reasoning: Paragraph details operational disruptions, scope (retail stores, e-commerce, distribution), and recovery actions from a specific cyber incident, fitting Incident Disclosure as it references a real event with impact narrative and response without financial materiality focus.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph focuses on the financial and operational impact of the Incident, including a materiality assessment for Q2 ended June 30, 2024, without providing an incident narrative or describing what happened. Per tiebreakers, financial impact assessment without incident details fits Strategy Integration.

provider: x-ai


content_category: Incident Disclosure

reasoning: This paragraph details the remediation, containment, operational impacts (communications, shipping, manufacturing), and financial costs of a specific cybersecurity incident, fitting Incident Disclosure as it describes response actions, scope, and impact of a real event. Tiebreakers confirm incident-related financial impact with response details prioritizes Incident Disclosure over Strategy Integration.


reasoning: This paragraph describes a real cybersecurity incident, including detection date, response actions (containment, investigation, system shutdown), ejection of threat actor on a specific date, and notifications to authorities, directly matching Incident Disclosure criteria with a narrative of what happened and response.


reasoning: The paragraph assesses the financial and operational materiality of a cybersecurity incident without providing any incident narrative, scope, or response details, focusing instead on materiality conclusions and cybersecurity insurance coverage, which aligns with Strategy Integration per tiebreakers for financial impact assessments without incident descriptions. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph discusses remediation plans, expected insurance recoveries for incident costs, and a materiality assessment concluding no material impact, which aligns with Strategy Integration per tiebreakers for financial impact and materiality without incident narrative. No specific facts qualify under the IS list, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes a specific ransomware incident including dates, scope (internal IT systems), origin, response actions (engaged experts, recovery, investigation), and outcomes, fitting Incident Disclosure. It references a real event with narrative rather than just financial impact or processes.


reasoning: The paragraph focuses on the materiality assessment and financial impact of 'this incident' without describing what happened, scope, or response, aligning with Strategy Integration per tiebreakers for financial impact without incident narrative.


reasoning: This paragraph describes a specific cybersecurity incident at CDK Global affecting the company's systems, including timeline (June 19, 2024, throughout July), restoration status, and scope of affected systems (DMS, CRM, apps), fitting Incident Disclosure. It contains multiple verifiable facts like a precise date, named firm (CDK), and named systems, exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses on the financial and operational impacts of the incident, expected costs, insurance coverage, and materiality assessments without any incident narrative or description of what happened, aligning with Strategy Integration per tiebreakers for financial cost/impact without incident details. No specific facts, named standards, dates, amounts, or named entities qualify it beyond generic boilerplate materiality language.


reasoning: This paragraph describes a real cybersecurity incident with specifics on detection date, unauthorized access, response actions (containment, investigation, incident response plan activation, system shutdowns), scope (IT systems, data encryption, manufacturing halt, order fulfillment impact), and ongoing mitigation, making 'Incident Disclosure' the clear fit over others like Strategy Integration which lacks financial materiality focus.


reasoning: This paragraph describes a specific cybersecurity incident at a third-party (CDK), including timeline (starting June 19, 2024), scope of affected systems (DMS, CRM, etc.), and response status (partial restoration), fitting Incident Disclosure. Multiple verifiable facts like dates, named firm, and systems qualify it as Quantified-Verifiable.


reasoning: This paragraph describes the operational scope, disruption timelines, and remediation actions for a specific cybersecurity incident, including halting and restoring operations, which matches Incident Disclosure criteria including incident response and impact details.


reasoning: The paragraph describes a real cybersecurity incident including unauthorized access, detection, response actions (e.g., incident response plan activation, system takedowns, law enforcement notification), and operational impacts (halted production at various locations), fitting Incident Disclosure. No specific verifiable facts like dates, named firms, or quantified details are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes a specific cybersecurity incident including the date it was detected (June 30, 2024), unauthorized access to systems, and initial response actions, directly matching Incident Disclosure criteria with a real event narrative. It references a prior filing but centers on the incident details rather than strategy or governance.


reasoning: The paragraph details an actual cybersecurity incident with detection date, response actions (initiating protocols, network isolation), scope (parts of network), operational impact (some disruption but operations continued materially), investigation, and notifications to regulators/law enforcement, directly matching Incident Disclosure criteria.


reasoning: The paragraph details financial arrangements (waived interest and lease payments totaling $3.7M) to provide liquidity for cybersecurity incident remediation, emphasizing business and financial impact without any incident narrative, scope, or response details, fitting Strategy Integration per tiebreakers.


reasoning: The paragraph describes financial and operational impacts (delayed revenue recognition, lost revenue, one-time expenses) from a past incident without any narrative of what happened, scope, or response, matching the tiebreaker for financial impact assessment → Strategy Integration.


reasoning: This paragraph describes a real cybersecurity incident with details on what happened (unauthorized access and deployment of encryption/monitoring software), when (specific date), scope (portions of IT systems and business applications), and response actions (incident response activation, law enforcement notification, external experts, containment), clearly fitting Incident Disclosure. It contains one verifiable specific date, qualifying as Firm-Specific with no additional hard facts for Quantified-Verifiable.


reasoning: This paragraph provides a narrative of an actual cybersecurity incident, detailing unauthorized access by a cybercrime organization, the scope of exfiltrated data (limited customer and employee PII from retail business environment), and response actions including investigation with external experts and notifications to affected parties, regulators, and law enforcement, which matches Incident Disclosure criteria.


reasoning: The paragraph describes ongoing investigation, response actions (reporting to law enforcement and regulators), scope of impact (no evidence of customer data access, no material operational or financial impact) for a specific cybersecurity incident, fitting Incident Disclosure. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


content_category: None/Other

reasoning: This paragraph is a cross-reference to risk factors in another section of the filing, providing no substantive cybersecurity disclosure.


reasoning: This paragraph describes a specific cybersecurity incident including detection date, scope (Canadian operations), response actions (isolation, engagement of professionals), and operational impacts (service delays in Canada), fitting Incident Disclosure. It contains one verifiable specific date but no second hard fact like named firms or tools, making it Firm-Specific rather than Quantified-Verifiable.


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal activities for monitoring data protection laws and implementing process changes to manage cybersecurity risks and ensure compliance, which aligns with Risk Management Process as it focuses on the company's own processes. No specific facts, named standards, roles, or details are present, making it Generic Boilerplate.


content_category: Board Governance

reasoning: The paragraph describes the board of directors' oversight of cybersecurity risks, delegated to the audit committee, which reviews and reports on risk management practices; the board and committee are the grammatical subjects, fitting Board Governance. No specific facts from the ✓ IS list are present, as 'audit committee' is standard/generic and cadences are vague, resulting in Generic Boilerplate.


reasoning: This paragraph describes a specific cybersecurity incident, including the date it was detected, the nature of unauthorized access, response actions taken (e.g., activating incident response procedure, engaging experts, notifying law enforcement), and operational impacts on systems, fitting the Incident Disclosure category precisely. No other category is more applicable as there is no focus on governance, management roles, processes, or strategy.


reasoning: This paragraph provides a standalone materiality conclusion stating no prior incidents have materially impacted the company and future threats could, with a cross-reference to risk factors, fitting Strategy Integration per guidelines. No specific facts, named standards, or unique details present, confirming Generic Boilerplate specificity.


content_category: Management Role

reasoning: The paragraph focuses on the Chief Technology Officer's qualifications, responsibilities for cybersecurity risk management, and reporting lines, making 'Management Role' the most applicable category as the CTO is the grammatical subject.


reasoning: This paragraph details the company's internal cybersecurity risk management processes, including biannual enterprise risk reviews involving the CISO and CIO, mitigation plans, and ERM integration with annual Board review. The focus on the company's own processes aligns with 'Risk Management Process,' with Board mention being brief.


reasoning: This paragraph details response actions, scope of impact (pharmacy, medical claims, payment services), and investigation into a specific real-world cyberattack on Change Healthcare, clearly fitting Incident Disclosure over other categories like Strategy Integration which lacks incident narrative.


reasoning: The paragraph describes the company's internal program for assessing, identifying, managing, and escalating cybersecurity threats and incidents, including controls for classification and reporting, which aligns with Risk Management Process as it focuses on the company's own processes. No specific facts, named standards, roles, or unique details are present, making it generic boilerplate.


reasoning: The paragraph identifies specific management roles (CIO, Information Security Director) and their qualifications, expertise, and team support, making Management Role the clear fit as these are the grammatical subjects and central topic.


reasoning: The paragraph focuses on the Audit Committee's central role in the Board's oversight of cybersecurity risks and how senior IT leadership informs the committee and senior management, making the board/committee the primary grammatical subject. No other category fits as centrally, per tiebreakers.


reasoning: The paragraph focuses on the Board of Directors and Enterprise Risk Management Committee's oversight, training, approvals, and reporting on cybersecurity programs, with the board/committee as the grammatical subjects.


