reasoning: The paragraph describes an actual cybersecurity incident including unauthorized access, data exfiltration (images of video meetings/screens), public release of data, and a monetary demand that was not paid—clearly constituting an incident narrative with response actions. However, no specific verifiable facts are present: no dates, dollar amounts, named third-party firms, named tools, or other hard facts that would elevate this to Firm-Specific or Quantified-Verifiable. All descriptions are general ('certain computer systems,' 'sensitive information,' 'additional cybersecurity measures').


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes Xylem's internal cybersecurity risk management programs, frameworks, and processes (what the CISO and Team DO), with no emphasis on personnel qualifications or background.

provider: minimax

stage: benchmark


content_category: Management Role

reasoning: The paragraph describes the composition and purpose of the Corporate Cybersecurity Steering Committee, with the CISO as chair and specific named roles/departments as members. The focus is on organizational structure and management oversight roles rather than specific risk management processes or board-level governance.


category_confidence: medium

reasoning: The paragraph's grammatical subjects are the CEO, CFO, and corporate controller describing their operational experience and role in informing the audit committee—this is management-level oversight, not board-level governance. All elements are standard public company boilerplate: generic executive titles, standard audit committee, generic briefing cadence ('once per year' is a minimum floor not a specific date), and generic topic descriptions with no named frameworks, programs, or unique identifiers.


content_category: Incident Disclosure

specificity_confidence: medium

reasoning: The paragraph describes an actual cybersecurity incident by referencing its operational impact (services remained operational during incident), the restoration timeline (by March 31, 2023), and its concluded status. While it references a real event, it lacks named third parties, specific dollar amounts, attack vectors, or unique firm-specific details that would elevate specificity beyond generic boilerplate status.


reasoning: The paragraph describes the company's own internal technical security controls and defensive measures (authentication requirements, encryption, DDoS protection), placing it squarely in Risk Management Process. The mention of AWS Shield as a named security product elevates this beyond generic boilerplate language to Firm-Specific, as it identifies a specific tool the company uses that is not universally present across all companies.


content_category: None/Other

reasoning: This paragraph is a forward-looking risk disclaimer describing potential consequences of hypothetical cyber-attacks (business disruption, reputational harm, litigation). It contains no description of actual incidents, specific governance processes, named roles, frameworks, or any firm-specific details about Li-Cycle's cybersecurity program. It is standard risk-factor boilerplate language that could apply to any company.


content_category: Third-Party Risk

reasoning: The paragraph is exclusively focused on third-party service provider oversight—due diligence, risk assessments, contractual requirements, and ongoing monitoring—which is the definitional scope of Third-Party Risk. The mention of SOC reports as a specific assessment tool elevates this beyond generic boilerplate, making it at least Sector-Adapted, though no firm-specific identifiers (named vendors, specific dates, dollar amounts) are present.


reasoning: The paragraph describes the company's internal ERM process with the ERMC as the grammatical subject, explaining how cybersecurity considerations are incorporated through quarterly assessments and action plans from the CISO and CDO. The named committee and cybersecurity-specific titles (CISO, CDO) identify this as firm-specific organizational structure rather than generic governance language.


reasoning: Paragraph describes an actual cybersecurity incident with narrative details (unauthorized access, encryption/monitoring software deployment, scope of affected systems), response actions (IR plan activation, law enforcement notification, external experts retained), and a specific discovery date. Contains two hard verifiable facts (October 15, 2025 date and FBI involvement), qualifying as Firm-Specific rather than Quantified-Verifiable (no named third-party cybersecurity firms or named products/tools).


content_category: Board Governance

reasoning: The Audit Committee is the grammatical subject throughout, describing its oversight cadence and reporting structure for cybersecurity incidents—a clear board governance focus. While CSO (Chief Security Officer) appears, it is not on the explicit list of cybersecurity-specific titles (CISO, CIO, CTO, etc.), and all other elements—Audit Committee oversight, quarterly cadence, and the range of topics discussed—are standard governance language that could appear in any company's filing.


reasoning: The paragraph describes the company's own internal incident detection and response processes, including a detection system, incident response plan, and testing procedures. This is internal process documentation, not board oversight, management role identification, vendor oversight, or incident narrative. No specific facts are present: 'annually' and 'periodically' are vague cadences, 'tabletop exercise' is a common practice without any specific dates, named tools, or verifiable details.


reasoning: The paragraph's grammatical subjects are the CISO and the Information Security Department, describing the role's responsibilities, reporting line to the Chief Risk Officer, and departmental duties. While it discusses organizational structure, no specific named individuals, named internal programs with unique identifiers, specific dates, dollar amounts, headcounts, or named third-party firms are present. All described activities (policy management, training supervision, access reviews, security monitoring) are standard practices applicable to any company.


reasoning: While the paragraph opens with board-level cybersecurity oversight, the majority of substantive content focuses on the CTO's specific responsibilities, reporting line, and particularly his extensive credentials and named industry affiliations — making the management role the central topic. Contains multiple firm-specific facts including a cybersecurity-specific title (CTO), specific reporting cadence, and unique industry committee memberships that identify this particular executive.


