reasoning: The paragraph describes the company's own internal cybersecurity processes and program activities (threat identification, system monitoring, incident response plan, employee training), which fits the Risk Management Process category. Third-party experts are mentioned only as a component supporting internal exercises, not as the central topic of vendor oversight. The paragraph contains no firm-specific identifiers—no named frameworks, roles, dates, named tools, or specific numbers—and all described practices (penetration testing, firewalls, phishing awareness) are generic security measures commonly used across organizations.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's own internal cybersecurity risk management controls and processes (incident response plan, risk assessments, vulnerability management, encryption, network controls, etc.), making it about Risk Management Process. It contains no named frameworks, specific dates, dollar amounts, named tools, or any other fact that would differentiate this disclosure from any other company's standard security controls list.

provider: minimax

stage: benchmark


content_category: Management Role

reasoning: The paragraph's grammatical focus is on the CIO's qualifications, reporting structure, and support team (Director of IT Security, vCISO), making this primarily about a management role. The combination of three cybersecurity-specific titles and a specific number of years of experience provides multiple hard verifiable facts, meeting the Quantified-Verifiable threshold.


content_category: Board Governance

category_confidence: medium

specificity_confidence: medium

reasoning: The paragraph centers on the CyTOC committee and Board oversight of cybersecurity risks, with the committee as the grammatical subject of multiple sentences describing briefing cadences and oversight activities. While management (CISO) is mentioned, it is in the context of reporting TO the board committee, not as the primary focus. The paragraph contains no specific dates, dollar amounts, named third-party firms, or named tools/products—just boilerplate language about regular updates, annual reporting, and periodic briefings that could appear in any company's disclosure.


reasoning: The paragraph describes Fortress's own cybersecurity assessment processes (third-party reviews, penetration testing, vendor assessments), making it a Risk Management Process disclosure. The specificity is Firm-Specific due to the named company organizational units (Fortress IT Management, infrastructure technology team), which are specific to this company's structure even though no named third-party firms, dates, or amounts are disclosed.


reasoning: Although the paragraph focuses on third-party risk, it describes the company's own internal program and processes for managing vendor risks rather than requirements imposed on vendors or vendor-specific oversight activities. The five-stage evaluation framework (planning, due diligence, contracting/onboarding, ongoing monitoring, termination/off-boarding) describes the company's internal risk management methodology, making Risk Management Process the appropriate category.


content_category: None/Other

reasoning: This paragraph is a general company description stating the company's business focus (pre-clinical biopharmaceutical company developing drug delivery systems). It contains no cybersecurity content whatsoever and does not address board oversight, management roles, risk processes, vendor risk, incidents, or financial/strategic cybersecurity considerations.


content_category: Strategy Integration

reasoning: This paragraph is a cross-reference to Risk Factors combined with a standard materiality disclaimer stating no cybersecurity threats have materially impaired operations or financial standing. While it references cybersecurity, it contains no incident narrative, no description of processes, and no specific details—only boilerplate language about the absence of material impact.


reasoning: This is a SPAC explicitly stating it has no business operations, no cybersecurity risk management program, and no formal processes for assessing cybersecurity risk. Per the tiebreaker rule, SPACs and shell companies explicitly stating they have no cybersecurity program or formal processes are classified as None/Other—the absence of a program is not a description of a program.


content_category: Incident Disclosure

reasoning: The paragraph describes an actual cybersecurity incident (unauthorized activity on IT systems) including what happened (unauthorized access), timing (Q4 fiscal 2025), response actions (activated incident response plan, containment measures, took systems offline), and scope of impact (order fulfillment temporarily disrupted, reduced sales volume, increased operational costs).


reasoning: The CISO is the grammatical subject throughout, describing what the CISO does (provides updates) and to whom, making this fundamentally about the CISO's reporting role rather than the board's oversight function. The presence of the CISO role and the named Technology Risk Management Committee provide firm-specific identification beyond generic governance language.


reasoning: The paragraph is primarily about the Board's oversight structure—specifically that the entire Board (not a named committee) oversees cybersecurity risk—with the Chief Risk Officer as the functional lead who reports directly to the Board. The Board is the grammatical subject of the core disclosure, making this Board Governance rather than Management Role. The specificity comes from naming the Chief Risk Officer and internal audit department as specific internal entities, which distinguishes this from generic boilerplate about board oversight.


reasoning: The paragraph's primary focus is on identifying and describing specific management roles (CISO, CTO, CIO) with their distinct cybersecurity responsibilities, rather than detailing internal processes. The CISO, CTO, and CIO are cybersecurity-specific titles with named oversight functions that distinguish this company's governance structure. While cybersecurity processes are mentioned, they serve as context for explaining what these roles oversee.


reasoning: The paragraph's grammatical subject is the Audit Committee, with board oversight of cybersecurity risk as the central topic; the CISO is mentioned only briefly as the presenter at committee meetings, making Board Governance the primary category over Management Role.


reasoning: This paragraph is a negative materiality statement (no incidents materially affected) with a cross-reference appended, which is a Strategy Integration disclosure per the tiebreakers. The year-end date (December 31, 2023) provides a firm-specific anchor, making this Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph focuses on individual qualifications, career history, and tenure of specific persons (senior IT consultant with 20+ years of Fortune 500 and life sciences experience), making Management Role the primary category. The specific duration, named company tier (Fortune 500), and industry sector are facts unique to this disclosure, elevating specificity to Firm-Specific.


reasoning: The paragraph's primary subject is the company's ERM program structure and oversight process, including committee composition and reporting lines—making it Risk Management Process. While Ms. Murray's board training credentials are mentioned, they serve as supporting detail about the ERM program rather than standing alone as board governance. The specificity exceeds Sector-Adapted because it names multiple specific roles, a named committee with unique composition, a named director with specific credentials, and identifiable training programs—none of which appear in standard boilerplate.


reasoning: The paragraph is classified as Board Governance because the board of directors is the grammatical subject approving the committee structure, and the reporting chain (Information Security Officer reports to the board) establishes board-level oversight of cybersecurity. While specific management roles (CIO, CTO, ISO) are named, they function as components of the board-approved governance structure rather than the primary focus.


reasoning: The paragraph describes the company's own internal cybersecurity risk assessment and management processes, with executive team members (CEO, CFO) as the grammatical subjects responsible for these functions. No cybersecurity-specific role (CISO, CTO, CIO) is named, no specific committee or team composition is identified, no dates or numbers appear, and the responsibilities described (budget approval, incident preparation, process approval, security reviews) are standard governance language applicable to any company.


reasoning: The paragraph describes the company's own internal cybersecurity risk management framework, including training, assessments, monitoring, and insurance—this is the company's internal processes, not vendor oversight. While third-party service providers are mentioned, they appear as external support to the company's program rather than as the central topic. No specific facts are present: no named frameworks (NIST, ISO), no specific dates, no named tools or products, no named third-party firms, no dollar amounts, and no specific headcounts or titles. All language is standard cybersecurity boilerplate applicable to any company's filing.


reasoning: This paragraph is a pure cross-reference to the Risk Factors section (Item 1A) containing no substantive cybersecurity disclosure. It merely cites two risk factor headings without describing any governance, processes, incidents, or strategy.


reasoning: The paragraph describes the company's own internal incident response process, including threat-level assessment and escalation procedures—this is a company's internal risk management function. No actual past incident is described, so Incident Disclosure does not apply. All named roles (CEO, CLO, EVP/Operations, CRO, CFO) are standard C-suite titles without cybersecurity-specificity, and 'incident response plans' and 'critical threat level' are generic descriptors with no named framework, specific dates, dollar amounts, or other hard-verifiable facts.


reasoning: The paragraph's grammatical subjects are the Audit Committee and its oversight role, making Board Governance the primary category. The mention of CISO (a cybersecurity-specific title) elevates the specificity to Firm-Specific, as Audit Committee oversight alone would be generic boilerplate.


reasoning: The paragraph describes internal cybersecurity team functions (policies, compliance, risk assessments, mitigation measures) rather than the qualifications or background of the named CIO/Security Officer, making it about the risk management process. Although a CIO title appears, no specific dates, dollar amounts, headcounts, named third-party firms, or named tools/products are present, and the mitigation measures described (network segmentation, detection/response, recovery) are generic security practices applicable to any company.


reasoning: The paragraph describes general management-level responsibilities for cybersecurity oversight (hiring, budgeting, incident preparation, process approval), but does not identify specific named roles (CISO, CTO, CIO) or individual qualifications. This is a description of internal processes and governance responsibilities rather than identification of a specific person or role.


reasoning: The paragraph's grammatical subject is the VP of Information Technology, describing their reporting responsibilities, coordination duties, and personal qualifications. While the Board is mentioned briefly as a recipient of reports, the paragraph's focus is on the management role and its qualifications—specifically the VP's 25+ years of experience in cybersecurity operations, which is a verifiable personal attribute. This last sentence is the key: it describes who the person IS, not what the cybersecurity program DOES.


reasoning: The paragraph describes the company's own internal security awareness training program and customer education efforts, which is a description of internal processes rather than board governance, management roles, or third-party oversight.


