content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, including integration into enterprise risk management. It contains no specific names, frameworks, or verifiable facts, making it generic boilerplate.

provider: google


content_category: Strategy Integration

reasoning: The paragraph discusses general cybersecurity risks and concludes with a standalone materiality statement regarding the impact of these risks on the company's business and financial condition.


content_category: Board Governance

reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities and reporting structure, making Board Governance the primary category. It is classified as Firm-Specific because it names specific internal committees and roles (Audit Committee, ERM Committee, CIO, VP Infrastructure).


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident, including the date of determination and the company's response actions, which falls squarely under Incident Disclosure.


reasoning: The paragraph details the company's internal risk management structure, specifically identifying the departments involved in their cybersecurity team, which classifies it as a Risk Management Process.


reasoning: The paragraph describes the company's internal risk management framework (ERM and ERA) and how cybersecurity is integrated into that process. It is classified as Firm-Specific because it names the company's specific internal programs (ERM and ERA) and provides a specific count of risk categories.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the affected system, and the scope of the unauthorized access, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access) and the company's immediate response actions, which falls squarely under Incident Disclosure. It is classified as Firm-Specific because it names the company and the specific date of the incident.


reasoning: The paragraph describes an ongoing cybersecurity incident, including the timeline and the nature of the threat actor, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of determination and the company's response actions, which fits the Incident Disclosure category.


content_category: Management Role

reasoning: The paragraph focuses on the responsibilities and reporting lines of the Chief Technology Officer, which is a management role. It is classified as Firm-Specific because it identifies specific roles (Chief Technology Officer, General Counsel) involved in the governance structure.


reasoning: The paragraph describes the company's internal risk management processes, including the frequency of reviews and the specific roles involved in those processes.


reasoning: The paragraph explicitly discusses the board of directors' oversight role and the specific delegation of cybersecurity risk review to the audit committee, making it a clear Board Governance disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents, which falls under Strategy Integration. It contains no specific facts, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery and the nature of the event (unauthorized access and encryption), which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the ongoing status and potential impact of a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on identifying specific management roles (CIO, Information Security Director) and their qualifications, which falls under Management Role. It reaches the Quantified-Verifiable level because it provides specific, verifiable metrics regarding the years of experience for these named roles.


reasoning: The paragraph describes a specific cybersecurity incident, including the date the company took action to isolate systems, which qualifies as an incident disclosure.


reasoning: The paragraph explicitly discusses the board of directors' oversight responsibilities and reporting cadence, placing it squarely in Board Governance. It is Firm-Specific because it identifies the 'audit committee' as the specific body responsible for reporting to the board.


reasoning: The paragraph describes how cybersecurity risk management is integrated into the company's broader enterprise risk management framework, which is a core component of internal risk management processes.


reasoning: The paragraph describes the company's internal process for evaluating vendors as part of their broader risk management framework. While it mentions third-party vendors, it does not provide specific oversight details or contractual standards, making it a description of internal process rather than third-party risk management.


reasoning: The paragraph describes a specific cybersecurity incident that occurred on a specific date and details the company's response actions, which is the definition of an incident disclosure.


reasoning: The paragraph describes the oversight relationship between the Committee and the Board regarding cybersecurity, which falls squarely under Board Governance. It contains no specific names of committees, roles, or dates, making it generic boilerplate.


reasoning: The paragraph describes the company's ongoing response to a cybersecurity incident and provides a materiality assessment, which aligns with the Incident Disclosure category. It contains no specific, verifiable facts or unique identifiers, rendering it generic boilerplate.


content_category: None/Other

reasoning: The paragraph consists entirely of forward-looking disclaimers and a cross-reference to another section of the filing, containing no substantive cybersecurity disclosure.


reasoning: The paragraph discusses the financial strategy regarding the incident, specifically the pursuit of insurance reimbursement, which falls under Strategy Integration.


reasoning: The paragraph provides a standalone materiality conclusion regarding the impact of an incident, which falls under Strategy Integration according to the tiebreaker rules.


reasoning: The paragraph describes ongoing incident response activities (forensic analysis) related to a previously mentioned incident, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's response actions to an ongoing cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific facts (e.g., names of firms, dates, or specific systems), making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal processes for incident response, business continuity, and risk evaluation. It is classified as Firm-Specific because it names specific internal roles (Chief Security Officer) and internal programs (Incident Response Program, Business Continuity Plan).


