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, which falls squarely under Risk Management Process. It contains no specific dates, named roles, named tools, or unique identifiers, making it generic boilerplate.

provider: google


content_category: Strategy Integration

reasoning: The paragraph discusses the potential business and financial impact of cybersecurity risks and concludes with a statement that such risks have not materially affected the company, which aligns with the Strategy Integration category.


content_category: Board Governance

reasoning: The paragraph focuses on the Board's oversight role regarding cybersecurity risks and incident reporting, making 'Board Governance' the primary category. It contains no specific facts (roles like CEO/General Counsel and committees like the Board are excluded by the rules), resulting in a 'Generic Boilerplate' specificity rating.


reasoning: The paragraph describes the company's internal risk management structure and processes for identifying and assessing cybersecurity threats. It is classified as Firm-Specific because it identifies a unique team composition involving specific departments (Legal, Compliance, and Finance).


reasoning: The paragraph describes the company's internal risk management processes, specifically how they utilize third parties to assist with policy design and monitoring. While it mentions third parties, the central topic is the company's own internal risk management framework rather than vendor oversight as a standalone risk management strategy.


content_category: Management Role

reasoning: The paragraph focuses on the identification, reporting lines, and qualifications of the Information Security Officer (ISO), which is the primary subject of the text.


content_category: None/Other

reasoning: The paragraph consists of a standard materiality disclaimer and a cross-reference to other sections of the filing, containing no substantive cybersecurity disclosure.


reasoning: The paragraph describes the company's internal risk management framework and processes, specifically how cybersecurity is integrated into their ERM and ERA programs.


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


reasoning: The paragraph describes the company's internal approach to managing cybersecurity risks and maintaining system integrity, which falls under Risk Management Process. It is classified as Sector-Adapted because it explicitly references ISO and NIST frameworks without providing firm-specific details.


reasoning: While the paragraph mentions the Board, the central focus is the identification and qualifications of the specific management role (HSE Director) responsible for the cybersecurity program.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities regarding cybersecurity, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it explicitly names the CIO and CISO as participants in these reviews, which are cybersecurity-specific roles.


reasoning: While the paragraph mentions Board oversight, the primary focus is on the specific management roles (VP, IT Data Security; CTO) and the internal Cybersecurity Committee structure, making 'Management Role' the most appropriate category.


reasoning: The paragraph describes the company's internal cybersecurity program, incident response planning, and risk assessment activities, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named third-party firms, or specific cybersecurity roles, making it generic boilerplate.


reasoning: The paragraph focuses on the board's delegation of cybersecurity oversight to the Audit Committee and the reporting structure to that committee, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies specific management roles (Vice President of Operation & Information Technology and Head of Information Technology) responsible for reporting to the board.


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management, including the use of specific frameworks and cross-departmental collaboration. It is categorized as Risk Management Process because it details the company's own internal assessment and defense strategies.


reasoning: This paragraph is a cross-reference to the Risk Factors section and contains no substantive cybersecurity disclosure.


reasoning: The paragraph describes the company's internal risk management and monitoring processes, including the role of an internal team and the use of third-party consultants. It contains no specific dates, named tools, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses entirely on the oversight responsibilities of the Audit Committee and the Board of Directors regarding cybersecurity. All entities mentioned (Audit Committee, Board, management) are considered generic under the provided guidelines, and no specific dates, tools, or unique programs are cited.


reasoning: The paragraph describes the company's internal incident response and escalation procedures, which falls under Risk Management Process. It is Firm-Specific because it names unique internal roles and committees (Senior Director of Information Security, Technology Risk Management Committee, Materiality Committee) rather than just generic management or board references.


reasoning: The paragraph consists entirely of forward-looking disclaimers and a cross-reference to a risk factor, with no substantive disclosure regarding governance, management, or specific processes.


reasoning: The paragraph focuses primarily on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity, making 'Board Governance' the primary category. While it mentions management roles, the board oversight is the central subject, and the mention of the CISO is a specific fact that elevates the specificity to Firm-Specific.


reasoning: The paragraph focuses on the identification, qualifications, and reporting lines of the CISO/CDIO, which is the primary definition of the Management Role category.


reasoning: The paragraph describes the company's internal cybersecurity program, incident response planning, and monitoring processes, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it explicitly references the NIST framework but lacks other firm-specific or verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity program and risk management processes. It contains no specific facts (no named frameworks, roles, dates, or tools), relying entirely on generic descriptions of security practices.


reasoning: The paragraph describes internal security practices like incident response planning, business continuity, and training, which falls under Risk Management Process. It contains no specific dates, named roles, named tools, or named frameworks, making it generic boilerplate.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the CIO and senior leadership regarding cybersecurity oversight, making 'Management Role' the primary category. It is classified as 'Firm-Specific' because it identifies the CIO and the ERM Committee, which are specific organizational details.


reasoning: The paragraph describes the company's internal processes for cybersecurity, such as incident identification, response, and testing, without naming specific tools, frameworks, or unique organizational structures.


reasoning: The paragraph focuses on the board's oversight role and provides a standalone materiality conclusion regarding past and potential future incidents without describing specific events or internal processes in detail. The mention of 'consultants' is generic and does not constitute a specific management role or firm-specific detail.


reasoning: The paragraph focuses on the Board of Directors' oversight role and reporting cadence, which places it squarely in Board Governance. It contains no specific facts (only generic roles like CEO/CFO/Audit Committee and generic cadences), resulting in a Generic Boilerplate classification.


reasoning: The paragraph focuses primarily on the Board and Audit Committee's role in cybersecurity oversight, which aligns with the Board Governance category. It is classified as Sector-Adapted because it references the NIST Cybersecurity Framework but lacks firm-specific details.


reasoning: The paragraph focuses on the Board's oversight responsibilities and the specific structure of its committees, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies a unique internal entity, the 'Cybersecurity Risk Subcommittee', which is not a standard or generic committee.


reasoning: The paragraph focuses on the responsibilities, qualifications, and role of the CISO, which is a cybersecurity-specific management role.


reasoning: The paragraph describes the company's internal incident detection and response processes, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it explicitly references the NIST Cybersecurity Framework (NIST CSF) but lacks other firm-specific or verifiable details.


reasoning: The paragraph describes the company's internal cybersecurity risk management policies, procedures, and strategy, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it explicitly references the NIST Cybersecurity Framework but lacks other firm-specific or quantified details.


reasoning: The paragraph focuses on the identification, qualifications, and reporting lines of the CISO and the Information Security team, which falls squarely under Management Role. It contains multiple verifiable facts, including specific certifications and years of experience, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph primarily describes the company's internal risk management program and its integration into the broader ERM framework. While it mentions the Board and specific roles, the core subject matter is the operational process of managing cybersecurity risk.


