reasoning: The paragraph states that a specific internal leadership role (head of the ITS Department) together with executive management is responsible for assessing and managing cybersecurity-related material risks, so it fits Management Role. However, it contains no extractable firm-specific details (no named cybersecurity title/committee, dates, tools, or frameworks), making it generic.


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: This paragraph focuses on the Board of Directors’ oversight and reporting it receives from specific cybersecurity leadership (CISO and CIO) regarding cyber threats, risk, and mitigation processes.

provider: openai


content_category: Management Role

specificity_confidence: medium

reasoning: The paragraph centers on the responsibilities and reporting line of a specific cybersecurity-related internal coordinator, which is a management-function description rather than a company-wide risk process or incident narrative.


content_category: Risk Management Process

category_confidence: medium

reasoning: The paragraph discusses maintaining and updating an incident response plan, focusing on continuous review and refinement of internal procedures. However, it contains no firm-specific details such as named roles, frameworks, tools, dates, or unique programs.


reasoning: The paragraph is written from the Board’s oversight perspective, describing information flow from board-related bodies and a cybersecurity team to the Board.


reasoning: The paragraph is centered on named cybersecurity management roles (CIO and VP of Information Security) and their responsibilities for cybersecurity risk management and supervision.


content_category: Strategy Integration

specificity_confidence: low

reasoning: The paragraph makes a materiality-based statement about cybersecurity incidents (no materially impacting or reasonably likely impacts) without describing any incident facts or internal process details.


reasoning: This paragraph describes general internal cybersecurity training and phishing simulation practices (phishing simulations, awareness/training cadence) but provides no named roles, frameworks/standards, dates, tools, or firm-specific identifiers.


category_confidence: low

reasoning: The paragraph discusses cybersecurity risk management in general (developing/implementing/maintaining measures), but it contains no internal process details, named frameworks, roles, dates, or other firm-specific facts.


reasoning: The paragraph discusses cyber insurance coverage as a means to mitigate potential financial losses, but contains no named standards, roles, programs, incidents, dates, amounts, or other firm-specific details.


reasoning: The paragraph describes the company’s internal activities to prevent, detect, mitigate, and remediate cyber incidents and how management stays informed via third-party notifications and ISP communications; the focus is on the organization’s monitoring/remediation process rather than a stand-alone incident narrative or vendor requirements.


reasoning: The paragraph focuses on who performs cybersecurity risk assessment/management (CFO serving as CISO) and describes the CISO’s reliance on resources, which is primarily management-role disclosure rather than a detailed process or incident.


reasoning: The paragraph assigns cybersecurity responsibility to management roles (CFO/COO/CEO), but it does not provide any cybersecurity-specific titles beyond generic C-suite roles or any firm-specific details. Since it lacks ✓ IS facts, it is treated as generic boilerplate.


content_category: None/Other

reasoning: The paragraph describes generic elements of a cybersecurity program (threat intelligence, forums, external experts) without naming any specific roles, committees, programs, tools, dates, standards, or verifiable facts tied to the company’s disclosure.


reasoning: The paragraph describes the company’s internal approach to assessing and managing cybersecurity material risks (monitoring and user training), but it contains no named roles, standards, dates, tools, or other firm-specific details.


reasoning: The paragraph describes the company’s own processes for identifying and managing cybersecurity-related risks across systems and data, but it provides no named roles, programs, frameworks, dates, tools, or quantified details.


reasoning: The paragraph provides a standalone materiality assessment (no material cybersecurity incidents and immaterial related expenses) without describing any specific incident, systems affected, or response actions.


reasoning: The paragraph is about the Board of Directors overseeing the cybersecurity program, but it uses generic governance language (e.g., quarterly/annual updates, ERM involvement) without any company-specific roles, committees, dates, or other verifiable details.


reasoning: The paragraph describes oversight and reporting from management to the Board/Audit Committee regarding cybersecurity risks and incidents, with the board-level entities as the grammatical focus. It contains no firm-specific cybersecurity roles, dates, tools, or other qualifying details beyond generic governance wording.


reasoning: The paragraph describes an internal cybersecurity initiative/team and its responsibilities (awareness, learnings, training), which fits the company’s own risk management/cybersecurity program processes.


reasoning: This is a general statement of cybersecurity objectives with no description of specific internal processes, frameworks, roles, incidents, or other firm-specific details.


reasoning: The paragraph describes a general cybersecurity training and policy-communication approach but contains no company-specific details, roles, frameworks, dates, or named programs beyond generic practices.


content_category: Third-Party Risk

reasoning: The paragraph describes a risk management process specifically directed at critical third-party service providers/suppliers/vendors, including due diligence and periodic monitoring against cybersecurity standards, which is vendor oversight-focused.


reasoning: The paragraph focuses on who handles cybersecurity day-to-day and suggests changing or outsourcing that function, which is management-role subject matter. It does not include any company-specific or cybersecurity-specific named roles, dates, tools, or other verifiable details.


reasoning: This paragraph is a standalone materiality conclusion stating no cybersecurity threats were identified as materially affecting strategy/financial condition, with a cross-reference to Item 1A. It does not describe an incident or name specific roles, frameworks, dates, tools, or other firm-unique details.


reasoning: The paragraph describes the company’s own cybersecurity program and internal incident response planning/communication processes, but it does not name any specific roles, systems, dates, products, frameworks, or other firm-unique details.


reasoning: The paragraph describes general internal responsibilities for cybersecurity professionals (analyzing threats, defining policy, implementing protections, monitoring/responding), which fits the company’s risk management/operational process. It contains no company-specific names, tools, roles (e.g., CISO), dates, or other verifiable facts, so it is generic boilerplate.


reasoning: This paragraph describes the company’s internal IT/cybersecurity program components (policies, procedures, assessments, monitoring, response plans, testing) but provides no named roles, frameworks, dates, tools, or other firm-specific details.


reasoning: The paragraph describes Thermon’s own cybersecurity risk management system and its aims (identify/assess/mitigate risks) but provides no company-specific program identifiers, roles, frameworks, tools, dates, or other verifiable details.


reasoning: The paragraph’s grammatical subject is who (specific management roles) implements and maintains the company’s cybersecurity risk assessment and management processes, making this primarily a management-role disclosure.


reasoning: The paragraph is focused on the company’s planned internal process for identifying, assessing, and managing cybersecurity risk within its broader risk management system. It also references a named system/program (BDTP TM), making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes the company’s internal incident response process (IRP) and how it is exercised, which is part of its cybersecurity risk management activities. However, it contains no named roles, standards, dates, products, tools, or other firm-specific identifiers.


reasoning: This is a materiality conclusion about potential financial impact, with no incident details or specific company cyber actions mentioned.


reasoning: The paragraph provides a materiality conclusion about financial/business impact from the incident, but contains no incident details or cybersecurity-specific roles/processes and no firm-specific hard facts.


reasoning: The paragraph focuses on financial reimbursement/cost recovery from cybersecurity insurance tied to a cyber incident, without describing incident details or internal risk management processes.


reasoning: The paragraph discusses potential financial/material impact and ongoing assessment, but it does not provide incident specifics (what systems/data were impacted) or actionable incident details beyond generic investigation language.


reasoning: The paragraph discusses cybersecurity insurance coverage and expected handling of costs, which is tied to financial/strategic impact rather than an incident narrative or internal risk processes. No firm-specific details (amounts, named insurers/tools, dates, or roles) are provided.


reasoning: The paragraph provides a materiality conclusion about financial impact (no determination of likely material effect) and does not describe what happened in an incident or any internal cyber process.


reasoning: The paragraph provides a materiality conclusion about financial/operational impact but does not describe what occurred or any concrete cybersecurity specifics (systems/data/scope). This fits strategy/financial impact integration rather than incident disclosure or risk/process descriptions.


reasoning: The paragraph discusses the expected business/financial impacts of an incident (management attention diversion, possible loss of revenue, higher expenses, regulatory penalties, litigation) and states operations were not materially disrupted, but it provides no incident specifics about what happened, when, or what systems/data were affected.


reasoning: This paragraph provides only a materiality/financial-impact conclusion about a cybersecurity incident without describing what occurred or detailing operational scope, and it contains no company-specific or verifiable details.


reasoning: The paragraph discusses downstream financial/business risks (litigation, customer behavior, regulatory scrutiny, and insurance cost) resulting from a cybersecurity incident, but it provides no incident specifics or verifiable details.


content_category: Incident Disclosure

reasoning: The paragraph references notification to law enforcement and regulators, but it does not describe any actual cybersecurity incident details (what happened, affected systems/data, dates, or impacts), making it non-substantive boilerplate rather than incident-specific disclosure.


reasoning: The paragraph describes an ongoing forensic investigation to determine the incident’s nature, scope, and impact, which is incident-specific disclosure. It contains no concrete details (no dates, systems/data, or named tools/parties), so it is generic boilerplate in specificity.


reasoning: The paragraph contains only a materiality assessment about financial/operational impact of an incident, with no incident details or named roles/frameworks, so it fits strategy/materiality integration rather than incident disclosure or process governance.


reasoning: The paragraph describes an ongoing disruption from a cybersecurity incident (networks/transactional services not accessible) and points readers to incident updates. However, it provides no extractable cybersecurity-specific named facts (per the allowed ✓ list) such as dates, systems, tools, or named parties.