reasoning: The paragraph provides standalone materiality conclusions regarding no material cybersecurity incidents, immaterial expenses, and no penalties/settlements in the last two fiscal years, without any incident narrative or description of actual events, aligning with Strategy Integration per tiebreakers.


reasoning: The paragraph describes the company's internal cybersecurity program, organization (CDRM), leadership (Global CISO), and processes for risk identification, assessment, management, mitigation, including adoption of NIST framework, making Risk Management Process the best fit. It focuses on own processes rather than management roles alone or board oversight.


reasoning: The paragraph centers on the AGM board of directors' involvement in overseeing the risk management program, including cybersecurity, which is a critical component of ERM, making 'Board Governance' the primary category as the board is the grammatical subject. While it mentions integration into ERM and use of NIST and ISO frameworks, the board oversight is the main focus.


reasoning: The paragraph focuses on the company's internal cybersecurity program integration into overall risk management systems and processes for threat mitigation, aligning with Risk Management Process; third-party risk is mentioned only as one component. No qualifying specific facts, named frameworks, or unique details are present, resulting in Generic Boilerplate.


reasoning: The paragraph provides materiality assessments stating no material impact from cybersecurity risks or past incidents on business strategy, operations, or financial condition, which aligns with Strategy Integration per tiebreakers for brief incident mentions with materiality conclusions as the main point. No named frameworks, roles, dates, or other specific facts qualify it beyond Generic Boilerplate.


reasoning: This paragraph details the company's internal cybersecurity incident response policy, escalation procedures to specific teams like the Incident Management Team, disclosure committee, and Privacy and Security Subcommittee, which aligns with Risk Management Process focusing on IR planning. No actual incidents, board oversight, or third-party focus is present.


reasoning: The paragraph describes the company's internal processes for cybersecurity training, employee testing, penetration testing, and assessments to manage risks and determine material impacts, which aligns with Risk Management Process. No board oversight, management roles, incidents, or third-party focus is present.


reasoning: This paragraph details the company's own internal processes for periodic threat and vulnerability assessments, risk prioritization, and mitigation strategies including incident response plans, fitting the Risk Management Process category. No specific facts, named standards, or unique details are present, making it Generic Boilerplate.


reasoning: The paragraph focuses on identifying the CISO and CTO, their tenure with the firm, and detailed qualifications, making 'Management Role' the clear fit as management roles are the grammatical subjects. No board, processes, incidents, or other elements are discussed.


reasoning: The paragraph focuses on the chief financial officer's primary responsibility for cybersecurity risks, reporting lines to/from consultants, and updates to a committee, making management roles the central topic with board oversight mentioned briefly. Per tiebreakers, this assigns to Management Role.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risks, including ERM integration and evaluation by specific teams, aligning with Risk Management Process. It mentions the CSO as part of this process but focuses on the overall risk management approach rather than management roles alone.


reasoning: The paragraph addresses the potential materiality of cybersecurity risks, resource expenditures including cyber insurance, and a standalone materiality conclusion without any incident narrative or specific processes described, aligning with Strategy Integration. No specific facts, named standards, or verifiable details are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph details the cybersecurity responsibilities of Mr. Gharib, making a management role (likely CISO or equivalent) the grammatical subject and central focus. Naming a specific individual unique to this company qualifies as a firm-specific fact.


reasoning: The paragraph details the company's internal cybersecurity risk management activities, including committee meetings, employee training, and security policies, making 'Risk Management Process' the most applicable category. Vendor management is mentioned only as an example policy, not centrally.


reasoning: The paragraph describes the company's use of external experts for audits, threat assessments, penetration testing, and evaluating its own risk management systems, which centers on its internal risk management processes rather than vendor oversight. No named standards, specific roles, dates, firms, or quantifiable details are present, making it generic boilerplate.


reasoning: The paragraph focuses on the Audit Committee's reporting to the Board on cybersecurity and the Board's receipt of briefings and presentations from the CIO, CISO, and CIRO, aligning directly with Board Governance criteria where the board or committee is the grammatical subject.


reasoning: This paragraph provides a standalone materiality conclusion stating no cybersecurity threats in 2023 materially affected or are likely to affect business strategy, operations, or financial condition, with no incident narrative, aligning with Strategy Integration per guidelines and tiebreakers.


reasoning: The paragraph focuses on the Board of Directors assigning the Audit Committee responsibility for cybersecurity oversight, including annual reviews, making board/committee the grammatical subject. No firm-specific facts or named standards are present, confirming generic boilerplate.


reasoning: The paragraph assesses the immateriality of past cybersecurity incidents and expenses over the last three fiscal years, with no incident narrative or description of events, aligning with standalone materiality conclusions under Strategy Integration. It includes a cross-reference to Risk Factors but provides substantive disclosure on financial non-impact.


reasoning: The paragraph discusses the company's processes for identifying, assessing, and managing cybersecurity risks, which aligns with Risk Management Process as it focuses on their own internal risk management activities. It lacks any named frameworks, specific roles, dates, numbers, or other firm-unique facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the company's own incident response plan and its internal processes for handling cybersecurity incidents, including coordination with third-party providers as a component, which fits Risk Management Process. No specific facts, named standards, or unique details are present, making it generic boilerplate.


reasoning: The paragraph focuses on the identification, reporting lines, and responsibilities of the CISO and CTO, making management roles the grammatical subject and central topic. No board oversight or internal processes are the primary focus.


reasoning: The paragraph details the company's internal processes for identifying risks, stakeholder collaboration, threat mitigation, and incident response escalation, aligning with Risk Management Process. It includes a specific team composition as a firm-unique fact, qualifying as Firm-Specific without named standards or multiple verifiable facts.


reasoning: Paragraph provides a standalone materiality assessment concluding no material past cybersecurity impacts during the fiscal year and notes potential future material risks, fitting Strategy Integration per guidelines. Contains one specific date (fiscal year end), qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard fact.


reasoning: The paragraph describes the company's use of third parties for ethical hacking, penetration testing, and program reviews as part of their internal cybersecurity controls and program effectiveness assessment, which fits Risk Management Process; third parties are a component of internal processes, not the central vendor oversight topic.


reasoning: Paragraph identifies a specific individual (Jack Wang) in a cybersecurity management role, details his qualifications and experience, and outlines his reporting lines to executive officers and the Board, making 'Management Role' the clear fit over Board Governance or others.


reasoning: This paragraph is a cross-reference to the Risk Factors section in the same Form 10-K, providing no substantive cybersecurity disclosure and fitting the 'None/Other' category for cross-references.


reasoning: This paragraph details the company's internal audit program, which conducts annual business risk assessments including cybersecurity evaluations and reports to business leaders for prioritization, fitting the Risk Management Process category as it focuses on the company's own internal risk assessment processes.


reasoning: The paragraph focuses on the Board establishing and overseeing via the Cybersecurity Committee, including the chair's cyber expertise, making Board Governance the clear fit as the board/committee is the grammatical subject. Specificity is Firm-Specific due to the named non-generic committee, specific year, and certification claim with named institutions, but lacks two hard verifiable facts like dates plus named cyber firms/tools for Quantified-Verifiable.


reasoning: The paragraph details the company's own cybersecurity activities, including a crisis simulation exercise and augmentation of monitoring, incident response, detection, and forensics using third-party engagements, which centers on internal risk management processes with vendors as a component rather than vendor oversight.


reasoning: Paragraph discusses general cybersecurity threats, risks to the company and third parties, and the need to expend resources, which is boilerplate risk language with no substantive disclosure on governance, processes, incidents, or strategy. No specific facts from the ✓ IS list are present.


reasoning: This paragraph consists of forward-looking disclaimers about potential cybersecurity incidents, insurance limitations, and a cross-reference to Risk Factors, providing no substantive cybersecurity disclosure and fitting 'None/Other'.


content_category: Third-Party Risk

reasoning: The paragraph centrally describes the company's processes for assessing third-party risks, including selection, oversight, and mitigation of risks from vendors, suppliers, and service providers during compromises, which aligns with Third-Party Risk rather than being a mere component of internal Risk Management Process.


reasoning: The paragraph identifies the Vice President of Operations as directing cybersecurity programs and outlines management's responsibilities for risk assessment and mitigation, making a management role the primary grammatical subject; board oversight is contextual rather than central, per tiebreakers favoring Management Role when management roles are the main focus.


reasoning: The paragraph identifies specific management roles (Vice President of Information Systems and CFO) and details their qualifications and tenure related to cybersecurity risk management, making 'Management Role' the clear fit per category definitions and tiebreakers.


reasoning: The paragraph discusses the company's internal cybersecurity risk management processes, which incorporate assessment and oversight of third-party service providers as a component, aligning with Risk Management Process per tiebreakers rather than making third-party risk the central standalone topic.


reasoning: The paragraph centers on the IT department under the CFO as responsible for cybersecurity risk assessment, management, qualifications, and reporting to the Audit Committee, fitting Management Role as it identifies roles and qualifications with the IT department as the grammatical subject.