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident that occurred in October 2023, including the nature of the event and the subsequent response actions, which classifies it as an Incident Disclosure.


reasoning: The paragraph focuses primarily on the specific roles (Director, IT Infrastructure & Security; VP of IT) and their responsibilities, making 'Management Role' the most appropriate category.


reasoning: The paragraph focuses on the potential material impact of cybersecurity threats on business strategy and financial standing, which falls under Strategy Integration. It mentions no specific facts; the roles mentioned (CEO, CFO) are generic, and 'MSP' is an unnamed entity.


reasoning: The paragraph describes the company's internal cybersecurity program, processes, and risk management framework adoption. It is classified as Firm-Specific because it explicitly claims maintenance of an ISO 27001 certification, which is a verifiable firm-specific fact beyond merely naming a standard.


reasoning: The paragraph focuses on the Board and its committees' oversight responsibilities, specifically detailing the establishment and role of the Cybersecurity Subcommittee.


reasoning: The paragraph describes internal training programs and preparedness exercises, which are components of the company's risk management process. It contains no specific facts, named tools, or unique identifiers, relying entirely on generic descriptions of common security practices.


reasoning: The paragraph describes the company's internal processes for assessing cybersecurity, managing vulnerabilities, and monitoring threats, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named third-party firms, or specific cybersecurity roles, making it generic boilerplate.


reasoning: The paragraph focuses on the Board's oversight structure and the delegation of cybersecurity risk responsibilities to the Audit Committee. All mentioned entities (Board, Audit Committee, management) are generic, and the reporting cadence is described as 'periodic', which does not meet the threshold for specific facts.


reasoning: The paragraph primarily focuses on a materiality conclusion regarding cybersecurity threats and past incidents, which falls under Strategy Integration. While it mentions a past incident, it does not describe the incident's nature, scope, or response, making it a materiality statement rather than an incident disclosure.


reasoning: The paragraph focuses on the responsibilities of the Enterprise Risk Management Committee and specific management roles (CISO, CDO) in overseeing cybersecurity risks, making 'Management Role' the most appropriate category.


content_category: Third-Party Risk

reasoning: The paragraph focuses primarily on the company's oversight of third-party providers, including contractual requirements and assessment processes, which aligns with the Third-Party Risk category. It contains no specific dates, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the role and qualifications of the CISO and the composition of the Information Security Council, which are management-related governance structures.


reasoning: The paragraph primarily describes the company's internal processes for employee training and third-party risk management, with third-party oversight presented as a component of the broader internal risk management framework. While it mentions third-party providers, the focus is on the company's own assessment and monitoring processes rather than the vendors themselves.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents without describing any specific event or internal process, which falls under Strategy Integration.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for the fiscal year, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year (fiscal 2025), which is a verifiable fact unique to this filing.


reasoning: The paragraph focuses on the qualifications, background, and reporting lines of the Chief Information Security Officer, which is the primary subject of the text.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and the frameworks used to guide it, which falls squarely under Risk Management Process.


reasoning: The paragraph focuses primarily on the responsibilities, qualifications, and reporting lines of the Vice President of Information Technology and Information Security Officer, making 'Management Role' the most appropriate category.


reasoning: The paragraph describes the company's general approach to using external experts and conducting training as part of its internal security processes. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph primarily describes the company's internal risk management processes, specifically how they integrate cybersecurity risk into their ERM program and align with the NIST framework.


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 describes a specific cybersecurity incident, including the date of detection, the nature of the event, and the company's response actions, which clearly falls under Incident Disclosure.


reasoning: The paragraph is a forward-looking disclaimer regarding the limitations of cybersecurity controls and includes a cross-reference to the Risk Factors section, containing no substantive cybersecurity disclosure.


reasoning: The paragraph describes the company's intended internal risk management processes and framework adoption. While it mentions the Board of Directors, the primary focus is on the implementation of risk management programs, assessment processes, and security tools, making 'Risk Management Process' the most appropriate category.


reasoning: The paragraph describes the company's general approach to risk management and cybersecurity processes without providing any specific details, frameworks, or unique identifiers.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risk, including risk assessments and control implementation. It is classified as Sector-Adapted because it references specific industry frameworks (CIS and PCI DSS) without providing firm-specific details like named roles or unique programs.


reasoning: The paragraph describes the ongoing nature and scope of a specific cybersecurity incident, including the timeline and affected systems, which constitutes an incident disclosure.


reasoning: The paragraph focuses primarily on the Board of Directors' and Audit Committee's oversight responsibilities regarding cybersecurity, making 'Board Governance' the correct category. It is classified as 'Firm-Specific' because it identifies a cybersecurity-specific role (CSO), which is a unique identifier according to the provided guidelines.


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


reasoning: The paragraph describes a specific cybersecurity incident, including the timeline of detection and response, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes an ongoing cybersecurity incident, including the nature of the breach (exfiltration of video meeting images) and the operational/financial impact, which places it squarely in Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of determination and the nature of the event, which classifies it as an Incident Disclosure.


reasoning: The paragraph describes the scope and nature of a specific cybersecurity incident, including the type of data accessed and the number of accounts affected, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including dates of detection and occurrence, and details about the nature of the unauthorized access and data exfiltration.


reasoning: The paragraph describes the scope and nature of data impacted by a cybersecurity incident, which is the core definition of Incident Disclosure. It contains no specific dates, dollar amounts, or named third-party firms, rendering it Generic Boilerplate in terms of specificity.


reasoning: The paragraph describes the status and impact of a specific cybersecurity incident, including remediation efforts and operational impact, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, rendering it generic in specificity.


reasoning: The paragraph describes an actual cybersecurity incident, including the scope (third-party provider's environment) and the nature of the data accessed, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, rendering it Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident (website defacement), including the date of occurrence and the affected system, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the ongoing investigation, scope, and impact of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, rendering it Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence, response actions taken, and the operational impact, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the nature and impact of a cybersecurity incident, including unauthorized access and operational disruption, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, relying instead on generic descriptions of the event.


reasoning: The paragraph is a standard legal disclaimer regarding forward-looking statements and safe harbor provisions, which contains no substantive cybersecurity disclosure.


reasoning: The paragraph focuses on the materiality assessment and financial impact of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence, the nature of the attack, and the ongoing operational impacts, which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes the financial impact and ongoing assessment of a specific cybersecurity incident, which falls under Incident Disclosure. It is Firm-Specific because it provides a unique, quantified financial estimate related to a specific event, though it only contains one hard verifiable fact (the dollar range), preventing it from being Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the event (unauthorized access, encryption, data theft), and the company's response actions, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the operational impact and recovery status of a previously disclosed cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, dollar amounts, named third-party firms, or other verifiable facts that would elevate it beyond boilerplate status.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of notification, the threat actor involved, and the timeline of the unauthorized access, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident involving a named subsidiary, including the date of discovery and the company's response actions, which qualifies as an incident disclosure.


reasoning: The paragraph focuses on the company's assessment of the materiality of the incident regarding financial condition and insurance coverage, which falls under Strategy Integration. It contains no specific dates, named entities, or verifiable facts, relying entirely on boilerplate language regarding materiality and insurance.


reasoning: The paragraph describes a specific cybersecurity incident, including the timeline of the event, the nature of the disruption, and the company's response actions, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the status, operational impact, and financial consequences of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It contains multiple verifiable facts, including a specific date and a dollar amount, qualifying it as Quantified-Verifiable.


reasoning: The paragraph focuses on the financial impact of the incident (insurance recovery) and provides a materiality assessment, which aligns with Strategy Integration. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the financial impact and materiality assessment of an incident, which falls under Strategy Integration. While it mentions an incident, the primary purpose of the text is to provide a financial outlook and materiality conclusion rather than describing the incident itself.