reasoning: The paragraph's grammatical subjects are 'our board of directors' and 'its Audit Committee,' with the content focused on the board's oversight role and briefing cadence for cybersecurity matters. While the paragraph mentions specific roles (SRC Director, CIO) and a committee (Audit Committee), these are standard governance structures, and the SRC Director is mentioned only as a reporting source to the board, not as a substantive description of the role itself. No unique frameworks, named programs, specific dates, dollar amounts, headcounts, named third-party firms, or named tools are present, making this generic boilerplate about board oversight.


reasoning: The paragraph describes internal security training infrastructure and integration processes, which falls under Risk Management Process. However, it contains no named frameworks, specific dates, named tools/products, dollar amounts, or other identifying details—only generic references to a Learning Management System and acquired companies. This could describe virtually any company's security training program.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach, including software programs (antivirus, endpoint detection, MFA) and company-wide policies. While it mentions a cross-departmental approach, the board and SVP are brief participants rather than the grammatical subject, making 'Risk Management Process' the appropriate category. The specific terms cited (antivirus protection, endpoint threat detection, MFA, incident response policies, employee handbook) are all generic security measures and standard policy types found in any company's disclosure, with no named frameworks, products, tools, or verifiable quantities.


reasoning: The paragraph primarily describes the CIO's roles (quarterly updates, annual briefings, chairing the Working Council), the CISO's responsibilities, and the CIO's biographical details (tenure since 2023, 30+ years experience, educational background) — making management role the dominant subject. While board oversight is mentioned briefly in the opening sentence, the bulk of the paragraph focuses on named management functions and personnel credentials, which aligns with the tiebreaker: management mentioned briefly + board oversight as main focus → Board Governance.


reasoning: This paragraph lists items the board oversees regarding cybersecurity (personnel capabilities, strategy, priorities, objectives, and resource allocation), which is characteristic of Board Governance disclosures. However, the paragraph uses generic language with no named committees, specific roles, dates, or other identifying details, making it standard boilerplate that could appear in any company's Item 1C disclosure.


reasoning: Management is the grammatical subject ('Management is responsible for...'), and the paragraph describes management's responsibilities (implementing policies, reporting to the Board) rather than describing the board's own oversight activities. The reporting cadence to the board is mentioned as part of management's obligation, not as a description of board governance practice.


reasoning: The paragraph is a forward-looking disclaimer and materiality statement (stating past incidents have not materially affected the company, insurance may not fully cover future incidents) with a cross-reference to Risk Factors. While past incidents are mentioned, no incident details are provided—only the materiality conclusion—so this is Strategy Integration rather than Incident Disclosure.


reasoning: The grammatical subject is the Information Security committee, which performs oversight functions (quarterly threat reviews, periodic strategy approval), characteristic of Board Governance. The paragraph describes committee oversight of the cybersecurity program rather than individual management qualifications or processes the function executes.


reasoning: The paragraph's grammatical subject is the Board of Directors, which is directly discussed in its oversight role over cybersecurity risk. The specificity is Generic Boilerplate because it contains only standard corporate governance language—'Board of Directors,' 'Audit Committee,' and 'executive officers'—with no named frameworks, specific dates, dollar amounts, named third-party firms, or other uniquely identifiable company details.


reasoning: The paragraph focuses on the CSO's role and the Executive Committee's evaluation of the CSO's expertise and qualifications, making Management Role the primary category. The mention of CSO (a cybersecurity-specific title not on the generic C-suite exclusion list) provides the firm-specific fact, distinguishing this from generic boilerplate.


reasoning: The paragraph describes the company's internal incident response plan and escalation protocols for reporting cybersecurity incidents to the Audit Committee and Board—clearly falling under risk management processes. However, it contains no named individuals, specific dates, dollar amounts, named third-party firms, or other uniquely identifiable facts; the phrase 'the Company's incident response plan' is a generic self-reference that does not constitute a specific fact. This is standard boilerplate that could appear in any company's disclosure.


reasoning: The paragraph's main purpose is a materiality conclusion — stating that no identified cybersecurity threats have materially affected the Company — with a forward-looking disclaimer, which classifies it as Strategy Integration rather than Incident Disclosure. No hard verifiable facts (dates, dollar amounts, named firms/products) appear; the language is entirely generic boilerplate applicable to any public company.


reasoning: Although the paragraph opens with a reference to risk assessment processes, the grammatical subject shifts to the CIO and their qualifications (15 years experience) and reporting line. Per the person-vs-function test, the paragraph is fundamentally about WHO manages cybersecurity (the CIO) and their credentials, making Management Role the primary category. The CIO's 15 years of experience and direct reporting structure to leadership are specific facts about the person holding this role.


reasoning: The paragraph describes how the company integrates third-party partners into its own cybersecurity risk management infrastructure and processes. While vendors are mentioned, they are described as a component supporting the company's internal program, not as the central topic of vendor oversight or due diligence. The specificity is Generic Boilerplate because no named third-party firms, specific tools, named frameworks, dates, or other verifiable facts appear—just a list of standard cybersecurity services.


reasoning: The paragraph's primary grammatical subject is the CFO directing cybersecurity programs, making Management Role the appropriate category. The governance structure (Audit Committee updates, no dedicated cybersecurity committee) is secondary context. The statement about no material incidents is a boilerplate materiality conclusion, not an incident narrative, and the appended Risk Factors cross-reference does not change the classification per the tiebreaker rules.


reasoning: The paragraph focuses on identifying specific management roles (chief risk officer and interim chief information officer) and describing their qualifications and experience levels, which is the hallmark of Management Role classification. The years of experience (over 15 years and over 30 years) for two named individuals provide two distinct hard facts that meet the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal cybersecurity risk management practices, including maintaining specialized teams and using third-party experts for validation—internal processes remain the central topic, with third-party experts functioning as a tool within that program rather than as independently managed vendors. No specific framework, named standard, named firm, or unique identifier appears; penetration tests and security posture assessments are common practices applicable across organizations.


reasoning: The paragraph focuses on the individuals serving in specific cybersecurity-related roles (CSO and CIPO) and describes their qualifications and experience, which is characteristic of Management Role classification. While it mentions that these roles assess and manage cybersecurity risks, the primary thrust is establishing who these people are and their credentials rather than describing internal processes. The specificity is Firm-Specific because it names cybersecurity-specific roles (CSO, CIPO) which are on the IS list, and includes a specific quantified metric (over 25 years of experience), though this is an attribute of the people rather than an external verifiable fact like a date or dollar amount.


reasoning: The paragraph's primary subject is the Audit and Examination Committee (a board committee) overseeing cybersecurity risk management, making Board Governance the appropriate category. The specificity is Generic Boilerplate because the named committee, ISO role, and quarterly reporting cadence are standard governance elements without any hard verifiable facts like specific dates, dollar amounts, named third-party firms, or named tools/products.


reasoning: While the paragraph opens with board oversight, the grammatical subject and substantive content focus on the CISO's identification, qualifications (15+ years experience), designation as IS Program Coordinator, and the incident response organizational structure under CISO direction — making Management Role the primary category per tiebreaker rules.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes—specifically the annual review of governance documents and maintenance of a three-year strategic plan—making 'Risk Management Process' the appropriate category. While the Audit & Risk Committee appears, the grammatical subject is the Information Security team and its processes, not the board's own oversight activities. The CISO is mentioned in the context of approving plans and providing reports, not personal qualifications or background.


reasoning: The paragraph describes board-level cybersecurity oversight and reporting structures, with the board/committee as the grammatical subject of the governance mechanism. While it references the COO and Audit Committee, both are generic roles found at every public company, and no cybersecurity-specific titles or named programs appear. The vague reference to 'beginning in 2024' does not constitute a hard verifiable fact.


reasoning: The paragraph centers on the CISO as the grammatical subject, detailing their responsibilities, reporting line to the CIO, and qualifications—placing primary emphasis on the management role rather than board oversight. The two or more hard verifiable facts (specific years of experience + named certifications) elevate this to Quantified-Verifiable.


reasoning: The CISO and CIO are the grammatical subjects performing the described actions (informing, providing briefings), making Management Role the appropriate category over Board Governance. The specificity is Generic Boilerplate because it contains no named frameworks, specific dates, named tools/products, named third-party firms, specific numbers, or any other fact unique to this company's disclosure—all elements are generic organizational references applicable to any financial institution.


reasoning: The paragraph describes the company's internal risk management process that includes vendor risk considerations as a component, not as the central focus with specific oversight mechanisms. This qualifies as Risk Management Process per the tiebreaker rule for internal processes mentioning vendors. The paragraph contains no specific details—no named vendors, frameworks, dates, or firm-specific facts—making it indistinguishable from any company's boilerplate disclosure.


content_category: Third-Party Risk

reasoning: The paragraph is exclusively focused on third-party service provider oversight—vendor questionnaires, due diligence, audit report collection, and contractual security terms—with no mention of the company's own internal cybersecurity processes. This centered focus on vendor oversight, rather than internal processes that merely include vendors as one component, warrants Third-Party Risk. It contains no named standards, frameworks, or any other specific fact that would elevate it from generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes (risk assessments, security measures, monitoring, incident escalation) as its central topic. While it mentions Mr. Blattner as the board member who receives incident reports, this is incidental to the description of the company's own processes rather than the board's governance role. No specific dates, dollar amounts, named third-party firms, named tools, or framework standards are present.


