content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

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

provider: google


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


content_category: Strategy Integration

reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and directs the reader to the Risk Factors section, which fits the Strategy Integration category.


content_category: Board Governance

reasoning: The paragraph focuses primarily on the Board's oversight responsibilities, including their role in receiving reports and materiality thresholds. While it mentions materiality, the primary subject is the Board's governance role, and all mentioned roles (President, CEO, General Counsel) and committees are on the exclusion list.


content_category: Management Role

reasoning: The paragraph focuses on the identification and reporting lines of the Information Security Officer (ISO) and Chief Risk Officer (CRO), which falls squarely under Management Role.


reasoning: The paragraph primarily describes the company's internal risk management program and its integration with ERM, making 'Risk Management Process' the most applicable category. While it mentions the Board and CISO, these are discussed in the context of how the risk program functions rather than as the primary focus of governance or management roles.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities and reporting structure, making Board Governance the primary category. It is classified as Firm-Specific because it names specific internal committees and cybersecurity-specific roles (CIO, VP Infrastructure) that are not generic.


reasoning: The paragraph discusses the company's general risk posture and concludes with a materiality statement regarding cybersecurity threats, which fits the Strategy Integration category.


reasoning: The paragraph describes the company's internal process for managing third-party risk as part of its broader risk management framework, rather than focusing on specific vendor oversight or a specific incident. It contains no specific facts, named entities, or unique identifiers.


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


reasoning: The paragraph describes the internal team composition and the specific methods used to identify and assess cybersecurity risks, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies a unique internal team composition (Legal, Compliance, and Finance departments).


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


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management, including the use of assessments, monitoring, and cross-departmental collaboration. It is classified as Sector-Adapted because it explicitly references the NIST framework but lacks unique, verifiable facts about the company's specific implementation.


reasoning: The paragraph focuses primarily on the roles and reporting lines of specific management positions (VP, IT Data Security; CTO) and the composition of the Cybersecurity Committee, which takes precedence over the brief mention of Board oversight.


reasoning: The paragraph focuses on the specific management role (HSE Director) responsible for cybersecurity oversight and their reporting relationship to the Board, which takes precedence over the general board oversight mentions.


reasoning: The paragraph describes the company's internal cybersecurity program, incident response planning, and risk assessment activities, which are core components of a Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents without describing any specific event or internal process details.


reasoning: The paragraph focuses on the oversight responsibilities of the Audit Committee and the Board regarding cybersecurity risks. All entities mentioned (Audit Committee, Board, management) and cadences (quarterly, periodic) are considered generic and do not meet the threshold for firm-specific disclosure.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and protocols. It contains no specific facts (no named frameworks, no named vendors, no specific dates, no specific roles), making it generic boilerplate.


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


content_category: None/Other

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


reasoning: The paragraph primarily focuses on the board of directors and the audit committee's oversight responsibilities regarding cybersecurity risks. While it mentions management roles, the board's oversight is the grammatical subject and central theme.


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


reasoning: The paragraph focuses on the identification, qualifications, and reporting lines of the CISO/CDIO, which falls squarely under Management Role. It is Quantified-Verifiable because it contains multiple hard facts, including specific dates (2021) and multiple named third-party firms (Comerica Bank, HSBC, Citibank, General Electric).


reasoning: The paragraph describes the company's internal risk management and assessment processes, including the role of an internal InfoSec team, which falls under Risk Management Process.


reasoning: The paragraph focuses on the Board's oversight structure, specifically detailing the formation and composition of a dedicated Cybersecurity Risk Subcommittee.


reasoning: The paragraph describes the company's internal security practices, such as incident response planning, disaster recovery, and security training, which falls under Risk Management Process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph primarily focuses on the materiality of past and potential future cybersecurity incidents, which falls under Strategy Integration. While it mentions board oversight and consultants, these are generic references that do not constitute specific governance or management disclosures.


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


reasoning: The paragraph focuses on the Board's oversight structure, specifically detailing the delegation of responsibilities to a named Cybersecurity Subcommittee.


reasoning: The paragraph focuses on the responsibilities and reporting lines of the CIO and senior leadership regarding cybersecurity oversight and incident response, making 'Management Role' the most appropriate category.


reasoning: The paragraph describes the company's internal cybersecurity processes, specifically its vulnerability management and incident response plan, which aligns with Risk Management Process. It is classified as Sector-Adapted because it references the NIST framework but lacks unique, firm-specific details.


reasoning: The paragraph describes the company's internal risk management processes, including how they develop controls and conduct assessments. It is classified as Sector-Adapted because it references recognized security frameworks (CIS and PCI DSS) without providing unique, firm-specific details.


reasoning: The paragraph focuses on the Board and Audit Committee's role in cybersecurity oversight, making 'Board Governance' the primary category. It is classified as 'Sector-Adapted' because it explicitly names the NIST Cybersecurity Framework but lacks other firm-specific details.


content_category: Third-Party Risk

reasoning: The paragraph focuses primarily on the company's oversight and requirements for third-party vendors, which aligns with the Third-Party Risk category. It contains no specific facts (dates, named firms, named tools, or specific roles) that would elevate it beyond generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management policies, procedures, and strategy, which falls squarely under Risk Management Process.


reasoning: The paragraph focuses on the specific management roles (Director, IT Infrastructure & Security; VP of IT) responsible for cybersecurity and their reporting lines, which defines the management structure.


reasoning: The paragraph focuses on the qualifications, responsibilities, and background of the CISO, which is the primary management role responsible for cybersecurity.


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


reasoning: The paragraph describes the company's internal incident detection and response processes and framework adoption, which falls squarely under Risk Management Process.


reasoning: The paragraph primarily discusses the potential material impact of cybersecurity threats on the business and financial standing, which falls under Strategy Integration. The mention of incident response practices involving the CEO, CFO, and an unnamed MSP is generic and does not provide specific, verifiable details.


reasoning: The paragraph primarily describes the Board of Directors' oversight responsibilities regarding cybersecurity risks and the reporting structure for such risks, which fits the Board Governance category.