reasoning: The paragraph describes the operational impact and remediation actions taken in response to a specific cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts that meet the criteria for Firm-Specific or Quantified-Verifiable classification.


reasoning: The paragraph describes the operational and financial impact of a specific cybersecurity incident, which falls under Incident Disclosure. It is Firm-Specific because it references specific fiscal quarters impacted by the event, though it does not meet the threshold for Quantified-Verifiable as it lacks two distinct hard facts like dollar amounts or named third-party firms.


reasoning: The paragraph describes a specific cybersecurity incident involving a named third-party vendor (CDK Global) and provides the specific date of the incident, qualifying it as an incident disclosure.


reasoning: The paragraph describes the nature, operational impact, and ongoing response to a specific cybersecurity incident, which is the definition of Incident Disclosure.


reasoning: The paragraph focuses on the materiality assessment and financial impact of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, dollar amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph describes the operational and financial impact of a specific cybersecurity incident, including the scope of the impact on vehicle sales, which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (ransomware) and its origin, which falls squarely under Incident Disclosure. It is Firm-Specific because it references specific dates related to the incident, though it does not meet the threshold for Quantified-Verifiable as it lacks two distinct types of hard facts (e.g., a named third-party firm or specific dollar amount).


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the event (unauthorized occurrences, encryption), and the operational impact, which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection and the company's immediate response actions, which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident involving a named third-party vendor (CDK Global) and provides specific dates of the event, fitting the criteria for Incident Disclosure.


reasoning: The paragraph describes the nature and scope of an ongoing cybersecurity incident, including the exfiltration of data, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic in specificity.


reasoning: The paragraph describes an active cybersecurity incident, including the detection, response actions, and operational impact, which fits the definition of Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the nature of the unauthorized access, and the company's response actions, which qualifies it as an Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the detection date and references to a prior filing, which places it squarely in the Incident Disclosure category.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including the detection date and the date the threat actor was removed, which qualifies as an incident disclosure.


reasoning: The paragraph describes the ongoing investigation and impact assessment of a specific cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, relying instead on standard incident response language.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the affected region (Canadian operations), and the company's response actions, which qualifies it as an Incident Disclosure.


reasoning: The paragraph focuses on the responsibilities and qualifications of the Chief Technology Officer regarding cybersecurity oversight, making 'Management Role' the primary category.


reasoning: The paragraph focuses on the financial strategy and liquidity adjustments made in response to a cybersecurity incident, specifically detailing capital amounts and loan waivers without describing the incident narrative.


reasoning: The paragraph focuses on identifying specific management roles (CIO, Information Security Director) and their qualifications, which places it squarely in the Management Role category.


reasoning: The paragraph describes the company's internal risk management processes and the roles involved in those reviews. While it mentions the CISO and CIO, these are specific roles that elevate the specificity beyond generic boilerplate.


reasoning: The paragraph describes the ongoing response and impact of a specific, named cybersecurity incident (the cyberattack on Change Healthcare), which falls squarely under Incident Disclosure.


reasoning: The paragraph focuses on the board of directors' oversight responsibilities and the delegation of risk management review to the audit committee, which fits the Board Governance category. It contains no specific facts, named cybersecurity roles, or unique identifiers, relying entirely on generic governance language.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents without describing any specific event or internal process, which falls under Strategy Integration.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence, the nature of the unauthorized access, and the resulting operational impact.


reasoning: The paragraph describes general internal activities related to risk management and regulatory compliance without referencing specific frameworks, roles, or unique company programs.


reasoning: The paragraph describes the company's internal approach to identifying and managing cybersecurity threats and incidents, which falls squarely under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the Board of Directors' oversight responsibilities, including training, policy approval, and delegation of duties to a specific committee.


reasoning: The paragraph focuses on the specific responsibilities of a named individual (Mr. Gharib) regarding cybersecurity oversight, which falls squarely under Management Role.


reasoning: The paragraph focuses on the management role (CFO) responsible for cybersecurity oversight and reporting lines, making 'Management Role' the primary category. It is classified as 'Firm-Specific' because it identifies a specific, non-generic committee (Nomination and Corporate Governance Committee) involved in the reporting structure.


reasoning: The paragraph focuses on the Audit Committee's role in overseeing cybersecurity risks, which aligns with Board Governance. No specific facts (such as named cybersecurity roles or unique committees) are present; 'Audit Committee', 'Chief Financial Officer', and 'senior leadership' are considered generic or standard roles/committees.


reasoning: This paragraph is a cross-reference to another section of the filing and does not contain substantive cybersecurity disclosure.


reasoning: The paragraph focuses on how cybersecurity is integrated into the company's internal enterprise risk management (ERM) framework. While it mentions board oversight, the primary subject matter is the integration of cybersecurity policies into the risk management process, and it cites specific industry frameworks.


reasoning: The paragraph focuses on the materiality of past cybersecurity incidents and expenses, which falls under Strategy Integration. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity organization and program structure, which falls under Risk Management Process. It is Firm-Specific because it names a unique internal organization (CDRM) and a specific role (Global CISO), in addition to referencing a standard.


reasoning: The paragraph describes the company's internal processes for incident response and escalation, focusing on the roles of specific internal teams (Incident Management Team, Privacy and Security Subcommittee).


reasoning: The paragraph focuses on the roles and collaboration of specific management positions (Chief Security Officer) in the context of risk management, making 'Management Role' the most appropriate category.


reasoning: The paragraph focuses on the materiality of cybersecurity risks to the company's financial condition and business strategy, which falls under Strategy Integration. It contains no specific dates, named roles, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes internal cybersecurity processes such as training, awareness updates, and penetration testing, which are standard components of a risk management program. No specific facts (dates, named tools, named firms, or unique programs) are mentioned, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk assessment and mitigation processes, which falls squarely under Risk Management Process. It contains no specific dates, named roles, named frameworks, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including specific committee structures and internal policy counts, which falls squarely under Risk Management Process.


reasoning: The paragraph focuses on the establishment and composition of a board-level committee (Cybersecurity Committee) and the specific qualifications of its chair, which falls squarely under Board Governance.


reasoning: The paragraph describes the company's internal risk management processes and integration with other corporate programs, which fits the Risk Management Process category. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on identifying the specific individual responsible for cybersecurity risk management and their qualifications, which falls squarely under Management Role.


reasoning: The paragraph provides a materiality conclusion regarding past incidents and financial impact without describing any specific incident, which aligns with the Strategy Integration category.


reasoning: The paragraph focuses on the Board's oversight and engagement with cybersecurity, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies specific cybersecurity-focused roles (CIO, CISO, CIRO) that brief the Board.


reasoning: The paragraph discusses the financial implications of cybersecurity risks, specifically mentioning cyber insurance and materiality, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for the fiscal year 2023, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year (2023), which is a verifiable fact.


reasoning: The paragraph describes the company's general approach to identifying and managing cybersecurity risks, which falls under Risk Management Process. It contains no specific facts, named roles, or frameworks, making it generic boilerplate.


reasoning: The paragraph focuses entirely on the identification, qualifications, and tenure of the CISO and CTO, which are management roles.