reasoning: This is a forward-looking/materiality conclusion about potential financial impact of an unspecified incident, with no incident narrative or scoping details and no named standards/tools/roles.


reasoning: The paragraph describes an actual cybersecurity incident (threat actor access and exfiltration) and notes that notifications to potentially affected parties and regulators are ongoing, including that some personally identifiable information was involved.


reasoning: The paragraph provides a materiality conclusion about financial/material operational impact but does not describe what happened in the incident or any cyber risk process details.


reasoning: The paragraph describes an ongoing disruption from an actual cybersecurity incident (restoring systems, resuming operations, and inability to estimate duration/extent), along with response actions (retained experts, working with law enforcement, notifying regulators), which aligns with incident disclosure despite lacking detailed scope.


reasoning: The paragraph includes a statement about maintaining the company’s own cybersecurity risk management program (identify, assess, manage, mitigate, and respond). Other sentences provide credentials and reporting context, but the substantive process description points to Risk Management Process.


reasoning: This is a legal boilerplate statement about the effect of a waiver period under credit/lease agreements, with no cybersecurity risk, incident, governance, management, third-party security, or cyber-specific content.


reasoning: This is a forward-looking procedural statement about notification to law enforcement and regulators, with no disclosed incident details, roles, named entities, or cyber-specific specifics.


reasoning: The paragraph’s grammatical subject is a management leadership change, including identification of named executives and interim executive role responsibilities for the subsidiary.


reasoning: The paragraph discusses expected reimbursement of cybersecurity incident direct costs through insurance recoveries, with no incident narrative details, dates, named insurers, or other firm-specific quantities.


reasoning: The paragraph describes a real cybersecurity incident, including notification and confirmation dates and the exposure of some customer information, which is incident-specific scope/impact.


reasoning: The paragraph provides a materiality conclusion about financial/operations impact of a cybersecurity incident, but does not describe what happened; this fits standalone financial impact/materiality language.


reasoning: The paragraph describes response actions taken in connection with a referenced prior cybersecurity incident (closing off unlawful access) and states customer notification will occur, which is incident-related disclosure even though it lacks concrete scope details.


reasoning: The paragraph describes the status of a cybersecurity incident response (contained incident, restored core IT environment, restoring business operations), which is incident-related disclosure even though it lacks concrete specifics.


reasoning: This paragraph describes ongoing containment, restoration of system access, and resumption of operations related to an incident, but it provides no specific incident details, dates, affected systems/data, or verifiable facts.


reasoning: The paragraph references a specific cybersecurity event/incidence (“the incident”) and discusses its operational impact (no material disruption) and potential impacts/remediation costs, which aligns with incident disclosure even though it lacks incident details.


reasoning: This paragraph references an ongoing cybersecurity incident and related response actions (investigation, engaging experts, notifying law enforcement), but it contains no concrete incident details (systems/data, timeline, scope, or quantified impacts). The materiality statement is boilerplate and does not add verifiable firm-specific facts.


reasoning: The paragraph provides a materiality/financial-impact conclusion about an incident (“reasonably likely to have a material impact”) and mentions ongoing forensic investigation, but does not describe what happened or the incident’s affected systems/data. This aligns best with strategy/impact integration rather than incident disclosure.


reasoning: The paragraph describes an ongoing cybersecurity incident investigation and the company’s assessment of scope of personal information in exfiltrated data, along with intent to provide required notifications. It does not include named tools, dates, or other verifiable company-specific details.


reasoning: This is a forward-looking materiality assessment related to a cybersecurity incident’s potential financial impact, without describing what happened or any incident scope details.


reasoning: The paragraph provides only a materiality/financial-impact conclusion about an incident (no description of what happened or affected systems beyond general operational statements), which fits strategy/financial integration materiality language rather than incident narrative.


reasoning: The paragraph describes an ongoing disruption to operations (online ordering in parts of the United States), which reads like an incident impact rather than a general risk management process. However, it provides no cybersecurity-specific details (no confirmed breach, systems, data scope, or response actions), so confidence is low.


reasoning: The paragraph describes an ongoing investigation/forensic analysis into whether threat actors took personally identifiable information, with expectations about when a definitive conclusion will be reached—this is part of disclosed incident handling and status. No named roles, dates, tools, or other ✓-list specifics are provided.


reasoning: This describes a concrete action taken in connection with an investigation into a cybersecurity-related incident (mailing notice letters), but provides no specific dates, systems, scope, or other verifiable incident details.


reasoning: The paragraph describes a real cybersecurity incident with an outage and the company’s activation of an incident response team, including a specific incident date.


reasoning: The paragraph discusses assessing potential financial/material impact of a cybersecurity incident but provides no incident narrative, affected systems/data, or specific figures/dates.


reasoning: The paragraph discusses an ongoing investigation, potential scope of affected data, and remediation/claims support tied to cyber insurance—typical of incident updates, but it provides no incident-specific details or named entities. Because it contains no ✓ IS specific facts (no dates, tools, firms, roles, or system/data details), it is treated as generic boilerplate for specificity.


reasoning: This paragraph describes an incident communications approach (a dedicated website and possible website disruption), but it provides no incident specifics such as what occurred, dates, impacted systems/data, or other verifiable details.


reasoning: The paragraph describes an actual cybersecurity incident in progress, including system access plus data exfiltration and encryption. It provides no verifiable firm-unique details (no dates, tools, named systems, or third parties), so the specificity remains generic.


reasoning: The paragraph describes outcomes of a real cybersecurity incident (IT systems/data restored, authorities closed investigation). However, it provides no uniquely identifiable details (no dates, affected systems names, or named third parties), making it non-firm-specific boilerplate.


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized third-party access) and provides a specific awareness date, fitting the Incident Disclosure category.


reasoning: This paragraph describes an actual cybersecurity incident’s operational impact (shipping/receiving, some manufacturing, back office functions) and restoration/temporary measures. It contains no named roles, dates, tools, or quantified figures, making it generic.


reasoning: The paragraph narrates a specific incident and states the Bank activated its response process after determining that a fourth-party vendor compromise caused the incident. However, it does not provide verifiable firm-specific details (names, dates, systems, or tools), so specificity remains generic.


reasoning: The paragraph provides a standalone materiality assessment of financial impact (expecting material impact on Q4 2023 results) without describing what occurred in the incident or related affected systems/data.


reasoning: The paragraph describes an actual cybersecurity incident and indicates unauthorized access to systems containing sensitive personal information, along with planned notifications to affected parties and regulators.


reasoning: The paragraph discusses continued monitoring of the incident’s timing and its materiality, but provides no incident details or processes. With no disclosed event mechanics or firm-unique facts, it reads like boilerplate materiality monitoring language.


reasoning: The paragraph describes a real cybersecurity event (a systems outage caused by a cyber attack) and immediate response actions (activation of an incident response team), which is characteristic of incident disclosure.


reasoning: The paragraph provides a materiality assessment of a cybersecurity incident’s impact on operations and financial condition, without describing what happened or incident scope; this aligns with strategy/financial materiality integration. No company-specific, named, dated, or quantified facts are provided.


reasoning: The paragraph provides only a materiality/financial-impact evaluation statement without describing what occurred in the incident or any concrete operational or scope details.


reasoning: This paragraph is the start of a specific cybersecurity/financial fraud incident disclosure, including a real incident date and what the unknown persons were attempting to do (fraudulently obtain funds).


reasoning: This paragraph describes an actual cybersecurity incident and its operational impact (inability to access reporting systems) along with the duration (~six weeks), which fits incident disclosure.


reasoning: This paragraph describes a real cybersecurity incident (unauthorized activity) with an explicit notification date and outlines response actions (investigate, contain, remediate). It is therefore incident disclosure rather than a general risk management discussion.


reasoning: The paragraph references a “cyber incident” and describes its impacts (rebuilding the website on a new server/hosting platform and enhancing security protocols), but provides no incident timing, affected data/systems scope, or quantified costs.


reasoning: This paragraph is general, forward-looking discussion of cybersecurity threats and the need to monitor/mitigate unauthorized access; it does not describe a specific internal process with identifiable details, roles, dates, or firm-unique programs.


reasoning: This paragraph only cross-references another press release/exhibit for details about restoration timelines and provides no substantive cybersecurity incident description or internal process information itself.


reasoning: The paragraph describes actions taken in connection with an unauthorized access (notifying regulatory authorities and working with law enforcement), which is part of an incident response narrative. It does not provide affected scope or operational/financial impact, but it is still incident-related rather than a general risk process.


reasoning: The paragraph discusses whether the cybersecurity incident will have a material financial impact, but provides no incident details or verifiable company-specific facts. This is consistent with strategy/financial materiality assessment rather than a governance or technical risk description.


reasoning: The paragraph describes Wendy’s internal cybersecurity risk management strategy and its components (framework-based controls assessment, regular risk assessments, infrastructure, dedicated cybersecurity teams, and training). It is not focused on an actual incident or on third-party/vendor oversight as the central topic.


reasoning: The paragraph describes the company’s own cybersecurity risk processes (threat assessment, layered security, training, monitoring, and assessment-based adjustments). It is not primarily about oversight of a vendor relationship as the central topic, even though third-party testing/compliance is included.