reasoning: The paragraph focuses on the Board's oversight of enterprise risk management, delegation to the audit committee for cybersecurity risk assessment, and the committee's responsibilities including quarterly reports, fitting Board Governance as the board/committee is the grammatical subject. No qualifying specific facts from the ✓ IS list (e.g., cybersecurity-specific roles, named non-generic committees, dates); Audit Committee and quarterly cadence are generic per ✗ NOT list.


reasoning: The paragraph focuses on the Board of Directors and Audit Committee's oversight of cybersecurity risks, including update cadences, with the board/committee as the grammatical subject, fitting Board Governance. No qualifying specific facts from the ✓ IS list (Audit Committee is explicitly generic per instructions) or named standards, resulting in Generic Boilerplate.


reasoning: The paragraph describes the company's own internal processes for monitoring, vulnerability remediation, incident response exercises, penetration testing, and employee training, making Risk Management Process the best fit; third-party involvement is a minor component, not central. No qualifying specific facts from the ✓ IS list (generic tools, cadences, and practices only), and no named frameworks, resulting in Generic Boilerplate.


reasoning: The paragraph focuses on the Board's oversight of cybersecurity risks, delegation to the Audit Committee, and the committee's review processes, with the board and committee as the primary grammatical subjects. It contains no specific facts from the approved list, only generic references to standard entities like the Board and Audit Committee.


reasoning: The paragraph details the company's integration of cybersecurity into its Enterprise Risk Management process and implementation of a cybersecurity risk management program to protect critical systems, directly matching the Risk Management Process category for internal risk assessment and ERM integration.


reasoning: The paragraph describes the company's adoption of cybersecurity risk management processes using a risk-based approach to assessing, identifying, and managing risks, integrated into overall risk management, which fits Risk Management Process. Board oversight is mentioned briefly as context, not the main subject.


reasoning: This paragraph details the company's own internal processes and measures for managing cybersecurity risks, including risk assessments, incident response plans, monitoring, and employee training, which aligns with Risk Management Process. It lacks any named frameworks, specific roles, dates, numbers, or unique firm facts, qualifying as Generic Boilerplate.


reasoning: The paragraph describes the company's adoption and implementation of the NIST Cybersecurity Framework and internal policies aligned with regulatory requirements, which fits Risk Management Process as it focuses on the company's own internal processes and framework adoption.


reasoning: The paragraph describes the company's internal processes for monitoring, assessing, and escalating cybersecurity incidents via its information security team and incident response plan, which aligns with Risk Management Process. It is not primarily about board oversight or management roles, as those are mentioned secondarily.


reasoning: The paragraph details the company's internal vulnerability assessment program, risk management framework, and vulnerability management processes, which aligns with Risk Management Process as it focuses on the company's own processes. No specific facts, named standards, roles, dates, or unique details are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph details the company's own internal processes and measures for managing cybersecurity risks, such as incident detection, vulnerability management, monitoring, and employee training, fitting Risk Management Process; vendor management is a minor component, not central. No specific facts, named frameworks, roles, dates, or quantifiable details are present, confirming Generic Boilerplate.


reasoning: The paragraph details the company's internal processes for cybersecurity risk mitigation, including cyber insurance review, business continuity/contingency/disaster recovery plans, and annual tabletop exercises for incident response readiness testing, fitting Risk Management Process as the company's own processes are the central topic.


reasoning: The paragraph focuses on the Director of Cybersecurity's responsibilities, qualifications, and reporting lines to the Head of IT and executive committee, making 'Management Role' the clear fit as management roles are the grammatical subjects. No board oversight or internal processes are central.


reasoning: This paragraph describes the company's internal processes for cybersecurity incident detection, severity assessment, triage, notification, and escalation through its Security Operations Center, which aligns with Risk Management Process. It contains no named frameworks, cybersecurity-specific roles, dates, quantified metrics, named tools, or other firm-specific facts from the approved list, making it Generic Boilerplate.


reasoning: This paragraph provides a narrative of a real cybersecurity incident, including the detection date, unauthorized access by a threat actor, data encryption, and immediate response actions like containment and engaging specialists, directly matching Incident Disclosure criteria.


reasoning: This paragraph describes a specific cybersecurity incident including detection date, unauthorized access to IT systems, and response actions like investigation, incident response plan activation, system shutdown, and law enforcement notification, clearly fitting Incident Disclosure. It contains one verifiable specific date, qualifying as Firm-Specific with no other qualifying facts or named standards.


category_confidence: medium

reasoning: The paragraph describes internal processes to oversee and identify cybersecurity risks specifically in connection with third-party service providers, fitting Risk Management Process as vendors are mentioned as a component of internal risk oversight rather than the central standalone topic; materiality statements are boilerplate and secondary.


reasoning: The paragraph details an actual cybersecurity incident including detection of unauthorized activity, response actions like containment and isolation, and involvement of experts/law enforcement, directly matching Incident Disclosure criteria with reference to a real event. It contains one hard verifiable fact (specific date), qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second such fact.


reasoning: The paragraph provides materiality assessments of an ongoing cybersecurity incident's operational and potential financial impacts without any incident narrative, scope, or response details, aligning with Strategy Integration per tiebreakers for financial/impact assessments without describing what happened. No qualifying specific facts, named standards, or verifiable details are present, resulting in Generic Boilerplate.


reasoning: This paragraph describes the details of a cybersecurity incident, including the threat actor's actions (access and exfiltration of limited data including some PII) and response (notifications to affected parties and regulators), fitting the Incident Disclosure category as it references a real event with scope and response actions. No firm-specific facts, dates, named entities, or standards are present, making it Generic Boilerplate.


reasoning: This paragraph details investigation findings and ongoing efforts regarding a specific cybersecurity incident, including absence of malware or ongoing access and assessment of potential data/system impacts, which matches Incident Disclosure criteria for incident narrative, response actions, and scope.


reasoning: The paragraph details a specific cybersecurity incident detected on February 6, 2024, including detection, response actions like initiating protocols, investigation, engaging a firm, notifications, and containment, which matches Incident Disclosure criteria for actual event narrative and response.


reasoning: The paragraph focuses on a materiality assessment and lack of material financial or operational impact from an incident, without any incident narrative, scope, or detailed response actions, fitting Strategy Integration per tiebreakers for financial impact assessment without describing what happened. No specific facts from the ✓ IS list are present, such as dates, roles, named entities, or quantified metrics, resulting in Generic Boilerplate.


reasoning: This paragraph describes response actions (contain and remediate) and scope/impact of a specific cybersecurity incident (Bank systems not compromised, no unauthorized transactions or fund transfers, members continued operations), fitting Incident Disclosure. No verifiable facts, named standards, roles, or unique details qualify it beyond Generic Boilerplate.


reasoning: The paragraph assesses the financial and operational impacts and materiality of a cybersecurity incident without any incident narrative, response details, or scope, aligning with Strategy Integration per tiebreakers for financial impact assessments without describing what happened. It includes two specific dates (quarter ended December 31, 2024, and full year 2024) as hard verifiable facts, meeting the threshold for Quantified-Verifiable.


reasoning: This paragraph describes the operational impacts, affected areas (distribution, billing, etc.), recovery status, and revenue percentage affected by a specific cybersecurity incident, directly matching Incident Disclosure criteria including scope and impact of a real event. It includes two hard verifiable facts (specific date and percentage), meeting Quantified-Verifiable threshold.


reasoning: This paragraph is a standard forward-looking statement disclaimer with no reference to cybersecurity or any substantive disclosure, directly matching the 'None/Other' category description.


reasoning: The paragraph focuses on the financial impact and materiality assessment of a past incident on Q2 results of operations, with specific EPS figures, fitting Strategy Integration per tiebreakers for financial cost/impact without incident narrative. No description of the incident itself (what happened, scope, response) rules out Incident Disclosure.


reasoning: This paragraph details a specific cybersecurity incident, including the detection date, nature of the unauthorized access and data encryption, and immediate response actions such as containment and engaging specialists, which matches Incident Disclosure criteria.


reasoning: The paragraph provides a materiality assessment of an ongoing cybersecurity incident, stating no material impact on operations or financial condition, without describing the incident itself, which fits Strategy Integration per tiebreakers for financial impact assessments without incident narrative. No specific facts, named standards, or unique details are present, confirming Generic Boilerplate.


reasoning: This paragraph describes a specific cybersecurity incident including timeline (May/June 2023), unauthorized access and exfiltration of SharePoint files, response actions (investigation, containment, remediation), and materiality assessment, fitting Incident Disclosure per guidelines and tiebreakers prioritizing incident narrative.


reasoning: This paragraph details the operational impacts (shipping, receiving, manufacturing), evidence of files taken, and response actions (investigation, notifications) for a specific cybersecurity incident, making it Incident Disclosure. No qualifying specific facts (dates, named entities, quantities) from the IS list; operational functions listed are generic.


reasoning: The paragraph provides a narrative of a real cybersecurity incident, including detection of unauthorized activity on IT systems and specific response actions like isolation on a given date, directly matching Incident Disclosure criteria.