reasoning: The paragraph focuses on the qualifications, experience, and professional affiliations of specific management roles (Vice President of Information Systems and Chief Financial Officer) regarding cybersecurity oversight.


reasoning: The paragraph describes the company's internal incident response plan and associated processes, which falls squarely under Risk Management Process. It contains no specific facts, named entities, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the management structure and oversight responsibilities for cybersecurity, specifically identifying the CFO as the leader of the IT department's risk management efforts.


reasoning: The paragraph focuses on the oversight responsibilities of the Board of Directors and the Audit Committee regarding cybersecurity, which falls under Board Governance. It contains no specific facts, as the entities and cadences mentioned are generic or explicitly excluded by the instructions.


reasoning: The paragraph describes the company's internal approach to identifying and addressing cybersecurity risks and incident response procedures, which falls under Risk Management Process. It contains no specific roles, dates, tools, or verifiable facts, making it generic boilerplate.


reasoning: While the paragraph mentions board oversight, the central focus is on the specific management role (Vice President of Operations) responsible for the cybersecurity program, which takes precedence under the provided tiebreaker rules.


reasoning: The paragraph describes the company's internal approach to risk management by utilizing external experts for assessments and testing, which falls under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal risk management processes, specifically their engagement of third-party firms for simulation exercises and ongoing monitoring. While it mentions third parties, the central topic is the company's own preparation and monitoring strategy, not the oversight of those vendors.


reasoning: The paragraph describes internal risk management activities like penetration testing and program reviews, which are standard components of a cybersecurity risk management process. It contains no specific dates, named tools, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a materiality assessment regarding cybersecurity risks and incidents, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year-end date.


reasoning: The paragraph describes the company's internal risk assessment and audit processes, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named third-party firms, or unique cybersecurity roles, making it generic boilerplate.


reasoning: The paragraph focuses on the identification and reporting lines of specific management roles (CISO and CTO) responsible for cybersecurity oversight.


reasoning: This paragraph is a cross-reference to another section of the filing (Risk Factors) and contains no substantive cybersecurity disclosure.


reasoning: The paragraph focuses on the Board's oversight responsibilities and the delegation of cybersecurity risk oversight to the audit committee, which is the primary subject of the text. All mentioned entities (Board, management, audit committee) and cadences (quarterly) are generic and do not meet the criteria for specific facts.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the Director of Cybersecurity, which is a cybersecurity-specific management role.


reasoning: The paragraph consists entirely of forward-looking disclaimers regarding potential risks and insurance limitations, which falls under the None/Other category.


reasoning: The paragraph consists entirely of generic statements about the importance of cybersecurity and the existence of common threats, without describing any specific governance, management, processes, or incidents.


reasoning: The paragraph focuses on the Board's oversight responsibilities and the delegation of cybersecurity oversight to the Audit Committee. It contains no specific facts, as the Board and Audit Committee are considered generic governance entities.


reasoning: The paragraph focuses on the Board of Directors' oversight responsibilities regarding cybersecurity risks, which is the primary definition of Board Governance. It contains no specific facts or unique identifiers, relying entirely on standard governance language.


reasoning: The paragraph describes how the company integrates third-party risk assessment into its broader internal cybersecurity risk management processes, making it a component of the internal process rather than a standalone vendor oversight discussion.


reasoning: The paragraph describes the company's internal security operations, tools, and testing procedures, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named third-party firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal approach to risk management and cybersecurity program implementation, which falls squarely under Risk Management Process. It contains no specific dates, named tools, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph is dedicated entirely to the company's processes for managing risks associated with third-party vendors and suppliers, which fits the definition for Third-Party Risk.


reasoning: The paragraph focuses on the company's cyber insurance strategy and the specific management role responsible for overseeing it, which aligns with Strategy Integration.


reasoning: The paragraph describes the company's internal adoption of cybersecurity frameworks and policies, which falls under Risk Management Process. It is classified as Sector-Adapted because it explicitly names the NIST Cybersecurity Framework without providing any firm-specific details.


reasoning: The paragraph describes the company's internal vulnerability assessment program and risk management approach, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal incident response processes and the operation of its Security Operations Center, which falls under Risk Management Process. It contains no specific dates, named tools, or unique identifiers, relying entirely on generic descriptions of security operations.


reasoning: The paragraph describes the company's internal processes for overseeing cybersecurity risks, which falls under Risk Management Process. It contains no specific dates, named entities, 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 company's internal cybersecurity measures and processes, which falls under Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's response to a specific cybersecurity incident, including the date systems were isolated, which qualifies it as an incident disclosure.


reasoning: The paragraph describes the status and potential impact of an ongoing cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific facts, dates, or named entities, relying entirely on boilerplate language regarding materiality and operational impact.


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management, which is the primary focus. It contains no specific facts, names, or dates, making it generic boilerplate.


reasoning: The paragraph describes the company's internal operational procedures for incident detection, assessment, and escalation, which constitutes a Risk Management Process.


reasoning: The paragraph focuses on the financial and operational materiality assessment of a cybersecurity incident rather than describing the incident itself or internal processes. While it mentions dates, it does not meet the threshold for Quantified-Verifiable as it lacks two independent, hard-verifiable facts like dollar amounts or named third-party firms.


reasoning: The paragraph describes the status and findings of an ongoing cybersecurity incident investigation, which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


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


reasoning: The paragraph describes the scope and impact of a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named tools, or other verifiable facts, making it generic.


reasoning: The paragraph describes the operational impact and recovery status of a specific cybersecurity incident, which falls squarely under Incident Disclosure. It contains two verifiable facts (a specific date and a percentage of revenue), meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's response actions to a cybersecurity incident and provides a materiality assessment regarding that specific event, which aligns with the Incident Disclosure category.


reasoning: The paragraph describes the scope and response actions related to a previously disclosed cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the timeline and scope of a specific cybersecurity incident, including the identification of affected systems and previous related activity, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the detection of unauthorized activity and the subsequent response actions taken by the company, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the operational impact and response actions related to a specific cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts that would elevate its specificity beyond boilerplate.


reasoning: The paragraph describes the status and impact of a cybersecurity incident, which falls under Incident Disclosure. It contains no specific facts, dates, or named entities, relying entirely on boilerplate language regarding materiality and operational continuity.


reasoning: The paragraph describes the scope and status of an ongoing cybersecurity incident, specifically detailing the exfiltration of data, which falls squarely under Incident Disclosure.


reasoning: The paragraph focuses on the financial materiality assessment of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, dollar amounts, or named entities, making it generic boilerplate.


reasoning: The paragraph describes the financial impact and response actions related to a specific cybersecurity incident, which classifies it as an Incident Disclosure.


reasoning: The paragraph focuses on the financial impact and materiality assessment of a previously disclosed incident without providing a narrative of the incident itself, fitting the Strategy Integration category.


reasoning: The paragraph describes specific dates regarding a regulatory delay for an incident disclosure, which falls squarely under Incident Disclosure. It is Firm-Specific because it contains specific dates related to the company's unique regulatory interaction, but does not meet the threshold for Quantified-Verifiable as it lacks two independent, non-date/non-role verifiable facts (e.g., named third-party firms or specific dollar amounts).


reasoning: This paragraph is a standard legal disclaimer regarding forward-looking statements and contains no substantive cybersecurity disclosure.


reasoning: The paragraph describes the scope of data exfiltrated during a cybersecurity incident, which directly relates to the incident disclosure category.


reasoning: The paragraph describes the financial impact of a specific cybersecurity incident, including dollar amounts and timeframes, which falls under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (ransomware) and the company's immediate response actions, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the company's response to an incident, including investigation and notification steps, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, relying entirely on standard incident response language.


