specific assessment methodologies) that would demonstrate cybersecurity expertise beyond generic risk management language.


fact: malware detection (domain term)

fact: phishing simulations (domain term)

reasoning: The paragraph describes what the cybersecurity program does (a multi-faceted security awareness program with trainings, simulations, and exercises), which directly answers 'What does the cybersecurity program do?' — making it RMP. The specificity is Domain-Adapted because terms like 'malware detection' and 'phishing simulations' demonstrate cybersecurity-specific vocabulary that a non-security ERM professional would not naturally use, passing the ERM test.


reasoning: The paragraph's primary function is disclosing the ABSENCE of a cybersecurity program—explicitly stating the company has 'not adopted any cybersecurity risk management program or formal processes for assessing cybersecurity risk.' This is not describing a cybersecurity governance structure, management role, or program—it is stating that none exists. No specific facts about cybersecurity measures, tools, frameworks, or verifiable claims are present; only negative assertions about the lack of any program.


fact: external and internal penetration testing

fact: tactics and techniques of cyber threat actors

fact: remediate identified vulnerabilities

fact: onboarding risk assessments prior to engagement

fact: cybersecurity-related contractual terms

fact: periodic risk assessments throughout the life cycle

reasoning: The paragraph's central topic is third-party service provider oversight—describing onboarding risk assessments, contractual security requirements, and ongoing lifecycle monitoring—which directly answers how third-party cyber risks are managed (→ TP). While the opening sentence addresses penetration testing (RMP) and closing sentence mentions insurance (SI), the majority of text describes the company's TP oversight methodology. The specificity level is Domain-Adapted because the paragraph demonstrates cybersecurity domain expertise in its specific references to penetration testing approaches, vulnerability remediation across severity levels, and contractual/assessment mechanisms for vendor oversight—language a generic ERM professional would not naturally use for non-cyber risks. No firm-specific or externally verifiable facts are present.


reasoning: The paragraph's central topic is third-party vendor cybersecurity oversight, describing Ashland's risk-based approach to identifying and managing cyber risks from vendors, especially those handling sensitive data like PII and trade secrets—this maps directly to Third-Party Risk (TP) under Rule 3. For specificity, while the paragraph mentions 'third-party vendor management program' and specific data types (PII, trade secrets), it contains no verifiable facts, firm-specific identifiers, or cybersecurity-specific domain terms that would pass the ERM test; the language is generic enough that swapping 'cybersecurity' for any other risk type would read identically, yielding Generic Boilerplate (Level 1).