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident that occurred in October 2023, including the nature of the event and the subsequent response actions taken by the company.


reasoning: The paragraph focuses on the management-level committee (ERM) and specific roles (CISO, CDO) responsible for cybersecurity risk oversight, fitting the Management Role category.


reasoning: The paragraph describes internal cybersecurity training programs and preparedness exercises, which are core components of a company's risk management process. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the role and qualifications of the CISO and the internal governance structure (ISC) led by the CISO. It qualifies as Quantified-Verifiable because it lists the CISO's specific years of experience and multiple specific professional certifications.


reasoning: The paragraph describes the company's internal risk management processes and frameworks. It is classified as Firm-Specific because it explicitly claims maintenance of an ISO 27001 certification, which is a verifiable firm-specific fact, rather than just referencing the standard.


reasoning: The paragraph focuses on the Board's oversight structure and the delegation of cybersecurity risk oversight to the Audit Committee. All mentioned entities (Board, Audit Committee) and cadences (periodic) are on the exclusion list, resulting in generic boilerplate.


reasoning: The paragraph primarily discusses the materiality of cybersecurity threats and past incidents on the company's financial condition and strategy, which falls under Strategy Integration. While it mentions a past incident, it does not describe the incident itself, but rather uses it to frame a materiality conclusion.


reasoning: The paragraph primarily serves as a materiality conclusion regarding cybersecurity risks and their impact on the company's financial condition and strategy, which falls under Strategy Integration.


reasoning: The paragraph focuses primarily on the company's oversight of third-party providers, including specific internal policies like the Sustainable Purchasing Charter and the role of the Information Security Department in monitoring vendors.


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


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


reasoning: The paragraph describes the company's internal cybersecurity risk management program and references the NIST Cybersecurity Framework, which is a recognized standard.


reasoning: The paragraph focuses on the qualifications, experience, and reporting lines of the Chief Information Security Officer, which falls squarely under Management Role.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, such as vulnerability management, disaster recovery, and threat monitoring, without providing any specific, verifiable details.


reasoning: The paragraph describes the company's internal approach to risk management, specifically the use of external experts and employee training to maintain security processes. It does not name specific firms, roles, or frameworks, making it generic boilerplate.


reasoning: The paragraph focuses primarily on the responsibilities, qualifications, and reporting lines of the VP of IT and the IT Executive Steering Committee, which falls under Management Role. It is classified as Quantified-Verifiable because it contains two or more hard facts (specific tenure duration and years of experience).


reasoning: The paragraph focuses on the Board of Directors' oversight responsibilities and their interaction with the CSO, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies a cybersecurity-specific role (CSO), which is on the ✓ IS list, distinguishing it from generic boilerplate.


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


reasoning: The paragraph is a standard forward-looking disclaimer regarding the limitations of cybersecurity controls and the nature of cyber threats, which falls under the None/Other category.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of determination and the nature of the event (unauthorized access), which places it squarely in the Incident Disclosure category.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of detection, the nature of the unauthorized access, and the company's response actions, which places it squarely in the Incident Disclosure category.


reasoning: The paragraph describes the company's intended internal risk management processes and oversight structure. It contains no specific facts, named roles, or unique identifiers, relying entirely on generic descriptions of cybersecurity practices.


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


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


reasoning: The paragraph describes the details, scope, and ongoing nature of a specific cybersecurity incident, which falls squarely under Incident Disclosure.


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


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


reasoning: The paragraph describes a specific cybersecurity incident, including dates of detection, the timeline of the breach, and the response actions taken, which fits the Incident Disclosure category.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of detection and the operational impact, which classifies it as an Incident Disclosure.


reasoning: The paragraph describes the details of an ongoing cybersecurity incident, including the nature of the exfiltrated data and the threat actors' demands, which places it squarely in the Incident Disclosure category.


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


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


reasoning: The paragraph describes the details, scope, and response actions related to a specific cybersecurity incident, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of occurrence, the nature of the attack (website defacement), and the company's response actions.


reasoning: The paragraph describes the nature and impact of a cybersecurity incident, including unauthorized access, operational limitations, and data exfiltration, which places it squarely in the Incident Disclosure category.


reasoning: The paragraph describes the scope and nature of an ongoing cybersecurity incident, including the exfiltration of data and the company's response actions, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, rendering it Generic Boilerplate.


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


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of occurrence, the nature of the attack (unauthorized access, encryption, exfiltration), and the current status of remediation efforts.


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


reasoning: The paragraph focuses on the financial impact and materiality assessment of an incident rather than describing the incident's mechanics or response actions, which aligns with Strategy Integration. It is Firm-Specific because it provides a unique, company-specific financial estimate.


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


reasoning: The paragraph describes the operational impact and recovery status of a previously disclosed cybersecurity incident, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other hard verifiable facts, making it generic in its description of operational status.


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


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the affected subsidiary, and the response actions taken, which clearly falls under Incident Disclosure.


reasoning: The paragraph describes the status, operational impact, and remediation of a specific cybersecurity incident, which places it squarely in Incident Disclosure. It contains multiple verifiable facts, including specific dates and a dollar amount, qualifying it as Quantified-Verifiable.


reasoning: The paragraph focuses exclusively on the materiality assessment of the incident regarding financial condition and insurance coverage, without describing the incident itself. It uses standard boilerplate language regarding materiality and insurance expectations.


reasoning: The paragraph focuses on the materiality assessment and financial impact of an incident, which falls under Strategy Integration. It contains three specific dates, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident, including the dates of occurrence and resolution, the nature of the disruption, and the response actions taken, which clearly falls under Incident Disclosure.


reasoning: Although the paragraph mentions remediation activities, the primary focus is on the financial impact (insurance recovery) and the materiality conclusion regarding the incident, which dictates the Strategy Integration category per the tiebreakers.


reasoning: The paragraph describes the nature, impact, and ongoing response to a specific cybersecurity incident, which falls squarely under Incident Disclosure. It lacks specific dates, named entities, or quantifiable metrics, rendering it generic in its specificity.