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


reasoning: The paragraph focuses on the materiality assessment of an incident regarding the company's financial condition and business operations, which falls under Strategy Integration. It is Firm-Specific because it identifies a specific product/system ('Dropbox Sign') affected by the incident.


reasoning: The paragraph describes the ongoing response to a specific cybersecurity incident, including the scope of the impact and the actions taken, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence and the company's response actions, which classifies it as an Incident Disclosure.


reasoning: The paragraph focuses on the potential financial impact and materiality assessment of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the timeline of the event and the nature of the data accessed, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized access) and the company's immediate response, which fits the definition of Incident Disclosure.


reasoning: The paragraph describes the response actions and timeline of a specific cybersecurity incident, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection and the date the threat actor was ejected, which clearly falls under Incident Disclosure.


reasoning: The paragraph provides specific details regarding the scope and impact of a disclosed cybersecurity incident, specifically the number of affected consumers.


reasoning: This paragraph is a standalone materiality conclusion regarding a cybersecurity incident without providing any descriptive details about the incident itself, which classifies it as Strategy Integration.


reasoning: The paragraph describes the ongoing investigation and status of a cybersecurity incident, which is the core definition of Incident Disclosure.


reasoning: The paragraph focuses on the materiality assessment of an incident rather than describing the incident itself, which aligns with Strategy Integration. It is Firm-Specific because it references a specific fiscal period end date (March 31, 2026).


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


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity detected on a specific date) and the company's immediate response actions, which fits the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident (data exfiltration) and the immediate response actions taken, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the scope and nature of a specific cybersecurity incident, including the type of data accessed and the number of affected users, which clearly falls under Incident Disclosure.


reasoning: The paragraph is a standard legal disclaimer regarding forward-looking statements and contains no substantive cybersecurity disclosure.


reasoning: The paragraph focuses on the financial impact and materiality assessment of a cybersecurity incident, which falls under Strategy Integration. It contains multiple verifiable facts, including a specific dollar amount and a specific date, qualifying it as Quantified-Verifiable.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph provides an update on a specific, previously disclosed cybersecurity incident (the Change Healthcare cyberattack) and references specific response actions and dates, fitting the Incident Disclosure category.


reasoning: The paragraph describes the company's ongoing response actions and operational status following a cybersecurity incident, which falls under Incident Disclosure.


reasoning: The paragraph describes the company's response actions to a cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named firms, or unique identifiers, relying entirely on standard incident response language.


reasoning: The paragraph describes a specific cybersecurity incident, including dates of occurrence and escalation, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the company's response to an unauthorized activity (incident), including taking systems offline and launching an investigation, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the response actions taken in relation to a specific cybersecurity incident, which falls squarely under Incident Disclosure. It is classified as Firm-Specific because it identifies a specific geographic location (Singapore) involved in the incident response, which is a unique fact.


reasoning: The paragraph describes the remediation status and outcome of a previously disclosed cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


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


reasoning: The paragraph provides a standalone materiality conclusion regarding the financial condition and results of operations without describing the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph provides a standalone materiality assessment regarding a cybersecurity incident without describing the incident itself or providing specific financial details, which aligns with the Strategy Integration category.


reasoning: The paragraph describes the status of an incident (containment) and general remediation efforts, which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the materiality assessment of an incident regarding the company's financial condition and results of operations, which falls under Strategy Integration. It is Firm-Specific because it references a specific internal financial metric, 'Operating Adjusted EBITDA', which is unique to the company's reporting.


reasoning: The paragraph describes the status of an ongoing incident investigation and potential regulatory obligations, which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the integration of cybersecurity into the company's broader enterprise risk management framework, which is a core component of risk management processes. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the board's oversight responsibilities and reporting structure, which falls under Board Governance. It contains no specific facts (Audit Committee, Board, and management are all generic terms per the instructions).


reasoning: The paragraph describes the company's internal approach to vendor evaluation as part of its broader risk management process, rather than focusing on specific vendor oversight requirements or a specific incident. It contains no specific facts, named entities, or frameworks, making it generic boilerplate.


reasoning: The paragraph focuses on the oversight activities of a committee (Board Governance) but contains no specific facts, named committees, or unique identifiers, relying entirely on generic terminology.


reasoning: This paragraph is standard legal boilerplate regarding the filing status of the report and contains no cybersecurity-related information.


reasoning: The paragraph focuses on the board of directors and the audit committee's oversight responsibilities regarding cybersecurity. It is classified as Generic Boilerplate because 'board of directors' and 'audit committee' are standard, non-specific entities, and no other unique facts are provided.


reasoning: The paragraph provides a materiality assessment regarding the financial impact of an incident without describing the incident narrative itself, which aligns with the Strategy Integration category.


reasoning: The paragraph describes general internal efforts to improve cybersecurity and infrastructure, which falls under the company's internal risk management processes, but contains no specific details or unique identifiers.


reasoning: The paragraph focuses on the qualifications and tenure of a specific cybersecurity management role, which falls under Management Role. It contains multiple verifiable facts (years of experience and start date), qualifying it as Quantified-Verifiable.


reasoning: The paragraph consists entirely of a forward-looking disclaimer and a cross-reference to another section of the filing, which falls under the 'None/Other' category.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its integration with enterprise risk management, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes oversight responsibilities, which is the primary function of Board Governance. It is classified as Firm-Specific because it names a specific internal body, the 'Cybersecurity Committee', which is not a generic committee like the Audit Committee.


reasoning: The paragraph describes the general purpose of the company's cybersecurity program, which falls under internal risk management processes, but contains no specific details or unique identifiers.


reasoning: This paragraph describes the professional background of an individual (Mr. Tao) and contains no information related to cybersecurity governance, risk management, or incident disclosure.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management without referencing any specific programs, frameworks, or unique organizational details.


reasoning: The paragraph consists of a section header and a generic risk factor statement regarding IT dependency, containing no substantive disclosure about specific processes, governance, or incidents.


reasoning: The paragraph identifies specific management roles (head of the ITS Department) responsible for cybersecurity risk management, which aligns with the Management Role category.


reasoning: The paragraph focuses on identifying specific management roles (CIO and Director of IT Security, Risk and Compliance) responsible for cybersecurity oversight.


reasoning: The paragraph describes internal security policies and training procedures, which falls under Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the Board of Directors' oversight and their receipt of reports from specific management roles (CISO and CIO), making 'Board Governance' the primary category.


reasoning: This paragraph describes generic cybersecurity threats and vulnerabilities without detailing specific internal processes, governance, or incidents, making it a standard risk disclosure statement.


reasoning: The paragraph focuses on the board of directors and the audit committee's oversight role regarding cybersecurity, which falls under Board Governance. It contains no specific facts, as 'audit committee' and 'board of directors' are considered generic governance terms.