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including specific training cadences and testing frequencies. It qualifies as Quantified-Verifiable because it contains multiple verifiable facts, such as the quarterly frequency of phishing tests and the annual frequency of penetration testing.


reasoning: The paragraph describes the company's general reliance on IT and standard risk management activities like monitoring and infrastructure development, without referencing specific frameworks, roles, or unique programs.


reasoning: The paragraph explicitly defines the composition of the company's internal 'Risk Management Team' by listing specific roles, which is the primary focus of the text.


reasoning: The paragraph details the company's internal risk management processes, including framework adoption, infrastructure, and training. It is classified as Firm-Specific because it identifies specific internal bodies like the 'Technology Committee' and 'Internal Audit team' involved in the process.


reasoning: This paragraph is a standard legal disclaimer regarding forward-looking statements and safe harbor provisions, which is boilerplate language and does not contain substantive cybersecurity disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of materiality determination, the nature of the unauthorized access, and the operational impact, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (website defacement), the timeline of events, and the company's response actions, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of the threat actor's communication, the nature of the data involved, and the company's specific response actions.


reasoning: The paragraph describes specific details of a cybersecurity incident, including dates, scope of impact, and financial remediation efforts, which clearly falls under Incident Disclosure.


category_confidence: low

reasoning: The paragraph is a general forward-looking risk discussion of potential impacts from cyber threats and includes a standalone materiality-style statement that cybersecurity risks have not materially affected the company. It does not describe any incident or internal program details beyond generic conditional language.

provider: openai


reasoning: The paragraph is explicitly about the Board’s Audit Committee’s oversight duties and reporting cadence (quarterly) for cybersecurity risk, including receiving reports from specific management roles.


specificity_confidence: medium

reasoning: The paragraph describes Emergent BioSolutions’ internal cybersecurity program integration with its ERM, including how risks are assessed, mitigated, monitored, and reported. It includes company-specific process details (ERM/ERA structure and the 12 risk categories), making it more than generic boilerplate.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment and mitigation activities and how they are integrated into its enterprise risk management, including likelihood/impact assessment and control identification. No board/management role, specific incident details, or vendor oversight requirements are central to the text.


reasoning: The paragraph describes a real cybersecurity incident (third-party unauthorized access) with response actions (incident response/business continuity protocols, containment, investigation, engagement of cybersecurity expertise, and law-enforcement notification) and includes a specific determination date (March 10, 2024).


reasoning: The paragraph describes a real cybersecurity incident (unauthorized third-party access) with a specific detection date, describes response actions (external experts, law enforcement notification, containment/remediation), and explains business impacts (disruptions/limited access to financial and operating reporting systems).


reasoning: The paragraph describes an actual cybersecurity incident (nation-state actor gaining access and exfiltrating employee email data) with ongoing activity and investigation results, which is classic incident disclosure. It includes a specific timeframe (late November 2023) and details about affected account types and subsequent attempts to access source code repositories.


reasoning: The paragraph narrates a specific real incident (unauthorized access) with a dated discovery, affected system (Dropbox Sign), and details of accessed data types and preliminary impact assessments.


reasoning: The paragraph describes the Company’s internal cybersecurity threat identification and risk management processes (team structure, monitoring methods, assessments, and IT investment). Third parties are mentioned only as part of these internal processes, not as the central subject.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access by a third party), provides a specific determination date (March 10, 2024), and states remediation and operational disruption, which is characteristic of incident disclosure.


reasoning: The paragraph centers on the CTO’s specific responsibilities and reporting/meeting relationship with General Counsel, which is management-role governance over cybersecurity. It includes unique role details and a quantified experience threshold.


reasoning: This paragraph is a standalone materiality/impact statement about known and potential cybersecurity risks, with a cross-reference to the Risk Factors section, but no incident narrative or internal/board process description.


reasoning: The paragraph is explicitly about board and audit committee oversight and reporting on cybersecurity risk management. It contains no company-specific entities beyond generic roles/titles (board, audit committee, management), so it reads as common boilerplate governance language.