reasoning: Paragraph assesses financial expenses and materiality of an incident without describing the incident itself, fitting Strategy Integration per tiebreakers for financial impact assessment absent incident narrative. No specific facts from the ✓ IS list; all elements are boilerplate phrases like 'material impact' and vague risks.


reasoning: This paragraph describes the scope of an actual cybersecurity incident, including additional exfiltrated data confirmed to contain PII and PHI from a company subsidiary providing patient support services, which matches Incident Disclosure criteria for incident narrative and affected data scope. No qualifying specific facts from the ✓ IS list (no dates, roles, named entities, quantifiers, or frameworks), resulting in Generic Boilerplate specificity.


reasoning: This paragraph provides a standalone materiality conclusion regarding the financial and operational impact of a cybersecurity incident without any incident narrative, scope, or response details, fitting Strategy Integration per tiebreakers. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: Paragraph details a real ransomware incident with date, scope (internal IT systems), discovery, response actions (containment, experts engaged, investigation), matching Incident Disclosure. Contains one verifiable specific date, making it Firm-Specific but not Quantified-Verifiable (only one hard fact).


reasoning: This paragraph describes the scope of a real cybersecurity incident, specifying the volume of personal data stolen (35.5 million consumers) and data not affected (no SSNs, bank info, payment cards, or passwords), directly matching Incident Disclosure criteria including affected data scope.


reasoning: The paragraph details financial impacts (expenses and lost revenue) from a cybersecurity incident without describing the incident itself, aligning with Strategy Integration per tiebreakers for financial cost assessments without incident narrative. Multiple verifiable facts including specific fiscal periods and dollar amounts confirm Quantified-Verifiable specificity.


reasoning: This paragraph describes a specific cybersecurity incident including unauthorized access, misdirection of a $250,000 wire payment, and deletion of email messages, with details on the scope and unrecovered payment, fitting Incident Disclosure per the criteria for actual event narratives and impacts.


reasoning: This paragraph describes the scope of data exfiltrated in a cybersecurity incident, specifying IT and financial information prepared for the Form 10-K filing ending August 31, 2025, which fits Incident Disclosure as it details affected data scope for a real event.


reasoning: The paragraph assesses financial impacts (no material operational effects but material Q1 expenses for notifications) and mentions cyber insurance for a past incident without describing what happened, aligning with Strategy Integration per tiebreakers for cost/impact assessment without incident narrative. No substantive incident details like scope, timing, or response actions are provided.


reasoning: This paragraph details regulatory delays in incident disclosure, ongoing law enforcement collaboration, apprehension of an individual involved, and the current status of affected data availability, which qualifies as incident response actions and descriptions related to a disclosed cybersecurity incident.


reasoning: This paragraph details the company's incident response actions, including launching an investigation with forensic investigators, notifying law enforcement, regulatory authorities, and affected users, which directly matches the Incident Disclosure category for descriptions of actual cybersecurity incidents and response actions.


reasoning: This paragraph details response actions to an ongoing cybersecurity incident (system restoration, retaining experts, law enforcement coordination, notifications) and specifies the scope (limited to Change Healthcare systems, others operational), directly matching Incident Disclosure criteria for incident response and affected systems scope.


reasoning: The paragraph focuses on materiality assessments of an incident's impact on business operations and financial condition without narrating what happened, aligning with Strategy Integration per tiebreakers for financial impact assessment without incident description. It references scope limited to Dropbox Sign but emphasizes no material impact and ongoing risks.


reasoning: The paragraph assesses the financial and operational impacts of a referenced incident, including expenses, risks, and materiality conclusions, without any incident narrative or description of what happened, aligning with Strategy Integration per tiebreakers for financial impact assessment without incident details.


reasoning: This paragraph details the incident detection, response actions including containment and remediation, a specific date of action, and resumption of operations, clearly describing an actual cybersecurity incident.


reasoning: This paragraph describes the scope of an actual cybersecurity incident, including file exfiltration, ongoing investigation into sensitive/personal information, and evaluation of notifications, which matches Incident Disclosure criteria with reference to a real event and response actions. No specific facts from the ✓ IS list (e.g., dates, named roles, firms, or quantified details) are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph provides a detailed narrative of an actual cybersecurity incident, including the date it occurred, unauthorized access by a threat actor, response actions (activating response plan with external experts, containment, remediation), restoration timeline, and lack of material impact, which directly matches Incident Disclosure criteria. It includes one verifiable specific date but no second hard fact like named firms or tools, confirming Firm-Specific specificity.


reasoning: This paragraph provides a narrative of a real cybersecurity incident, including the date of identification (June 9, 2025), unauthorized access to information systems, discovery via employee communications from a threat actor, and activation of the incident response plan, directly matching Incident Disclosure criteria.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident, including what happened (unauthorized access and exfiltration of call logs), when (multiple precise dates), scope (customer call and text records), and initial response (incident response process and external experts), clearly fitting Incident Disclosure. It contains four specific dates, exceeding the threshold for Quantified-Verifiable.


reasoning: Paragraph focuses on financial costs ($600,000), operational impacts (two weeks lost production), and materiality conclusion for Q4 ending June 29, 2024, without describing the incident itself, fitting Strategy Integration per tiebreakers for financial impact assessment absent incident narrative.


reasoning: This paragraph is a standard forward-looking statement disclaimer with no reference to cybersecurity or any substantive disclosure, directly matching the 'None/Other' category description for forward-looking disclaimers and non-cybersecurity content.


reasoning: This paragraph details a real cybersecurity incident, including the detection date, suspicious activity on IT systems, and response actions like isolation and investigation, which matches Incident Disclosure. No other categories fit as it focuses on the event narrative rather than processes, roles, or strategy.


reasoning: This paragraph describes a real cybersecurity incident including detection date, scope (portion of IT systems), response actions (investigation, incident response plan activation, system shutdown), and containment outcome, directly matching Incident Disclosure criteria with no stronger fit elsewhere.


reasoning: This paragraph provides a narrative of an actual cybersecurity incident, including the detection date, unauthorized access to company data and systems, and specific response actions like engaging experts, counsel, and law enforcement, directly matching Incident Disclosure criteria.


reasoning: This paragraph provides a narrative of a real cybersecurity incident, including the date discovered, nature of the event (data exfiltration from information systems, potentially including personal information), and initial response actions (containment and investigation), which directly matches Incident Disclosure. It contains one specific verifiable fact (date), qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: This paragraph provides a detailed description of an actual cybersecurity incident, including the scope of unauthorized access to specific personal information types for approximately 8.4 million users, directly matching the Incident Disclosure category criteria for incident narrative and affected data scope.


reasoning: The paragraph assesses the financial and operational impact of an incident without providing any narrative of what happened, focusing on materiality conclusions, which aligns with Strategy Integration per tiebreakers for financial impact assessment without incident description and brief incident mention with materiality as main point.


reasoning: The paragraph details the company's response to a specific cybersecurity incident, including activation of protocols, containment measures, investigation assistance, law enforcement notification, and ongoing restoration and notification efforts, fitting Incident Disclosure. No named frameworks, roles, dates, firms, products, or other specific facts qualify under the ✓ IS list; all elements are generic or boilerplate phrases.


reasoning: This paragraph provides a standalone materiality conclusion regarding an incident's impact on financial condition without any incident narrative or description of what happened, aligning with Strategy Integration per tiebreakers. It contains no specific facts, frameworks, or details unique to the company, making it generic boilerplate.


reasoning: This paragraph describes a specific ransomware incident including dates, what happened (encryption of files, unauthorized disclosure), response actions, and scope, fitting Incident Disclosure. It includes two specific dates, qualifying as Quantified-Verifiable.


reasoning: The paragraph provides a materiality assessment and financial impact conclusion for a referenced incident without any narrative description of what happened, aligning with Strategy Integration per tiebreakers. It includes one specific date (March 31, 2026), qualifying as Firm-Specific with no other verifiable facts reaching Quantified-Verifiable.


reasoning: This paragraph details the company's incident response actions, such as activating its cybersecurity response plan, conducting an internal investigation with external advisors, taking systems offline, notifying law enforcement, and assessing impacted data, which matches Incident Disclosure criteria for describing response to a real event. It lacks any specific dates, named entities, quantifiable metrics, or unique firm facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes response actions taken to an actual cybersecurity incident, including containment measures, enhanced monitoring, expert engagement, and notifications, fitting the Incident Disclosure category which includes incident response actions for a real event. No narrative of what happened or scope is provided, but the focus on post-incident actions aligns with this category over others like Risk Management Process.


reasoning: This paragraph provides a narrative of a real cybersecurity incident, including the date learned (February 21, 2024), data exfiltration from information systems possibly containing personal information, and initial response actions like containment and investigation, directly matching Incident Disclosure criteria.