reasoning: The paragraph describes the Partnership's own approach to risk management that incorporates third-party assistance (audits, penetration testing, threat assessments), making it about internal processes rather than vendor oversight. Per the tiebreaker rule, internal processes mentioning vendors as a component map to Risk Management Process. No specific facts are present: external experts are unnamed, practices are common (penetration testing, threat assessments are listed in the NOT facts), and cadences are vague ('regular').


reasoning: This paragraph describes an actual cybersecurity incident—a phishing attack resulting in a fraudulent payment—with two specific dates (April 28 and June 29, 2023) and a specific dollar amount ($54,300), clearly meeting the threshold for Incident Disclosure as the central topic.


reasoning: Paragraph describes internal audit processes for the company's own information security program, which falls under risk management processes. However, the language is completely generic with no named entities, specific dates, numbers, or other identifying details — 'Internal Audit provider(s)' is vague and could apply to any company.


reasoning: The paragraph's grammatical subject is the FE Board and its committees, describing their oversight structure and responsibilities for cybersecurity risk management. While the CISO is mentioned, it is in the context of reporting TO the board, not as the primary subject. The paragraph contains firm-specific details including the named Operations and Safety Oversight Committee (beyond generic Audit Committee), a specific CISO role, and the timeframe 'since 2022' when oversight authority was delegated.


reasoning: The board of directors is the grammatical subject and the paragraph describes their oversight role, making Board Governance the appropriate category. The paragraph contains no specific facts—no named committees, roles, dates, frameworks, or unique identifiers—only generic boilerplate language about board involvement in cybersecurity oversight and an aspirational statement that they are 'in the process of formalizing' governance structures.


reasoning: The paragraph focuses on the company's general approach to cybersecurity risk management, including detection efforts and the implementation of a risk assessment process and incident response plan. It does not describe any actual incident, nor does it identify specific management roles or discuss board governance. The cross-reference to Item 1A is appended to substantive disclosure rather than standing alone.


reasoning: The paragraph describes committee governance structure (Engineering Risk Steering Group) and its oversight responsibilities, with the CISO mentioned as the committee chair and as a member of another committee—these named committee structures are unique to this firm's governance architecture.


reasoning: The paragraph describes an actual cybersecurity incident—an email spoofing attempt—detailing what happened (scammer impersonating a subsidiary), when it occurred (May 2014), how it was detected (by the Company and customer), and the outcome (no money transferred). This constitutes a real incident narrative, fitting the Incident Disclosure category.


reasoning: The paragraph describes the company's internal risk identification and assessment processes, detailing the various methods used (monitoring threat environment, automated tools, audits, vulnerability assessments, tabletop exercises). While two roles are mentioned, the focus is on the processes they employ rather than the individuals themselves. No specific frameworks are named, no unique identifiers for internal programs appear, no third-party firms or products are named, and no specific dates or numbers are provided—only generic descriptions of common security practices that could appear in any company's filing.


reasoning: This paragraph describes the company's own internal cybersecurity processes (risk assessments to identify threats to systems, data, and infrastructure), which falls under Risk Management Process. The paragraph contains no specific facts—no named frameworks, dates, titles, tools, dollar amounts, or other identifying details—making it entirely generic boilerplate that could appear in any company's filing.


reasoning: The paragraph describes BNY Mellon's internal cybersecurity risk management processes, including the CISO-led Information Security Division's responsibilities for threat intelligence, incident response, and monitoring. While third parties are mentioned, they are described as assisting BNY Mellon's own processes rather than being the central topic. The paragraph qualifies as Firm-Specific because it references the CISO role (a cybersecurity-specific title), which meets the threshold for at least one specific fact.


reasoning: This paragraph is a pure cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure content—it merely tells readers to look elsewhere for information.


reasoning: This paragraph describes an actual cybersecurity incident—the Fortra GoAnywhere breach—including the exploit method (zero-day vulnerability), data scope (PHI and PII of customers' employees and third parties), and response actions (engaged outside experts, provided notifications to data owners and State Attorneys General). The named vendor, named product, and specific timeframe distinguish this as firm-specific rather than generic incident language.


reasoning: The paragraph describes the company's own internal cybersecurity processes—end-user training, layered defenses, monitoring, penetration testing, and policy reviews with third-party experts—but contains no named frameworks, tools, dates, dollar amounts, or other specifics unique to this company. No hard verifiable facts are present.


reasoning: This is a SPAC explicitly stating it has 'not adopted any cybersecurity risk management program or formal processes for assessing cybersecurity risk.' Per the tiebreaker rules, SPACs and shell companies that explicitly state they have no cybersecurity program or no formal processes are classified as None/Other regardless of incidental mentions of board oversight. The absence of a program is not a description of a program.


reasoning: The paragraph is a standalone materiality conclusion stating no known cybersecurity risks are likely to materially affect the company, combined with a boilerplate statement about the absence of material incidents—no actual incident is described. This falls under Strategy Integration per tiebreaker rules.


reasoning: Paragraph describes an actual cybersecurity incident with narrative details (date, attack type, scope, response actions), qualifying it as Incident Disclosure. The specific date establishes it as firm-specific rather than generic boilerplate.


reasoning: The CIO is the grammatical subject throughout the paragraph, with the 20+ years of cybersecurity experience serving as a distinguishing qualification that identifies this as a specific management role rather than generic process description. The paragraph focuses on who manages the cybersecurity program and their specific responsibilities, establishing both identity and duties.


reasoning: The paragraph's grammatical subject is the Audit Committee of the Board of Directors, which is charged with overseeing cybersecurity risk — this is Board Governance. The specificity reaches Firm-Specific because it names the CISO (a cybersecurity-specific role) and the specific Senior Vice President role, which identify unique personnel within this company's governance structure rather than generic boilerplate.


reasoning: This paragraph describes an actual cybersecurity incident at the company — including what happened (cyberattack, data exfiltration), when it occurred (Q3 2022), operational impact (sales delays, system outages), and response actions (containment, restoration, notifications, remediation). While it mentions financial costs and insurance, these are incidental to the incident narrative rather than the main focus. The one specific fact (September 2022 timeframe) is sufficient to elevate from Generic Boilerplate to Firm-Specific.


reasoning: This paragraph is solely a cross-reference to risk factor disclosures in Item 1A, containing no substantive cybersecurity disclosure about governance, management, processes, incidents, or strategy.


reasoning: The paragraph describes the company's incident management reporting process (internal risk management), with specific named roles mentioned as part of that process rather than as the focal identification of a cybersecurity-specific leadership role. The materiality disclaimer and risk factors cross-reference are pure boilerplate.


reasoning: This paragraph is a forward-looking disclaimer stating that no material cybersecurity incidents have occurred and warning about future uncertainty. It contains no substantive disclosure about any actual incident, governance, management, or processes — it's purely boilerplate risk language disclaiming future risk.


reasoning: The paragraph describes the company's own cybersecurity tools and monitoring infrastructure (SIEM, PAM, SOC), which constitutes internal risk management processes. While it mentions technology categories, it names no specific products, named third-party firms, named internal programs, or recognized standards (NIST, ISO, etc.), making it indistinguishable from any generic financial institution's security disclosure.


reasoning: This paragraph is a high-level introductory framing statement describing Logitech's two-part security capability structure (cybersecurity + product security) without disclosing any substantive processes, programs, or specifics. It lacks details about actual risk management activities, frameworks, roles, or any quantifiable information that would constitute a meaningful cybersecurity disclosure under Item 1C.


reasoning: This paragraph describes an actual cybersecurity incident—a business email compromise resulting in theft of 26 BTC worth ~$560,000—detailing the attack method (email impersonation), scope (specific cryptocurrency amount and value), and response actions (engaging law enforcement). Multiple hard verifiable facts (specific BTC quantity, specific dollar amount) support Quantified-Verifiable rating.


reasoning: The paragraph focuses on Board and Audit Committee oversight of cybersecurity risk management, with the CFO reporting on a quarterly basis — all standard governance structures with no named frameworks, specific dates, or firm-specific details that would distinguish this disclosure.


reasoning: The paragraph explicitly states the company has no business operations, no cybersecurity risk management program, and no formal processes for assessing cybersecurity risk—this is a SPAC explicitly disclaiming the existence of a cybersecurity program, which falls under None/Other per classification rules. The brief mention of board oversight is incidental and qualified with 'if there is any,' not a substantive description of governance.


reasoning: This is a SPAC explicitly stating it has no cybersecurity risk management program or formal processes. Per calibration guidance, the absence of a program is not a description of a program—it is a declaration of its nonexistence. Although board oversight and materiality conclusions are mentioned, these are incidental to the primary disclosure that no cybersecurity program exists.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and NIST framework adoption without mentioning board governance, named executives, incidents, or third-party vendors. The NIST naming elevates it from Generic Boilerplate to Sector-Adapted, but no firm-specific facts are present.