reasoning: The paragraph describes the company’s internal process for reviewing cybersecurity within enterprise risk management (biannual review, mitigation plans, and annual board review), making Risk Management Process the primary category. It includes named management roles (CISO, CIO) and specific review cadences, but no hard external metrics or named programs beyond roles.


reasoning: This paragraph centers on named management roles (CIO, Information Security Director) and the cybersecurity team’s responsibilities, along with the directors’ experience and expertise.


reasoning: The paragraph discusses an ongoing cybersecurity incident and states that it is reasonably likely to have a material impact on business operations until recovery is completed, which is characteristic of incident disclosure. It does not provide concrete incident details (e.g., dates, systems, scope) or other firm-unique facts.


reasoning: The paragraph describes a real cybersecurity incident, including the date it was discovered, the threat actor’s actions (illegal access and encryption), and response steps (containment, investigation, external specialists, access restriction). It therefore fits Incident Disclosure and includes multiple externally verifiable specifics.


reasoning: The paragraph describes that cybersecurity risk management procedures are incorporated into the company’s enterprise risk management program, but it does not name any specific roles, systems, dates, frameworks, or unique details.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized occurrences), provides a concrete date (May 1, 2024), and details response actions such as activating the incident response plan, shutting down IT systems, and notifying law enforcement.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized activity), containment/assessment/remediation actions, and incident-response steps. It includes a specific date (December 20, 2023) but no named experts, systems, regulators, or quantified impacts, so it is firm-specific rather than quantified-verifiable.


reasoning: This paragraph describes incident-related actions (notifying/cooperating with law enforcement and assessing regulatory notification obligations) and includes materiality conclusions tied to the incident. However, it provides no incident specifics (dates, systems, scope) beyond generic response and materiality language.


reasoning: The grammatical subject is the board committee (“The Committee”) and it describes oversight/receiving reports and reporting activities related to cybersecurity. The paragraph is generic (no named committee, roles, cadence, dates, systems, frameworks, or incident details).


category_confidence: medium

reasoning: The paragraph describes the company’s own cybersecurity risk management process for assessing vendors (risk-based vendor evaluation criteria), not vendor oversight as the central topic. It includes general internal-process details but no named frameworks, dates, roles, or uniquely verifiable external facts.


reasoning: This paragraph is a standalone materiality conclusion stating the incident is not reasonably likely to materially impact financial condition or results of operations, with no incident narrative or other company-specific details.


reasoning: This paragraph is a generic disclaimer about the possibility of material adverse effect and cross-references Item 1A, without describing any incident, named roles, frameworks, or firm-specific details.


reasoning: The paragraph describes an ongoing cybersecurity incident with forensic analysis, investigation status, and whether conclusive evidence has been identified—core incident disclosure language.


reasoning: The paragraph is centered on the board (and specifically the audit committee) overseeing and receiving updates on cybersecurity processes, including a minimum reporting cadence of at least annually.


reasoning: The paragraph discusses insurance reimbursement for costs/expenses/losses related to a cyber incident and notes timing/amount uncertainty, which is framed as financial/strategic impact rather than describing incident details or internal controls.


reasoning: The paragraph describes ongoing restoration efforts after a disruption/incident and includes incident-response actions (retaining experts, coordinating with law enforcement, notifying regulators), but provides no firm-specific identifiers, dates, or quantified scope.


reasoning: This paragraph is a standalone materiality conclusion using generic conditional/legal language and does not describe an incident or internal processes. It states the company’s conclusion about whether the incident is reasonably likely to materially impact financial condition or business results.


reasoning: The paragraph is primarily generic risk-factor language about cybersecurity threats and potential impacts, with only broad statements that the company “continuously monitor[s] and develop[s]” its networks. It does not describe a specific internal process in enough detail to qualify as a firm-specific risk management program.


reasoning: The paragraph describes Wendy’s own cybersecurity risk management strategy and internal processes (controls framework, assessments, infrastructure, personnel, and training). It includes firm-unique details such as the Internal Audit team review and the Technology Committee of the Board, indicating a Risk Management Process category with firm-specific specificity.