reasoning: The paragraph's grammatical subject is third-party vendors and the central topic is how the company oversees cybersecurity threats from those vendors, making Third-Party Risk the appropriate category. However, the paragraph contains no named third-party firms, specific contractual standards, named programs, dates, or other verifiable specifics—only generic descriptors like 'comprehensive, risk-based approach' and 'outside auditors or consultants' without identifiers.


reasoning: The paragraph describes the Bank's own internal cybersecurity processes (monitoring, training, penetration testing, incident response planning, cyber insurance) with no reference to vendor-specific risk management requirements or named third-party vendors — consistent with Risk Management Process. All content is generic cybersecurity boilerplate with no named frameworks, tools, dates, or firm-specific facts.


reasoning: The paragraph is primarily about identifying specific named individuals (CTO, DPI Head, SSA), their qualifications, career histories, and reporting relationships—making Management Role the dominant category. While the Audit Committee receives reports, management roles are the grammatical subjects throughout. Contains firm-specific facts including three cybersecurity-specific titles, named internal programs, a specific start date (1997), and a named prior employer (Bear Stearns).


reasoning: The paragraph describes an actual cybersecurity incident — a 'complex criminal scheme' involving fraudulently-induced wire transfers — including the incident narrative (what happened), timing (early Fiscal 2024), response actions (contacted banks, law enforcement, informed audit committee), and scope/impact (loss amount of $2.7 million net of recovery). The two specific hard facts (fiscal period and dollar amount) qualify this as Quantified-Verifiable.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes, including their risk assessment approach and the types of risks they monitor. No board oversight, management roles, third-party vendors, incidents, or financial materiality are discussed as primary topics.


content_category: Strategy Integration

reasoning: This paragraph contains a standalone materiality conclusion ('not aware of any cybersecurity threats that have materially affected or are reasonably likely to materially affect') with no description of an actual incident, which classifies it as Strategy Integration. The paragraph lacks any firm-specific facts — no named frameworks, roles, dates, or company-specific processes — making it Generic Boilerplate that could appear in any company's disclosure.


reasoning: This paragraph is a negative attestation stating no material breaches have occurred, combined with generic boilerplate language about 'periodically reviewing policies and procedures.' It contains no substantive disclosure about actual cybersecurity governance, processes, or risk management activities.


reasoning: This paragraph is a high-level introductory statement acknowledging cybersecurity threats and general resource allocation. It does not describe actual governance processes, management roles, risk assessment methodologies, or any specific company practices. The language is entirely generic and could appear in any company's cybersecurity disclosure without modification.


reasoning: The paragraph identifies the Manager of Information Technology as the individual who leads the Company's cybersecurity function and reports to the Audit Committee, making the management role the grammatical subject and primary focus. The Audit Committee is mentioned as the recipient of reports rather than the actor, so Board Governance is secondary. The named cybersecurity-specific role (Manager of IT) qualifies this as Firm-Specific rather than generic boilerplate.


reasoning: The paragraph describes a risk management process—specifically the briefing cadence and information flow that enables oversight of cybersecurity risks—rather than focusing on qualifications of named individuals or specific management role assignments. While both management and the board are mentioned, the grammatical subject is the briefing process itself (what it involves, what it enables). The named roles (CEO, COO, CIO, CLO) are the recipients of briefings, not the subject of discussion about their qualifications or tenure.


reasoning: This paragraph is a forward-looking risk disclaimer acknowledging past incidents and potential future failures without providing any incident narrative, process details, or governance specifics. The vague reference to 'cyber-attacks or other malicious activities in the past' lacks any description of what happened, when, scope, or response actions, making it a generic risk statement rather than an Incident Disclosure.


reasoning: The paragraph's primary focus is the company's own internal cybersecurity risk management processes and how they're integrated into enterprise risk management, rather than board governance or incident disclosure. The specific departmental composition of the assessment team (information security, finance, compliance, legal) provides one firm-specific fact, but no hard verifiable facts that would elevate to Quantified-Verifiable.


reasoning: Paragraph describes management-level oversight structures (CCO, Compliance Committee, Information Governance and Privacy Committee) and their specific compositions, responsibilities, and interactions—all firm-specific governance elements rather than generic boilerplate. No hard verifiable external facts (dates, dollar amounts, named third-party firms) present.


reasoning: This paragraph is a materiality disclaimer asserting no known cybersecurity incidents have materially affected the company, which per the tiebreaker rules is classified as Strategy Integration even though it is boilerplate. It contains no firm-specific details, named frameworks, or hard verifiable facts—only a generic statement and cross-reference to Risk Factors.


reasoning: The paragraph describes how the company's cybersecurity risk management integrates with its enterprise risk management program, which is a description of internal processes (Risk Management Process). It contains no specific facts—no named frameworks, standards, dates, dollar amounts, named roles, or firm-specific details—and consists entirely of generic boilerplate language that could appear in any company's filing.