reasoning: The paragraph describes the company’s own incident evaluation criteria, decision-making process by the CSO, escalation approach, and internal Incident Response Program/Business Continuity Plan practices. It is primarily about internal risk management processes (not a standalone incident narrative or vendor security oversight as the central topic).


reasoning: The paragraph describes response actions during restoration (manual processing and alternative distribution channels), which is typical of incident impact/mitigation language. However, it provides no specific incident details (date, systems/data affected), so the classification as Incident Disclosure is uncertain.


reasoning: The paragraph centers on the Board and specifically the Board’s Risk Committee overseeing cybersecurity risk and meeting cadence within the ERM program. It includes a named committee and detailed oversight activities, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes QRHC’s internal cybersecurity risk mitigation activities (controls, awareness, monitoring, resiliency, and continuous improvement) and how they are integrated into its risk management systems. Although it mentions third-party oversight, the central topic is the company’s own risk management processes.


reasoning: The paragraph describes general cybersecurity risks and susceptibility of the company’s technology systems (cloud, internet, vessel systems) but does not discuss any internal risk-management activities, named frameworks, roles, committees, incidents, or firm-unique programs.


reasoning: The paragraph describes the company’s own cybersecurity program components (governance, technical safeguards, incident response/recovery planning, and internal risk management approach), which is best categorized as an internal risk management process. Although it mentions third-party risk and board/committee support, those are elements within the broader company program rather than third-party oversight being the central focus.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach and assigns responsibility for risk assessment/mitigation to the CISO (and reporting lines to the CTO). It also details internal governance for GIS and includes firm/role/program-specific background for the CISO and CTO, enabling high specificity.


reasoning: The paragraph focuses on the company’s own cybersecurity risk management approach (program, policies, processes, investments). It is general and forward-looking overall, but it clearly describes internal cybersecurity risk management, and it includes named regulators as specific context.


reasoning: The paragraph primarily describes Bel’s internal cybersecurity practices and controls (monitoring, training, penetration testing, layered defenses) and how Bel manages cyber risk from third-party hosting through its own access and reporting requirements. Named roles/structures and SOC 1/SOC 2 evidence make it firm-specific rather than generic or purely third-party oversight.


reasoning: The paragraph discusses Oracle’s own cybersecurity risk posture and impact (including vendor activity) but is framed mainly as risk-factor disclosure rather than a concrete internal process; category assignment is therefore uncertain. It includes firm-specific facts such as “During fiscal 2024” and Oracle-specific statements about materiality of cybersecurity threats.


reasoning: This paragraph is generalized risk/forward-looking boilerplate describing potential cyber threats and possible impacts, without naming any roles, committees, dates, tools, programs, or specific internal processes.


reasoning: The paragraph describes the company’s own cybersecurity risk management strategy and internal controls (identification/escalation, technical safeguards, incident response/recovery planning, and employee education). It contains no named roles/committees, specific dates, proprietary programs, tools/products, or quantified details, so it is generic.


reasoning: The paragraph describes the company’s own cybersecurity processes (risk framework adoption, monitoring, controls, testing, and vendor due diligence as part of its internal risk practices), rather than a board role or a disclosed incident. It includes a named internal IT leadership structure and the use of the NIST framework, making it firm-specific rather than generic.


reasoning: The paragraph describes the company’s own cybersecurity risk identification, mitigation, monitoring, and response/recovery planning (including IRP/BCP and a Disaster Recovery Plan), as well as annual enterprise risk assessment sharing. It is not primarily about an actual incident or third-party security oversight.


reasoning: The paragraph centers on the designated Chief Information Officer and his qualifications, responsibilities, and review/oversight activities, making it primarily a management-role description rather than incident disclosure or a pure risk-process narrative.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach (monitoring, assessments, policies, training) and treats third parties/suppliers as part of that overall process rather than making vendor oversight the exclusive focus.


reasoning: The paragraph primarily describes the company’s internal cybersecurity program, controls, monitoring, incident/threat processes, and an escalation/ERM linkage, with third-party supplier risk handled as part of those processes. Board oversight and the reporting line to the CFO are present but not the main subject.


reasoning: The paragraph centers on a third-party IT/cybersecurity firm being outsourced to oversee and manage cybersecurity risk processes and controls, including specific roles (vCISO) and team capabilities. It also includes verifiable details such as “over 30 years” and named certifications (CISSP/CISA/CISM).


reasoning: This paragraph primarily describes the company’s own Cybersecurity Program and how it assesses/manages cybersecurity risk (including an incident response plan), along with internal governance/administration details. Although it mentions oversight bodies and leadership roles, the central topic is the firm’s risk management process for cybersecurity.


reasoning: The paragraph describes general capabilities of the company’s IT systems to detect cyberattacks and discusses potential consequences, but it does not disclose a specific incident, named frameworks/roles/tools, or firm-unique facts. It is therefore generic boilerplate about cybersecurity risk and protections.


reasoning: The paragraph describes AGM’s own cybersecurity program elements within its ERM approach (governance, controls, technical safeguards, incident response planning, and third-party risk management as part of its internal process). It is not an incident narrative, nor is vendor oversight the standalone focus.


reasoning: The paragraph centers on Board of Directors and the Audit Committee oversight of cybersecurity risks and reporting to the Board. It does not include any company-unique details, specific dates, tools, firms, or other firm-specific cybersecurity identifiers.


reasoning: The paragraph describes the company’s own cybersecurity program elements—controls, incident response/recovery planning, and ongoing risk management activities (including third-party risk management as part of internal process), rather than an actual incident or board/role information.


reasoning: The paragraph centers on a specific internal management structure ("Risk Management Team") and the responsibilities of the Sr. Director of IT/IT team in monitoring and briefing on cybersecurity risks to the Audit Committee.


reasoning: The paragraph centers on who within management and technology is responsible for cybersecurity (named technology leaders and a designated CISO) and describes their qualifications and roles, making it primarily a management-role disclosure rather than process or incident reporting.


reasoning: The paragraph discusses general recognition of cybersecurity risks and the need to maintain processes, but it provides no firm-specific mechanisms, frameworks, roles, dates, or incident details beyond boilerplate statements.


reasoning: The paragraph describes the company’s own cybersecurity monitoring and incident/crisis planning processes, including use of a response security service and its Cybersecurity Incident Response Plan framework.


reasoning: The paragraph describes the company’s internal cybersecurity measures, monitoring, incident detection/response, risk assessments, and related policies/programs. However, it provides no named cybersecurity roles, committees, internal program identifiers, third-party firms, tools/products, dates, or recognized standards, so the content is generic.


reasoning: The paragraph describes the company’s own cybersecurity controls and risk processes (monitoring/detection, encryption, access controls, disaster recovery testing, vulnerability scanning, third-party risk register, and cyber insurance), without focusing on a specific board/committee or named incident.


reasoning: The paragraph centers on named cybersecurity and security leadership roles (CISO, Information Security Team, and CCO) and their responsibilities/qualifications for managing cybersecurity risk, which is management-role disclosure rather than an internal risk process description.


reasoning: Although the paragraph begins with Board and Risk Committee oversight, most of the text describes Schwab’s own integrated information security and monitoring practices, training, access controls, and engagement activities as part of its risk management processes.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment and risk management program (what risks are assessed and how security is maintained), but contains no firm-specific identifiers such as named tools/roles/dates/frameworks or quantified facts.


reasoning: This paragraph describes the Company’s internal cybersecurity incident-preparedness and response process (Agility Plan, escalation to the CMT, coordination, and training). Third-party consultants are mentioned only as part of assessing the company’s program rather than being the central oversight topic.


reasoning: The paragraph discusses use of an internal IRP and describes general security incidents and threats, but it does not provide a specific company detail beyond generic statements and cross-references to a risk factor.


reasoning: The paragraph describes USCF’s internal information security program, annual cybersecurity risk evaluation, and mitigation activities (including how it conducts due diligence on third-party providers) as part of the Trust’s risk management approach.


reasoning: The paragraph describes Northern Trust’s internal cybersecurity/technology risk management program, policy, governance, and integration with enterprise risk management. Vendor controls are mentioned only as a supporting element within the company’s Third-Party Risk Management Program, not as the central topic.


reasoning: The paragraph describes the company’s own processes for identifying, assessing, and managing cybersecurity risks and links them to business operations and financial condition, without naming any firm-specific roles, programs, dates, tools, or third parties.


reasoning: The paragraph centers on named cybersecurity-related executive roles (CIO/CTO/CISO) and their expertise/responsibilities for managing cybersecurity risk, which is primarily a management-role disclosure rather than an incident narrative or third-party-risk requirement.


reasoning: The paragraph describes Embecta’s own cybersecurity monitoring and risk management processes (SOC monitoring, frameworks, penetration testing, and policy review/approval by a named internal committee). Vendor oversight is included as part of the company’s third-party risk management program rather than being the central topic.


reasoning: The paragraph describes the Company’s own cybersecurity program, including its risk-based approach, monitoring via a SOC, and metrics—i.e., internal risk management processes. It also names the SOC and specific leadership roles (CIO/CISO), making it firm-specific beyond generic boilerplate.