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


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


reasoning: The paragraph focuses on the materiality assessment and financial impact of the incident, which falls under Strategy Integration. It contains two specific dates, qualifying it as Quantified-Verifiable.


reasoning: The paragraph focuses on the financial and operational impact (revenue recognition delays and loss of business) of a previously disclosed incident, rather than describing the incident itself or internal security processes.


reasoning: The paragraph describes the details of a specific cybersecurity incident (ransomware), including dates of occurrence and disclosure, which falls squarely under Incident Disclosure.


reasoning: The paragraph details the timeline and response actions of a specific cybersecurity incident, providing two distinct, verifiable dates.


reasoning: The paragraph focuses on the financial and operational materiality of an incident, including insurance coverage, without describing the incident itself. Per the tiebreaker rules, standalone materiality conclusions and financial impact discussions are classified as Strategy Integration.


reasoning: The paragraph describes the scope, impact, and status of a specific cybersecurity incident involving a third-party provider, which falls squarely under Incident Disclosure.


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


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


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


reasoning: The paragraph describes the scope and nature of a cybersecurity incident, including the type of data accessed and the company's response actions, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph describes the ongoing investigation, status of data theft, and materiality assessment of a specific incident, which falls squarely under Incident Disclosure. It contains no specific dates, named third-party firms, or other verifiable facts, making it generic.


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


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of detection, the nature of the unauthorized access, and the operational impact, which places it squarely in the Incident Disclosure category.


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


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


reasoning: The paragraph primarily describes the company's internal risk management processes and integration, with management roles mentioned as participants in that process rather than the central topic.


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


reasoning: The paragraph describes an actual cybersecurity incident, the company's response actions, and the operational impact, which fits the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, making it Generic Boilerplate.


reasoning: The paragraph focuses on the financial implications and liquidity arrangements resulting from a cybersecurity incident, rather than describing the incident itself.


reasoning: The paragraph focuses on the responsibilities and qualifications of the Chief Technology Officer, which is a management role.


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


reasoning: The paragraph describes the company's internal cybersecurity program and risk management structure, making it a Risk Management Process disclosure. It is Firm-Specific because it names a unique internal organization (CDRM) and a specific cybersecurity role (Global CISO).


reasoning: The paragraph describes the board's oversight structure and delegation to the audit committee, which fits the Board Governance category. It contains no specific facts, roles, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph focuses on the management role responsible for cybersecurity oversight (the CFO) and reporting lines. It is classified as Generic Boilerplate because CFO, Nomination and Corporate Governance Committee, and generic consultants are all on the exclusion list.


reasoning: The paragraph focuses on the Board's oversight role via the Audit Committee. While it mentions management roles (CFO, Senior IT leadership), these are generic titles and the primary subject is the Board's governance structure.


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


reasoning: The paragraph is a cross-reference to another section of the filing and contains no substantive cybersecurity disclosure.


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


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and incidents without describing any specific events or processes.


reasoning: The paragraph primarily describes the integration of cybersecurity into the company's enterprise risk management (ERM) framework, which falls under Risk Management Process. While it mentions the board, the focus is on the operational integration of policies and frameworks rather than board governance mechanics.


reasoning: The paragraph describes internal risk management activities such as training, awareness updates, penetration testing, and assessments. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph describes the company's internal risk management processes and integration of cybersecurity into broader enterprise risk management, which fits the Risk Management Process category. It contains no specific facts, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal procedures for identifying and escalating cybersecurity incidents, which falls squarely under risk management processes.


reasoning: The paragraph focuses on the identification, qualifications, and tenure of the CISO and CTO, which falls squarely under Management Role. It contains numerous verifiable facts, including specific years of experience, certifications, and start dates, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses on the roles responsible for managing cybersecurity risks, specifically highlighting the Chief Security Officer (CSO) and their collaboration with internal teams.


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


reasoning: The paragraph identifies a specific individual (Jack Wang) and his qualifications/responsibilities regarding cybersecurity risk management, which directly addresses the management role category.


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


reasoning: The paragraph provides a standalone materiality assessment regarding cybersecurity risks and the absence of material incidents, which falls under Strategy Integration.


reasoning: The paragraph focuses on the Board of Directors and the Audit Committee's oversight role regarding cybersecurity. All mentioned entities (Board, Audit Committee, management) and cadences (annually) are on the '✗ NOT' list, resulting in a Generic Boilerplate classification.


reasoning: The paragraph describes the company's internal incident response and escalation procedures, which falls under Risk Management Process. It is classified as Firm-Specific because it names specific internal entities like the 'Incident Management Team' and 'Privacy and Security Subcommittee'.


reasoning: The paragraph focuses on the qualifications, experience, and professional background of specific management roles (VP of Information Systems and CFO) regarding cybersecurity oversight.


reasoning: The paragraph focuses on the reporting lines and responsibilities of the CISO and CTO, which places it squarely in the Management Role category.


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


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including specific committee oversight and internal roles, which is characteristic of a Risk Management Process disclosure.


reasoning: The paragraph describes the company's use of external experts as part of its internal risk management and testing processes, which falls under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's incident response plan and its general components, which falls under internal risk management processes. It contains no specific facts, named entities, or frameworks.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity threats for the year 2023, which is classified as Strategy Integration.


reasoning: The paragraph focuses on the Board's oversight activities and the briefings they receive, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies specific cybersecurity-related roles (CIO, CISO, CIRO) that present to the Board.


reasoning: The paragraph focuses on the management structure and oversight responsibilities for cybersecurity, specifically identifying the CFO and the IT department's experience level.


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


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


reasoning: The paragraph primarily focuses on the responsibilities of management and specifically identifies the Vice President of Operations as the individual overseeing cybersecurity programs, which aligns with the Management Role category.


reasoning: The paragraph describes the company's internal risk management activities, specifically the engagement of third-party firms for simulation exercises and ongoing monitoring, which falls under Risk Management Process. It is Firm-Specific because it references a specific timeframe ('fiscal 2024') and unique engagement activities, though it does not name the specific firms, preventing it from being Quantified-Verifiable.


reasoning: The paragraph describes the Board's establishment of a specific Cybersecurity Committee and details the qualifications of its chair, which is a governance matter.