reasoning: The paragraph's grammatical subject is the Sponsor (a BlackRock subsidiary) responsible for Trust oversight, with the Board of Directors mentioned briefly as report recipients, making Management Role the primary category per tiebreaker rules. No specific facts are present—'Sponsor,' 'BlackRock,' 'ERM framework,' and 'Board of Directors' are all generic organizational references that could appear in any filing, and 'periodically' is a vague cadence qualifier.


reasoning: The paragraph's primary function is a materiality conclusion (no material cybersecurity incidents in three years) combined with general risk acknowledgment and a cross-reference to Risk Factors. It does not describe an actual incident, internal processes, or governance structure—it merely states the absence of material incidents. This is characteristic of Strategy Integration. While 'December 31, 2024' is a specific date, it is merely the reporting period endpoint, and the paragraph contains no firm-specific details, named frameworks, or unique identifiers that would elevate it beyond boilerplate.


reasoning: The paragraph focuses on the company's own internal cybersecurity processes—training programs, phishing testing, and awareness initiatives—rather than board oversight or management personnel specifics. While 'CISO' appears, it functions as a reference to a reporting recipient rather than a description of the CISO's qualifications, background, or reporting line, which keeps this in Risk Management Process.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes (identification, assessment, and management of threats), with the cybersecurity team as the subject. No specific dates, named frameworks, tools, or firm-unique details are provided — all language is generic boilerplate applicable to any company's cybersecurity program.


reasoning: The paragraph's primary subject is the Board's oversight responsibilities, with the Board as grammatical subject throughout. The disclosure is Firm-Specific because it references the company's own ERM framework and a specific four-category risk taxonomy that reflects the company's internal organizational structure, distinguishing it from generic governance language.


reasoning: The paragraph focuses on third-party service provider cyber risk exposure as its central topic (not merely a component of broader processes), and describes the company's approach to monitoring those risks. However, it contains no specific details—no named vendors, no contractual security requirements, no specific monitoring tools or methodologies—that would elevate it beyond generic boilerplate language about vendor risk.


reasoning: The paragraph is primarily about the vCISO's qualifications (CISSP certification, decade of experience in specific domains), contractor status, and direct reporting line to the board—all identifying a management role. While it briefly describes oversight functions, the focus is on who the vCISO is and their credentials rather than detailing processes. The committee composition (management + third-party provider) and the vCISO's unique third-party contractor status are firm-specific facts that distinguish this disclosure from generic boilerplate.


reasoning: The primary purpose of this paragraph is a materiality conclusion ('we did not identify any cybersecurity threats that have materially affected') rather than describing an incident. While ETI's past incident is mentioned with some specifics, it serves as background context for XBP's own assessment, and the paragraph's main thrust is the company's forward-looking materiality stance.


reasoning: The paragraph describes the company's own Cybersecurity Risk and Compliance Program, internal policies, and processes for detecting/preventing/responding to incidents, with explicit adoption of the CIS Controls framework (v8.0). This is a description of internal risk management processes, making 'Risk Management Process' the appropriate category. The paragraph is Sector-Adapted because it names a recognized framework (CIS Controls) while containing no other firm-specific verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity tools (endpoint detection, firewalls, etc.) and processes (vulnerability assessments, penetration testing, tabletop exercises) — all standard internal risk management activities. No named third-party firms, specific dates, dollar amounts, or firm-unique details appear; all practices described are common across the industry.


reasoning: The paragraph describes the company's internal risk management processes and how cybersecurity is integrated into enterprise risk management, with the IT Security Incident Response Plan serving as the focal example. This is fundamentally about internal processes (Risk Management Process), not board governance, management roles, vendor oversight, or financial materiality. However, the description contains no firm-specific identifiers—'IT Security Incident Response Plan' is functionally equivalent to the generic 'incident response plan' in the NOT list, and there are no specific dates, dollar amounts, named third parties, or named tools.


reasoning: The paragraph describes the company's own internal cybersecurity processes including risk assessments, incident response planning, security operations, and employee training, making Risk Management Process the appropriate category. While third-party risk management is mentioned, it is presented as one component of the broader internal program rather than the central topic. The paragraph contains no named frameworks (only 'prevailing cybersecurity standards'), no specific dates, no named products/tools, no third-party firm names, and no quantifiable metrics—making it entirely generic boilerplate that could appear in any company's filing.


reasoning: The paragraph is about a named individual (Director of IT) and their qualifications, credentials, experience duration, and reporting line — making this a Management Role disclosure. Two or more hard verifiable facts are present: specific years of experience ('over 12 years' and 'over 20 years') and a named cybersecurity-specific title (Director of IT).


reasoning: The paragraph describes the company's internal cybersecurity risk management processes—how it identifies, assesses, and manages cyber risks through its ERM system, the NIST framework adoption, layered cybersecurity strategy, and company-wide policies. While the Board and committees are mentioned, they appear as participants in the risk management process rather than as the primary subject. The NIST framework reference is the distinguishing factor that elevates this from Generic Boilerplate to Sector-Adapted; the content otherwise describes standard practices without unique firm-specific details.