reasoning: The paragraph describes the company’s own cybersecurity risk management approach (policies, standards, processes, and practices) and investment intentions. It does not narrate a specific incident or name any cybersecurity-specific roles, committees, tools, dates, or other firm-unique details.


reasoning: The paragraph focuses on SITE Centers’ internal cybersecurity risk assessment/management activities (including security governance and an Incident Response Plan) rather than describing an actual incident or third-party oversight. The CTO and the governance committee are discussed primarily as part of the company’s cybersecurity risk management process.


reasoning: The paragraph describes Riot’s internal cybersecurity monitoring/response tooling and controls (EDR, SIEM, network/firewall protections, ransomware defense, training) and includes an internal notification requirement, which is best categorized as its risk management process rather than an incident or board/management role.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment, incident management/response, vulnerability remediation, and integration into overall risk management processes. It mentions third-party diligence as part of those internal steps, not as the central focus of vendor oversight.


reasoning: The paragraph discusses the company’s own cybersecurity risk management approach (policies/processes/resources) but contains no company-specific roles, named committees, tools, dates, or standards beyond generic language. Board/management oversight is mentioned, but the dominant content is the company’s general risk management practices rather than incident disclosure or a named governance mechanism.


reasoning: The paragraph describes MEG’s internal incident response plan (IRP), its alignment to NIST RMF, and the roles/oversight for executing incident response and escalation, which are core elements of its risk management process.


reasoning: The paragraph is centered on identifying Luca Fabbri (and coordination with General Counsel Christine Garrison) and describing his responsibilities for cybersecurity risk management and incident reporting, i.e., a management-role focus.


reasoning: The paragraph centers on managing cybersecurity risks arising from third-party service providers, describing the vendor management program and assessment/audit practices and contractual obligations imposed on providers.


reasoning: The paragraph describes the company’s own cybersecurity risk management program, specifically an incident response plan, escalation, annual testing/tabletop exercises, and involved internal functions. It does not include any firm-unique named roles, tools, standards, dates, products, or other hard verifiable facts from the ✓ IS list.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment and management activities (policies/program, monitoring controls, due diligence, and a third-party risk management program as part of its broader processes), not a specific incident or a board/management role.


reasoning: The paragraph centers on the Audit Committee and Board oversight structure for cybersecurity (reporting cadence, escalation on material incidents, and how oversight is conducted). It includes firm-specific details such as CIO/CISO quarterly updates and a NIST Cybersecurity Framework Scorecard.


reasoning: The paragraph is primarily framed around the board’s oversight responsibilities and delegation to a board committee. It also describes management and the Director of IT, but the board/committee oversight is the dominant subject and organizing theme.


reasoning: The paragraph describes WTW’s own cybersecurity risk management strategy and operational processes (incident response planning, technical safeguards, education/training, threat intelligence) rather than a board/committee role or an incident narrative.


reasoning: The paragraph discusses the company’s assessment that it did not experience a material cybersecurity incident in 2023, the likelihood of future material impact, and mentions cybersecurity insurance coverage. It does not describe incident details or internal risk-management processes with firm-specific operational facts.


reasoning: This paragraph is purely forward-looking safe-harbor and disclaimer language without describing any actual cybersecurity incident facts, impact details, systems/data affected, or specific processes.


reasoning: The paragraph describes the company’s internal cybersecurity and incident readiness processes (disaster recovery plan, incident response policies, escalation to a crisis management team, and internal assurance activities), which are part of its risk management approach rather than a disclosed incident or third-party oversight as the central topic.


reasoning: The paragraph describes the company’s own cybersecurity risk-management activities (policies, audits, vulnerability/disaster recovery planning, monitoring, training, IR planning), with prioritization based on likely business impact. While it mentions vendor risk management and a managed security operations center, the overall focus is internal risk-reduction processes rather than vendor oversight as the central topic.


reasoning: This paragraph centers on the Board/Audit Committee’s oversight responsibilities and review activities for the company’s cybersecurity program. It also specifically names the company’s CTO as part of that governance review.


reasoning: The paragraph describes the company’s internal cybersecurity security program structure, reporting requirements, and an enterprise-wide IT working group for incident response and escalation, including inputs from the CISO/CIO—i.e., internal risk management processes rather than a disclosed incident or third-party oversight.


reasoning: The paragraph describes a real cybersecurity incident (unauthorized third-party access and file exfiltration) with impacts (system shutdown, disruption, limited access to financial/operating reporting systems) and includes notification/assessment steps and a material impact determination tied to a specific date.


reasoning: The paragraph is a generalized statement about not having identified material cybersecurity incidents, with a generic note about potential threats involving third-party vendors and a cross-reference to Risk Factors. It contains no incident narrative details, named roles/committees/tools, or other firm-specific facts.


reasoning: The paragraph describes a real cybersecurity incident (defaced website), the actions taken (restored from backups, took the site down, temporary page), and impact (cancelled a seminar). It also includes verifiable dates and the specific domain affected, supporting high confidence in Incident Disclosure.


reasoning: This is forward-looking/boilerplate disclosure about lacking formal cybersecurity policies and intentions to develop a framework, with no board/management role, no described internal risk process, and no incident details or named standards/tools.


reasoning: The paragraph discusses general material cybersecurity risk and potential business/financial impacts (disruptions, theft, reputational harm, investigation/remediation costs) without describing the company’s internal risk processes or any actual incident details.


reasoning: The paragraph is primarily describing Alternus’s internal cybersecurity activities and risk management practices (assessment, prevention/detection/response/recovery, and how risks are evaluated, including for third-party providers). It also references the CIO and specific controls like SOC 2, but the dominant theme is the company’s cybersecurity/risk management process.


reasoning: The paragraph describes a specific reported cybersecurity incident (threat actor email, implied data theft from customer accounts and internal systems, actions taken, and law-enforcement cooperation). It includes incident narrative details with dates and scope indicators, which fits Incident Disclosure.


reasoning: The paragraph describes a real disclosed cybersecurity incident with concrete results (accounts accessed, data saved/deleted), incident update facts (perpetrator identified, devices turned over), and specific customer compensation amounts and timing.


reasoning: The paragraph centers on the CISO/CIO/CTO roles and reporting responsibilities within the cybersecurity program, with board oversight mentioned primarily as the recipients of updates/escalations.


reasoning: The paragraph’s central theme is how Ardent manages cybersecurity risk created by interactions with third parties (service providers/vendors), including dedicated vendor security risk assessments and use of FAIR to quantify third-party cyber risk.


reasoning: The paragraph discusses management creating cybersecurity risk appetite metrics for approval by the Board, focusing on board-level oversight. However, it contains no cybersecurity-specific roles, committees, dates, frameworks, or other firm-unique details, so it is generic.


reasoning: The paragraph describes an internal training activity as part of information security practices, but it provides no named roles, frameworks, dates, tools, or other firm-specific details.


reasoning: This paragraph narrates a real cybersecurity incident (detected date, unauthorized access by a third party, actions taken, and operational/data scope such as access limitations to financial and operating reporting systems and potential exfiltration). It is therefore best categorized as Incident Disclosure.


reasoning: The paragraph describes the company’s own cybersecurity safeguards, vulnerability assessment/threat intelligence, and its incident response plan testing cadence—all internal processes without naming any unique roles, tools, dates, or standards.


reasoning: The paragraph is focused on a risk management program specifically to oversee cybersecurity risks arising from third-party service providers, including annual third-party risk assessments tied to contractual cybersecurity requirements.


reasoning: The paragraph is centered on the qualifications of specific management cybersecurity roles (CISO and VP of Information Security), including their experience and activities.


reasoning: The paragraph describes internal investigation and assessment steps after receiving notice of a cybersecurity threat (determining whether an incident occurred, isolating affected systems, and using outside advisors for investigations). It does not narrate a specific incident or provide firm-unique program/tool/date details.


reasoning: This paragraph describes the company’s own cybersecurity program and how it is integrated into enterprise risk management, including assessments, training, threat monitoring, and incident risk oversight. While it mentions third parties, the main subject is the company’s internal risk management process rather than third-party risk requirements.


reasoning: The paragraph describes ongoing cybersecurity risk/audit activities (annual control audits, risk assessments, remediation, and review of results), which is an internal risk management process rather than an incident or standalone strategy statement. However, it does not include any cybersecurity-specific named roles, tools, standards, dates, or other firm-unique facts from the ✓ list, so specificity is kept at Generic Boilerplate.


reasoning: The paragraph describes JetBlue’s cybersecurity strategy at a high level (detection/analysis/response, managing cyber risks, resilience), but it contains no named roles, frameworks, programs, dates, tools, or incident details that would make it firm-specific or verifiable.


reasoning: The paragraph is explicitly about the board-level Risk Committee’s role in overseeing cyber risk and overseeing ERM, including reporting and engagement with management.


reasoning: The paragraph describes the company’s internal procedures and controls for assessing and managing cybersecurity risks (including policies, training, and risk processes) as part of enterprise risk management, without detailing a specific incident or naming concrete frameworks/roles/vendors.


reasoning: The paragraph describes the company’s internal security/IT involvement in onboarding and oversight via its Project Management Office and Vendor Management Office processes, which is an internal risk management activity rather than a standalone incident or board role.