reasoning: The Audit Committee is the grammatical subject reviewing IT systems and evaluating the information security program, making this Board Governance. The content contains only generic references (Audit Committee, management, information security program) with no specific dates, named frameworks, named roles beyond the standard Audit Committee, or other differentiating facts that would set this disclosure apart from any other company's 10-K.


reasoning: This paragraph contains only forward-looking risk acknowledgment language about cybersecurity threats and their potential material impact. It does not describe any actual incidents, governance processes, management roles, or firm-specific cybersecurity programs. The reference to 'service providers (including the transfer agent)' is generic boilerplate that could appear in any company's filing.


reasoning: This paragraph primarily describes an actual cybersecurity incident (the MOVEit incident) including the investigation conducted with PBI, the scope of affected data (2.5-2.7 million individuals, social security numbers), and the response actions. While there is a concluding materiality statement, the substantive content is the incident description itself, not a standalone financial/materiality assessment.


reasoning: The paragraph describes an actual cybersecurity incident in December 2022 involving unauthorized data extraction from the company's IT system, including personal data of employees, and details response actions (investigation, containment, engaging third-party experts). This fits 'Incident Disclosure' as it narrates what happened in a real event, response actions, and affected data scope. The paragraph contains one hard verifiable fact (December 2022 date), making it Firm-Specific but not Quantified-Verifiable (third-party experts are unnamed, no dollar amounts, percentages, or named firms/tools).


reasoning: The Board is the grammatical subject of the sentence, describing its oversight function and delegation of cybersecurity oversight to the CEO and CFO—this is standard board governance language. No specific facts are present: 'Board,' 'CEO,' and 'CFO' are all generic organizational terms that apply to any company, and 'cybersecurity risk management program' and 'incident response plans' are standard generic program references.


reasoning: The paragraph contains a standalone materiality conclusion (no material incidents to date) combined with a cross-reference to Risk Factors. Per the tiebreaker rules, a brief mention of a past negative conclusion with no incident narrative = Strategy Integration, not Incident Disclosure. The content contains no company-specific facts, dates, named frameworks, or unique identifiers.


reasoning: The paragraph describes the company's own internal processes for managing cybersecurity risks (risk assessment, incident detection, vulnerability management, disaster recovery, etc.) as the grammatical subject, making Risk Management Process the appropriate category. While third-party providers are mentioned, they appear as a component of the company's own oversight process rather than as the central topic. The paragraph contains no specific facts—no named frameworks, tools, dates, numbers, or cybersecurity-specific roles—that would elevate it beyond generic boilerplate describing standard security practices.


reasoning: The paragraph describes internal incident management processes and disclosure protocols—specifically the 36-hour materiality reporting requirement and the CMT's role in developing disclosure determinations. These are firm-specific operational details about the company's own risk management processes rather than descriptions of a real incident or board governance structures.


reasoning: The paragraph describes the company's own internal cybersecurity processes—independent assessments, a 5-year planning horizon, defense mechanisms (training, vulnerability management, MFA, tabletop exercises), and vendor assessment procedures—all as components of the company's own risk management program. While third-party cloud suppliers are mentioned, they are discussed as entities the company assesses before engagement, not as parties on whom security requirements are imposed. The paragraph lacks any named third-party firms, specific dates, dollar amounts, percentages, or named products/tools that would elevate specificity beyond generic boilerplate.


reasoning: This paragraph contains a standalone materiality conclusion ('have not been materially affected') without any description of actual incidents, specific dates, or firm-specific details. The cross-reference to Risk Factors is incidental to the main point of stating no material business impact.


reasoning: The paragraph describes the cybersecurity reporting structure flowing from management (CFO, IT consultant) to the audit committee and then to the full Board—placing the board/committee as the central grammatical subjects and governance overseers. However, no specific facts are present: CFO is a generic C-suite role (not cybersecurity-specific), IT consultant is unnamed, and 'periodic' and 'regular' are vague cadences without actual dates.


reasoning: This paragraph describes an actual email spoofing incident with specific dates (April 9, 11, and 12, 2024), a specific dollar amount ($30,825), and detailed narrative of what happened, scope, and response actions—including internal reporting, bank contact, law enforcement involvement, and specific corrective measures adopted.


reasoning: The paragraph describes the organizational structure and delegation of cybersecurity oversight responsibilities between the General Partner, Investment Manager, and Board of Directors. While it mentions the Board has 'certain oversight rights,' the primary focus is on identifying the management structure and how the Sponsor manages cybersecurity operations, making Management Role the appropriate category. The paragraph contains only organizational identifiers and no hard verifiable facts, specific dates, named frameworks, or cybersecurity-specific processes or roles (no CISO/CIO, no specific team composition, no tools), qualifying it as Generic Boilerplate.


reasoning: The paragraph primarily describes the cybersecurity leadership structure and individual qualifications, including the CISO's 15 years of experience and CISSP certification, the named Risk and Technology Committee and Enterprise Risk Committee, and the specific composition of the Enterprise Risk Committee. While it mentions board oversight and risk processes, the dominant focus is on the management roles and their qualifications.


reasoning: The paragraph describes a specific cybersecurity incident (MOVEit) with concrete details including a filing date (June 22, 2023), named vendor (PBI), named tool (MOVEit), approximate affected count (2.5-2.7 million), and data types exposed (social security numbers). It also describes response actions (investigation launch). While it ends with a materiality conclusion, the primary focus is describing what happened.


reasoning: This paragraph is a pure cross-reference to the Risk Factors section, containing no substantive cybersecurity disclosure. Per the classification rules, cross-references with no materiality conclusion or independent disclosure fall under None/Other.


reasoning: The paragraph is anchored on the CIO's qualifications and organizational authority over the cybersecurity program, making Management Role the primary category. The specific years of experience (12 years, 7 years) constitute two hard verifiable facts, elevating this to Quantified-Verifiable specificity.


reasoning: This paragraph consists entirely of hypothetical risk factor language describing potential future cyber threats and their general business impacts (reputational damage, regulatory fines, service disruption). It contains no description of actual incidents, no discussion of the company's own processes, governance, or specific management roles, and no materiality conclusions. It is a standard risk factor enumeration with no substantive disclosure about the company's cybersecurity program.


reasoning: The paragraph is a forward-looking risk acknowledgment and disclaimer stating the company lacks resources for cybersecurity protection, with no description of actual board governance processes, management roles, or incidents. The conditional language ('in the event of') describes a hypothetical reporting structure rather than an actual practiced process, and the closing statement about no prior incidents is merely a temporal reference with no specifics.


reasoning: The paragraph's grammatical subject is the Vice President of Information Technology, who is identified as the central point person for cybersecurity monitoring and reporting—this aligns with Management Role. However, the paragraph contains no firm-specific facts: no cybersecurity-specific titles beyond the generic VP of IT, no named frameworks, no named tools or third-party firms, no specific dates, dollar amounts, or headcounts. The description of the IT landscape as 'not large or complex' and having a 'limited data footprint' are qualitative descriptors applicable to many small companies, making this Generic Boilerplate.


reasoning: The paragraph describes internal security training processes but contains no specific identifiable details—no named third-party firms (only 'information technology partner'), no specific dates, no named programs, and no unique organizational facts. The language is standard boilerplate that could appear in any company's disclosure.


reasoning: The paragraph's grammatical subject is the Board/Audit Committee, focusing on their oversight responsibilities, reporting cadences, and committee composition—all hallmarks of board governance. While it mentions 'quarterly' briefings and the CIO, these are generic governance elements without specific dates, named frameworks, tools, or firm-specific identifiers that would elevate the specificity.


reasoning: The paragraph describes the company's internal technology team's ongoing processes for managing cybersecurity maturity, setting objectives, and implementing improvements—clearly internal risk management activities. While a specific role (Director of Information Technology) is mentioned, the focus is on what the team does (defining work plans, setting objectives, implementing investments), not on the person's biographical details, so Management Role does not apply.


reasoning: This paragraph is primarily a forward-looking materiality disclaimer ('could potentially have a material adverse effect on our business strategy, results of operations, and financial condition') with only a brief, non-specific acknowledgment of past threat encounters and procedural adjustments. No actual incident is described with any detail—no dates, scope, affected systems, or response actions—which precludes Incident Disclosure. The language is entirely generic boilerplate that could appear in any company's cybersecurity disclosure.


reasoning: The paragraph's primary focus is the Board's delegation of cybersecurity oversight to the Audit and Compliance Committee and the management reporting structure to that committee, with governance explicitly named as the sub-topic. While the second section touches on risk management processes, the main subject is board-level oversight and reporting lines.


reasoning: The paragraph's grammatical subjects are the CISO and Cybersecurity team, focusing on the CISO's qualifications (20 years experience, certifications), reporting structure, and oversight responsibilities. While processes like monitoring and vulnerability scanning appear, they are subordinate to describing the management role rather than constituting the primary topic.


reasoning: The paragraph's primary substance is a standalone materiality conclusion ('the Bank has not experienced any S1-Critical/Material incidents') rather than incident disclosure, governance description, or process explanation. The regulatory context and SEC rule discussion serve as framing for this conclusion. Per tiebreaker rules, a materiality conclusion without an incident narrative qualifies as Strategy Integration.