reasoning: The paragraph describes the company's own internal cybersecurity risk management program and processes, with the program being the grammatical subject. Third-party professionals are mentioned as part of the internal team structure, not as the central topic of vendor oversight. The naming of NIST Cybersecurity Framework makes this Sector-Adapted rather than Generic Boilerplate.


reasoning: The paragraph centers on the Chief Digital Information Officer as a person — detailing their qualifications, tenure (27 years), and educational background — making this a Management Role disclosure. The presence of a specific number (27 years) and a named institution (California State University, Bakersfield) provides two independently verifiable hard facts, crossing the threshold into Quantified-Verifiable specificity.


reasoning: The paragraph's grammatical subjects are the named management roles (CTO, CAO/GC, CCO) that comprise the Cybersecurity Team, with the team composition being the primary focus rather than the board. This identifies specific management-level positions responsible for cybersecurity governance at Ladder. The specificity is Firm-Specific because it names cybersecurity-specific executive titles that are unique to LADR's organizational structure; however, it falls short of Quantified-Verifiable as it contains no hard verifiable facts (dates, dollar amounts, headcounts, named third-party firms beyond generic 'outsourced technology firm,' or named tools/products).


reasoning: The paragraph describes the company's own internal risk assessment methodology and security control selection process, which is the core of Risk Management Process. It names the CIS Critical Security Controls framework, which qualifies as a recognized standard but contains no unique firm-specific details.


reasoning: The paragraph's grammatical subject is third-party service provider oversight, and the entire content focuses on vendor risk management processes: questionnaires, due diligence, audit report collection, and contractual security terms. No specific vendors, dates, tools, or firm-unique identifiers are mentioned—all practices described are standard industry approaches applicable to any company.


reasoning: The paragraph describes the company's own internal information security processes for identifying, assessing, and managing cybersecurity risks—making this a Risk Management Process disclosure. However, the language is entirely generic boilerplate: no named frameworks, tools, roles, dates, or other firm-specific details are present.


reasoning: The paragraph focuses on board committee oversight of cybersecurity risk, describing the cadence (at least twice a year) and reporting structure between management, the Audit Committee, and the full Board of Directors. All entities mentioned are standard governance bodies (Audit Committee, Board of Directors, management team) with no cybersecurity-specific roles (CISO, CTO, etc.) named, and no firm-specific details such as named programs, specific dates, or organizational compositions that would distinguish this disclosure from any other company's filing.


reasoning: The paragraph describes the company's own internal cybersecurity risk assessment, monitoring, and protection processes, which is the hallmark of Risk Management Process. While it lists various security categories (MDR, SIEM, vulnerability management, EDR, etc.), these are generic security tool categories with no named products, vendors, frameworks, dates, or other verifiable specifics that would elevate it to Firm-Specific or higher.


reasoning: The paragraph references 'the Data Incident' and mentions regulatory inquiries, indicating a real disclosed incident occurred, but this paragraph itself does not describe what happened in the incident (no dates, access details, scope, or response actions). It is essentially a regulatory acknowledgment and cross-reference to Note 11, containing no hard verifiable facts.


reasoning: The paragraph focuses on identifying specific management roles (ISO, Director of IT, Director of Information Services) and their reporting lines, making Management Role the appropriate category. The specificity is Generic Boilerplate because while it names cybersecurity-relevant roles, the responsibilities (identity access management, vulnerability management, incident response, third-party risk management) and reporting structure to CFO/CRO are standard industry practice with no unique firm identifiers, dates, amounts, or named tools/programs.


reasoning: The paragraph's substantive content focuses on identifying the CISO and detailing their professional background and qualifications (20 years of experience, Fortune 500 and Government clients), which is the defining subject matter for Management Role, even though the opening sentence references management's risk oversight function. The CISO's credentials and experience duration constitute two hard verifiable facts.


reasoning: The paragraph describes the company's own cybersecurity risk management program components (risk assessments, security team, external providers, training, incident response plan, third-party risk process), which is the core subject matter of Risk Management Process. While 'third-party risk management' is mentioned, it is listed as one component of the overall internal program rather than the central topic. No specific facts were identified: no named frameworks, dates, numbers, named products, or named third-party firms; 'quarterly' training is a vague cadence without specific dates; and the described elements (risk assessments, security controls, incident response plan) are generic practices applicable to any company.


reasoning: This paragraph is a forward-looking disclaimer expressing uncertainty about cybersecurity program effectiveness, combined with a materiality caveat and cross-reference to Risk Factors. It contains no substantive disclosure about the company's actual cybersecurity practices, governance, incidents, or assessments.


reasoning: The paragraph describes the company's own internal incident reporting, escalation, and response processes (four-tier risk system, recovery plans, materiality determination), making Risk Management Process the primary category. While CISO, CIO, and CFO are mentioned, they appear only as participants in the incident review process, not as the grammatical subject or focus of the paragraph. The paragraph contains no specific dates, dollar amounts, named third-party firms, named products/tools, named internal programs, or firm-specific certifications—it describes standard incident response practices that could appear in any company's disclosure.