reasoning: This paragraph describes the scope of an actual cybersecurity incident (exfiltrated files, sensitive/personal information in accessed systems) and response actions (investigation, notification evaluation), directly matching Incident Disclosure criteria. No qualifying specific facts from the ✓ IS list (no dates, names, numbers, roles, etc.), resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a standard legal disclaimer about non-filed information and incorporation by reference, containing no substantive cybersecurity disclosure or content.


reasoning: The paragraph describes response and remediation actions for a specific disclosed incident, including containment and ongoing efforts with experts, fitting Incident Disclosure as it references incident response actions for a real event without narrative details. No specific facts from the ✓ IS list or hard verifiable items are present, resulting in Generic Boilerplate.


reasoning: The paragraph provides a materiality assessment of a previously disclosed cyber incident's impacts on business operations and financial condition, stating they are not material, which aligns with Strategy Integration per tiebreakers for financial impact without incident narrative or brief incident mention with materiality as main point. No qualifying specific facts are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph details the scope of affected data and what was not compromised in a specific cybersecurity incident ('The Incident'), fitting the Incident Disclosure category as it describes the incident's impact on data and systems without narrative of what happened or response actions. No qualifying specific facts from the ✓ IS list (no dates, roles, named firms/tools, numbers, etc.), and no named standards, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes remediation actions, restoration of access, and confirmation of data integrity following a cybersecurity incident, fitting the Incident Disclosure category as it details response actions and scope of impact for a real event. No specific facts qualify under the ✓ IS list, resulting in Generic Boilerplate specificity.


reasoning: The paragraph discusses incorporating cybersecurity risk management into overall enterprise risk management programs with shared methodologies and governance, directly matching Risk Management Process (ERM integration). No specific facts, frameworks, roles, or details are present, making it generic boilerplate.


reasoning: The paragraph focuses on the board of directors' oversight of cybersecurity risks and annual updates from the audit committee, making board the grammatical subject and fitting Board Governance. No qualifying specific facts from the ✓ IS list; Audit Committee and annual cadence are generic per ✗ NOT list, resulting in Generic Boilerplate.


reasoning: The paragraph focuses on the financial and operational materiality assessment of a cybersecurity incident, stating no expected material impact on financial condition or results of operations, with Targus not being a significant EBITDA contributor last year; this aligns with Strategy Integration per tiebreakers for financial impact without incident narrative. No specific facts from the ✓ IS list (no dates, numbers, named roles/committees/programs/tools/firms, or certifications), resulting in Generic Boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity risk management process, including a risk-based approach to evaluating third-party vendors as a component, which fits Risk Management Process per tiebreakers. No named standards, roles, dates, or other specific facts are present, confirming Generic Boilerplate.


reasoning: The paragraph briefly references a past cybersecurity incident but primarily focuses on its immaterial financial and operational impact assessment and future materiality conclusion, aligning with Strategy Integration per tiebreakers (brief mention of incident + materiality as main point). No incident narrative, scope details, or response actions are provided.


reasoning: This paragraph is a forward-looking disclaimer about potential cybersecurity incidents and a cross-reference to Risk Factors, containing no substantive disclosure on governance, processes, incidents, or strategy, thus fitting 'None/Other'.


reasoning: The paragraph updates on the real Change Healthcare cyberattack, referencing incident response actions such as data assessment, notifications to impacted individuals/providers/customers, and service restoration progress, fitting Incident Disclosure despite cross-referencing a press release. None/Other was considered due to the exhibit reference, but substantive response details tip it to disclosure.


reasoning: The paragraph focuses on the Committee's receipt of reports and updates from management on cybersecurity risks and incidents, as well as its reporting to the full Board, which aligns with board/committee oversight under Board Governance. No specific facts qualify under the ✓ IS list, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses on the board of directors and its audit committee overseeing cybersecurity risk management and assessments, directly matching the Board Governance category as the board/committee is the grammatical subject.


reasoning: Paragraph describes ongoing response actions to a referenced cybersecurity incident (communication with stakeholders, following internal standards, assessing effects) and minimal operational impact (continued global service provision), fitting Incident Disclosure as it covers incident response and scope of impact without financial details or narrative of the event itself.


reasoning: The paragraph describes the company's own internal cyber risk management program, including identification, assessment, mitigation, response, and integration with enterprise risk management processes, which aligns with Risk Management Process. No specific facts, named frameworks, roles, or verifiable details are present, making it generic boilerplate.


reasoning: The paragraph describes the company's ongoing investments and enhancements to internal controls and processes for protecting systems and data, which aligns with Risk Management Process as it focuses on the company's own internal cybersecurity practices. No specific details, roles, frameworks, or incidents are mentioned, making it generic boilerplate.


reasoning: The paragraph consists of generic boilerplate statements about dependence on IT systems and third-party technology with no substantive cybersecurity disclosure, fitting None/Other.


reasoning: The paragraph discusses the company's implementation of a cybersecurity program as part of enterprise risk management to assess, identify, and manage cybersecurity risks, directly matching Risk Management Process. It contains no named frameworks, roles, dates, numbers, or other specific facts, qualifying as Generic Boilerplate.


reasoning: The paragraph describes oversight responsibilities for cybersecurity policies, data privacy compliance, and evaluation of the Cybersecurity Committee's composition and performance, which aligns with board or committee oversight of cyber risk. The grammatical focus is on review, oversight, and evaluation by what appears to be a governing body.


reasoning: The paragraph describes the company's own cybersecurity program and its protective design, which aligns with Risk Management Process as it focuses on internal processes. It contains no specific details, named entities, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the general professional background of Mr. Tao in business consultation, operations, management, and marketing, with no reference to cybersecurity, roles, processes, or incidents, making it non-cybersecurity content.


reasoning: The paragraph specifies management roles, particularly the head of the ITS Department and executive management, as primarily responsible for assessing and managing cybersecurity risks, fitting the 'Management Role' category as these are the grammatical subjects.


reasoning: The paragraph discusses cybersecurity risk management as an integral part of the company's overall enterprise risk management program, directly fitting the Risk Management Process category due to ERM integration. No specific facts, named standards, or unique details are present, making it Generic Boilerplate.


reasoning: The paragraph centers on the Board of Directors as the grammatical subject receiving quarterly reports from the CISO and CIO on cybersecurity threats, risks, and mitigation processes, directly matching Board Governance criteria for board oversight and briefing cadence.


reasoning: This paragraph lists generic cybersecurity threats and vulnerabilities like malware, ransomware, and phishing without referencing any company processes, governance, incidents, or specific actions, making it non-substantive boilerplate.


reasoning: The paragraph details the company's internal incident response and recovery frameworks and testing practices, aligning with Risk Management Process as it focuses on own internal processes for IR planning. No specific facts from the ✓ IS list or named standards are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the company's internal processes for protecting PII through a policy and employee training programs, which fits Risk Management Process. No specific facts, named standards, or unique details qualify it beyond generic boilerplate.


reasoning: The paragraph focuses on the identification, experience, and joining date of the company's cybersecurity-specific officer, directly matching Management Role criteria for CISO-like qualifications.


reasoning: This paragraph describes general oversight of strategic and material risks by the board and executive officers with no mention of cybersecurity, qualifying as non-cybersecurity content under None/Other.


reasoning: The paragraph focuses on the audit committee reporting to the board and the board receiving briefings from management on cyber risks, with the board and committee as the grammatical subjects, fitting Board Governance. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate.


reasoning: This paragraph provides a standalone materiality conclusion stating no cybersecurity incidents have materially affected the business, results of operations, or financial position, fitting Strategy Integration per tiebreakers. No incident narrative or other process details are present.


reasoning: The paragraph centrally describes the company's process for reviewing and monitoring key third-party IT providers' cybersecurity measures, including use of a specific tool, making vendor oversight the primary topic. This fits Third-Party Risk as it focuses on oversight of vendors rather than internal processes.


reasoning: The paragraph describes a generic step in the incident response process (eradication phase), focusing on the company's internal IR planning without referencing any specific incident or event. No firm-specific details, named standards, or verifiable facts are present, making it boilerplate.


reasoning: The paragraph vaguely mentions using reputable third-party providers' products with cybersecurity protections but lacks any substantive disclosure on processes, oversight, incidents, or strategy, making it non-cybersecurity substantive content.


reasoning: The paragraph focuses on identifying specific management roles (CIO and Director of IT Security, Risk and Compliance) and their qualifications (combined 20 years experience), which directly matches the 'Management Role' category as these roles are the grammatical subjects.


reasoning: This paragraph is a section header ('Risk Management and Strategy') followed by a generic introductory sentence with no substantive disclosure on cybersecurity processes, fitting 'None/Other' for headers and non-substantive content.


reasoning: The paragraph discusses the qualifications and experience of the company's information technology team in cybersecurity, with the team as the grammatical subject, aligning with Management Role. No specific roles like CISO or unique details are mentioned, but it fits the category over others like Risk Management Process which requires internal processes.