reasoning: This paragraph is purely forward-looking safe-harbor and disclaimer language about expectations and potential differences, with no incident narrative details or company-specific cyber facts.


reasoning: This paragraph is centered on the company's named internal management structure (CFO, CLO, Sr. Director of IT, etc.) and its reporting/briefing responsibilities to the Audit Committee, which is management-role governance for cyber risk.


reasoning: This paragraph describes S&T’s internal incident response and business continuity processes (evaluation criteria, CSO role, escalation, incident response program, training/testing). While it references third-party managed systems, the central topic is S&T’s own risk management program, not vendor oversight as the primary focus.


reasoning: The paragraph describes a real cybersecurity incident (defaced website), specific dates, the affected domain, repeated defacement after restoration, response actions (taking site down, forensic specialists, FBI notification), and resulting operational/financial impact (cancelled seminar).


reasoning: This paragraph describes a real cybersecurity incident (unauthorized access and exfiltration), its assessed material impact, response actions (shutting down systems to isolate from the Internet), notifications intent, and restoration/residual remediation steps.


reasoning: The paragraph describes the company’s internal cybersecurity risk management program (threat assessment, layered security, training, and third-party assessment processes). It also includes multiple concrete, externally verifiable details such as quarterly phishing testing, annual penetration testing/reviews, and specific compliance/standards (NIST, ISO, SOC-1, SOC-2).


reasoning: The paragraph describes an identified cybersecurity incident and provides concrete investigation results (accounts accessed, accounts affected, data deletion) plus specific compensation amounts and dates, which is classic incident disclosure with verifiable metrics and timing.


reasoning: The paragraph describes a specific cybersecurity event (email from an unknown threat actor), includes dates, details of how data was accessed, and documents response actions (termination, fraud-monitoring, customer warnings) plus non-payment and law enforcement cooperation.


reasoning: The paragraph details the company's own internal processes for assessing, identifying, managing cybersecurity risks, and integrating them into enterprise risk management, directly matching Risk Management Process. Mention of third-party providers is a minor component within these processes, not the central topic.

provider: x-ai


reasoning: The paragraph describes potential business and financial impacts from cybersecurity risks and includes a standalone materiality conclusion that such risks have not materially affected the company to date, with no incident narrative, aligning with Strategy Integration. It contains no named entities, frameworks, dates, roles, or verifiable facts, making it generic boilerplate.


reasoning: Paragraph describes the company's internal multi-stakeholder team and processes for identifying, assessing, and managing cybersecurity risks, including monitoring methods, with vendors as a component rather than the central focus. Team composition with specific departments is a firm-unique fact, qualifying as Firm-Specific but not reaching Quantified-Verifiable without two+ verifiable metrics.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risks, including report cadences from named committees and roles, fitting Board Governance as the board committee is the primary subject. Multiple named committees and roles confirm Firm-Specific detail without reaching Quantified-Verifiable thresholds like dates or metrics.


reasoning: Paragraph describes the company's internal ERM and ERA processes for risk assessment, prioritization (including 12 cybersecurity categories), monitoring quarterly, and reporting, which fits Risk Management Process as the central topic of own processes. No board or management as subjects, no vendors central, no incidents.


reasoning: This paragraph describes a real cybersecurity incident with details on timing, affected system (Dropbox Sign), scope of data access, response actions, and limitations, directly matching Incident Disclosure criteria. It contains multiple verifiable facts including a specific date and named systems/products, exceeding the threshold for Quantified-Verifiable.


reasoning: Paragraph describes a real cybersecurity incident with what happened (unauthorized access by third party to portions of information environment), when (determined on March 10, 2024), scope, detection, containment measures, disruptions, ongoing investigation, and response actions (engaged expertise, notified law enforcement), clearly fitting Incident Disclosure.


reasoning: This paragraph details an actual cybersecurity incident, including the date of detection, unauthorized access to IT systems, response actions like activating procedures, engaging external experts, notifying law enforcement, and operational disruptions, clearly fitting Incident Disclosure. It includes one verifiable firm-specific fact (the date), qualifying as Firm-Specific per the decision test.