reasoning: The paragraph's grammatical subjects and primary focus are the Audit Committee's oversight activities (conducting annual reviews, participating in strategic decisions, receiving briefings), which places it in Board Governance territory. The COO is described as a messenger to the board, not as the primary subject. The disclosure contains no named standards, specific dates, dollar amounts, headcounts, or other verifiable facts that would distinguish this filing—it describes a standard governance structure applicable to any public company.


reasoning: The Director of Infrastructure is the grammatical subject throughout, describing that role's monitoring responsibilities and incident response capabilities — consistent with Management Role. However, 'Director of Infrastructure' is not a cybersecurity-specific title (unlike CISO/CIO/CTO), and 'incident response plan' is a generic program name; there are no hard verifiable facts, named frameworks, named tools, or other Firm-Specific elements.


reasoning: The paragraph is primarily about the company's own internal cybersecurity risk management program, describing the IT team's oversight of processes, risk assessments, vendor due diligence, and employee training. The grammatical subject is the company's processes, not the board. The VP of IT & Facilities title qualifies as a cybersecurity-specific role that elevates this to Firm-Specific.


reasoning: Paragraph describes an actual cybersecurity incident (phishing attacks) with specific details including the targeted system (online banking platform), attack method (malicious look-alike phishing sites), and timing (beginning of the year), along with response outcomes. While no hard verifiable facts (exact dates, dollar amounts) are present, the incident-specific details distinguish this from generic boilerplate.


reasoning: The paragraph focuses on board-level cybersecurity risk oversight, with the board of directors and audit committee as grammatical subjects, clearly fitting the Board Governance category. The content contains only standard governance language ('board of directors,' 'audit committee') with no specific facts such as named committees, cybersecurity-specific roles, frameworks, dates, or third-party firms—making it indistinguishable from any public company's boilerplate disclosure.


reasoning: The paragraph primarily describes the Director of IT's responsibilities and the composition of the IT team, making Management Role the dominant category; while the Board is mentioned briefly in the opening, the grammatical subject shifts to the Director of IT and team structure. The paragraph contains multiple firm-specific facts including the Director of IT title, named certification (CISSP), third-party provider arrangement, and 24/7 monitoring capability, though these are organizational details rather than independently verifiable quantitative facts.


reasoning: This paragraph is a standalone materiality conclusion about cybersecurity threats, explicitly stating they have not materially affected the company and are not reasonably likely to. It contains no incident narrative, process descriptions, or governance details—it is purely a disclaimer about potential financial impact. Per the tiebreakers, materiality disclaimers without incident description map to Strategy Integration.


reasoning: The paragraph describes the company's own planned cybersecurity improvement activities (threat detection, tabletop exercises, industry collaboration) which are internal risk management processes. Although 'industry partners and regulatory authorities' are mentioned, the focus is on enhancing the company's own resilience, not managing vendor security risks. The paragraph contains no named frameworks, specific dates, named tools, specific roles, or other firm-identifying details—only generic cybersecurity practices that could apply to any company.


reasoning: The paragraph primarily focuses on identifying key management roles and their collaboration structure (CTO leading cybersecurity professionals alongside Compliance Manager, InfoSec Manager/ISO, and Enterprise Risk Manager) rather than describing internal security processes in detail. While third-party engagement is mentioned, it is described as supporting the management-led program rather than being the central topic. The CTO's extensive experience establishes qualifications for the leadership role, fitting Management Role as the grammatical subject.


reasoning: This paragraph primarily describes a contractual service arrangement (NEE affiliates providing IT/cybersecurity functions) with board oversight mentioned only as a parenthetical governance detail, making it a structural cross-reference rather than substantive cybersecurity disclosure.


reasoning: The paragraph focuses on the company's own cybersecurity program evaluation and risk assessment processes (internal processes), with the Audit Committee mentioned only as the recipient of results. The mention of the NIST Framework makes this Sector-Adapted; it contains no firm-specific details beyond naming the standard.


reasoning: The paragraph's primary focus is on identifying specific management roles (Vista CIO and CCO) and detailing the CIO's personal qualifications (appointed in 2017, over 20 years of experience), which constitutes information about the PERSON rather than the function they perform. The brief mention of Board oversight does not change the main subject to Board Governance.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes, including risk assessment procedures, monitoring tools, and defensive measures. Despite mentioning specific threat intelligence services (O&G, CISA, FBI InfraGard), no named frameworks, specific products, named third-party firms, or verifiable metrics are included—only generic descriptions of cybersecurity practices that could apply to any company.


reasoning: The paragraph describes the company's own internal risk management approach (policies, standards, testing, integration with ERM) without identifying a specific management person or discussing board governance. It names NIST as the framework used, making it Sector-Adapted rather than Generic Boilerplate, but contains no facts unique to Freshpet.


reasoning: The paragraph describes management roles (Executive Director of IT and CFO) as the grammatical subjects and outlines their responsibilities for cybersecurity oversight. While roles are identified, the specific responsibilities listed (hiring, integrating risk, incident preparation, approving processes) are standard organizational functions applicable to any company. No unique firm identifiers (no named programs, specific dates, dollar amounts, or named third-party firms) are present.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes: ERM integration, assessment cadence, and reporting structures. This is clearly Risk Management Process. The specificity threshold is met because the paragraph names a cybersecurity-specific role (CISO) in the Enterprise Risk Committee composition, which qualifies as a Firm-Specific fact (CISO is on the ✓ IS list; generic C-suite titles like CEO/CFO are not).