reasoning: The paragraph describes the company's internal incident response and recovery processes, which falls under Risk Management Process. It contains no specific facts (dates, named tools, named roles, or frameworks), making it generic boilerplate.


reasoning: The paragraph describes the company's general approach to integrating cybersecurity into their enterprise risk management program, which falls under Risk Management Process. It contains no specific facts, dates, or named programs.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents without describing any specific event, which falls under Strategy Integration.


reasoning: The paragraph discusses the qualifications of the IT team, which falls under Management Role, but it contains no specific details, names, or verifiable facts, making it generic boilerplate.


reasoning: This paragraph serves as a section header and introductory sentence, containing no substantive disclosure or specific details.


reasoning: The paragraph focuses on the roles of the CSO and CISO and their reporting lines, which places it primarily in the Management Role category. It is Firm-Specific because it names a specific internal committee (Global Security Steering Committee) and specific cybersecurity roles.


reasoning: The paragraph focuses on the oversight and monitoring of third-party service providers, which is the central topic of the Third-Party Risk category. It is classified as Firm-Specific because it names a specific tool (Security Scorecard) used for this purpose.


reasoning: This paragraph describes generic business services and does not provide substantive disclosure regarding cybersecurity governance, risk management, or specific incidents.


reasoning: The paragraph describes standard incident response procedures (eradication) which are part of the company's internal risk management processes. It contains no specific facts, named entities, or unique identifiers.


reasoning: The paragraph focuses on the Board's oversight role and the cadence of reporting, which falls under Board Governance. It contains no specific facts (Audit Committee and 'the Board' are generic, and 'regular' is a generic cadence).


reasoning: The paragraph focuses on the responsibilities and reporting lines of a specific cybersecurity role (internal cybersecurity coordinator), which falls under Management Role.


reasoning: The paragraph provides a materiality assessment regarding past cybersecurity incidents and their financial impact, which falls under Strategy Integration. It is Quantified-Verifiable because it cites two specific, verifiable time periods.


reasoning: The paragraph explicitly identifies specific management roles (CIO and VP of Information Security) responsible for cybersecurity, making 'Management Role' the correct category.


reasoning: The paragraph explicitly identifies the specific management role (CFO serving as CISO) responsible for cybersecurity, which places it squarely in the Management Role category.


reasoning: The paragraph describes general cybersecurity program activities like threat intelligence and external assessments, which are standard components of a risk management process. It contains no specific dates, named tools, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents and their financial impact without describing any specific incident narrative.


reasoning: The paragraph explicitly addresses the status of cybersecurity incidents, which falls under Incident Disclosure, and contains two specific dates, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal process for monitoring cybersecurity incidents and receiving notifications, which falls under Risk Management Process. It contains no specific roles, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph describes standard internal security practices like phishing simulations and training, which fall under the company's internal risk management processes. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph discusses cyber insurance as a financial mitigation strategy, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph focuses on the responsibilities of specific management roles (CFO, COO, CEO) regarding cybersecurity. However, these roles are considered generic C-suite titles and do not qualify as cybersecurity-specific roles or specific facts under the provided guidelines.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight role regarding cybersecurity risks and incident reporting, which falls squarely under Board Governance.


reasoning: The paragraph describes the company's internal processes for identifying and managing cybersecurity risks, which falls squarely under Risk Management Process. It contains no specific dates, named roles, frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal approach to maintaining and updating its incident response plan, which is a core component of risk management processes.


reasoning: The paragraph describes the company's internal approach to managing cybersecurity risks, which falls under Risk Management Process. It contains no specific names, dates, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph contains only generic statements about board and management responsibilities without referencing specific cybersecurity governance, roles, or processes.


reasoning: The paragraph describes general functions of cybersecurity personnel (analyzing threats, monitoring, responding) which constitutes internal risk management processes, but contains no specific roles, names, or unique identifiers.


reasoning: The paragraph describes an internal cybersecurity program and team established by the company, which falls under the company's internal risk management processes.


reasoning: The paragraph focuses on the Board of Directors' oversight role regarding cybersecurity, which falls squarely under Board Governance. It contains no specific facts (only generic references to the Board, periodic updates, and quarterly/annual cadences), resulting in a Generic Boilerplate classification.


reasoning: The paragraph describes internal risk management processes, including training and vendor oversight, without naming specific programs, tools, or frameworks. It is a generic description of standard cybersecurity practices.


reasoning: The paragraph explicitly discusses the management of cybersecurity and the roles responsible for it, fitting the 'Management Role' category. It contains no specific facts, named roles, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes internal security training practices, which falls under the company's internal risk management processes. It contains no specific facts, named entities, or frameworks, making it generic boilerplate.


reasoning: The paragraph is a generic introductory statement regarding the importance of cybersecurity and does not contain substantive details about governance, management, or specific risk processes.


reasoning: This paragraph is a generic statement of goals regarding cybersecurity and business continuity, lacking any substantive disclosure about processes, governance, or specific incidents.


reasoning: The paragraph describes the company's internal incident response planning and testing processes, which falls under Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program and incident response processes, which falls under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the qualifications and reporting lines of specific management roles (CTO and senior director of cybersecurity and compliance), which places it squarely in the Management Role category.


reasoning: The paragraph describes the company's internal cybersecurity risk management system and its general objectives, which falls squarely under Risk Management Process.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for a specific fiscal year, which falls under Strategy Integration.


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident without describing the incident itself, which falls under Strategy Integration.


reasoning: The paragraph discusses financial recovery efforts (cyber insurance) related to an incident without describing the incident itself or providing specific financial details, which aligns with Strategy Integration.


reasoning: The paragraph identifies specific management roles responsible for cybersecurity risk management, which aligns with the Management Role category.


reasoning: The paragraph describes the company's response actions to an ongoing cybersecurity incident, which falls under Incident Disclosure. It contains no specific facts (dates, named firms, or tools), relying entirely on generic language regarding incident response.


reasoning: The paragraph describes the status of an ongoing incident investigation, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program and general risk management activities, which falls under Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: This paragraph provides a standalone materiality conclusion regarding a cybersecurity incident without describing the incident itself, 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 approach to risk management and identifies a specific internal system (BDTP TM) that will be subject to these processes.


reasoning: The paragraph discusses cybersecurity insurance coverage and future financial assessment, which falls under Strategy Integration. It contains no specific facts (no named insurers, no dollar amounts, no dates), making it generic boilerplate.


reasoning: The paragraph describes the operational impact of an ongoing cybersecurity incident and provides a specific URL for incident updates, which constitutes an incident disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph describes the scope and response actions related to a previously disclosed cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration. It contains only standard boilerplate language regarding financial impact and no specific, verifiable facts.


reasoning: The paragraph discusses the potential financial and business impacts (litigation, insurance costs, regulatory scrutiny) resulting from a cybersecurity incident without describing the incident itself or providing specific details, which aligns with Strategy Integration.


reasoning: The paragraph describes incident response actions (notifying law enforcement and regulators) related to a disclosed matter, which falls under Incident Disclosure. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration according to the tiebreaker rules.