reasoning: The paragraph's grammatical subject is the Board's oversight function, with governance language (considers, delegated, oversees) framing the entire disclosure; the CTO and VPCS are introduced within that governance context rather than as the primary subject.


reasoning: The paragraph describes the audit committee's oversight activities and reporting structure for cybersecurity risks, making Board Governance the applicable category. While the paragraph mentions 'AGM's CSO or CISO,' this appears incidentally as a report provider rather than as a substantive description of a management role's qualifications or function—the paragraph's focus remains on board committee oversight activities, not the person delivering reports.


reasoning: The paragraph's grammatical subjects are the ISO and Information Security team, focusing on management role identification, responsibilities, and reporting structure; the cybersecurity-specific title (ISO) elevates this beyond generic organizational boilerplate.


reasoning: The paragraph centers on identifying specific management roles (Information Security Manager reporting to CIO) and their qualifications/experience, making Management Role the primary category. While it contains elements of risk management process (incident response team, GRC platform, third-party MDR), these are supporting context for describing who manages cybersecurity rather than standalone process descriptions.


reasoning: The paragraph describes the company's internal approach to integrating cybersecurity within enterprise risk management—a process topic with no grammatical reference to any board, committee, or named management role. It contains no firm-specific details, dates, dollar amounts, named frameworks, tools, or third parties.


reasoning: The grammatical subject is the CTO, and the paragraph focuses on the person's qualifications (25 years of experience), role identification, and reporting line (to CEO). While the Board is mentioned, it serves only as the recipient of briefings rather than the subject of governance oversight.


reasoning: The paragraph describes the function of a security team and its responsibilities (risk assessment processes, security controls, incident response) rather than identifying specific individuals or their qualifications, placing it squarely in Risk Management Process. The content contains no named entities, specific dates, unique identifiers, named frameworks, or any other fact from the IS list—it's entirely generic security-team boilerplate that could appear in any company's disclosure.


reasoning: The paragraph describes the company's internal cybersecurity policies, processes, and internal controls aligned with security frameworks—the substance is about the company's own risk management activities, making Risk Management Process the primary category. While the Secure Controls Framework, NIST, and ISO are named, the description contains no firm-specific details (no dates, numbers, named tools, or unique implementation facts) and consists of generic boilerplate language about maintaining IT capacity and security that could apply to many organizations.


reasoning: The paragraph discusses cyber risk insurance coverage and contains a forward-looking disclaimer about coverage adequacy, with no description of any actual incident or event. Per the category tiebreakers, paragraphs discussing insurance or financial implications without incident narrative are classified as Strategy Integration. The language is standard boilerplate that could appear in any company's filing—no specific dates, dollar amounts, named insurers, or other identifying details are present.


reasoning: The paragraph's grammatical subject is the VP of IT/Information Security Officer, and the majority of content focuses on the person's responsibilities, qualifications (24 years of experience, 2 years in role), and the management structure they oversee. While the paragraph mentions committee composition and team details, these support the characterization of the management role rather than standing as independent process descriptions.


reasoning: The paragraph describes the company's own IT Security Policy and its components (authentication, employee training, logging/monitoring, encryption, vulnerability scanning, phishing simulations, and external providers as one component). This is the company's internal security program, not vendor oversight as a standalone topic, not incident disclosure, and not board or management role identification.


reasoning: The paragraph centers on the company's OWN internal risk management assessment process (enterprise information security risk management assessment) as the grammatical subject, with the CISO mentioned as the overseer of that process. The Audit Committee briefings are a secondary element. The presence of the CISO title, a cybersecurity-specific role, elevates this beyond generic boilerplate.


reasoning: The paragraph's grammatical subject is the Board's oversight structure — specifically how the risk committee oversees cybersecurity risk with support from the CISO and CRO. The CISO and CRO are mentioned as supporting roles within the governance framework, not as persons being described by their qualifications or background. This is Board Governance, not Management Role, because the board/risk committee is the primary actor being described.


reasoning: The paragraph describes the company's own internal incident response plan and its generic processes (triage, assess severity, escalate, contain, investigate, remediate), which is the core of Risk Management Process. No specific facts are present—no named programs, dates, dollar amounts, headcounts, named tools, or third-party firms. The language ('triage,' 'escalate,' 'contain,' 'remediate') describes standard incident response practices that could appear in any company's disclosure, making this Generic Boilerplate.


reasoning: The paragraph's grammatical subject is the board of directors and its oversight role, describing the governance structure for cybersecurity. While the board is described as not directly overseeing, the paragraph explains how oversight authority is structured and delegated, which constitutes board governance content. The paragraph contains firm-specific identifiers (named CEO Mr. Tao Guolin, named Information Security Committee, specific PRC subsidiary) that distinguish it from generic boilerplate.


reasoning: The paragraph's grammatical subject is the Board, describing its active involvement in cybersecurity risk oversight. While the paragraph transitions to describe the company's cybersecurity approach, the opening frames this as board-level governance. The specificity is Sector-Adapted because it names recognized frameworks (ISO and NIST) but contains no firm-specific facts—no named roles, specific dates, numbers, or unique identifiers beyond the standard naming of these industry frameworks.


reasoning: This paragraph describes an actual cybersecurity incident (business email compromise leading to BTC theft): it includes a specific date range, named threat actor, specific cryptocurrency quantity (26 BTC), dollar amount ($560,000), and documented response actions (engagement with US Federal law enforcement). The narrative covers what happened, scope, and outcome, which are hallmarks of incident disclosure.


reasoning: The CIO is the grammatical subject throughout, with substantial space devoted to their professional credentials and background. While the paragraph mentions the cybersecurity program and incident response plan, these are incidental to establishing the management role's qualifications rather than describing internal processes in detail.


reasoning: The paragraph describes management's supervision of internal cybersecurity risk management processes (prevention, detection, mitigation, remediation) without referencing any specific incidents, named roles, frameworks, or unique firm details. It contains only generic references ('internal security personnel,' 'external consultants,' 'security tools') that lack the specificity needed to distinguish this company's practices. No named third-party firms, tools, dates, or quantified information appear.


reasoning: The paragraph describes what management as a function does (oversees assessment and management of threats, will notify the board of incidents) rather than identifying a specific person or their qualifications, so Management Role does not apply; instead, it describes internal processes for cyber risk oversight, making it Risk Management Process. The content contains only generic references ('management,' 'board of directors') with no named frameworks, specific dates, dollar amounts, named third-party firms, or other firm-specific facts, resulting in Generic Boilerplate. The trailing 'Public Offering.' appears to be a misplaced section header fragment.


reasoning: The paragraph's substantive content focuses on the qualifications, career history, and credentials of identified individuals (CIO and Senior Director of Information Security), including specific certifications and years of experience. This clearly meets the Management Role classification, even though the opening sentences briefly describe the program's reporting structure.


reasoning: This paragraph is a standalone materiality conclusion (cybersecurity threats have not/materially affected business strategy, financial condition, or results of operations), which is the defining feature of Strategy Integration. The brief mention of investment in cybersecurity is incidental and not the main point. For specificity, there are zero specific facts—no dates, dollar amounts, named entities, or firm-unique details—making this pure boilerplate language.


reasoning: The paragraph centers on the CISO's reporting function and escalation procedures, making Management Role the primary category despite board oversight being mentioned. While the paragraph names the CISO and Compliance Committee (specific facts), the overall content describes standard corporate governance reporting structures without unique firm-specific details—no named programs, specific dates, dollar amounts, headcounts, or named tools.


reasoning: The paragraph's grammatical subject is the Board/Audit Committee providing cybersecurity oversight, making Board Governance the primary category. The inclusion of the CISO and CTO as cybersecurity-specific roles (which appear on the ✓ IS list) elevates this beyond generic boilerplate, despite the Audit Committee being a standard committee name excluded from the IS list.


reasoning: The paragraph describes an actual cybersecurity incident—the May 2020 ransomware attack—including what happened (data removal by cybercriminal), the scope (subset of data from self-hosted environment), and resulting legal consequences, making this an Incident Disclosure.


reasoning: The paragraph's grammatical subject is the cybersecurity risk assessment and management processes, not the IT Lead personally—the IT Lead is described as implementing/maintaining these processes rather than as a standalone subject. The qualifications mentioned are incidental details about who operates the process, not a biographical profile of the person. The specific years of experience (11 and 8) are verifiable firm-specific facts that distinguish this disclosure from boilerplate.


reasoning: The paragraph describes internal committee structure and processes (IT Steering Committee composition and functions, quarterly reporting cadence) rather than board-level oversight or individual qualifications, making Risk Management Process the appropriate category. The specific committee composition and reporting structure identify this company's unique governance arrangement.


reasoning: The paragraph's primary substantive content describes the CISO as a person—detailing the CISO's 20 years of experience, industry background, educational credentials (MBA), and specific professional certifications (CISSP, CISM, GLAW, GSEC), along with reporting lines. While the Risk Committee's oversight role is mentioned, the CISO's personal qualifications are the grammatical focus of the most detailed portion of the paragraph, satisfying the Person-vs-Function test for Management Role.