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


reasoning: The paragraph discusses the potential material adverse effect of cybersecurity incidents and the limitations of cybersecurity insurance, which falls under Strategy Integration. It contains no specific facts, dates, or named entities, making it generic boilerplate.


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


reasoning: The paragraph focuses on the Board's delegation of cybersecurity oversight to the audit committee. It is classified as Generic Boilerplate because it relies entirely on generic governance terms (Board, management, audit committee, quarterly reports) without naming specific cybersecurity roles, unique committees, or verifiable facts.


reasoning: The paragraph focuses entirely on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity risks. All entities mentioned (Board, Audit Committee) and cadences (periodic, annual) are considered generic and do not meet the threshold for firm-specific or quantified-verifiable facts.


reasoning: The paragraph focuses entirely on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity risk. All entities mentioned (Board, Audit Committee) are on the exclusion list for specific facts, resulting in a generic classification.


reasoning: The paragraph describes the company's internal audit and risk assessment process, which falls under Risk Management Process. It contains no specific facts, named tools, or unique identifiers, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management and integration with ERM, which fits the Risk Management Process category. It contains no specific facts, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes how the company integrates third-party risk assessment into its broader internal cybersecurity risk management processes, making it a description of internal risk management.


reasoning: The paragraph focuses on the responsibilities and qualifications of the Director of Cybersecurity, which is a management role.


reasoning: The paragraph describes the company's internal security operations, tools, and training programs, which falls under Risk Management Process. It contains no specific dates, named third-party firms, or unique identifiers, relying entirely on common industry practices.


reasoning: The paragraph primarily discusses the company's approach to cyber insurance and business continuity planning, which falls under Strategy Integration. While it mentions a specific management role (Vice President of Finance and Treasurer), the core topic is the financial/risk mitigation strategy of insurance.


reasoning: The paragraph focuses exclusively on the company's approach to managing risks associated with third-party vendors and service providers, making Third-Party Risk the central topic.


reasoning: The paragraph describes the company's adoption of internal frameworks and policies to manage cybersecurity risk, which falls under Risk Management Process. It is classified as Sector-Adapted because it explicitly names the NIST Cybersecurity Framework but contains no other firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity measures and processes, which falls under Risk Management Process. It contains no specific facts, named frameworks, or unique identifiers.


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


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


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


reasoning: The paragraph describes the company's internal incident response processes and monitoring capabilities, which falls under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the materiality assessment and potential business impact of an incident without providing specific details about the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and oversight, using standard boilerplate language without referencing specific frameworks, roles, or unique identifiers.


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


reasoning: The paragraph describes the company's internal cybersecurity measures and risk management processes, which is the definition of the Risk Management Process category. It contains no specific facts, named frameworks, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of detection and the subsequent response actions taken by the company.


reasoning: The paragraph is a generic risk statement regarding cybersecurity threats and potential business impact, lacking specific details on governance, management, processes, or incidents.


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


reasoning: The paragraph describes the scope and impact of a previously disclosed incident (data exfiltration and PII involvement), which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph describes the internal operational processes for monitoring and escalating cybersecurity incidents, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies a specific management role (Senior Vice President, IT Operations) responsible for these processes.


reasoning: The paragraph focuses on the financial and operational materiality of an incident rather than describing the incident itself, fitting the Strategy Integration category. It is Quantified-Verifiable because it references two specific time periods (the quarter ended December 31, 2024, and full year 2024).


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


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


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


reasoning: The paragraph describes a specific cybersecurity incident, including the date of discovery, the nature of the event (unauthorized access and encryption), and the company's immediate response actions.


reasoning: The paragraph describes a specific cybersecurity incident, including the detection of unauthorized activity and the company's response actions (isolating systems), which falls squarely under Incident Disclosure.


reasoning: The paragraph describes the timeline, scope, and nature of a specific cybersecurity incident, making it an Incident Disclosure. It contains multiple verifiable facts (two specific dates and a named system), qualifying it as Quantified-Verifiable.


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


reasoning: The paragraph focuses on the materiality assessment of an incident (financial condition and operational impact) rather than describing the incident details themselves, which aligns with Strategy Integration. It contains no specific facts, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the materiality assessment of an incident and standard response actions without providing specific details about the incident itself.


reasoning: The paragraph describes the timeline and status of a specific cybersecurity incident, including law enforcement involvement and the status of the data, which falls squarely under Incident Disclosure.


reasoning: The paragraph focuses on the materiality assessment of an incident regarding financial condition and operations, which falls under Strategy Integration. It contains no specific facts, dates, or metrics, relying entirely on boilerplate language.


reasoning: The paragraph focuses on the financial impact (accrued expenses) and insurance coverage related to an incident, rather than describing the incident narrative itself, which aligns with Strategy Integration.


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


reasoning: The paragraph describes the scope and findings of an ongoing cybersecurity incident investigation, which falls squarely under Incident Disclosure.


reasoning: The paragraph focuses exclusively on the financial materiality and impact of a previously disclosed incident, providing specific earnings per share figures and the estimated financial impact without describing the incident itself.


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


reasoning: The paragraph focuses on the financial impact (expenses and revenue) of a cybersecurity incident without providing a narrative description of the incident itself, which aligns with the Strategy Integration category.


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


reasoning: The paragraph describes the scope of data exfiltrated during a cybersecurity incident, which is a core component of incident disclosure.


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


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


reasoning: The paragraph focuses on the materiality assessment of an incident regarding financial condition and business operations, which falls under Strategy Integration. It contains no specific dates, named third-party firms, or other verifiable facts, relying instead on standard boilerplate language regarding materiality.


reasoning: The paragraph describes the scope and impact of a specific cybersecurity incident, including the number of affected consumers and the types of data involved, which classifies it as an Incident Disclosure.


reasoning: The paragraph describes the company's response actions to a specific incident, including investigation and notification procedures, which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident, including the date of occurrence, the nature of the event (unauthorized access), and the company's response actions, which fits the Incident Disclosure category.