reasoning: The paragraph focuses on the internal cybersecurity coordinator's role in assessing risks, collaborating with the IT team, and reporting to the CEO, which directly matches the 'Management Role' category criteria for identifying roles and reporting lines.


reasoning: This paragraph provides a standalone materiality conclusion stating no significant cybersecurity breach or associated costs occurred in specified periods, with no incident narrative. It fits Strategy Integration per tiebreakers for materiality assessments without incident details.


reasoning: The paragraph identifies the CFO serving as CISO and describes their role in managing cybersecurity processes, with management roles as the grammatical subject and central topic.


reasoning: The paragraph describes elements of the company's own cybersecurity programs, including threat intelligence investment, industry engagement, and use of external experts for testing and assessment, which fits Risk Management Process as internal processes with external components mentioned briefly. No specific facts from the ✓ IS list or named standards are present, making it Generic Boilerplate.


reasoning: The paragraph focuses on CSO and CISO (management roles) staying informed and communicating updates, including reporting lines to a committee and board, making Management Role the primary category per guidelines and tiebreakers.


reasoning: The paragraph centers on the Board receiving regular updates on cybersecurity risks from the Audit Committee and Cybersecurity team, with the Board as the grammatical subject, directly fitting Board Governance. No specific facts qualify under the ✓ IS list, as 'Audit Committee' is generic, 'Cybersecurity team' is not a specific composition or role, and 'regular' is a vague cadence, resulting in Generic Boilerplate.


reasoning: The paragraph discusses the company's ongoing review, refinement, and updates to its incident response plan based on lessons learned and best practices, which directly pertains to their own internal risk management processes, specifically incident response planning.


reasoning: The paragraph focuses on the Board and Audit Committee receiving regular reports and updates from management on cybersecurity risks and incidents, with the board/committee as the grammatical subject, fitting Board Governance. No firm-specific facts, named standards, or verifiable details are present, confirming Generic Boilerplate.


reasoning: This paragraph provides a standalone materiality conclusion regarding no material cybersecurity incidents or expenses in the last three fiscal years, with no incident narrative, fitting Strategy Integration per tiebreakers. It lacks any named standards, specific dates, roles, or verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph focuses on specific management roles (CIO and VP of Information Security) as the grammatical subjects with primary responsibility for cybersecurity, fitting 'Management Role'. No board, processes, incidents, or third-party centrality is present.


reasoning: The paragraph details the company's internal practices for employee training and phishing simulations, which are components of their risk management processes for cybersecurity awareness and incident response.


reasoning: This paragraph provides a standalone materiality conclusion stating no cybersecurity incidents have materially impacted or are likely to impact the company as of specific dates, fitting Strategy Integration per tiebreakers. No incident narrative or other processes are described.


reasoning: The paragraph focuses on management's monitoring of prevention, detection, mitigation, and remediation of cybersecurity incidents, which aligns with the company's internal risk management processes; mentions of service providers and ISP personnel are components of this process rather than the central topic.


reasoning: The paragraph discusses cyber insurance coverage to mitigate financial losses, which aligns with Strategy Integration including cyber insurance and financial impact mitigation. No specific details, roles, or incidents are mentioned, making it boilerplate.


reasoning: The paragraph describes the company's approach to developing, implementing, and maintaining cybersecurity measures to protect information systems and data, focusing on its own internal risk management processes without referencing board, management roles, incidents, or third parties.


reasoning: The paragraph describes the company's own internal strategies for assessing, identifying, and managing cybersecurity risks, including traffic monitoring tools and user training, which fits Risk Management Process as it focuses on internal processes.


reasoning: The paragraph describes the company's own implemented processes to identify, assess, and manage cybersecurity risks to their systems and data, directly matching 'Risk Management Process'; third-party services are mentioned only as part of the scope, not centrally. No specific facts, named frameworks, roles, dates, or quantifiable details are present, confirming Generic Boilerplate.


reasoning: The paragraph describes the responsibilities of specific C-suite executives (CFO, COO, CEO) for managing cybersecurity risks and policies, making management roles the grammatical subject and central topic. No board oversight or internal processes are discussed, fitting 'Management Role' over other categories.


reasoning: The paragraph focuses on the Board of Directors providing oversight of the cybersecurity program through periodic updates and annual discussions as part of enterprise risk management, directly matching the Board Governance category where the board is the grammatical subject.


reasoning: The paragraph details the functions of cybersecurity professionals in analyzing threats, defining policies, implementing protections, and monitoring/responding to incidents, which describes the company's own internal risk management processes. No specific facts, named standards, roles, or verifiable details are present, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity awareness training and a risk management process for third-party providers, including due diligence and monitoring, which fits Risk Management Process as vendors are a component of internal processes rather than the central topic. No named standards, roles, dates, or unique facts elevate specificity beyond generic boilerplate.


reasoning: This paragraph describes the company's own internal cybersecurity risk management system for identifying, assessing, and mitigating risks and protecting information assets, which directly matches 'Risk Management Process' as the topic of internal processes.


reasoning: The paragraph describes the company's internal cybersecurity training program for employees and contractors, including communication of security policies and practices, which fits Risk Management Process as it focuses on the company's own processes. No specific facts, named standards, or verifiable details are present, making it generic boilerplate.


reasoning: The paragraph contains only generic boilerplate language about high-level goals for cyber incidents with no substantive details on processes, roles, incidents, or specifics, fitting None/Other.


reasoning: The paragraph describes the company's own internal Incident Response Plan (IRP) and its testing via annual tabletop exercises, which aligns with Risk Management Process focusing on IR planning and internal processes. No specific facts from the ✓ IS list are present, and no named standards, making it Generic Boilerplate.


reasoning: The paragraph explicitly addresses 'Management's Role' in handling day-to-day cybersecurity by IT staff, including their qualifications (lack of specialized training) and future considerations, making 'Management Role' the clear fit. No specific facts from the ✓ IS list or named standards are present, confirming Generic Boilerplate.


reasoning: The paragraph describes the company's multi-layered cybersecurity program, including administrative, physical, and technical measures, and incident response plan, which are internal risk management processes. No board, management roles, incidents, or third-parties are the focus.


reasoning: The paragraph describes the company's establishment of an internal multi-disciplinary team for cybersecurity awareness and training, which is a core element of its own risk management processes. No other category fits as centrally, with no board/management focus, incidents, or third-party emphasis.


reasoning: This paragraph provides a standalone materiality conclusion stating no cybersecurity threats materially affected the business in 2024, with no incident narrative, fitting Strategy Integration. The cross-reference to Risk Factors supports this as a materiality assessment rather than substantive process or incident details.


reasoning: The paragraph describes the company's own internal cybersecurity programs, including policies, procedures, assessments, monitoring, response plans, and testing for controls, which aligns with Risk Management Process as the focus on OWN internal processes. No specific facts from the ✓ IS list are present, and no named standards, making it Generic Boilerplate.


reasoning: This paragraph states a materiality conclusion regarding an incident's impact on financial condition without any incident narrative or description, aligning with Strategy Integration per tiebreakers for financial impact assessments without incident details. No specific facts, frameworks, or verifiable elements are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes the company's planned comprehensive process for identifying, assessing, and managing cybersecurity risks as part of its broader risk management system, which aligns with Risk Management Process. No other categories fit as there are no mentions of board, management roles, incidents, third-parties, or financial strategy.


reasoning: The paragraph details ongoing forensic analysis and investigation into a specific cybersecurity incident, which qualifies as incident response actions under Incident Disclosure for a real event referenced in an Item 1.05 filing. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph identifies specific management roles, including the Senior Director of IT and CFO, responsible for implementing and maintaining cybersecurity processes, making 'Management Role' the most applicable category as management roles are the grammatical subject.


reasoning: This paragraph provides a standalone materiality conclusion regarding an incident's impact on financial condition and operations, with no incident narrative or description, aligning with Strategy Integration per tiebreakers. It contains no specific facts, frameworks, or details unique to the company, making it generic boilerplate.


reasoning: The paragraph addresses cyber insurance reimbursement for costs stemming from a cyber incident, which aligns with Strategy Integration as it covers financial impact and insurance without describing the incident itself or providing a narrative, per tiebreakers for financial cost assessment without incident details.


reasoning: The paragraph identifies specific management roles (chief technology officer and senior director of cybersecurity and compliance), their professional certifications/qualifications, and reporting lines to the Audit Committee, making Management Role the most applicable category over the brief mention of a generic risk management program.


reasoning: The paragraph discusses the potential material financial impact of an incident without providing any incident narrative, details on what happened, or response actions, aligning with Strategy Integration per tiebreakers for financial impact assessments without incident description. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph assesses the financial and operational impacts of 'the Incident,' including no material disruption to operations and potential losses from revenue, remediation, penalties, and litigation, without describing the incident itself, aligning with Strategy Integration for materiality assessments. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes ongoing response actions to a cybersecurity incident, including system restoration efforts, engagement of experts, and notifications to law enforcement and regulators, which fits Incident Disclosure as it details response to a real event with operational impact. No firm-specific facts, named standards, or verifiable details are present, making it Generic Boilerplate.