reasoning: The paragraph describes standard incident response actions (notifying law enforcement and regulators) following an incident, which falls under Incident Disclosure. It contains no specific facts, named entities, or unique details, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: This paragraph discusses legal waivers related to credit and lease agreements, which are standard legal boilerplate and do not pertain to cybersecurity governance, risk management, or incident disclosure.


reasoning: This paragraph describes executive leadership changes at a subsidiary, which is a corporate governance matter unrelated to cybersecurity oversight, risk management, or incident disclosure.


reasoning: The paragraph discusses the potential financial and operational impact of an incident without describing the incident itself, which aligns with Strategy Integration.


reasoning: The paragraph describes a specific cybersecurity incident involving a third-party provider, including the dates of notification and confirmation, which qualifies as an incident disclosure.


reasoning: The paragraph discusses the potential material impact of an incident without describing the incident itself, which aligns with the definition of Strategy Integration for standalone materiality assessments.


reasoning: The paragraph discusses the financial impact and recovery (insurance) of an incident without describing the incident itself or providing specific financial details, which falls under Strategy Integration.


reasoning: The paragraph describes specific response actions taken in relation to a previously disclosed incident, which falls under Incident Disclosure. It contains no specific dates, named tools, or other verifiable facts, making it generic.


reasoning: The paragraph describes the status of an incident (containment and restoration), which falls under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the status of an ongoing investigation into a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality assessment regarding a cybersecurity incident without describing the incident itself or providing specific financial details.


reasoning: The paragraph provides a standalone materiality assessment regarding an incident without describing the incident itself, which falls under Strategy Integration.


reasoning: The paragraph describes the status of an ongoing cybersecurity incident, specifically containment and restoration efforts, which falls squarely under Incident Disclosure.


reasoning: The paragraph discusses the materiality of an incident without describing the incident itself or providing specific financial details, which aligns with the Strategy Integration category for standalone materiality assessments.


reasoning: The paragraph describes the status of an ongoing cybersecurity incident, including the investigation and insurance involvement, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes ongoing incident response actions and provides a materiality assessment regarding a disclosed incident, which falls under Incident Disclosure.


reasoning: The paragraph describes the operational impact of an ongoing cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, making it generic in specificity.


reasoning: The paragraph provides an update on the operational and financial impact of a disclosed incident, which is a core component of incident disclosure.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph discusses the ongoing assessment of materiality regarding an incident without describing the incident itself, which aligns with the Strategy Integration category for standalone materiality assessments.


reasoning: The paragraph describes a specific response action (notifying individuals) taken in the context of an ongoing incident investigation, which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic.


reasoning: The paragraph discusses the potential financial impact and materiality of an incident without describing the incident itself, which aligns with the Strategy Integration category. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident (systems outage caused by an attack) and provides the date of occurrence, which qualifies as an incident disclosure.


reasoning: The paragraph describes the nature of an ongoing cybersecurity incident (unauthorized access, data exfiltration, and encryption), which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph provides an update on the status of a previously disclosed cybersecurity incident, including remediation efforts and the conclusion of an investigation, which falls squarely under Incident Disclosure.


reasoning: The paragraph describes a specific cybersecurity incident that occurred on a specific date, which falls squarely under Incident Disclosure.


reasoning: The paragraph discusses the materiality of an incident without describing the incident itself, which falls under Strategy Integration. It contains only standard boilerplate language regarding financial impact assessments.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, which qualifies it as an incident disclosure.


reasoning: The paragraph describes the status of an ongoing investigation into a cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the cause and response to a specific cybersecurity incident, placing it squarely in Incident Disclosure. It contains no specific dates, named vendors, or other verifiable facts, making it generic.


reasoning: The paragraph describes the nature of a cybersecurity incident (unauthorized access to systems containing personal information) and the company's response (notification plans), which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the operational impact of a cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named systems, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes actions taken in response to an ongoing cybersecurity incident, specifically the creation of a dedicated communication channel for the event.


reasoning: The paragraph provides a materiality assessment regarding a specific incident's impact on financial results, which falls under Strategy Integration. It is Firm-Specific because it references a specific fiscal period (fourth quarter of 2023) rather than being purely generic boilerplate.


reasoning: The paragraph describes the operational impact of a specific cybersecurity incident, which falls under Incident Disclosure. It is classified as Firm-Specific because it provides a quantified duration of the operational disruption, which is a unique fact about this specific event.


reasoning: The paragraph discusses the financial/operational impact of an incident without describing the incident itself or providing specific costs, dates, or entities, making it a strategy/impact disclosure.


reasoning: The paragraph provides a standalone materiality assessment regarding an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it generic boilerplate.


reasoning: The paragraph discusses the materiality of an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts, dates, or entities, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident (unauthorized activity) and provides the date of occurrence, which qualifies as an incident disclosure.


reasoning: The paragraph describes a specific cybersecurity incident (an attempt to fraudulently obtain funds) and provides a specific date, which qualifies as an incident disclosure.


reasoning: The paragraph describes actions taken in response to an incident (notifying authorities and working with law enforcement), which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding an incident without describing the incident itself, which falls under Strategy Integration according to the tiebreakers.


reasoning: The paragraph describes operational response actions taken in the context of an ongoing incident (implied by 'systems are being restored'), which falls under Incident Disclosure. It contains no specific dates, named tools, or verifiable facts, making it generic.


reasoning: The paragraph describes the ongoing response and restoration efforts related to a specific cybersecurity incident (Change Healthcare), which falls under Incident Disclosure.


reasoning: The paragraph describes the company's internal cybersecurity processes, including threat assessment, training, and vendor oversight, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it references specific frameworks (NIST, ISO, SOC-1, SOC-2) without providing firm-specific details like named tools, specific dates, or unique internal program names.


reasoning: The paragraph describes the company's internal cybersecurity risk management strategy, including frameworks used and oversight processes. It is categorized as Risk Management Process because it details the company's own internal approach to identifying and managing threats.


reasoning: The paragraph describes the company's internal processes for evaluating and responding to cybersecurity incidents, including the specific role of the CSO and named internal programs.


reasoning: The paragraph focuses on the composition and responsibilities of the 'Risk Management Team' and the specific role of the Sr. Director of IT, which aligns with the Management Role category.


reasoning: The paragraph primarily describes the company's internal risk management processes, including staffing, vendor oversight, and security measures. While it mentions third-party providers, the central topic is the company's internal process for managing those risks rather than the oversight of the vendors themselves.


reasoning: This paragraph is a standard risk factor disclosure describing general cybersecurity threats and potential consequences, without detailing specific governance, management, or internal processes.


reasoning: The paragraph focuses primarily on identifying the specific management roles (CISO and CTO) responsible for cybersecurity, their reporting lines, and their professional qualifications. While it touches on risk management processes, the detailed biographical information about the CISO and CTO makes 'Management Role' the most accurate classification.


reasoning: The paragraph focuses primarily on the Board's oversight responsibilities and the specific role of the Risk Committee in cybersecurity governance, making Board Governance the most appropriate category.


reasoning: The paragraph focuses primarily on identifying the specific roles (IT Manager, General Counsel, etc.) and committees (IT Steering Committee) responsible for administering the cybersecurity program, making 'Management Role' the most appropriate category.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks for the fiscal year, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year (fiscal 2024) in the context of its materiality assessment.