reasoning: The paragraph describes the company's internal process for identifying, assessing, and managing cybersecurity risks using various methods (automated tools, threat subscription services, audits, vulnerability assessments). While third-party partners are mentioned, they are described as part of the company's own risk management approach, not as the central topic of vendor oversight. No specific verifiable facts are present—no named frameworks, specific dates, dollar amounts, headcounts, or named third-party firms—just generic risk management methods.


reasoning: The paragraph centers on vendor oversight requirements imposed on third-party SaaS providers and service partners (onboarding risk assessments, contractual security obligations, breach notification requirements), making Third-Party Risk the appropriate category. The content contains no named frameworks, specific dates, dollar amounts, named third-party firms, or other verifiable facts—only generic descriptions of standard third-party risk management practices that could appear in any company's disclosure.


reasoning: The paragraph describes an internal governance mechanism—a named cross-functional committee with specific departmental composition—that oversees and manages technology and operational risks including cybersecurity. Although it mentions management oversight, the focus is on the structural process for assessing and managing risk rather than on a named individual's qualifications or background.


reasoning: The grammatical subject is 'The Committee' (a board committee) overseeing cybersecurity reporting and updates, making this a Board Governance disclosure. The paragraph contains only generic boilerplate language—'annual reports' is a vague cadence (not a specific date), 'management' is generic, and there are no named frameworks, specific dates, named roles, or other verifiable specifics that would elevate the specificity.


reasoning: The paragraph's primary focus is on identifying specific cybersecurity leadership roles (CIO and CISO) and detailing their qualifications and experience backgrounds, which is the hallmark of Management Role content. While significant governance structures are described, the personal credentials of the named officers (their exact experience levels, prior employers, and specific certifications) are firm-specific facts that elevate this beyond generic governance language.


reasoning: The paragraph centers on the board of directors' oversight role and reporting cadences, making Board Governance the appropriate category. The paragraph contains no specific verifiable facts—no named third-party advisors, no specific dates, no dollar amounts, no named products, and no unique program identifiers—making it standard boilerplate language that could appear in any company's disclosure.


reasoning: The paragraph describes the company's own internal security measures and controls (incident response plan, vulnerability management, encryption, access controls, etc.), making it about internal risk management processes. While a CISO is mentioned, it appears as one item in a long list of security measures rather than as the grammatical subject or focal point about the person's qualifications or background. The paragraph contains no named frameworks (NIST, ISO 27001), no specific dates, no dollar amounts, no named third-party firms, no specific headcounts, and no unique firm-specific details — all items listed are standard, generic security practices any company could claim.


reasoning: The paragraph describes the company's own internal cybersecurity risk management program including policies, standards, processes, and practices based on recognized frameworks. This is a description of the company's internal processes, not board governance, management roles, vendor oversight, an incident, or financial/business strategy.


reasoning: The paragraph describes the company's internal cybersecurity training and awareness programs (monthly training, phishing exercises, role-based training for higher-risk positions), which are internal risk management processes. It contains no named frameworks, tools, third-party firms, specific dates, or other identifying details—only generic descriptions of standard security awareness practices that could appear in any company's disclosure.


reasoning: The paragraph describes the company's incident response policy and its escalation/reporting procedures, which are internal processes. While the CFO and Audit Committee are mentioned, they appear as participants in the policy mechanism rather than as the grammatical subject of board oversight activities. No specific dates, dollar amounts, headcounts, named tools, named third-party firms, cybersecurity-specific titles (CISO, CTO, CIO), or named internal programs are present.


reasoning: The paragraph describes the company's own cybersecurity risk management program components (policies, risk assessments, security team, training, third-party vetting) rather than board-level governance or a specific incident. The third-party reference is about the company's internal vetting process, not vendor-imposed requirements. The paragraph contains no named frameworks, specific dates, dollar amounts, headcounts, named products, or named third-party firms—only generic descriptions of common security practices that could appear in any filing.


reasoning: The paragraph describes a governance committee structure that oversees cybersecurity processes and reports to the Audit Committee/Board of Directors. The grammatical subject is the committee itself and its oversight functions, making Board Governance the appropriate category. The committee's specific composition (CISO, CFO, COO, General Counsel, CTO) and named internal program (InfoSec Roadmap) and team (InfoSec team) distinguish this as firm-specific disclosure rather than generic boilerplate.


reasoning: The paragraph leads with identifying the CIO and describes their professional qualifications (CISSP certification) and reporting structure (directly to CEO), making Management Role the primary category. While internal processes are mentioned, they are framed as activities under the CIO's direction. The CISSP credential and specific CIO-to-CEO reporting line are firm-specific facts beyond generic boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity program and processes (risk management integration, disaster recovery testing, vulnerability scanning, annual program evaluation), with no board governance, named management roles, third-party risk emphasis, or incident narrative. There are no hard verifiable facts (no specific dates, dollar amounts, named firms/products, or quantified metrics), and while it references 'external advisors' and 'industry standards,' it names neither. The described activities—encryption, scanning, tabletop exercises, backup principles—are common practices without firm-specific details.