reasoning: Paragraph describes a real cybersecurity incident with timeline (late November 2023), scope (small percentage of emails from specific teams), affected systems (source code repositories), and ongoing response, clearly fitting Incident Disclosure over other categories.


reasoning: This paragraph describes a real cybersecurity incident including the determination date, unauthorized access to portions of the information environment, immediate response protocols, containment measures, business disruption, and remediation, directly matching Incident Disclosure criteria with incident narrative over financial impact. It contains one firm-unique verifiable fact (specific incident date), qualifying as Firm-Specific per the decision test.


reasoning: The paragraph focuses on the Chief Technology Officer's responsibilities, qualifications, and reporting line to the General Counsel, making 'Management Role' the clear fit as management roles are the grammatical subjects. No board or processes are central; it's about role identification and structure.


reasoning: Paragraph describes the company's internal enterprise risk management processes, including biannual reviews with participation from CISO, CIO, business segments, and executive management, plus annual Board review and cross-functional mitigation, fitting Risk Management Process. Names specific roles (CISO, CIO) unique to the company, qualifying as Firm-Specific with no frameworks or additional verifiable facts for higher levels.


reasoning: Paragraph states no material past cybersecurity impacts but acknowledges potential future material effects, qualifying as a standalone materiality conclusion under Strategy Integration. No specific facts, named entities, frameworks, dates, or unique details present, confirming Generic Boilerplate.


reasoning: The paragraph focuses on identifying specific management roles (CIO, Information Security Director), their qualifications, experience, and responsibilities, making 'Management Role' the clear fit. No board oversight or internal processes are the primary subject.


reasoning: The paragraph describes the board of directors' oversight of cybersecurity risks and delegation to the audit committee, making the board and committee the grammatical subjects, which directly matches Board Governance. No other category fits as well, as it focuses on governance structure rather than internal processes or incidents.


reasoning: The paragraph details the status of an ongoing cybersecurity incident investigation, its known material impact on business operations, and uncertainty on financial effects, which describes a real event and aligns with Incident Disclosure per tiebreaker for incident narrative plus financial impact. No named entities, dates, frameworks, roles, or verifiable facts are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph details a real cybersecurity incident, including the detection date, unauthorized access by a threat actor, encryption of data files, and specific response actions like internal investigation and engaging external specialists, clearly fitting Incident Disclosure. It contains one firm-unique verifiable fact (specific date), qualifying as Firm-Specific with no frameworks or additional verifiable details.


reasoning: This paragraph details a real cybersecurity incident, including the detection date, unauthorized access to IT systems, and specific response actions like investigation, system shutdown, and law enforcement notification, clearly fitting Incident Disclosure. It includes one verifiable firm-specific fact (the date), qualifying as Firm-Specific per the decision test.


reasoning: This paragraph details a real cybersecurity incident, including unauthorized activity detection, containment/remediation steps, system isolation on a specific date, and coordination with experts/law enforcement/regulators, matching Incident Disclosure criteria. It focuses on event narrative and response, not processes or governance.


reasoning: Paragraph details incident response actions (notifying law enforcement, assessing regulatory obligations) and financial materiality assessment for a specific incident, aligning with Incident Disclosure per category definition and tiebreaker for incident-related financial impact.


reasoning: The paragraph describes integration of cybersecurity risk management into the company's enterprise risk management programs, sharing methodologies, reporting, and governance, which directly matches Risk Management Process (ERM integration). No specific facts, frameworks, roles, or unique details are present, confirming Generic Boilerplate.


reasoning: The paragraph details the company's own internal cybersecurity risk management process, including a risk-based evaluation of third-party vendors as a component, which aligns with Risk Management Process per tiebreakers rather than central Third-Party Risk focus. It contains no named entities, frameworks, dates, roles, or unique firm-specific facts, making it generic boilerplate.


reasoning: This paragraph is a forward-looking disclaimer about potential cybersecurity incidents and a cross-reference to Risk Factors, providing no substantive disclosure on any cybersecurity topic.


reasoning: The paragraph focuses on the Committee's receipt of reports and updates from management on cybersecurity risks and incidents, as well as its reporting to the full Board, which directly matches Board Governance criteria where the board or committee is the grammatical subject.