reasoning: This paragraph describes the company's reliance on IT systems and the general nature of cyber threats, which constitutes standard risk factor disclosure rather than specific governance, management, or process details.


reasoning: The paragraph describes the company's internal security controls, monitoring, and risk management processes, making 'Risk Management Process' the most appropriate category. It is classified as 'Sector-Adapted' because it explicitly references the NIST CSF framework but lacks other firm-specific or verifiable facts.


reasoning: The paragraph focuses on the identification and qualifications of the cybersecurity team (including the vCISO and other specific roles) responsible for managing the company's cyber risk. It qualifies as Quantified-Verifiable because it lists multiple specific professional certifications (CISSP, CISA, CISM) and a specific number of years of experience.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and regulatory compliance. While it mentions specific regulators, these are standard for a financial institution and do not constitute unique internal processes or specific cybersecurity program details.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including the adoption of the NIST framework and the specific management roles responsible for oversight.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as monitoring, training, and policy development. It contains no specific dates, named tools, named third-party firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph primarily describes the company's internal cybersecurity program, risk assessment processes, and oversight structure, which falls under Risk Management Process. While it mentions board and management roles, these are discussed in the context of the overall risk management framework.


reasoning: The paragraph outlines the company's internal cybersecurity program, including governance, incident response, and risk management processes, making 'Risk Management Process' the most appropriate category. It is 'Firm-Specific' because it identifies specific cybersecurity roles (CIO, Global Head of IT Security) unique to the company's organizational structure.


reasoning: The paragraph describes the company's internal incident response processes, specifically naming internal programs (Agility Plan) and committees (CMT) used to manage cybersecurity risks.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as incident response planning, technical safeguards, and employee training. It contains no specific dates, named tools, named third-party firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph primarily details the company's internal risk management processes, including specific frameworks (NIST) and internal programs (IRP, BCP, Disaster Recovery Plan) used to identify, mitigate, and respond to risks.


reasoning: The paragraph consists of generic risk disclosures and a standard materiality disclaimer regarding potential future impacts, with no specific details about governance, management, or actual incidents.


reasoning: The paragraph describes the company's internal cybersecurity processes, such as incident response planning, technical safeguards, and risk management, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program, including governance, technical safeguards, and incident response, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies specific roles (CISO, AHL's CISO) and specific internal departments involved in the process.


reasoning: The paragraph describes the company's internal security tools (EDR, SIEM, firewalls) and operational procedures for incident reporting, which falls under Risk Management Process. It is Firm-Specific because it includes a specific reporting deadline (24 hours) and a specific strategic timeline (2025), though it lacks the two hard verifiable facts required for Quantified-Verifiable.


reasoning: The paragraph is primarily focused on the qualifications, responsibilities, and reporting lines of the Chief Information Officer, which falls under Management Role. While it discusses risk reporting processes, the central narrative is the management of these risks by specific roles.


reasoning: This paragraph is a standard, generic risk factor disclosure describing potential threats and impacts without detailing specific governance, management, or internal processes.


reasoning: The paragraph describes the company's internal cybersecurity monitoring, incident response planning, and engagement with external experts, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it names a specific internal program, the 'Cybersecurity Incident Response Plan'.


reasoning: The paragraph focuses primarily on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity, which aligns with the Board Governance category. It contains no specific facts, named cybersecurity roles, or unique programs, rendering it generic boilerplate.


reasoning: The paragraph focuses on the materiality of cybersecurity risks and explicitly states that no material incidents occurred during the fiscal year, which aligns with Strategy Integration.


reasoning: The paragraph primarily focuses on the Board of Directors and the Risk Committee's role in overseeing cybersecurity risk management, which aligns with the Board Governance category.


reasoning: The paragraph describes general cybersecurity threats and provides a forward-looking disclaimer regarding potential future impacts, which falls under the 'None/Other' category as it does not describe a specific incident, governance structure, or internal process in detail.


reasoning: The paragraph focuses on identifying specific management roles (CISO, CDO, CIO) and their qualifications, which is the primary subject of the text.


reasoning: The paragraph describes the company's internal cybersecurity measures, processes, and safeguards, which falls squarely under Risk Management Process. It contains no specific dates, named third-party firms, named products, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the responsibilities and qualifications of the Chief Technology Officer and the internal Security and Privacy Governance Committee, making 'Management Role' the primary category.


reasoning: The paragraph describes the internal risk management processes implemented by the manager (USCF) to oversee cybersecurity and third-party providers, making it a Risk Management Process disclosure.


reasoning: The paragraph focuses on identifying specific management roles (CISO, CCO) and their qualifications, experience, and responsibilities regarding cybersecurity risk management.


reasoning: The paragraph focuses primarily on identifying specific management roles (CTO, CIO, CISO) and their qualifications, which aligns with the Management Role category.


reasoning: The paragraph describes the company's internal cybersecurity and technology risk management program, policies, and frameworks, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it names a specific internal committee (Business Risk Committee) and specific frameworks (NIST and CRI) used by the company.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and oversight, which falls under Risk Management Process. It contains no specific facts, named roles, or unique programs, making it generic boilerplate.


reasoning: The paragraph primarily describes the company's internal risk management processes, including monitoring, framework adoption, and vendor assessment. It is classified as Firm-Specific because it names a specific internal committee (Information Security Risk Committee) and multiple specific frameworks.


reasoning: The paragraph describes the company's internal security controls, processes, and risk management activities, which falls squarely under Risk Management Process. It contains no specific facts, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph consists entirely of definitions of cybersecurity terms and a cross-reference to other sections of the filing, containing no substantive disclosure about the company's specific governance, management, or risk processes.


reasoning: The paragraph primarily describes the company's internal processes for risk assessment, incident response, and monitoring, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies a specific cybersecurity-related role (Senior Director of Information Technology) involved in the risk evaluation process.


reasoning: The paragraph primarily focuses on a materiality conclusion regarding cybersecurity risks and their potential impact on the company's financial condition and strategy, which falls under Strategy Integration. While it mentions a risk assessment program, the core purpose of the paragraph is the disclaimer regarding materiality.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment approach, and monitoring functions, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it identifies specific cybersecurity leadership roles (CIO and CISO) responsible for reviewing the program.


reasoning: The paragraph describes the company's internal approach to cybersecurity, including the implementation of an Information Security Program, committee oversight, and third-party risk management, which falls under Risk Management Process. It contains no specific dates, named tools, named firms, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph primarily focuses on the board's oversight responsibilities and the delegation of these duties to the Audit Committee, making 'Board Governance' the most appropriate category. While it mentions management roles, the board's oversight is the grammatical subject and primary focus of the disclosure.


reasoning: The paragraph primarily describes the company's internal processes for managing cybersecurity risks, including vendor assessments and incident response protocols. While it mentions third parties, the focus is on the company's internal review and approval processes, making 'Risk Management Process' the most appropriate category.


reasoning: The paragraph describes the company's internal cybersecurity strategy, processes, and incident response planning, which falls squarely under Risk Management Process. It is classified as Firm-Specific because it names a unique internal program, the 'Information and Cyber Security Incident Response Plan (ICSIRP)'.