reasoning: The paragraph describes an actual cybersecurity incident — the mechanism (employee interactions with suspicious websites), response actions (promptly contained, forensic investigation), and scope/impact assessment — which qualifies as Incident Disclosure per the tiebreaker rules. The specificity is Generic Boilerplate because there are no hard verifiable facts: no specific dates (only 'the reporting period'), no named third-party firms, no named tools/products, and no dollar amounts or headcounts. The description 'employee interactions with suspicious websites' and 'forensic investigation' are standard incident language without identifying specifics.


reasoning: The paragraph describes the company's own internal cybersecurity program elements (risk assessments, security team, external providers, training, incident response plan, third-party risk process) — these are internal processes rather than board oversight or specific management roles. While third-party risk is mentioned, it is only one component within a broader description of the overall cybersecurity program.


reasoning: The paragraph describes the company's internal risk assessment processes and committee structure—specifically an annual cybersecurity risk assessment incorporating stakeholder input, known vulnerabilities, external intelligence, tabletop exercises, and penetration testing. The Information Security Steering Committee led by a CISO conducting quarterly reviews establishes this as an internal Risk Management Process disclosure.


reasoning: The paragraph identifies specific named roles (CIO, VP Information Technology, Manager of Security) and their collective qualifications (over 50 years of experience), focusing on the persons leading cybersecurity rather than describing internal processes. The presence of multiple hard verifiable facts—named cybersecurity-specific roles and a specific years-of-experience metric—meets the Quantified-Verifiable threshold.


reasoning: The paragraph describes internal risk management processes and methods (monitoring threat environment, automated tools, scans, audits, third-party assessments) that the SVPF and Director of IT perform. Per the person-vs-function test, since the paragraph focuses on what these roles DO (activities, tools, processes) rather than the individuals' qualifications or backgrounds, this is Risk Management Process. The roles named (SVPF, Director of IT) are generic IT/finance titles, not cybersecurity-specific roles like CISO, and the methods described are standard practices without any named frameworks, tools, or firm-specific details.


reasoning: The paragraph describes the company's own internal cybersecurity monitoring and response mechanisms (continuous monitoring tools, incident response plan, employee training), making 'Risk Management Process' the appropriate category. It contains no named frameworks, products, dates, roles, or other specifics that would elevate it beyond generic boilerplate language.


reasoning: This paragraph is a standalone materiality conclusion stating that known cybersecurity threats have not materially affected the company's business, with a standard forward-looking disclaimer. It does not describe any specific incident (no dates, scope, or response actions), making it a Strategy Integration category per tiebreaker rules. It contains no specific facts—no named frameworks, roles, dates, dollar amounts, or firm-specific details—and is boilerplate language applicable to any public company.


reasoning: The paragraph's central topic is vendor oversight — describing the Vendor Risk Management Program, policy, onboarding process, and periodic vendor reviews — making Third-Party Risk the appropriate category. While the paragraph references the Interagency Guidance on Vendor Relationships (a regulatory guidance document), it contains no firm-specific details such as named vendors, specific dates, dollar amounts, headcounts, or named third-party firms.


reasoning: The paragraph describes an actual cybersecurity incident — it states when (June 30, 2024) the company detected unauthorized third-party access to certain information systems and that external cybersecurity experts were retained to investigate. Per the tiebreaker rules, describing what happened in an incident (access, date) triggers Incident Disclosure, not Strategy Integration, even though expenses are mentioned.


reasoning: This paragraph is a standalone materiality conclusion stating that monitoring has not identified cybersecurity risks expected to significantly affect the company's condition. No actual incident is described, only a forward-looking risk assessment conclusion, making Strategy Integration the appropriate category. The paragraph contains no specific dates, named frameworks, named roles, dollar amounts, or any other identifiable facts—it is pure boilerplate language that could appear in any company's filing unchanged.


reasoning: This paragraph is a forward-looking risk disclaimer about potential future cybersecurity incidents affecting the company through customers/suppliers. It does not describe any actual incident, governance process, management role, or specific strategy. It is boilerplate language that could appear in any company's filing unchanged.


reasoning: This paragraph primarily describes a real cybersecurity incident at subsidiary Targus: unauthorized access discovery date, investigation scope, containment measures, business disruption, and regulatory notification. The brief materiality conclusion at the end is appended to the incident narrative, not the main point of the paragraph.


reasoning: The paragraph describes the company's own internal cybersecurity processes and standards (encryption, access controls, incident detection, employee training), which is the core definition of Risk Management Process. It contains no named roles, committees, specific dates, named tools, or third-party firms that would elevate it beyond generic boilerplate; all measures listed (encryption standards, access controls, MFA, etc.) are standard security practices applicable to any company.