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


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


reasoning: The paragraph describes the response actions taken regarding a specific cybersecurity incident, including the date of system isolation, which qualifies it as an Incident Disclosure.


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


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


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


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


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


reasoning: The paragraph focuses exclusively on the materiality and potential financial impact of a previously mentioned incident without providing any descriptive details about the incident itself.


reasoning: The paragraph focuses on the materiality assessment of an incident rather than describing the incident itself, which aligns with Strategy Integration. It contains a specific fiscal period, making it Firm-Specific.


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


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


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


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


reasoning: The paragraph describes the company's response actions and ongoing operations in the context of a specific, previously disclosed incident, which falls under Incident Disclosure.


reasoning: The paragraph focuses on the financial impact and materiality of the incident, including specific costs and dates, rather than describing the incident narrative itself.


reasoning: The paragraph describes the company's response actions to a cybersecurity incident, which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


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


reasoning: The paragraph describes the timeline, nature (ransomware), and impact (encryption, unauthorized disclosure) of a specific cybersecurity incident, which fits the Incident Disclosure category. It contains two specific dates, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the details of a specific cybersecurity incident, including the date of discovery and the nature of the event (data exfiltration), which classifies it as an Incident Disclosure.


reasoning: The paragraph provides an update on the status and response actions related to a specific, previously disclosed cybersecurity incident (the Change Healthcare cyberattack).


reasoning: The paragraph describes the company's response actions to an unauthorized activity (incident), which fits the Incident Disclosure category. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the ongoing investigation and assessment of an incident, which is a core component of incident disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses on the materiality assessment of a previously disclosed incident, which falls under Strategy Integration. It contains no specific facts, dates, or metrics, relying entirely on boilerplate language regarding materiality.


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


reasoning: The paragraph describes the specific scope and impact of a cybersecurity incident, including the types of data affected, which qualifies it as an incident disclosure.


reasoning: The paragraph focuses on the materiality of an incident regarding the company's financial condition and business operations, which falls under Strategy Integration. It is Firm-Specific because it names a specific subsidiary (Targus) and a specific financial metric (Operating Adjusted EBITDA).


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


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


reasoning: The paragraph focuses on the board's oversight role and reporting structure. It contains no specific facts (e.g., named cybersecurity-specific roles, unique committees, or specific dates), relying entirely on generic terminology like 'board of directors', 'audit committee', and 'annual basis'.


reasoning: The paragraph describes the company's internal process for evaluating vendors as part of their broader risk management framework. It does not name specific vendors, tools, or unique programs, making it generic boilerplate.


reasoning: The paragraph focuses on the oversight responsibilities of a committee and the board regarding cybersecurity risks and incidents. It uses only generic terms (e.g., 'the Committee', 'management', 'the Board', 'periodic reports') and contains no specific facts.


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


reasoning: The paragraph focuses on the board of directors and the audit committee's oversight role regarding cybersecurity, which falls under Board Governance. It contains no specific facts (e.g., named cybersecurity committees, specific dates, or unique programs), relying entirely on generic governance terminology.


reasoning: The paragraph describes oversight responsibilities and explicitly mentions a 'Cybersecurity Committee,' which is a named non-generic committee, placing it in Board Governance and Firm-Specific.


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


reasoning: The paragraph describes general internal efforts to improve cybersecurity and internal controls without referencing specific frameworks, roles, or unique company programs.


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


reasoning: The paragraph describes the professional background of an individual (Mr. Tao) but does not mention cybersecurity roles, oversight, or processes, making it irrelevant to the cybersecurity disclosure requirements.


reasoning: The paragraph provides a materiality conclusion regarding the financial impact of a cybersecurity incident, which is classified as Strategy Integration.


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


reasoning: The paragraph describes the company's internal approach to risk management and cybersecurity program implementation, which falls squarely under Risk Management Process. It contains no specific facts, named entities, or unique identifiers.


reasoning: This paragraph is a standard legal disclaimer regarding the filing status of the report and contains no substantive cybersecurity disclosure.


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


reasoning: The paragraph focuses on the Board of Directors' oversight and reporting cadence, making 'Board Governance' the primary category. It is classified as 'Firm-Specific' because it identifies specific cybersecurity-focused roles (CISO and CIO) reporting to the board, which are on the 'IS' list.


reasoning: The paragraph is a generic risk factor statement describing dependency on IT systems and third parties, without detailing specific governance, management processes, or actual incidents.


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


reasoning: The paragraph describes the company's internal approach to integrating cybersecurity into its enterprise risk management program, which falls under Risk Management Process. It contains no specific facts, dates, or named tools, making it generic boilerplate.


reasoning: The paragraph describes internal security policies and training procedures, which are core components of a company's risk management process. It contains no specific facts, named tools, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph identifies specific management roles (CIO, Director of IT Security, Risk and Compliance) and their qualifications, which falls squarely under Management Role.


reasoning: The paragraph focuses on the board of directors and the audit committee's oversight role regarding cybersecurity. It is classified as Generic Boilerplate because 'audit committee', 'board of directors', and 'management team' are all explicitly listed as generic terms in the provided instructions.


reasoning: This paragraph is a generic disclaimer describing common cybersecurity threats and vulnerabilities without detailing the company's specific risk management processes, governance, or incidents.


reasoning: The paragraph uses generic language regarding board and executive oversight without referencing specific cybersecurity governance structures, roles, or processes.


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


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


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


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


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


reasoning: The paragraph describes a standard step in an incident response process (eradication), which falls under internal risk management processes. It contains no specific details, dates, or unique identifiers, making it generic boilerplate.