reasoning: The paragraph describes the company’s internal cybersecurity responsibilities and activities (risk assessment, incident prevention/response, vulnerability assessments, continuous monitoring) as part of its own processes. It does not identify a named cybersecurity executive/committee or any unique firm-specific tools, dates, or standards, so it is not Firm-Specific.


reasoning: This paragraph is a high-level description of the company’s lack of operations and a statement that it has not adopted cybersecurity risk management programs; it does not describe any incident, specific governance/role, or internal cybersecurity processes beyond generic assertions.


reasoning: The paragraph discusses whether the company has processes for assessing and managing cybersecurity-related material risks, but it provides no named roles, frameworks, dates, tools, or other company-specific details.


reasoning: The paragraph describes the company’s internal incident response plan actions and remediation/prevention approach. It does not provide a real disclosed incident, named cybersecurity roles, or firm-unique identifiers.


reasoning: The paragraph centers on named cybersecurity/IT governance roles (CISO and other named officers) overseeing and participating in cybersecurity risk management and incident processes.


reasoning: The paragraph describes the Board of Directors’ oversight and review activities related to cybersecurity and data privacy (i.e., the Board is the grammatical subject). It contains no company-unique named roles, committees, dates, frameworks, or tools, making it generic boilerplate.


reasoning: The paragraph describes the company’s internal security practices (defense-in-depth, vulnerability remediation, and having an incident response and disaster recovery plan), but it does not name any specific roles, frameworks, dates, tools, or firm-specific programs.


reasoning: This paragraph is a forward-looking/materiality disclaimer stating the company is not aware of reportable incidents and generally describes potential future reporting and referral. It also includes a cross-reference to Item 1A Risk Factors rather than providing an actual incident, named roles, or company-specific cyber details.


reasoning: The paragraph describes generic cybersecurity practices (security awareness training, phishing testing) and general mention of cybersecurity insurance, with no incident narrative, no board/management roles, no named programs/tools/standards, and no firm-unique specifics.


reasoning: The paragraph focuses on relying on third-party service providers to identify, assess, and manage cybersecurity-related risks, which is primarily a third-party risk oversight statement rather than an internal risk management process or an incident narrative.


reasoning: This is a forward-looking materiality/awareness statement without describing any actual incident, impacts, governance/roles, or internal risk processes. It contains no cybersecurity-specific roles, dates, tools, frameworks, or firm-specific facts.


reasoning: The paragraph centers on a board committee (Audit Committee) providing oversight and receiving updates on cybersecurity risks and incident communication/mitigation planning. However, it does not include any firm-specific cybersecurity roles, named internal programs, or verifiable details beyond generic governance language.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment and mitigation activities (assessment against CIS, monitoring, vulnerability assessments, and an information security policy/training). It does not disclose an incident, but it outlines internal risk management processes. It references the Center for Internet Security (CIS) standards, making it sector-adapted rather than firm-specific.


reasoning: The paragraph describes the board of directors reviewing and discussing cybersecurity risk and reports from management. However, it contains no firm-specific details, named roles/committees/metrics, or dates/frameworks beyond generic governance language.


reasoning: The paragraph provides general forward-looking statements about the limits of security controls and risk-based decision-making, without describing the company’s specific processes, frameworks, roles, named tools, dates, incidents, or measurable impacts.


reasoning: The paragraph describes the company’s own cybersecurity risk management objective and improvement initiatives, including an internal review process overseen by the Chief Technology Officer and conducted by the Technology Leadership Centre.


reasoning: The paragraph primarily describes BlackRock’s own cybersecurity program and processes (governance, controls, incident response/recovery planning, and how third-party risks are handled) rather than focusing solely on vendor oversight. It includes firm-specific internal governance structures and roles (Risk Committee, CRO, CISO, TRCC, ERC), making it more than generic boilerplate.


reasoning: The paragraph centers on the company’s internal cybersecurity program, dedicated teams, and committees for preventing/detecting/remediating incidents—i.e., its own risk management process. While it mentions board discussion, the grammatical focus is on the firm’s internal risk management structure and responsibilities.


reasoning: The paragraph’s grammatical subject is named management roles (CIO, CTO, and Information Security Officer) and it describes their accountability for the information security program and related responsibilities.


reasoning: This paragraph is forward-looking and boilerplate risk language stating that cybersecurity risks have not yet materially affected results, without describing any incident details, named parties/roles, or specific cyber programs/frameworks.


reasoning: The paragraph describes internal cybersecurity activities (evaluating effectiveness of its cybersecurity program and hosting table-top exercises) with third-party providers as support, but it does not name any company-specific programs, standards, roles, dates, tools, or vendors.


reasoning: The paragraph centers on the Head of Cybersecurity’s responsibilities and reporting/informing senior leadership and incident response teams, making it primarily a management-role description rather than board-only oversight or internal risk processes. It also contains firm-specific elements like the Head of Cybersecurity and the incident response plan.


reasoning: The paragraph discusses the company’s (and third parties’) ability to implement and effectiveness of security controls and detection/understanding of events, which is part of the company’s risk/security process rather than a specific incident or governance/role.


reasoning: The paragraph describes the company’s own cybersecurity monitoring/testing and patching processes (including use of a SOC service) rather than making vendor oversight the central topic. It includes a named system/service (“SOC as a Service”) and references OCC regulatory exams, making it more than generic boilerplate.


reasoning: The paragraph describes the company’s internal incident response and vulnerability management processes, including how incidents are escalated and who participates in mitigation/remediation. It does not provide any firm-unique details from the ✓ list (e.g., named cybersecurity roles/committees beyond generic references).


reasoning: The paragraph describes the company’s own cybersecurity program and internal risk management activities (controls, monitoring, patching, and audits), not an actual incident or board/management role. It also mentions third parties only as part of executing the internal program, not as the central topic.


reasoning: The paragraph describes the company’s own risk assessment and security controls, including how it manages third-party risks as part of its internal processes. It does not narrate a real incident or focus primarily on vendor requirements as the central topic.


reasoning: The paragraph describes the company’s own technical safeguards and monitoring practices as part of its cybersecurity risk management, but it contains no firm-specific identifiers, dates, roles, named tools/products, or frameworks.


reasoning: The paragraph describes Western Digital’s own ERM process and how cybersecurity incident impacts are identified, assessed, managed, reported, and mitigated. It does not provide company-specific named roles, committees, dates, tools, or incident details, making it generic in terms of specificity.


reasoning: The paragraph centers on board-level oversight by a board committee of cybersecurity risk, including how it reports with the CISO and incident handling under a named plan.


reasoning: The paragraph describes the company’s internal control activities for testing and evaluating findings, and it mentions vendor SOC report reviews as part of those general controls (not as a standalone vendor oversight requirement). No named roles, firms, products, dates, or cybersecurity-specific identifiers are provided.


reasoning: The paragraph centers on who performs cybersecurity responsibilities (ISO and SVP/IT Manager) and describes the ISO’s qualifications and tenure, which is management-role disclosure rather than an internal process or incident narrative.


reasoning: The paragraph describes the company’s own cybersecurity program and how it assesses and manages cyber risks, including use of frameworks and ongoing review activities. It also states the firm holds active HITRUST certification and SOC 2 Type II compliance, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph is general forward-looking language stating lack of awareness of material cyberattacks and a cross-reference to Item 1A, with no cybersecurity incident narrative or company-specific governance/process details.


reasoning: The paragraph describes general cybersecurity activities (penetration testing, program measurement, incident response experts, and information sharing) but contains no firm-specific details, named frameworks/standards, tools, roles, dates, or quantified facts.


reasoning: The paragraph’s primary substantive focus is requirements and due diligence imposed on vendors that store sensitive Company information (encryption and access controls). It also includes a general, non-incident materiality conclusion, but there are no firm-specific, named, dated, or third-party-specific details to raise specificity.


reasoning: The paragraph centers on Berkshire’s dependency on third-party service providers and the associated risk of cyber-attacks on those providers, including monitoring of service-provider risk. It contains no named entities, dates, tools, or other firm-unique specifics.


reasoning: The paragraph is centered on named management roles (CCO and CISO), their responsibilities, reporting/assistance relationships, and qualifications, rather than describing a company-wide risk process or an incident.


reasoning: The paragraph describes internal participants’ roles within the company’s cybersecurity risk management program (i.e., an internal risk management process). It names the Chief Information Officer, making it firm-specific, but provides no additional concrete operational details.


reasoning: The paragraph’s grammatical subject is the CIO and describes reporting lines and responsibilities for the information security program, which fits Management Role.


reasoning: The paragraph is primarily about the CISO’s qualifications, responsibilities (monitoring and incident response coordination), and reporting line, with a brief mention of COO’s board Risk Committee role.


reasoning: The paragraph is general boilerplate about executive management responsibility and risk oversight without naming specific roles, committees, or internal programs, and it is cut off mid-sentence, providing no concrete cybersecurity processes or incident details.


reasoning: The paragraph centers on a named governance body (Cybersecurity Council) chaired by the CISO and describes its oversight role, reporting/escalation to senior management and the Board, and its meeting cadence and scorecard review.