reasoning: This paragraph is a negative assurance statement (no material incidents) combined with forward-looking disclaimers and a cross-reference to Risk Factors — it contains no substantive disclosure about the company's actual cybersecurity program, governance, or processes. The mention of 'policies and procedures' is generic and not described.


reasoning: This paragraph describes an actual cybersecurity incident with specific details including the date identified (October 28, 2023), operational impact (ability to ship orders affected), response actions (facilities returned to normalized operations by mid-December 2023), and financial impact ($1.5 million in expenses). The incident narrative and response actions are the central focus, making this an Incident Disclosure rather than Strategy Integration.


reasoning: The paragraph describes the company's own cloud-first strategy and mentions vendor audits as a component of their approach, making this about internal risk management processes rather than standalone vendor oversight requirements. The mention of SSAE (a recognized auditing standard) elevates this to Sector-Adapted, but there are no firm-specific details such as named vendors, specific dates, or unique identifiers.


reasoning: The paragraph focuses on the company's internal incident response structure and processes (IRT composition, annual tabletop testing), not on the CISO as a person. While the CISO is mentioned, the emphasis is on what the IRT does and who participates, making this Risk Management Process. The paragraph contains firm-specific details: the CISO title, the specific departmental composition including company-unique ECDP department, and the annual testing cadence for the IRP.


reasoning: The paragraph describes the company's own internal monitoring processes for cybersecurity incidents. While third-party service providers are mentioned, they are referenced as a component of the company's internal monitoring scope, not as the central topic of vendor oversight or contractual security requirements. The language contains no named frameworks, tools, dates, or other identifying details—it's boilerplate that could appear in any company's disclosure.


reasoning: The paragraph is a standalone materiality conclusion stating that cybersecurity threats have not materially affected the company, which aligns with Strategy Integration classification. Although it references 'previous cybersecurity incidents,' the main purpose is the materiality/impact assessment, not describing what happened in any incident. The appended cross-reference to Risk Factors does not change the classification per the tiebreaker rules.


reasoning: This paragraph is a pure cross-reference to Risk Factors sections with no substantive disclosure about the company's own cybersecurity governance, processes, incidents, or financial materiality. It contains no firm-specific facts, no actual governance details, and no incident narrative.


reasoning: This paragraph is a business-context framing statement describing why IT systems and data privacy matter to the company's operations. It acknowledges regulatory exposure (HIPAA, CCPA) and lists types of data handled, but does not describe any actual governance processes, risk management activities, or strategic decisions. It reads as introductory background material rather than substantive disclosure of governance, processes, or incident information.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes and framework adoption (PCI DSS, CIS Controls), making Risk Management Process the appropriate category. It names specific recognized standards, which elevates it beyond generic boilerplate to Sector-Adapted specificity.


reasoning: Although the paragraph opens with board governance language (Audit Committee oversight, annual reporting cadence), the substantial majority of content focuses on the biographical and credential details of the named CISO and CIO — their educational backgrounds from named universities, CISSP certification, professional memberships, and coaching role at Carnegie Mellon. Per the person-vs-function test, this is about who the individuals are rather than what the cybersecurity function does, making Management Role the primary category. The 5-year threat assessment and named journals provide multiple hard verifiable facts.


reasoning: This paragraph is a standalone materiality conclusion stating no cybersecurity incidents materially affected the company in 2024, followed by standard disclaimers and a cross-reference to Risk Factors—no description of any incident, process, role, or governance structure.


reasoning: The paragraph describes the company's own internal incident response plan (IRP) and its design principles, including protection objectives, escalation procedures, and framework adoption—this is internal risk management process content. The Audit Committee mention is incidental (the escalation target), not the primary subject. Specificity is Sector-Adapted because it names the NIST Cybersecurity Framework; after filtering out the Audit Committee (explicitly NOT a specific fact per the ✗ NOT list) and 'incident response plan' (also NOT on the IS list), no firm-identifying facts remain.


reasoning: The paragraph's grammatical subjects are the management roles (CFO, General Counsel, Head of IT) and the primary focus is on identifying who holds these roles and their qualifications/experience levels, which fits Management Role per the person-vs-function test. The paragraph is Firm-Specific because it identifies the named Information Technology Steering Committee and provides specific experience durations (10 years, 30 years) that are unique to this company's disclosure.


reasoning: The paragraph describes the company's own internal risk management and mitigation measures (policies, incident response plan, vulnerability management, encryption, network security controls, etc.), making Risk Management Process the appropriate category. No specific frameworks are named (only 'security standards/certifications' generically), no named tools/products, no dates, no dollar amounts, no headcounts, and no named third-party firms — the paragraph is a standard inventory of common cybersecurity practices applicable to any company.


reasoning: The grammatical subject of the first three sentences is the CISO and SVP of IT, with emphasis on their specific roles, tenure, and qualifications. While incident response and materiality processes are mentioned, they are framed as part of these individuals' accountability rather than as standalone internal processes. The final sentence is a generic materiality conclusion with no incident narrative.


reasoning: The paragraph describes the company's own internal cybersecurity processes including firewall monitoring, patch management, internal cloud infrastructure, and backup procedures. There is no mention of board oversight, named management roles, actual incidents, or business/financial impact. The controls described are generic security practices that could appear in any company's disclosure.


reasoning: The paragraph describes the company's own internal processes for managing third-party risk (VP of IT oversight, SOC-1 review, access limitations), making it Risk Management Process rather than Third-Party Risk, which applies when requirements are imposed ON vendors. The presence of a named cybersecurity-specific role (VP of Information Technology) and named SOC-1 audit reports provides firm-specific detail beyond generic boilerplate.


reasoning: This paragraph describes a specific cybersecurity incident involving stolen BTC, forensic investigation findings, insurance claims, control modifications, and includes a specific dollar amount ($560,000) and specific time period (Q2 2023), meeting the threshold for Quantified-Verifiable. The narrative describes what happened (theft of BTC), the response (forensic analysis, payment, control modifications), and the scope (impact to Sphere 3D).


reasoning: The paragraph describes Visa's internal processes for managing cybersecurity risk through assessments, vulnerability disclosure programs, bug bounty programs, and remediation tracking—these are company-internal risk management activities. However, no specific facts are present: no named third-party firms, products, dates, dollar amounts, headcounts, or certifications. The language ('internal security assessments,' 'external security researcher testing,' 'bug bounty programs') is standard cybersecurity disclosure boilerplate that could appear in any large company's filing.


reasoning: The paragraph describes a training/briefing process for management to assess cybersecurity risks, which is an internal risk management process. While third-party service providers are mentioned, they are referenced incidentally as the source of briefings rather than as the central topic of vendor oversight. No specific dates, named firms, certifications, or other identifiable details are present.


reasoning: The paragraph describes the company's internal cybersecurity governance framework and processes, including how business units operate their own cybersecurity programs. While it mentions third-party vendor oversight, this is described as one component of the policies rather than a standalone focus. The paragraph contains no named frameworks, specific titles, dates, numbers, or other identifiable facts—it relies entirely on generic descriptions like 'companywide cybersecurity policy,' 'senior management,' and 'appropriate qualifications and experience.'


reasoning: While the paragraph mentions the Audit Committee's oversight role (Board Governance), the second sentence provides substantive detail about the CIO/CISO function—specifically naming these roles and listing the granular topics they report on (cybersecurity events, vulnerability management, ransomware readiness, global trends). Per the tiebreaker, where board oversight is mentioned briefly and management roles are the substantive focus, Management Role applies. The named cybersecurity-specific titles (CISO, CIO) and the specific reporting topics distinguish this from standard boilerplate governance language.


reasoning: This paragraph describes an actual cybersecurity incident involving stolen BTC, a forensic investigation by a third-party firm, and a specific $560,000 payment made in Q2 2023. The incident narrative, response actions, and financial impact together constitute an incident disclosure. Two or more hard verifiable facts are present: the named firm (third-party), specific dollar amount ($560,000), and specific time period (quarter ended June 30, 2023).


reasoning: The paragraph focuses on the company's own internal cybersecurity organization and its processes (controls, tools, and third-party risk management practices), placing it squarely in Risk Management Process. The mention of CISO provides a firm-specific identifier that distinguishes this from generic boilerplate.


reasoning: This paragraph describes a general access control practice without any company-specific details, named roles, frameworks, or identifiable information. The language is purely boilerplate security terminology that could appear in any company's disclosure.


reasoning: This paragraph is a general policy acknowledgment statement expressing the importance of cybersecurity without describing any actual processes, roles, incidents, or substantive disclosures. It is boilerplate language that could appear in any company's filing unchanged.


reasoning: The paragraph describes the company's own internal third-party risk management program and processes rather than specific requirements imposed on vendors, making it a Risk Management Process disclosure; the language is entirely generic with no named entities, dates, frameworks, or other identifying specifics that would distinguish this company's disclosure.


reasoning: The paragraph describes the company's Information Security Department and its functions (standards development, procedures, protective measures), which is an internal process topic. While it mentions a department, it contains no specific named roles (CISO, CTO), named committees, specific certifications, named frameworks, tools, dates, or quantified metrics — only generic descriptions of departmental responsibilities that could apply to any company.