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


reasoning: The paragraph focuses on the Board's oversight activities and the cadence of reporting, which falls under Board Governance. It contains no specific facts (Audit Committee, Board, and regular updates are all generic/standard terms).


reasoning: The paragraph provides a materiality conclusion regarding the absence of cybersecurity incidents and financial impact for specific fiscal periods.


reasoning: The paragraph focuses on identifying the specific management role (CFO serving as CISO) responsible for cybersecurity oversight.


reasoning: The paragraph describes general risk management activities like threat intelligence and external assessments without naming specific frameworks, tools, or unique internal programs.


reasoning: The paragraph explicitly identifies specific management roles (CIO and VP of Information Security) responsible for cybersecurity oversight, which places it squarely in the Management Role category.


reasoning: The paragraph focuses on the Board and Audit Committee's oversight role regarding cybersecurity risks. It is classified as Generic Boilerplate because it relies entirely on generic terms (Board, Audit Committee, management, regular reports) without naming specific cybersecurity roles, committees, or unique programs.


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


reasoning: The paragraph provides a materiality conclusion regarding cybersecurity incidents without describing a specific event, which falls under Strategy Integration. It is classified as Quantified-Verifiable because it contains two specific dates.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents and financial impact without describing any specific event, which falls under Strategy Integration. It contains no specific facts (dates, named entities, or verifiable metrics), making it Generic Boilerplate.


reasoning: The paragraph serves as an introductory sentence for the company's cybersecurity risk management program and does not contain any specific details or unique identifiers.


reasoning: The paragraph is a high-level introductory statement about the importance of cybersecurity, lacking any substantive details regarding specific processes, governance, or incidents.


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


reasoning: The paragraph describes standard internal security practices like phishing simulations and training, which are common components of a company's risk management process. It contains no specific facts, named tools, or unique identifiers.


reasoning: The paragraph describes the cybersecurity responsibilities of specific executive roles (CFO, COO, CEO). However, these roles are explicitly listed in the ✗ NOT list as generic C-suite titles, making the content generic boilerplate.


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


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


reasoning: The paragraph describes the company's internal approach to risk management, including monitoring and training, which falls under Risk Management Process. It contains no specific names, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the general functions of cybersecurity personnel without naming specific roles, committees, or unique programs, making it a generic description of management/staff responsibilities.


reasoning: The paragraph describes the company's internal risk management framework in general terms without referencing specific tools, frameworks, or unique processes.


reasoning: The paragraph describes internal security training practices, which falls under the Risk Management Process category. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph focuses on the Board of Directors' oversight role and their cadence for receiving updates, which falls squarely under Board Governance. All mentioned elements (Board of Directors, periodic updates, quarterly, annual, enterprise risk management) are on the ✗ NOT list, resulting in Generic Boilerplate.


reasoning: The paragraph describes internal risk management processes, including training and vendor oversight, without naming specific tools, frameworks, or unique organizational details.


reasoning: The paragraph explicitly discusses the management of cybersecurity and the roles responsible for it, fitting the Management Role category. It contains no specific facts (no named roles, dates, or unique identifiers), making it generic boilerplate.


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


reasoning: This paragraph is a generic statement of intent regarding cybersecurity goals and does not describe specific governance, management, processes, or incidents.


reasoning: The paragraph describes the company's intent to implement a risk management process for cybersecurity threats, which falls under Risk Management Process. It is classified as Firm-Specific because it references a unique internal system, 'BDTP TM'.


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


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


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


reasoning: The paragraph discusses financial recovery (insurance claims) related to an incident without describing the incident itself, which falls under Strategy Integration. It contains no specific facts (dates, amounts, named insurers), making it generic boilerplate.


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


reasoning: The paragraph identifies specific management roles responsible for cybersecurity risk management, which falls under the Management Role category. It is Firm-Specific because it names a specific cybersecurity-related title ('Senior Director of IT'), while CFO and Treasurer are generic C-suite roles.


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


reasoning: The paragraph describes the company's response to an ongoing incident, including system restoration efforts and engagement with external parties, which falls under Incident Disclosure. It contains no specific dates, named firms, or other verifiable facts, making it generic boilerplate.


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


reasoning: The paragraph describes the establishment of an internal cybersecurity awareness program, which is a core component of the company's risk management and training processes.


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


reasoning: The paragraph discusses cybersecurity insurance and financial coverage for incidents without describing a specific event or internal process, which falls under Strategy Integration. It contains no specific facts (dates, named firms, specific dollar amounts), making it generic boilerplate.


reasoning: The paragraph describes the nature of a previously disclosed incident (data exfiltration and PII involvement) and the ongoing response actions (notifications), which fits the Incident Disclosure category.


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


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


reasoning: The paragraph describes the operational impact of an ongoing incident and directs readers to a specific company-hosted status page for updates, which constitutes incident disclosure.


reasoning: The paragraph discusses the potential material impact of an incident without providing any specific details about the incident itself, fitting the criteria for Strategy Integration.


reasoning: The paragraph discusses the potential financial and business impacts (litigation, insurance costs) of a cybersecurity incident without describing the incident itself, which aligns with the Strategy Integration category.


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


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


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


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


reasoning: This paragraph describes executive leadership changes at a subsidiary, which is a corporate governance or personnel matter, not a cybersecurity-specific disclosure.


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


reasoning: The paragraph discusses the materiality and potential financial/operational impact of an incident without providing any specific details about the incident itself, which aligns with the Strategy Integration category.


reasoning: The paragraph discusses the financial impact and insurance recovery expectations related to an incident without describing the incident itself, which aligns with the Strategy Integration category.


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


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


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


reasoning: The paragraph describes specific response actions taken in relation to a disclosed incident, fitting the Incident Disclosure category. It contains no specific dates, named third-party firms, or other verifiable facts, rendering it Generic Boilerplate.


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


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


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


reasoning: While the paragraph mentions an incident, the primary purpose of the statement is to provide a materiality conclusion regarding the financial impact, which falls under Strategy Integration per the tiebreaker rules.


reasoning: The paragraph describes the operational impact of an ongoing cybersecurity incident, specifically noting disruptions to online ordering systems, which qualifies as incident disclosure.


reasoning: The paragraph discusses the materiality of an incident without describing the event itself, which falls under Strategy Integration per the tiebreaker rules. It contains no specific facts, dates, or entities, making it Generic Boilerplate.


reasoning: The paragraph describes the nature of an ongoing cybersecurity incident, including unauthorized access, data exfiltration, and encryption, which falls squarely under Incident Disclosure.