reasoning: The paragraph describes Xenon Pharmaceuticals’ internal cybersecurity risk management program components (risk assessments, asset/threat identification, prevention/detection, DLP, and control effectiveness), which fits the Risk Management Process category. It references a named standard (NIST) and describes general program elements without Xenon-specific named programs, dates, tools, or quantified metrics.


reasoning: The paragraph centers on a named board-style committee (Cyber Security Subcommittee) performing an initial assessment of whether a notable cybersecurity incident has occurred.


reasoning: The paragraph focuses on how the CISO reports cybersecurity updates to the IOC (board/oversight body), including meeting cadence and executive sessions. Although it also describes internal day-to-day responsibilities, the grammatical emphasis is on the CISO’s updates to the IOC.


reasoning: The paragraph focuses on due diligence and security-related contract provisions during third-party procurement and contracting, which is central to third-party risk oversight. It contains no named standards, roles, dates, tools, or other firm-unique details.


reasoning: The paragraph describes an annual briefing/review process involving the Audit Committee, which is board-level oversight of cyber risk. However, it lacks qualifying firm-specific cybersecurity details (no CISO/CTO title, no non-generic named cyber committee, and no specific dates/tools/frameworks).


reasoning: The paragraph primarily describes the company’s internal cyber incident response process (plan, reporting/escalation workflow, and who manages response). Board/Audit Committee notification is mentioned, but it is a component of the incident response governance rather than the main focus.


reasoning: The grammatical subject is a specific management role (“VP of IT and Facilities”) and it describes that role’s responsibilities for cybersecurity activities.


reasoning: The paragraph discusses the company’s (lack of) internal risk assessment and how a risk assessment would be performed and integrated into management systems, which is part of its own risk management process. It contains no named roles, frameworks, dates, tools, or other firm-specific details.


reasoning: The paragraph centers on the Audit Committee’s direct oversight and reporting/notification to the Board regarding cybersecurity risk. It uses generic committee/cadence language without any company-specific or named cyber roles, dates, or other verifiable details.


reasoning: The paragraph describes the company’s own cybersecurity risk management activities (policies/programs/controls, prevention/identification/mitigation, monitoring, vulnerability/risk reduction, training) rather than an incident or board/management roles. It contains no named roles, tools, programs, dates, or recognized standards, so it is generic.


reasoning: The paragraph describes internal security and privacy awareness training and ongoing updates/testing of security controls as part of the company’s cybersecurity risk management approach, without naming any specific framework, tool, role, date, or other firm-specific details.


reasoning: The paragraph is centered on a named board committee (Technology Committee) and describes its ongoing oversight responsibilities for technology and cyber/security risk.


reasoning: This paragraph is forward-looking and uses generic risk language about potential cybersecurity attacks and impacts, without describing a real incident, named roles/committees, internal processes, or any firm-specific details.


reasoning: The paragraph describes the company’s own security/risk management activities (monitoring, backup/recoverability principles, physical protection mechanisms, and internal review of third-party/cloud services) rather than an incident or board/management role.


reasoning: The paragraph describes the company’s internal cybersecurity activities (monitoring threats, using threat intelligence/tools, mitigating risks), but it contains no firm-specific identifiers such as named roles, tools/products, dates, frameworks, or products.


reasoning: The paragraph describes the company’s internal cybersecurity activities (monitor/detect/mitigate/respond and a dedicated cyber security center) and use of consultants/exercises, which fits risk management process. However, it contains no named roles, tools, firms, standards, dates, or other firm-specific details, so it is treated as generic boilerplate.


reasoning: The paragraph describes the company’s internal incident detection-to-response process (policy, triage, escalation, and use of expertise), which is an internal risk management activity. It does not narrate an actual incident or focus primarily on vendor oversight or board governance.


reasoning: The paragraph centers on the Board's oversight of cybersecurity risks, including receiving presentations, incident updates, and annual discussions, with the Board as the primary grammatical subject. No qualifying specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.

provider: x-ai


reasoning: The paragraph describes the company's internal multi-stakeholder team and processes for identifying, assessing, and managing cybersecurity risks, including monitoring and threat evaluation methods, which fits Risk Management Process. Vendors are mentioned as components of the internal process, not as the central topic.


reasoning: The paragraph describes the company's internal processes for assessing, identifying, and managing cybersecurity risks, including integration into enterprise risk management, with third-party threats mentioned only as a component. No specific facts, named frameworks, roles, or quantifiable details are present, making it generic boilerplate.


reasoning: The paragraph describes potential cybersecurity risks and their possible business/financial impacts, concluding with a standalone materiality assessment that threats have not materially affected the company to date, with no incident narrative. It contains no specific facts, named frameworks, roles, dates, or quantifiable details qualifying for higher specificity.


reasoning: Paragraph states no material cybersecurity impact to date and cross-references risk factors, qualifying as a standalone materiality conclusion under Strategy Integration. No qualifying specific facts or named standards present, making it generic boilerplate.


reasoning: The paragraph centers on engaging third-party service providers for cybersecurity assistance and imposing specific certification and breach reporting requirements on them, making vendor/supplier oversight the primary topic per category guidelines. No incident narrative or other categories apply as the main focus.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risks, including receiving reports from the ERM Committee, CIO, and VP Infrastructure, making the board committee the grammatical subject. This aligns with Board Governance rather than Management Role, as the emphasis is on oversight rather than management qualifications.


reasoning: This paragraph is a cross-reference to the risk factors section and quotes generic boilerplate language about potential cybersecurity risks, providing no substantive disclosure on governance, processes, incidents, or strategy.


reasoning: The paragraph describes the company's internal risk management processes, including ERM integration, annual ERA, risk assessment, mitigation, monitoring, and reporting, making 'Risk Management Process' the best fit. Board reporting is mentioned only briefly at the end.


reasoning: The paragraph details the company's own internal Information Security programs aligned to ISO and NIST frameworks, incorporating specific NIST CSF functions for risk assessment and management, making Risk Management Process the best fit. It names recognized frameworks (ISO, NIST) but lacks any firm-specific facts like roles, dates, or unique programs.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risk management, including review cadences, discussions with management like the CIO and CISO, and reporting to the Board, which directly matches Board Governance criteria where the board or committee is the grammatical subject.


reasoning: The paragraph primarily describes the company's own internal risk management processes, including integration into ERM, framework adoption (FFIEC), periodic reviews, and cross-functional approach to threat mitigation. Board oversight and CISO reporting are mentioned but are components of the broader risk management process, not the central focus.


reasoning: The paragraph focuses on the Information Security Officer (ISO)'s role, reporting line to the CRO, qualifications, and oversight responsibilities, making management roles the grammatical subject and central topic.


reasoning: The paragraph primarily details management roles, reporting lines (VP IT Data Security reports to CTO), and the Cybersecurity Committee composed of executive management, legal, and operations leaders, with board oversight mentioned only briefly; per tiebreakers, this assigns to Management Role over Board Governance.


reasoning: The paragraph details the company's own internal cybersecurity processes, including incident response planning, risk assessments, vulnerability scanning, penetration testing, monitoring by the IT team, training, and mitigation measures, making Risk Management Process the most applicable category. It contains no named frameworks, cybersecurity-specific roles, dates, named firms, or other firm-unique facts from the ✓ IS list, resulting in Generic Boilerplate specificity.


reasoning: The paragraph provides a standalone materiality conclusion stating no material past cybersecurity incidents or risks have affected the company, with forward-looking statements on potential future impacts, fitting Strategy Integration per guidelines. No specific facts, frameworks, or unique details are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph focuses on the board and Audit Committee's oversight of cybersecurity risks, including reporting from specific IT executives, aligning directly with Board Governance criteria where board/committee is the grammatical subject.


reasoning: The paragraph primarily describes the Board of Directors' oversight responsibilities for cybersecurity risks, assessments, reviews, and discussions, with the board as the frequent grammatical subject; the HSE Director's role supports this governance structure rather than being the central focus.


reasoning: The paragraph describes the Trustee's own cyber risk management program, protocols, training, and third-party assessment integrated into overall risk management, which fits Risk Management Process as the company's internal processes are the central topic. No board, management roles, incidents, or third-party risk as primary focus.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including framework adoption (NIST), team assessments, monitoring, third-party assistance as a component, and integration into policies and ERM, making Risk Management Process the best fit. Third-party engagement is mentioned but not central, per tiebreakers. Specificity is Firm-Specific due to named framework and specific departmental team composition, with no hard verifiable facts reaching Quantified-Verifiable.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities for cybersecurity risks, including monitoring through reports from management and reporting to the full Board, which aligns directly with Board Governance as the board committee is the grammatical subject.


reasoning: The paragraph details the company's own internal processes for risk identification, assessment, monitoring threat intelligence, evaluating controls, and mitigating third-party risks as a component, making Risk Management Process the best fit. No qualifying specific facts from the ✓ IS list (e.g., no named roles like CISO, specific dates, named firms, or frameworks), resulting in Generic Boilerplate.


reasoning: The paragraph details the company's own internal cybersecurity program, including vulnerability management, monitoring via a managed security service provider, and an incident response plan designed per NIST, which aligns with Risk Management Process; third-party provider and board mentions are incidental components, not central. It names the NIST framework but lacks firm-specific facts like named roles, dates, or unique programs.