reasoning: The paragraph describes internal incident response planning, cross-functional coordination, and escalation procedures—classic internal risk management processes. While it mentions an 'Incident Response Committee' and an 'SVP Administration,' neither constitutes a cybersecurity-specific role or non-generic committee per the IS criteria, and no hard verifiable facts (dates, amounts, named third parties, named tools) are present. The description could apply broadly to any company's cybersecurity program.


reasoning: This paragraph is a materiality disclaimer stating that no cybersecurity threats have materially affected the company during 2023-2024. Following the tiebreaker rules, a materiality conclusion ('have not materially affected...our business strategy, results of operations or financial condition') is classified as Strategy Integration even when boilerplate. There are no firm-specific facts—the time references describe the assessment window, and 'material adverse effect' is standard legal language applicable to any SEC filing.


reasoning: This paragraph contains a materiality conclusion (stating no cybersecurity incidents have materially affected or are reasonably likely to materially affect the company), which qualifies as Strategy Integration per the tiebreaker guidance for materiality disclaimers. The cross-reference to Risk Factors is appended to the materiality statement, which does not change the classification. The paragraph contains no firm-specific details, dates, named entities, or hard verifiable facts—only standard boilerplate language applicable to any company.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes, including vulnerability assessments, technical controls, disaster recovery, and employee training programs. No board governance, management roles, third-party risk, or incidents are discussed. All practices and tools named are generic (multi-factor authentication, data encryption, network security) with no named products, named third-party firms, specific dates, or other firm-specific identifying facts that would elevate the specificity.


reasoning: The paragraph describes specific committee structures (OROC and IT Steering Committee), their leadership, compositions, and meeting cadences for cybersecurity oversight, which falls under Board Governance. While OROC and IT Steering Committee are management-level committees rather than board committees, the governance oversight function is the primary subject. The named committees with specific compositions exceed generic boilerplate language about 'the board' or 'management.'


reasoning: This paragraph describes the qualifications, credentials, career history, and tenure of named individuals (CISO, CTO, Head of IT Infrastructure), making Management Role the appropriate category. The paragraph contains multiple hard verifiable facts including specific years of experience (24, 28, 20), named certifications (CISA, CRISC), specific registration (FINRA Series 99), and named degrees, satisfying the Quantified-Verifiable threshold.


reasoning: This is a standalone materiality disclaimer stating that no known cybersecurity threats have materially affected (or are reasonably likely to materially affect) the company. Per the tiebreaker rules, materiality disclaimers with no incident narrative classify as Strategy Integration, and the language is pure boilerplate with no company-specific, date-based, or other identifiable facts.


reasoning: The paragraph states no material cybersecurity events have occurred and contains only forward-looking risk language plus a cross-reference to Item 1A Risk Factors — no substantive disclosure of actual cybersecurity governance, processes, or incidents. Per the tiebreaker guidelines, a pure cross-reference with no materiality conclusion would be None/Other, and this paragraph lacks the substance to qualify as Strategy Integration.


reasoning: The paragraph describes Cheniere's own internal cybersecurity processes: ongoing assessments, risk strategy sessions, penetration testing, and training programs. While the board is mentioned briefly as training participants, the grammatical subject and focus are on the company's internal risk management activities, not board governance structures. The paragraph contains one firm-specific identifier (Cyber Incident Response Plan), qualifying it as Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and management processes and their integration into the enterprise risk management program. While the Audit Committee and Board are mentioned, they appear only incidentally as part of describing how the ERM program is overseen, with the focus remaining on management's implementation of internal processes. The paragraph contains no named frameworks, specific dates, cybersecurity-specific titles, named tools, or other verifiable facts unique to Cohu.


reasoning: The paragraph describes a management-level committee (Bank Technology Governance Committee) and its oversight responsibilities for the cybersecurity program, with specific attention to reporting relationships between the director of information security and this committee. The focus is on governance structure and management roles rather than board oversight.


reasoning: The paragraph describes the Bank's own internal cybersecurity risk management framework, including its integration with Enterprise Risk Management and its various security programs and activities. This is management's own processes, not board oversight, incident disclosure, or third-party risk. No specific facts were found—no named roles (CISO/CIO/CTO), no specific dates, no dollar amounts, no named third-party firms, no named tools or products, and no named internal programs with unique identifiers. The programs named ('Enterprise Risk Management program,' 'Information Security program,' 'Cybersecurity Incident Response Plan,' 'business continuity management program') follow standard naming conventions used across the industry and do not qualify as firm-specific identifiers.


reasoning: The paragraph describes the company's internal cybersecurity operations and processes (continuous threat monitoring, incident response plans), placing it in Risk Management Process. However, it contains no specific facts—no named frameworks, tools, personnel, dates, or unique identifiers—making it entirely generic boilerplate language applicable to any company.


reasoning: The paragraph centers on the IT security team's internal processes—measuring/managing cybersecurity risk, implementing policies, and overseeing incident response—which maps to Risk Management Process rather than Management Role (which would focus on the person's qualifications rather than function). While a named cybersecurity-relevant role (VP of IT Services) and specific reporting relationships appear, the paragraph is fundamentally about what the security team does operationally, not about the individual's background or credentials.


reasoning: The paragraph's grammatical subject is the company's own cybersecurity management program and its functions (identify, assess, manage, mitigate, respond). The Audit Committee mention is incidental as the recipient of reports within that program structure. The specificity qualifies as Sector-Adapted because it names ISO as a recognized framework benchmark, but contains no firm-specific operational details, named internal programs, specific dates, or verifiable external facts.


reasoning: The paragraph's main focus is on the company's internal process of evaluating and implementing safeguards following risk assessments, which constitutes a risk management process. While the sentence 'Our IT leadership reports to our Chief Executive Officer (CEO)' touches on management structure, it merely describes a standard reporting line without naming a cybersecurity-specific role (CISO, CTO) or providing details about the person's qualifications, making it incidental to the primary process discussion.


reasoning: The paragraph primarily describes management's cybersecurity function, but the explicit naming of the CTO with specific credentials ('over 20 years of cyber and risk management experience') as the leader elevates this to Management Role. The specific qualification is a firm-identifying fact that ties the role to a named individual.


reasoning: The paragraph describes the company's own internal processes for risk assessment and incident response, which are internal cybersecurity practices. It contains no firm-specific details—no named frameworks, specific dates, named personnel, unique programs, or verifiable quantities. The language ('risk assessments designed to help identify material cybersecurity risks,' 'cybersecurity incident response plan that includes procedures') is generic boilerplate that could appear in any company's 10-K Item 1C disclosure.


reasoning: The paragraph primarily describes the company's own internal cybersecurity processes (incident response plan, governance structure, risk assessment/management/reporting, framework development) rather than a specific incident or board/management roles. While third-party subcontractors are mentioned, they appear as a component within the company's own risk management approach rather than as the central topic. The paragraph contains no named frameworks, specific dates, dollar amounts, headcounts, named tools, or named third-party firms—just generic security terminology applicable to any company.


reasoning: The paragraph describes the company's own internal cybersecurity risk management framework covering monitoring, insider threats, information sharing, third-party oversight, training, and supplier engagement. While it mentions vendors and suppliers, it describes how the company integrates vendor oversight into its own processes rather than focusing on vendor-imposed requirements as a standalone topic. No cybersecurity-specific roles (CISO/CTO/CIO), named committees, named frameworks (NIST/ISO), named third-party firms, or specific dates/dollar amounts are present—this is standard boilerplate applicable to any company's disclosure.


reasoning: This paragraph describes an actual cybersecurity incident with specific dates, unauthorized access methodology, malware type, exfiltration scope, and the last confirmed activity date—all hallmarks of an Incident Disclosure rather than a process description.


reasoning: The paragraph is entirely focused on third-party provider oversight—assessments before engagement, ongoing monitoring, and compliance with cybersecurity standards—which is the defining topic of Third-Party Risk. However, all language is generic boilerplate with no named vendors, specific dates, named frameworks, or any other verifiable specifics that would elevate the specificity level.


reasoning: The paragraph describes the company's own internal Information Security Program, including its design, monitoring activities, and control implementation — all internal risk management processes. While governance bodies are mentioned as overseers, the grammatical subject is the program itself, not the board.


reasoning: The paragraph describes the company's internal risk management approach—integrating cybersecurity into enterprise risk management and using NIST CSF as an assessment guide—which are internal processes rather than governance structures or incident narratives.


reasoning: The paragraph describes the company's internal IT risk identification process and risk register, which is an internal risk management process. The grammatical subject is 'The Company' describing its own processes. No specific persons, named committees, dates, dollar amounts, or firm-specific details appear—the 'risk register' is a generic internal structure, not a uniquely named program, and the categories listed (cybersecurity, data privacy, governance, application development) are standard boilerplate.


reasoning: The paragraph describes board oversight of cyber risk governance as its central topic, with the CFO as the managing agent. It contains no named frameworks, programs, roles beyond generic C-suite titles, or any verifiable external facts.


reasoning: The paragraph focuses on which management roles (Executive Officer and Vice President of Technology) provide briefings to the Board, making Management Role the primary category. While the board is mentioned as the recipient, it is not the grammatical subject. This is generic boilerplate describing standard reporting relationships found in virtually any company's cybersecurity governance disclosure—no named individuals, specific dates, named programs, or other identifying facts.