reasoning: This paragraph states a standalone materiality conclusion regarding a cybersecurity incident's impact on financial condition without any incident narrative, response details, or scope, aligning with Strategy Integration per tiebreakers for materiality assessments. It uses boilerplate language with no named entities, dates, roles, or verifiable facts, confirming Generic Boilerplate specificity.


reasoning: The paragraph discusses cybersecurity insurance coverage for various costs, which falls under Strategy Integration as it addresses cyber insurance without referencing a specific incident or other processes. No firm-specific facts, dates, numbers, or named entities are present, making it generic boilerplate.


reasoning: This paragraph provides a materiality assessment of a cybersecurity incident's impact on operations and financial condition without any incident narrative, scope, or response details, aligning with Strategy Integration per tiebreakers for financial impact assessments without describing what happened. It contains no specific facts, named standards, or unique details, making it generic boilerplate.


reasoning: The paragraph provides a materiality assessment of a past cybersecurity incident without any narrative description of the event, response, or scope, aligning with Strategy Integration per tiebreakers for financial impact assessments without incident details. No specific facts are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph addresses legal waivers under credit and lease agreements with no mention of cybersecurity, classifying it as non-cybersecurity content under None/Other.


reasoning: This paragraph describes the details of a cybersecurity incident, including unauthorized access, data exfiltration of limited data including some PII, and ongoing notification response actions, referencing a real previously disclosed event. It fits Incident Disclosure as it provides incident narrative, scope of affected data, and response actions without focusing on financial impact or processes.


reasoning: The paragraph discusses ongoing business and financial risks stemming from a past cybersecurity incident, including litigation, customer behavior changes, regulatory scrutiny, and potential increases in cybersecurity insurance costs, which aligns with Strategy Integration (business/financial impact and cyber insurance) rather than Incident Disclosure due to the absence of any incident narrative, timeline, scope, or response details.


reasoning: This paragraph assesses the materiality of an incident's impact on operations and financial condition without any incident narrative, aligning with Strategy Integration per tiebreakers for financial impact assessments without describing what happened. It contains no specific facts, named standards, or unique details, making it generic boilerplate.


reasoning: This paragraph describes incident response actions, specifically notifications to law enforcement and regulatory bodies about 'the matter,' which references a cybersecurity incident, fitting Incident Disclosure. It contains no specific facts, named entities, dates, or unique details, making it generic boilerplate.


reasoning: This paragraph assesses the materiality of a cybersecurity incident on operations and financial condition without any incident narrative, response details, or scope, aligning with Strategy Integration per tiebreakers for financial impact assessments without describing what happened.


reasoning: This paragraph details incident response actions involving notifications to law enforcement and regulators about 'the matter,' fitting Incident Disclosure as it describes response to a real event without narrative details. It contains no specific facts, named entities, dates, or standards, making it Generic Boilerplate.


reasoning: This paragraph states a materiality conclusion for an incident without describing what happened, its scope, or response actions, aligning with Strategy Integration per tiebreakers for standalone materiality assessments. It contains no specific facts from the ✓ IS list, only boilerplate language, making it Generic Boilerplate.


reasoning: The paragraph describes executive resignations and appointments in a subsidiary with no reference to cybersecurity risks, incidents, governance, or processes, making it non-cybersecurity content classified as None/Other.


reasoning: The paragraph provides a materiality assessment of an incident's impact on operations and financial condition without any incident narrative, scope, or response details, aligning with Strategy Integration per tiebreakers for financial impact assessments without describing what happened.


reasoning: The paragraph references a past incident briefly but focuses primarily on materiality conclusions (no material disruption) and ongoing evaluation of financial, legal, and reputational impacts, fitting Strategy Integration per tiebreakers for incident impact assessment without narrative details.


reasoning: This paragraph provides a narrative of a real cybersecurity incident experienced by a third-party provider, including specific dates of notification and confirmation, and scope of customer information exposure, directly matching Incident Disclosure criteria.


reasoning: The paragraph describes response actions to a specific cybersecurity incident, including closing the point of access and notifying impacted customers, fitting the Incident Disclosure category as it references a real event and response without financial details or other focuses.


reasoning: The paragraph addresses financial impacts (direct costs) and cyber insurance recoveries for a cybersecurity incident without any incident narrative, description of what happened, or scope, aligning with Strategy Integration per the tiebreaker for financial cost/impact assessment without incident details.


reasoning: The paragraph describes the scope and operational impact (inaccessibility of certain networks and transactional services) of an ongoing cybersecurity incident and references a specific status page for updates, aligning with Incident Disclosure criteria for affected systems and incident details.


reasoning: This paragraph details response actions to a specific cybersecurity incident, including containment, restoration of the core IT environment, and progress on business operations recovery, which aligns with Incident Disclosure criteria. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph assesses the financial materiality of an incident without providing any incident narrative, scope, or details of what happened, aligning with Strategy Integration per tiebreakers for financial impact assessment without incident description. No specific facts, named entities, dates, or quantifiable details are present, making it generic boilerplate.


reasoning: This paragraph describes the ongoing investigation into the scope of potentially affected data and response actions including remediation and coordination with a cyber insurance provider, which fits Incident Disclosure as it references aspects of a real cybersecurity incident's scope and response without a full narrative. No firm-specific or verifiable facts are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes response actions (containment, system restoration, resuming operations) to a specific cybersecurity incident referenced as 'the incident,' fitting Incident Disclosure criteria for actual event response without narrative details or financial impact.


reasoning: The paragraph describes ongoing investigation and forensic analysis into a cybersecurity incident involving threat actors and potential PII theft, fitting Incident Disclosure as it references response actions for a real event. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph assesses the financial and operational impact of a past incident without providing any incident narrative, scope, or response details, aligning with Strategy Integration per tiebreakers for materiality conclusions as the main point. No specific facts, named standards, or unique details are present, making it Generic Boilerplate.


reasoning: This paragraph provides a materiality assessment regarding the financial impact of an incident without any incident narrative or details, aligning with Strategy Integration per tiebreakers for standalone materiality conclusions.


reasoning: This paragraph details the ongoing investigation of a cybersecurity incident, assessment of exfiltrated personal information scope, and planned notifications to affected parties and regulators, directly matching Incident Disclosure criteria for incident response and scope without financial impact or other process details.


reasoning: Paragraph references an incident briefly with generic response actions (unnamed experts, law enforcement) and focuses on a materiality conclusion regarding financial impact, fitting the tiebreaker for brief incident mention + materiality as Strategy Integration rather than full Incident Disclosure which requires narrative or scope details.


reasoning: The paragraph discusses monitoring the timing and materiality of an ongoing incident investigation, which aligns with materiality assessments in Strategy Integration rather than detailing the incident itself (no narrative, scope, or response actions). Tiebreaker supports Strategy Integration for brief incident mention with materiality as the main point.


reasoning: This paragraph describes the nature of a specific cybersecurity incident, including unauthorized access, data exfiltration, and encryption on non-production systems, fitting the Incident Disclosure category as it provides an incident narrative with scope details. No firm-specific or verifiable facts are present, as all descriptions use vague terms like 'certain Company systems' and lack dates, names, or quantities.


reasoning: Paragraph describes operational impacts (shops open, online ordering disruptions in parts of US, uninterrupted deliveries) as part of a cybersecurity incident disclosure in Item 1.05, fitting 'operational impact of a disclosed incident' without narrative of what happened. Medium confidence due to lack of explicit incident reference or response actions, but contextually aligns with Incident Disclosure over Strategy Integration (no financial/materiality focus).


reasoning: The paragraph describes response actions (mailing notification letters) following an investigation into a cybersecurity incident, fitting Incident Disclosure as it references actual incident response without financial details or narrative of what happened. No specific facts from the ✓ IS list or named standards are present, making it Generic Boilerplate.


reasoning: The paragraph discusses assessing the material financial impact of an incident without any incident narrative, description of what happened, or response actions, fitting Strategy Integration per tiebreakers for financial impact assessment without incident details. No specific facts or named standards are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes the restoration of impacted IT systems and data from a cyber incident, ongoing minor operational impacts, and the closure of the authorities' investigation, which references a real event and response actions, fitting Incident Disclosure. No specific facts like dates, names, or quantifiers qualify it beyond Generic Boilerplate.


reasoning: This paragraph provides a narrative of a real cybersecurity incident, specifying the date of awareness and the event of unauthorized access to certain systems, which directly matches the Incident Disclosure category.


reasoning: Paragraph describes an actual cybersecurity incident with date, cause (systems outage from attack), and response (activated incident response team), fitting Incident Disclosure. Contains one specific date as a verifiable fact, qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard fact.