reasoning: The paragraph describes the company's internal cybersecurity processes, including incident response planning, tabletop exercises, business continuity plans, employee training, and a risk-based approach to security controls, which aligns with Risk Management Process. No specific facts from the ✓ IS list are present, such as named roles, committees, dates, or quantifiable metrics, making it Generic Boilerplate.


reasoning: The paragraph focuses on the Board's and Audit Committee's oversight of cybersecurity risks, including the formation and charter requirements of a specific Cybersecurity Risk Subcommittee, making Board Governance the clear fit as board/committees are the grammatical subjects.


reasoning: The paragraph centers on the CDIO/CISO's identification, qualifications, reporting lines, team oversight, and brief committee briefings, making 'Management Role' the primary category per guidelines and tiebreakers favoring management focus over brief board mention. Multiple hard verifiable facts (specific date 'since 2021' and named firms Comerica Bank, HSBC, Citibank, General Electric) exceed the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses on the board of directors and audit committee's oversight of cybersecurity risks and incidents, including their interactions with management, making board/committee the primary grammatical subjects; management roles are mentioned but secondary per tiebreakers.


reasoning: The paragraph describes the company's own internal processes for threat identification, investigation, risk assessment, escalation, and reporting to committees, which aligns with Risk Management Process. It includes cybersecurity-specific roles and named non-generic committees, qualifying as Firm-Specific, but lacks two or more hard verifiable facts (e.g., dates, dollars, external firms) for Quantified-Verifiable.


reasoning: The paragraph details the company's own internal processes for protecting data/systems, incident identification/response, monitoring tools, and periodic testing including penetration testing, fitting Risk Management Process as the central topic. No named standards, cybersecurity-specific roles, dates, named tools/firms, or other firm-unique facts qualify it beyond Generic Boilerplate.


reasoning: The paragraph focuses on the Board, Audit Committee, and Cybersecurity Subcommittee's oversight responsibilities for cybersecurity risks, with the committees as the primary grammatical subjects. This directly matches 'Board Governance' criteria for board/committee oversight.


reasoning: The paragraph briefly mentions past non-material cybersecurity incidents and emphasizes management's materiality assessments for current and potential future incidents, fitting Strategy Integration per tiebreakers for brief incident mentions with materiality conclusions as the main point. No detailed incident narrative or other category-defining elements like board oversight or internal processes dominate.


reasoning: The paragraph centers on the Board of Directors and Audit Committee overseeing cybersecurity risks, receiving quarterly reports from management on incidents, risks, and vulnerabilities, with the board as the primary grammatical subject. No firm-specific facts qualify under the ✓ IS list; all elements (Audit Committee, CEO/CFO, quarterly cadences, unnamed MSP) are generic or on the ✗ NOT list.


reasoning: The paragraph describes the company's internal policies, procedures, risk assessments, control development based on frameworks, and risk prioritization processes, which aligns with Risk Management Process. Third-party involvement is a minor component of assessments, not the central topic.


reasoning: The paragraph focuses centrally on vendor/supplier security oversight, including assessments, contractual requirements, and third-party consultant engagements for penetration studies, fitting Third-Party Risk. No qualifying specific facts from the ✓ IS list or named standards are present, confirming Generic Boilerplate.


reasoning: The paragraph centers on the CIO and senior leaders reviewing cybersecurity metrics, leading the response plan, and reporting to committees, aligning with management roles and reporting lines as the grammatical subjects; board/committee oversight is secondary per tiebreakers.


reasoning: The paragraph provides a standalone materiality assessment stating no material breaches or significant expenses to date and acknowledges potential future impacts on business and finances, fitting Strategy Integration; incident response practices are mentioned briefly but not centrally. No qualifying specific facts from the ✓ IS list (CEO/CFO are generic C-suite, MSP is unnamed), resulting in Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including policies for threat detection, vulnerability management, assessments, penetration testing, and third-party oversight as one component, with adoption of the NIST CSF framework. Vendor monitoring is mentioned but not central, fitting Risk Management Process per tiebreakers.


reasoning: The paragraph describes the company's internal training programs, including security awareness, phishing simulations, tabletop exercises, and response tests, as mechanisms to assess, identify, and manage cybersecurity risks, which aligns with Risk Management Process. No board, management roles, vendors, incidents, or strategy elements are the focus.


reasoning: The paragraph describes the company's internal information security program, including adoption of the NIST CSF framework, incident detection and response processes, operational plans, and regular review/exercises, which aligns with Risk Management Process. No board, management roles, third-parties, incidents, or strategy elements are the focus.


reasoning: The paragraph primarily describes the Board of Directors and Audit Committee's active involvement in oversight of the cybersecurity program as part of risk management, making Board Governance the most applicable category despite blending into a general description of processes. It names the NIST Cybersecurity Framework, qualifying as Sector-Adapted with no firm-specific facts from the ✓ IS list.


reasoning: The paragraph describes a specific past cybersecurity incident including what happened (unauthorized access and download of user information from 23andMe.com accounts), when (October 2023), and response actions (system enhancements, password resets, two-factor verification), meeting the criteria for Incident Disclosure. The cross-reference to risk factors is secondary to the incident narrative.


reasoning: The paragraph primarily describes specific management roles such as the Director, IT Infrastructure & Security, their qualifications, expertise, leadership of programs, and reporting lines to the VP of IT and executives, aligning with Management Role. Board mentions are secondary to the focus on management structure.


reasoning: The paragraph focuses on the CISO as the primary subject, detailing their qualifications, experience, education, responsibilities, and team oversight, which aligns with 'Management Role' category. It contains firm-specific facts like the CISO role and quantified experience but lacks two hard verifiable facts (e.g., dates, dollars, named firms) for Quantified-Verifiable.


reasoning: The paragraph describes the Board's overall responsibility for enterprise risk management, delegation to the Audit Committee for oversight of cybersecurity risks, and reporting cadences from management to the Board and committees, making the board/committee the grammatical subject. Audit Committee is explicitly generic per guidelines, with no firm-specific facts, named frameworks, or verifiable details.


reasoning: The paragraph details the company's internal cybersecurity program, including framework adoption (NIST), certification (ISO 27001), security controls, monitoring, incident response, and assessments, making 'Risk Management Process' the best fit as it focuses on the company's own processes. Vendor mention is peripheral, not central.


reasoning: Paragraph provides a standalone materiality conclusion stating no material cybersecurity risks identified in fiscal 2025, without describing any specific incident, aligning with Strategy Integration per tiebreakers. Includes one firm-specific date ('fiscal 2025'), qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard verifiable fact.


reasoning: The paragraph focuses on the Information Security team led by the CISO, their certifications and qualifications, the CISO's background and education, and reporting lines to the CITO and CEO, making management roles the grammatical subject and primary topic. It contains multiple firm-specific facts like named cybersecurity roles, quantified experience, and unique education/certifications, but fewer than two hard verifiable facts (no dates, dollars, headcounts, or named incident firms/tools) for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk management processes through the ERM committee, including quarterly assessments and integration of cybersecurity reports from the CISO and CDO, making 'Risk Management Process' the most applicable category. It is not primarily about board oversight or specific management roles/qualifications, but the company's own processes for identifying, monitoring, and remediating risks.


reasoning: Paragraph briefly mentions a past cybersecurity incident in August 2020 but focuses on materiality assessment (no material impact to date, forward-looking risks), matching Strategy Integration tiebreaker for brief incident mention + materiality conclusion as main point.


reasoning: This paragraph consists of forward-looking disclaimers about general cybersecurity risks, dependency on IT, and limitations of controls, with a cross-reference to Risk Factors, fitting None/Other as it provides no substantive disclosure.


reasoning: The paragraph describes the company's internal cybersecurity assessments, vulnerability management, monitoring, disaster recovery, and other risk management processes performed by its technology team and operational risk group, making 'Risk Management Process' the most applicable category. No specific facts from the ✓ IS list are present, as team names are generic, the external firm is unnamed, and content consists of common practices without dates, numbers, named roles, or standards.


reasoning: This paragraph provides a standalone materiality conclusion stating no material past cyber incidents or risks likely to materially impact the business, with forward-looking statements on potential future impacts, fitting Strategy Integration per tiebreakers. No incident narrative or specifics are described, ruling out Incident Disclosure.


reasoning: The paragraph describes the company's own internal processes for assessing, identifying, and managing cybersecurity risks, aligned with general industry standards, which fits 'Risk Management Process'. No specific frameworks, roles, dates, or other firm-unique facts are mentioned, making it generic boilerplate.


reasoning: The paragraph describes the company's own cybersecurity risk management program, including framework adoption (NIST CSF and SOX) for identifying, assessing, and managing risks, which directly matches Risk Management Process. No board, management roles, incidents, vendors, or financial strategies are mentioned.


reasoning: The paragraph centrally focuses on vendor/supplier security oversight, including the Sustainable Purchasing Charter, pre-engagement assessments, and ongoing monitoring by the Information Security Department, which aligns with Third-Party Risk criteria over general internal processes.


reasoning: The paragraph focuses on the CISO's role, leadership of the ISC, qualifications, experience, and certifications, making management roles the central grammatical subject. No board involvement or internal processes as primary topic.