reasoning: The paragraph's primary grammatical subjects are the Audit Committee and Board of Directors, describing their oversight cadence (at least annually, and for material incidents), which constitutes Board Governance. While the CIO's reporting responsibilities and 20+ years of experience are mentioned, they serve as the mechanism through which board oversight occurs rather than the central topic.


reasoning: The paragraph's grammatical subjects are the Board of Directors, Audit Committee, and reporting relationships from management roles to the board level, making Board Governance the primary topic. The CISO, CTO, and Enterprise Risk Management Committee are identified as named parties in the governance structure, which qualifies as firm-specific information beyond generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management process—specifically how the program interfaces with other departments to identify threats and how processes are regularly updated. No board governance, named management roles, or actual incidents are discussed. The language is entirely generic with no identifiable firm-specific details.


reasoning: The paragraph describes internal processes (crisis management team structure, disclosure committee, materiality evaluation) rather than individual qualifications, making Risk Management Process the appropriate category. The mention of CIO, CISO, and the named 'cyber incident disclosure committee' provide firm-specific identifiers that go beyond generic boilerplate.


reasoning: This paragraph describes an actual cybersecurity incident including the nature and scope of affected systems, response actions taken (notifications, credit monitoring services), coordination with law enforcement, and litigation consequences. The 1.3 million figure provides a specific verifiable fact, making this Firm-Specific rather than generic boilerplate.


reasoning: This paragraph is a standalone materiality conclusion ('no cybersecurity incidents during the year ended December 31, 2023 had a material impact') with a forward-looking disclaimer and a cross-reference to Risk Factors. It contains no incident narrative, no named entities, and no specific details about the company's cybersecurity program. The date reference is standard SEC filing language, not a firm-specific fact. Per the tiebreakers, a materiality conclusion with no incident reference is Strategy Integration, but with only boilerplate language it remains Generic Boilerplate for specificity.


reasoning: The paragraph primarily describes remediation actions taken and ongoing security measures (forensic investigation, SIEM/SOC monitoring, quarterly access reviews) rather than describing what happened in the incident itself—it never states how the incident occurred, what systems were affected, or what data was accessed. The materiality conclusion is incidental boilerplate at the end, not the focus. Since no named products (SIEM/SOC is a generic category, not a named tool like Splunk or CrowdStrike), named third parties, specific dates, or specific numbers appear, this is Generic Boilerplate.


reasoning: The paragraph's grammatical subjects are the CISO and the CGC (a named internal committee), with board oversight mentioned only parenthetically as context. The CGC's composition (Deputy CISOs) and specific governance responsibilities (approving enterprise risk assessments, NIST CSF alignment) establish firm-specific organizational details about management-level cybersecurity governance.


reasoning: The paragraph centers on Audit Committee oversight of cybersecurity risk, with the CISO mentioned as part of the reporting structure to that committee — making Board Governance the primary focus. The mention of CISO (a cybersecurity-specific role) and the specific reporting line to the Audit Committee creates a firm-specific fact that distinguishes this disclosure from generic governance language.


reasoning: The paragraph describes the company's internal cybersecurity training and personnel development processes—how staff maintain knowledge through certifications, industry participation, and exercises—which maps to Risk Management Process. While it names multiple specific certifications and industry organizations, it describes general practices any company could adopt without any firm-specific verifiable facts like dates, dollar amounts, or named third-party firms.


reasoning: The paragraph describes PAG's own internal cybersecurity processes and programs (security awareness training, vulnerability scanning, incident response plan, patch management, access controls), which is the core of Risk Management Process. No board oversight is the grammatical subject, no incident is described, no management person's qualifications are discussed, and no vendor oversight requirements are the central topic.


reasoning: Although the paragraph opens with Audit Committee oversight, the substantive content focuses on the CIO's specific qualifications (10+ years, two other public companies) and the supporting team's quantified experience (13+ years average). The mention of the CIO's career history at multiple companies and specific team experience counts make this primarily about the management role, with two hard verifiable facts supporting Quantified-Verifiable specificity.


reasoning: This paragraph is a standalone materiality assessment stating no known cybersecurity threats have materially affected the company, with a cross-reference to risk factors. Per the tiebreaker rules, a materiality conclusion with no incident narrative is Strategy Integration, and the cross-reference does not change this classification. The paragraph contains only boilerplate language with no named entities, dates, dollar amounts, or other verifiable specifics.


reasoning: The paragraph describes the specific roles (CFO, VP of Internal Audit) and their cybersecurity oversight responsibilities, including receiving quarterly updates and managing the cyber incident response plan. While the Board is mentioned, the grammatical focus is on management-level roles and their specific functions in overseeing and communicating about cybersecurity risk.


reasoning: This paragraph describes an actual cybersecurity incident, detailing the scope (1.3 million consumers), response actions (notifications to regulators, credit monitoring services), and ongoing legal proceedings—making Incident Disclosure the appropriate category. The specific number of 1.3 million potentially impacted consumers is a verifiable firm-specific fact, though the paragraph lacks the multiple independent hard facts (e.g., specific dates, dollar amounts, or named external firms) needed to reach Quantified-Verifiable.


reasoning: This paragraph is a forward-looking disclaimer stating the company is not aware of material weaknesses or malware in its systems. It contains no substantive disclosure about actual cybersecurity governance, processes, roles, or incidents—it merely asserts the absence of known problems.


reasoning: The paragraph's grammatical subjects are the board and Audit Committee, and its primary focus is on board-level oversight structures, reporting cadences, and governance processes for cybersecurity risk. While management roles are mentioned, they appear only in the context of reporting to the board—not as the central topic. The specificity is Generic Boilerplate because all elements are standard governance structures found at virtually any public company: board oversight, Audit Committee, quarterly updates, annual briefings, and generic management involvement with no named frameworks, specific certifications, named third parties, dates, or other verifiable firm-specific facts.


reasoning: The paragraph centers on the IT Director's qualifications and leadership role in cybersecurity, with the grammatical subject being the IT Director (a management role). While the ITSC is mentioned, it functions as supporting context for the management structure rather than being about board-level oversight. The paragraph contains specific experiential credentials (25+ years IT, 15+ years cybersecurity) and a named internal committee (ITSC) with specific composition, making it firm-specific rather than generic boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity programs and safeguards—how b1BANK adapted its programs to identify and address threats—which is the core of risk management process disclosure. The mention of NIST CSF as a framework reference elevates the specificity to Sector-Adapted rather than generic boilerplate, as it names a recognized standard while containing no firm-specific facts beyond the company name.


reasoning: The paragraph focuses on the CISO's personal qualifications, experience level, tenure timing, and reporting structure—all of which describe the management role rather than the cybersecurity function's processes.


reasoning: The paragraph's main purpose is a standalone materiality conclusion ('we have not experienced a cybersecurity incident that has had a material impact to date') paired with general forward-looking risk acknowledgments. No actual incident is described, no board or management roles are the subject, and no internal processes are discussed.


reasoning: The paragraph describes the company's internal ERM Program processes and incident response plan procedures, with management team as the grammatical subject overseeing these internal processes. No specific dates, dollar amounts, headcounts, named third-party firms, or named tools appear. The program names ('Enterprise Risk Management Program,' 'incident response plan') are generic functional descriptions without unique identifiers, and the practices described (risk identification, triage, disclosure) are standard boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management structure and processes, centering on the CRO-led Enterprise Risk function and its coordination with the CISO. The CISO title qualifies as a cybersecurity-specific role (per the IS list), which distinguishes this from generic boilerplate and makes it firm-specific rather than generic.


reasoning: This paragraph is a forward-looking risk acknowledgment expressing potential vulnerability to cybersecurity threats, with no description of actual incidents, processes, roles, or specific financial impacts. It contains no specific facts and reads as standard risk language applicable to any company.


reasoning: This paragraph contains a standalone materiality conclusion (cybersecurity risks have not materially affected operations, business strategies, or financial results) with a cross-reference to Risk Factors. According to the tiebreaker rules, a materiality assessment with no incident narrative is classified as Strategy Integration. The paragraph contains no specific dates, dollar amounts, named frameworks, named tools, or any other uniquely identifiable facts—it's entirely boilerplate language applicable to any company.


reasoning: This paragraph is a general acknowledgment of cybersecurity risk categories with a cross-reference to Regulation S-K Item 106(a). It contains no substantive disclosure about the company's actual cybersecurity governance, processes, or incident history—it merely lists risk types that could appear in any company's filing unchanged.


reasoning: The paragraph describes the responsibilities of the Information Security Management Committee, a named management committee, in overseeing internal cybersecurity processes including risk management activities, incident response preparedness, and regular reporting to the Board's Compliance and Information Security Committee. The named committee structure (management committee coordinating with board committee) provides firm-specificity beyond generic boilerplate, even though the listed responsibilities are themselves standard governance functions.


reasoning: This paragraph is a forward-looking risk disclaimer asserting no material incidents have occurred and warning of potential future risks. It contains no incident narrative, no discussion of actual board or management actions, and no description of internal processes or governance—it's standard boilerplate language about hypothetical cybersecurity risks.