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


reasoning: The paragraph focuses exclusively on the materiality assessment of an incident without providing any descriptive details about the event itself.


reasoning: The paragraph discusses the materiality of an incident without providing any narrative details about the event itself, which aligns with the Strategy Integration category per the tiebreaker rules.


reasoning: The paragraph describes a specific response action (mailing notification letters) taken in the context of an ongoing incident investigation, which falls under Incident Disclosure.


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


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


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


reasoning: The paragraph describes the occurrence of a specific cybersecurity incident, including the date of discovery, which classifies it as an Incident Disclosure.


reasoning: The paragraph describes the operational impact of an ongoing incident (website inaccessibility) and provides a specific company-created resource for incident communication, which is a direct component of incident disclosure.


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


reasoning: The paragraph describes the operational impact of a specific cybersecurity incident, including the duration of the disruption, which qualifies it as an incident disclosure.


reasoning: The paragraph describes the nature of a cybersecurity incident (unauthorized access to sensitive information) and the company's response (notification plans), which falls squarely under Incident Disclosure. It contains no specific dates, named entities, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph discusses the financial/operational impact of an incident without providing a narrative of the incident itself, which aligns with the Strategy Integration category. It contains no specific dates, dollar amounts, or other verifiable facts, making it generic boilerplate.


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


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


reasoning: The paragraph focuses exclusively on the materiality assessment of a cybersecurity incident without describing the incident itself, which aligns with the Strategy Integration category.


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


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


reasoning: The paragraph describes a specific cybersecurity incident (attempted fraudulent fund acquisition) and provides the date of detection, which qualifies as an incident disclosure.


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


reasoning: The paragraph describes operational response actions taken in the context of an ongoing incident (system restoration), which falls under Incident Disclosure. It contains no specific dates, named tools, or other verifiable facts, making it generic.


reasoning: The paragraph references a specific ongoing cybersecurity incident involving the Change Healthcare systems and provides a specific date for the company's update on the situation.


reasoning: The paragraph describes the operational impact and response actions taken following a cybersecurity incident, which falls under Incident Disclosure.


reasoning: The paragraph focuses on the composition and responsibilities of the internal management team (the 'Risk Management Team') and the specific role of the Sr. Director of IT, making 'Management Role' the primary category.


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


reasoning: The paragraph describes the company's internal processes for evaluating and responding to cybersecurity incidents, including the specific role of the CSO and named internal programs like the Incident Response Program and Business Continuity Plan.


reasoning: The paragraph primarily describes the company's internal cybersecurity team structure, monitoring processes, and vendor assessment procedures, which falls under Risk Management Process. While it mentions third-party providers, the focus is on the company's internal requirements for those vendors rather than the vendors' own security oversight.


reasoning: The paragraph details the company's internal cybersecurity processes, including threat assessment, layered security, and training, which falls squarely under Risk Management Process. It is classified as Sector-Adapted because it explicitly references recognized frameworks (NIST, ISO, SOC-1, SOC-2) without providing unique, verifiable facts about the company's specific implementation or tools.


reasoning: The paragraph focuses primarily on the roles, responsibilities, and qualifications of the CISO and CTO, making 'Management Role' the most appropriate category. It contains multiple verifiable facts, including specific years of experience, named companies, and named programs, qualifying it as Quantified-Verifiable.


reasoning: The paragraph focuses on the specific roles (IT Manager, IT Steering Committee) responsible for administering the cybersecurity program and details the experience levels of these individuals, making it a management role disclosure.


reasoning: The paragraph describes the company's internal risk management processes, including security controls, training, and monitoring. It is classified as Sector-Adapted because it explicitly references the NIST CSF framework but lacks other firm-specific details.


reasoning: The paragraph primarily discusses the company's materiality assessment regarding cybersecurity threats and incidents, which falls under Strategy Integration. It is classified as Firm-Specific because it references a specific fiscal year (fiscal 2024) in the context of its materiality conclusion.


reasoning: The paragraph focuses on identifying the specific roles and qualifications of the individuals responsible for cybersecurity management, including the vCISO and other security staff. It qualifies as Quantified-Verifiable because it lists multiple specific professional certifications and a specific number of years of experience.


reasoning: The paragraph focuses on the oversight responsibilities of the Board and its Risk Committee, making Board Governance the primary category. It is classified as Firm-Specific because it identifies a 'Risk Committee,' which is explicitly listed as a non-generic committee in the provided instructions.


reasoning: This paragraph describes general operational dependencies on IT systems and lists common cybersecurity threats, which constitutes standard risk factor boilerplate rather than a specific disclosure of governance, management, or internal processes.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and regulatory compliance, which falls under Risk Management Process. It contains no specific facts (dates, named tools, specific roles, or unique programs) that would elevate it beyond generic boilerplate, as naming regulatory bodies like the FDIC is standard for financial institutions.


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


reasoning: The paragraph describes the company's internal cybersecurity risk management strategy, including incident response, technical safeguards, and general risk assessment processes. It contains no specific facts, named roles, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph outlines the company's internal cybersecurity program, including governance, technical safeguards, and incident response planning, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies specific cybersecurity roles (CIO and Global Head of IT Security) that are unique to the company's organizational structure.


reasoning: This paragraph is a standard, generic risk factor disclosure describing potential cybersecurity threats and their potential impacts without referencing any specific internal processes, governance, or incidents.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including monitoring, training, and policy development. It contains no specific names of tools, firms, dates, or unique identifiers, making it generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity tools, processes, and strategic initiatives, which falls under Risk Management Process. It is classified as Firm-Specific because it includes a specific timeframe for incident reporting (24 hours) and specific strategic goals for the year 2025.


reasoning: The paragraph details the company's internal cybersecurity risk management strategy, including the use of specific frameworks, internal oversight committees, and internal audit processes.