reasoning: The paragraph describes the company's internal processes for risk assessment, framework adoption (NIST), integration into ERM, and ongoing review by security and ERM teams, making Risk Management Process the best fit. Board and management are mentioned briefly at the start but are not the focus.


reasoning: The paragraph details the company's internal processes for assessing and testing information security using external experts, conducting training, and refining policies based on results, which aligns with Risk Management Process; third-party engagements are a component of these internal processes, not the central focus. No qualifying specific facts from the ✓ IS list or named standards are present, resulting in Generic Boilerplate.


reasoning: The paragraph details the company's intended internal processes for identifying, assessing, managing cybersecurity risks, including vulnerability management, penetration testing, and integration into overall risk management, which fits Risk Management Process; brief Board oversight mention does not change the primary focus on own processes. No qualifying specific facts from the ✓ IS list (e.g., no named roles, dates, firms, or standards), resulting in Generic Boilerplate.


reasoning: This paragraph describes a real cybersecurity incident with specifics on date, what happened (unauthorized access), scope of data accessed, response actions, and limitations on impact, directly matching 'Incident Disclosure'. It contains two hard verifiable facts (specific date and named product), qualifying as Quantified-Verifiable.


reasoning: The paragraph focuses on the Board of Directors and Audit Committee's oversight of cybersecurity risks, including meeting cadences with the CSO, making Board Governance the clear fit as board/committee is the grammatical subject. CSO is a cybersecurity-specific role qualifying as a firm-specific fact, but no named frameworks, dates, or other hard verifiable facts elevate it beyond Firm-Specific.


reasoning: This paragraph details an actual cybersecurity incident, including the date it was determined (March 10, 2024), unauthorized access to portions of the information environment, immediate response actions, business disruption, and ongoing investigation with law enforcement notification, directly matching 'Incident Disclosure' criteria with a real event narrative.


reasoning: This paragraph describes a real cybersecurity incident including the date it occurred, unauthorized access details, response actions, containment measures, business disruption, and remediation status, directly matching Incident Disclosure criteria with a narrative of what happened, scope, and impact. It includes one verifiable specific date, meeting Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: The paragraph focuses on the identification, qualifications, responsibilities, and reporting lines of the VP of IT (Information Security Officer) and the IT Executive Steering Committee composition, making management roles the primary subject. Brief Audit Committee mention does not shift focus per tiebreakers.


reasoning: This paragraph describes a specific cybersecurity incident including the date it was detected, unauthorized access to IT systems, response actions like activating incident procedures and engaging experts, and operational impacts on business applications, fitting Incident Disclosure perfectly. It contains one verifiable specific date but no additional hard facts like named firms or amounts, making it Firm-Specific.


reasoning: This paragraph details a specific cybersecurity incident including timeline (late November 2023 access, detected January 12, 2024, access removed January 13, 2024), scope (small percentage of employee emails including senior leadership and cybersecurity/legal functions), and response actions, fitting Incident Disclosure per guidelines and tiebreakers. Multiple specific dates qualify as two or more hard verifiable facts for Quantified-Verifiable specificity.


reasoning: This paragraph details a specific cybersecurity incident including timeline, scope of access (employee emails of senior leadership and cybersecurity/legal functions), exfiltration, and ongoing attempts to access source code repositories and systems, fitting Incident Disclosure. It contains one specific date and named departmental functions as firm-specific facts, but lacks a second hard verifiable fact for Quantified-Verifiable.


reasoning: This paragraph details a specific cybersecurity incident involving a former employee accessing customer data from up to 33 million accounts, including data types, response actions, and regulatory involvement, fitting Incident Disclosure. It contains one verifiable quantified fact (33 million accounts) but lacks a second hard fact for Quantified-Verifiable, making it Firm-Specific.


reasoning: Paragraph details a specific cybersecurity incident with date of detection, unauthorized access description, response actions (incident response activation, external experts, law enforcement notification), and scope of impact on systems and operations, matching Incident Disclosure criteria. Contains one verifiable specific date, qualifying as Firm-Specific with no additional hard facts for Quantified-Verifiable.


reasoning: This paragraph describes the cybersecurity incident's scope (impacted IT systems, billing and label making functions), response actions (removal of third party, restoration via contingency plans and backups), and operational impact (operations continued), directly matching Incident Disclosure criteria with reference to a real event. No qualifying specific facts from the ✓ IS list (no dates, named roles, firms, tools, or quantified metrics), resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes a real cybersecurity incident with details on what happened (website defacement by bad actor), specific timing, scope (company website), and response actions (restoration from backups, site takedown, review), directly matching Incident Disclosure. It includes two hard verifiable facts: a specific date and a named system (wytecintl.com).


reasoning: This paragraph describes an actual cybersecurity incident including unauthorized access, data exfiltration (images of video meetings and screens), threat actor demands, response actions (closing access, bolstering defenses), and operational/financial impacts, fitting Incident Disclosure per guidelines and tiebreakers prioritizing incident narrative over financial aspects.


reasoning: This paragraph describes a specific cybersecurity incident, including detection dates, unauthorized access details, data exfiltration scope (client PII, administrative data, employee/contractor accounts), response actions (incident response activation, investigation, containment, remediation), and notifications to law enforcement/regulators, directly matching Incident Disclosure criteria.


reasoning: The paragraph focuses on the CISO's identification, qualifications, experience, certifications, reporting lines, and management's cybersecurity experience, making 'Management Role' the primary category as management roles are the grammatical subjects. Brief board oversight does not shift it to Board Governance per tiebreakers.


reasoning: This paragraph consists entirely of forward-looking statement disclaimers, cross-references to risk factors, and boilerplate legal language with no substantive cybersecurity disclosure.


reasoning: This paragraph describes the details of a cybersecurity incident, including the exfiltration of files, engagement of experts, scope of data affected (personal information of clients' end-users), and ongoing response actions like analysis and client notifications, fitting Incident Disclosure. No specific facts from the ✓ IS list (no dates, named firms, roles, numbers, etc.) qualify it beyond Generic Boilerplate.


reasoning: This paragraph describes an actual cybersecurity incident, including unauthorized access by a threat actor, temporary limitations on IT systems, halted production operations, and data exfiltration, with details on investigation and planned notifications, directly matching Incident Disclosure criteria with a real event reference to the Original Form 8-K. No qualifying specific facts (e.g., dates, named entities, quantified metrics) are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph assesses the materiality of the incident's impact on business operations, financial statements, and expected costs without providing any incident narrative, scope, or response details, fitting Strategy Integration per tiebreakers for financial impact assessments without describing what happened. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph provides a narrative of a specific cybersecurity incident, including the third-party provider's response, scope of accessed personal information (names, DOB, SSN/TIN), lack of misuse, and customer notifications, with a brief financial impact note, aligning with Incident Disclosure per tiebreakers. No qualifying specific facts from the ✓ IS list (no dates, named firms, roles, numbers, or unique programs) or named standards, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes the scope and content of data affected in a specific cybersecurity incident, including details on call/text records, telephone numbers, interaction counts, durations, and cell site IDs for AT&T wireless customers and MVNOs, which fits Incident Disclosure as it references a real event's data/systems scope. No qualifying specific facts from the ✓ IS list (no roles, committees, dates, named tools/firms, or quantified metrics) are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes a real cybersecurity incident with what happened (access, encryption, exfiltration), date, response actions, scope of affected systems/files, and operational impacts, directly matching Incident Disclosure. Contains one verifiable specific date, qualifying as Firm-Specific with no named frameworks or additional hard facts for higher levels.


reasoning: This paragraph describes a specific cybersecurity incident including the date of discovery, unauthorized access to file systems, response actions like activating incident response protocols, containment measures, and operational impact of temporary business interruption, fitting Incident Disclosure. It contains one verifiable specific date but no second hard fact like dollar amounts or named firms, making it Firm-Specific.


reasoning: The paragraph assesses the financial impact and preliminary expense estimates for 'the Incident' without describing the incident itself, what happened, scope, or response actions, aligning with Strategy Integration per tiebreakers for financial cost assessments without incident narrative. It contains one quantified dollar range, qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard verifiable fact.


reasoning: This paragraph describes an actual cybersecurity incident with details on detection date, unauthorized access, encryption, data theft (personal data), response actions (containment, investigation, system shutdown, incident response plan), and operational impacts, directly matching Incident Disclosure criteria. It includes one verifiable specific date, qualifying as Firm-Specific with no other hard facts or named entities reaching Quantified-Verifiable.


reasoning: This paragraph provides a detailed narrative of a specific cybersecurity incident, including what happened (disruption caused by former executive), timeline, scope (website, email, IT systems), response actions (restore, investigate, compel reinstatement), and ongoing impacts, matching Incident Disclosure criteria. Two specific dates qualify it as Quantified-Verifiable.


reasoning: Paragraph describes the scope, operational impacts (website offline, delayed communications), lack of material effects on IP/customer data, and ongoing response to a specific unauthorized incident by a former executive officer, fitting Incident Disclosure criteria with reference to a real event, narrative, and impact assessment.


reasoning: The paragraph describes a real cybersecurity incident with specifics on notification date, access start date, threat actor identity, unauthorized access to email environment, data exfiltration scope from specific functions, and response actions, directly matching Incident Disclosure criteria including narrative, scope, and response.