reasoning: This paragraph details a real cybersecurity incident with a specific date, system outage description, and response actions (activating incident response team), directly matching Incident Disclosure criteria. It includes one verifiable specific date, making it Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: The paragraph describes the operational scope and impact of a specific cybersecurity incident, including affected areas like shipping, manufacturing, and back office functions, along with response actions such as temporary measures and restoration efforts, fitting the Incident Disclosure category. No firm-specific or verifiable facts are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph details the company's immediate response actions and determination of the incident's cause (fourth-party vendor compromise), directly describing elements of an actual cybersecurity incident, which aligns with Incident Disclosure. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the scope of a cybersecurity incident (threat actor access to a portion of IT system containing sensitive personal information) and response actions (planned notifications), fitting Incident Disclosure as it references a real event with narrative details. No firm-specific or verifiable facts are present, making it Generic Boilerplate.


reasoning: This paragraph assesses the potential material financial impact of an incident without any incident narrative, response details, or scope, aligning with Strategy Integration per tiebreakers for financial cost/impact assessment without describing what happened.


reasoning: The paragraph assesses the material impact of an incident on operations and financial condition without describing the incident itself, aligning with Strategy Integration per tiebreakers for financial impact assessment without incident narrative. No specific facts, standards, or unique details are present, making it generic boilerplate.


reasoning: This paragraph assesses the financial and operational materiality of a past cybersecurity incident without providing any incident narrative, response details, or scope, aligning with Strategy Integration per tiebreakers for materiality conclusions as the main point. It contains no verifiable facts, named standards, or firm-specific details, making it Generic Boilerplate.


reasoning: The paragraph assesses the financial materiality of a past cybersecurity incident on quarterly results and overall financial condition without describing the incident itself, matching the tiebreaker for financial impact assessment without incident narrative → Strategy Integration. It references a specific fiscal quarter as the sole firm-specific fact, qualifying as Firm-Specific but not Quantified-Verifiable due to only one verifiable fact.


reasoning: The paragraph describes the operational impact of a cybersecurity incident (primary website inaccessible during disruption) and a specific response action (creation of a special incident communications website), fitting Incident Disclosure as it references a real event's scope and response. It includes one firm-specific fact (the unique incident website URL), qualifying as Firm-Specific but not Quantified-Verifiable due to only one verifiable element.


reasoning: This paragraph describes the operational impact and scope of a specific cybersecurity incident, including affected systems (financial and operating reporting systems) and duration of disruption, fitting Incident Disclosure. It references a real event with details on what happened and scope, not just financial assessment.


reasoning: This paragraph provides a narrative of an actual cybersecurity incident, including the specific date of notification, description of unauthorized activity on IT systems, and initial response steps, directly matching Incident Disclosure criteria.


reasoning: This paragraph provides a narrative of an actual cybersecurity incident, including the specific date of detection and the nature of the fraudulent attempt to obtain funds, which directly matches the Incident Disclosure category.


reasoning: The paragraph describes response actions (notifying regulators and working with law enforcement) to an unauthorized access incident, fitting Incident Disclosure as it references a real event and incident response without narrative details, scope, or impact.


reasoning: Paragraph describes financial and operational impacts (costs for rebuilding website and enhancing security) of a cyber incident without any narrative of what happened, when, or scope, matching the tiebreaker for financial cost/impact assessment → Strategy Integration. No specific facts from the ✓ IS list (no dates, names, numbers, roles, etc.), so Generic Boilerplate.


reasoning: Paragraph describes specific response actions (manual processing, alternative channels) taken during system restoration following a cybersecurity incident, directly fitting Incident Disclosure criteria for incident response actions in an Item 1.05 filing. No qualifying specific facts from the ✓ IS list; generic practices only.


reasoning: The paragraph primarily describes the company's own internal cybersecurity risk management processes, including adoption of the CIS Controls Framework, regular risk assessments integrated with ERM, infrastructure design, dedicated personnel, and training programs. Brief mention of the Technology Committee reviewing assessments does not shift the focus from internal processes to Board Governance.


reasoning: The paragraph details the company's internal processes for evaluating cybersecurity incidents, escalation procedures, Incident Response Program, and Business Continuity Plan, including reassessment of risks and training, which aligns with Risk Management Process. It focuses on the company's own incident response and continuity planning rather than board oversight, management roles, third-party risks, or specific incidents.


reasoning: This paragraph is a cross-reference to a press release exhibit (Exhibit 99.1 issued on March 7, 2024) describing progress on system restoration, providing no substantive cybersecurity disclosure itself.


reasoning: The paragraph focuses on the company's own internal processes for monitoring and developing IT networks to prevent, detect, and mitigate cyber risks, which aligns with Risk Management Process. It contains no specific details, named entities, frameworks, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the company's overall cybersecurity program, including governance structures, cross-functional risk management, technical safeguards, incident response planning, third-party risk as one component, and employee training, which centers on the company's own internal processes. Named cybersecurity-specific roles (CIO and Global Head of IT Security) qualify as firm-specific facts, but no hard verifiable facts like dates or named firms reach Quantified-Verifiable.


reasoning: The paragraph focuses on the Board's and Risk Committee's oversight of cybersecurity risks, including their roles in ERM, reviews, and reporting cadences, making Board Governance the clear fit. The named Risk Committee qualifies as a firm-specific fact, elevating specificity to Firm-Specific without reaching Quantified-Verifiable due to lack of two or more hard verifiable facts.


reasoning: The paragraph describes the company's own internal processes for assessing, identifying, and managing cybersecurity risks, including threat assessment, layered security, training, tools, third-party assessments, and vendor risk management, which centrally fits Risk Management Process; third-party elements are components, not the focus. It names recognized standards (NIST, ISO, SOC 1/2) but has no firm-specific facts from the ✓ IS list or 2+ verifiable hard facts.


reasoning: The paragraph provides a standalone materiality conclusion stating no material cybersecurity risks or incidents affected the company in fiscal 2024, with forward-looking risks and cross-references, fitting Strategy Integration per tiebreakers. No incident narrative or other process details are described.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including framework adoption (NIST CSF), security controls, training, third-party oversight as a component, monitoring, and resiliency plans. Third-party risk is mentioned but as part of the overall internal program, not centrally focused.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including team monitoring, training, penetration tests, and vendor oversight as components of those processes. While management roles and third-party requirements are mentioned, they are not the central focus per tiebreakers favoring Risk Management Process for internal processes with vendors as a component.


reasoning: The paragraph centers on the internal Risk Management Team's composition, roles, monitoring activities, and reporting to the Audit Committee, with management roles as the grammatical subjects and primary focus per category guidelines and tiebreakers. Board and Audit Committee oversight are secondary recipients of management's briefings.


reasoning: The paragraph primarily describes the company's own internal cybersecurity risk management program, including policies, standards, processes for assessing and managing risks, and resource allocation to meet regulatory requirements, aligning with 'Risk Management Process'. No specific facts from the ✓ IS list are present, and no named frameworks or standards are mentioned, resulting in Generic Boilerplate specificity.


reasoning: This paragraph provides a generic description of reliance on IT systems and broad cybersecurity risks like cyber-attacks and ransomware, without referencing board oversight, management roles, internal processes, incidents, or strategies, making it non-substantive disclosure under 'None/Other'. It contains no named frameworks, specific roles, dates, or verifiable facts, qualifying as Generic Boilerplate.


reasoning: The paragraph focuses on identifying specific management roles (IT Manager, General Counsel) and their qualifications, reporting lines (managed by General Counsel, overseen by IT Steering Committee), and crisis response team composition, making 'Management Role' the most applicable category. No board oversight is mentioned, and while the Cybersecurity Program is referenced, the central topic is the roles administering it.


reasoning: This paragraph consists entirely of forward-looking disclaimers and generic descriptions of cybersecurity risks and potential impacts, with no substantive disclosure on governance, processes, incidents, or strategy.


reasoning: The paragraph outlines the company's own internal cybersecurity processes across identification/escalation, technical safeguards, incident response planning, third-party risk as one component, and employee training, fitting 'Risk Management Process'. No named frameworks, roles, dates, numbers, or other specific facts qualify it beyond generic boilerplate.


reasoning: The paragraph details the company's own internal processes for assessing, identifying, and managing cybersecurity risks, including adoption of the NIST framework, oversight by specific management roles, and measures like testing, vendor audits, and training, which fits Risk Management Process; vendor due diligence is a component, not central.


reasoning: The paragraph centers on the CISO and CTO as the primary subjects responsible for cybersecurity risk assessment, monitoring, management, and mitigation, including their qualifications, reporting lines, and experience, fitting 'Management Role'. It contains multiple hard verifiable facts such as named roles (CISO, CTO), quantified experience (13+ and 20+ years), named firms (IBM, Axway), and named program (OWASP Security Shepherd), exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including multi-layered defense, monitoring, information sharing, policies, training, and supplier engagement as components of these processes. Vendor-related activities are mentioned as part of the broader internal processes, not as the central topic.


reasoning: This paragraph describes generic cybersecurity risks, hypothetical impacts, a boilerplate statement of no material past incidents without any narrative or details, and includes a cross-reference to risk factors, providing no substantive cybersecurity disclosure.