reasoning: The paragraph primarily describes the company's internal risk management processes, including frameworks used, software tools for monitoring/protection, and incident response planning. While it mentions specific internal plans (IRP, BCP, Disaster Recovery Plan), these are generic program names rather than unique identifiers, so the mention of the NIST Framework is the primary driver for the specificity rating.


reasoning: The paragraph outlines the company's internal cybersecurity program components, including governance, technical safeguards, and incident response, which falls under Risk Management Process. It is classified as Firm-Specific because it identifies specific roles (AGM's CISO and AHL's CISO) that are unique to the organization's structure.


reasoning: The paragraph discusses the potential business and financial impact of cybersecurity risks and includes a standalone materiality conclusion regarding past incidents, which aligns with the Strategy Integration category.


reasoning: The paragraph describes the company's internal incident response and risk management processes, specifically naming their internal 'Agility Plan' and 'Crisis Management Team' (CMT), which qualifies it as Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity processes, including incident response, technical safeguards, and risk management, without referencing any specific tools, frameworks, or unique identifiers.


reasoning: The paragraph focuses on identifying specific management roles (CISO, CIO, CDO) and their qualifications, making it a clear Management Role disclosure. It contains multiple quantified facts regarding years of experience, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses primarily on the Board of Directors and the Audit Committee's oversight responsibilities regarding cybersecurity risks. It contains no specific facts, named cybersecurity roles, or unique programs, relying entirely on generic governance terminology.


reasoning: The paragraph describes the company's internal cybersecurity monitoring, incident response protocols, and engagement with external experts as part of its risk management framework. It is classified as Firm-Specific because it names a specific internal program, the 'Cybersecurity Incident Response Plan'.


reasoning: The paragraph describes the company's internal security controls, processes, and risk management activities, which falls squarely under Risk Management Process. It contains no specific dates, named tools, named firms, or unique identifiers, relying entirely on generic descriptions of common security practices.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity incidents for the fiscal year, which falls under Strategy Integration. It is Firm-Specific because it references a specific fiscal year-end date.


reasoning: The paragraph primarily focuses on the Board of Directors and the Risk Committee's oversight responsibilities regarding cybersecurity risk. While it mentions internal processes, the grammatical subject and primary focus is the governance structure.


reasoning: The paragraph discusses the company's general exposure to cybersecurity threats and explicitly concludes that these incidents have not had a material impact on the company's financial condition or business strategy, which aligns with the Strategy Integration category.


reasoning: The paragraph focuses on the qualifications and responsibilities of the Chief Technology Officer and the internal governance committee, placing it squarely in Management Role. It qualifies as Quantified-Verifiable because it contains multiple hard facts, including specific years of experience, named certifications, and named internal programs/committees.


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


reasoning: The paragraph describes the company's internal cybersecurity measures and risk management processes. It contains no specific facts (dates, named tools, named firms, or specific roles) that would elevate it beyond generic boilerplate.


reasoning: The paragraph focuses primarily on identifying specific management roles (CISO, CIO, CTO) and their qualifications, which aligns with the Management Role category. It qualifies as Quantified-Verifiable because it provides multiple specific years of experience for these named roles.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, policies, and frameworks, making it a clear example of Risk Management Process. It is Firm-Specific because it names specific internal policies and committees (e.g., Business Risk Committee, Cyber and Technology Risk Management Policy) rather than just generic frameworks.


reasoning: The paragraph focuses on the reporting structure of the cybersecurity program (Head of InfoSec reporting to the CFO) and the specific qualifications of the security team, which are key indicators for the Management Role category.


reasoning: The paragraph describes the internal risk management and information security program of the manager (USCF), including risk assessment and due diligence processes. While it mentions third-party oversight, this is presented as a component of the broader internal risk management program rather than the central topic.


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


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


reasoning: The paragraph consists entirely of definitions of cybersecurity terms and a cross-reference to the Risk Factors section, containing no substantive disclosure regarding the company's specific governance, management, or processes.


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


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management, including the implementation of an Information Security Program and a third-party risk management program. It contains no specific names, dates, or verifiable facts, making it generic boilerplate.


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


reasoning: The paragraph focuses on identifying the specific management personnel responsible for cybersecurity oversight and details their qualifications and experience. It qualifies as Quantified-Verifiable because it contains multiple specific dates, named firms, and quantified years of experience.


reasoning: While the paragraph mentions board oversight, the core of the disclosure focuses on the specific management role (Director of IT) responsible for the cybersecurity program and the reporting structure surrounding that role.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management and oversight without naming specific frameworks, roles, or unique programs. It relies entirely on boilerplate language regarding risk mitigation and oversight.


reasoning: The paragraph focuses on the roles, responsibilities, and specific professional qualifications of the CISO and CCO, making Management Role the primary category.


reasoning: The paragraph is primarily focused on the qualifications, background, and reporting responsibilities of the Chief Information Officer, which aligns with the Management Role category.


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


reasoning: The paragraph describes the company's internal cybersecurity risk management strategy, processes, and specific internal programs like the ICSIRP, which falls squarely under Risk Management Process.


reasoning: The paragraph primarily describes the company's internal processes for security programs, incident reporting, and escalation procedures across its subsidiaries. While it mentions various roles, the core subject matter is the operational framework for managing cybersecurity risk.


reasoning: The paragraph describes the company's internal incident response plan and testing procedures, which falls squarely under Risk Management Process. It contains no specific facts (dates, named firms, named tools, or unique identifiers), relying entirely on generic terminology like 'executive officers', 'senior management', and 'annual' testing.


reasoning: The paragraph describes the company's internal incident response plan, the specific roles of the CISO and CIO in executing that plan, and their engagement with external entities like the Department of Defense, which are core components of their risk management process.


reasoning: The paragraph primarily focuses on the Board's oversight responsibilities and the reporting structure of management to the Board, making Board Governance the most appropriate category. While it mentions management roles (CIO/CISO) and frameworks (NIST), these are presented in the context of the Board's oversight activities.