reasoning: The paragraph centers on the board of directors' oversight of cybersecurity risks and its information flow from the audit committee, directly matching Board Governance criteria where the board or committee is the grammatical subject.


reasoning: This paragraph contains a standalone materiality conclusion stating the incident is not reasonably likely to materially impact financial condition or results of operations, which aligns with Strategy Integration. It lacks any incident narrative, process details, or other category elements.


reasoning: This paragraph describes ongoing incident response actions (forensic analysis and investigation) for a specific cybersecurity incident, fitting Incident Disclosure as it includes response details tied to a real event without narrative of the event itself. No specific facts, frameworks, or unique company details are present, making it generic boilerplate.


reasoning: This paragraph provides a standalone materiality conclusion regarding the Incident's impact on financial condition and operations, with no incident narrative or other details, fitting Strategy Integration per guidelines. No specific facts, frameworks, roles, or verifiable details are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes response actions to a cybersecurity incident, including system restoration, retaining experts, working with law enforcement, and notifying regulators, which fits Incident Disclosure. It contains no specific facts, names, dates, or frameworks, making it generic boilerplate incident response language.


reasoning: The paragraph describes the company's internal efforts to monitor and develop IT networks for preventing, detecting, and mitigating cyber risks, fitting Risk Management Process. No specific frameworks, roles, dates, or unique facts are mentioned, making it generic boilerplate.


reasoning: The paragraph details a specific response action (submitting insurance claims for reimbursement) stemming from 'the cyber incident,' which qualifies as an incident response action under Incident Disclosure rather than general strategy or insurance discussion. No named entities, dates, amounts, or other verifiable facts are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph details the company's internal processes for evaluating cybersecurity incidents, escalation procedures, Incident Response Program, Business Continuity Plan, training, testing, and risk reassessment, aligning with Risk Management Process; third-party vendors are mentioned only as a minor component of business continuity plans, not centrally.


reasoning: This paragraph consists entirely of a forward-looking statement disclaimer and safe harbor provisions, referencing 'the Incident' without any substantive cybersecurity disclosure, cross-referencing other filings, which fits 'None/Other'.


reasoning: The paragraph details the company's own internal cybersecurity risk management processes, including adoption of the CIS framework, annual assessments, regular risk assessments integrated with ERM, infrastructure design, dedicated personnel teams, and training programs. Board committee review is mentioned as a component but not the central focus.


reasoning: The paragraph describes the company's own internal processes for cybersecurity risk management, including threat assessment, layered security, training, tools, third-party assessments, and vendor risk checks, with vendors as one component rather than the central focus.


reasoning: This paragraph details a real cybersecurity incident with narrative on unauthorized access, exfiltration, response actions (investigation, notifications, system shutdowns, restoration), and operational impacts, directly matching Incident Disclosure; tiebreaker prioritizes incident narrative over materiality mention.


reasoning: This paragraph describes a real cybersecurity incident with details on what happened (website defacement), timeline (August 25, 2025), response actions (restoration from backups, site takedown, forensic specialists, FBI report), and impacts (canceled seminar, financial losses), clearly fitting Incident Disclosure per guidelines and tiebreaker for incident narrative plus financial impact.


reasoning: This paragraph describes updates on a real cybersecurity incident, including specific dates, scope of access (33 million accounts, 3,000 with data saved and deleted), perpetrator identification and cooperation, and response actions like a compensation program, directly matching Incident Disclosure. Financial impacts are integrated into the incident narrative rather than standalone.


reasoning: This paragraph details a real cybersecurity incident including date of notification, method of breach (paid contractors/employees outside US), scope (customer accounts, internal docs on specific systems), detection, response actions (terminations, monitoring, customer warnings, law enforcement cooperation), fitting Incident Disclosure. Contains one verifiable date and named subsidiary firm, qualifying as Firm-Specific but not two+ for Quantified-Verifiable.


reasoning: The paragraph details the company's internal Risk Management Team composition, their monitoring of cybersecurity risks, continual risk exercises and assessments, quarterly meetings to discuss threats and controls, and briefings to the Audit Committee, focusing on the company's own internal risk management processes. While board oversight is mentioned as a recipient of updates, the core topic is the internal processes rather than board as the primary subject.