reasoning: This paragraph describes a specific cybersecurity incident—the December 15, 2020 ransomware event—with details about what happened (ransomware), what systems were affected (operational and IT), and the operational impact (service delays). The cross-reference to Risk Factors at the end does not negate the primary purpose of describing an actual disclosed incident.


reasoning: The paragraph describes the company's internal Cybersecurity Steering Committee and its operational responsibilities for monitoring and managing cybersecurity risks, integrating risk management with business processes—making this about internal risk management processes rather than individual qualifications or incident disclosure.


reasoning: This paragraph describes actual cybersecurity incidents from September 2022—a network intrusion at Rockstar Games involving theft of confidential development footage, and a separate credential breach at a 2K Games vendor platform used for customer support. It includes incident narrative (what happened, when), scope (what systems/data were affected), and response actions (user notification, restricting further activity). Although the costs mentioned are characterized as immaterial, the paragraph's primary purpose is describing the incidents themselves, making Incident Disclosure the appropriate category.


reasoning: The paragraph describes Management's oversight responsibilities and reporting relationship with the Board regarding cybersecurity, making 'Management Role' the appropriate category. The language is entirely generic boilerplate with no named frameworks, specific dates, named programs, cybersecurity-specific titles (only generic 'Management'), or any other identifiable firm-specific details—it's standard governance language that could appear in any company's 10-K.


reasoning: This paragraph is a forward-looking risk acknowledgment stating the company recognizes cybersecurity risks exist, but describes no actual processes, programs, roles, or specific incidents. The company explicitly notes it is a 'start-up company with limited operations,' making this a general risk disclaimer with no substantive cybersecurity disclosure. All content is generic and could apply to any filing.


reasoning: The Audit Committee is the grammatical subject throughout the paragraph, and the disclosure focuses on the Board's oversight structure and reporting cadence rather than describing the CIO's qualifications or background. The mention of the Chief Information Officer as leader of the cybersecurity team qualifies as a specific fact (cybersecurity-specific title per the guidance), elevating this beyond Generic Boilerplate.


reasoning: The paragraph describes the company's own internal security controls and processes (change management, patching, MFA, backups, monitoring), making Risk Management Process the appropriate category. All elements are standard, unnamed practices without any firm-specific identifiers—no named third parties, specific dates, named programs, or verifiable metrics—resulting in Generic Boilerplate.


reasoning: The paragraph's grammatical subjects are the VP Internal Audit, CDIO, CISO, and information security team—identifying management roles and their reporting relationships in cybersecurity governance. While an ERM process is mentioned, it serves as context for the role structure rather than being the focus. No specific dates, dollar amounts, named third-party firms, named tools, certifications, or unique identifiers are present.


reasoning: The paragraph's grammatical subject is the Co-President (management role) who develops mitigation strategies, implements controls, and reports to the board—making this primarily about management's cyber responsibility. The Audit Committee discussion is secondary (where they report TO), consistent with the tiebreaker for 'board oversight mentioned briefly + management roles as main focus.'


reasoning: The paragraph describes the ISO's reporting line to management and the BRCC (a named committee), which is the management structure for cybersecurity oversight. The grammatical subject is the ISO and their role, not the board itself.


reasoning: The paragraph's grammatical subjects are the Board of Directors and Audit Committee, describing their oversight activities (receiving updates, annual discussions with management). While it references cybersecurity risk management, the governance actors and cadences are entirely generic boilerplate: 'Board of Directors,' 'Audit Committee,' 'periodic,' 'annual,' and 'CEO' are all standard governance terms that appear across virtually all SEC filings and do not constitute firm-specific facts.


reasoning: The paragraph's grammatical subjects are the Board's oversight and the Audit Committee, with management roles mentioned as participants in the board's oversight cadence. The focus is on board-level cybersecurity governance rather than management's independent functions. While the paragraph names a cybersecurity-specific title (Head of Information Security), it contains no dates, dollar amounts, headcounts, named frameworks, or other verifiable external facts that would elevate it beyond generic boilerplate language about board oversight structures.


reasoning: The paragraph describes an actual cybersecurity incident (the September 14, 2023 data breach), including the attack method (social engineering on an outsourced IT support vendor), scope (loyalty program database with SSNs/driver's license numbers), and response actions (IRP activation, containment, law enforcement notification, third-party engagement). While it references a past incident rather than a new material event, the detailed narrative of what happened qualifies as Incident Disclosure.


reasoning: The paragraph's grammatical subject is the company's assessment and management processes, with the VP of IT mentioned as a component within that process rather than as the primary focus. The content describes internal risk management integration, making Risk Management Process the appropriate category.


reasoning: The paragraph primarily describes the company's own comprehensive cybersecurity program and internal risk management processes, with third-party service provider considerations mentioned as one component of their internal risk evaluation—not as a standalone vendor oversight topic. No specific dates, named frameworks, specific roles, dollar amounts, or other verifiable facts are present.


reasoning: The paragraph is primarily about the CISO's biographical and professional qualifications (20+ years experience, education, technology expertise) and the composition/credentials of the IS team. Applying the PERSON-VS-FUNCTION test, the paragraph describes WHO the CISO is and their background rather than what the cybersecurity function does day-to-day. The multiple specific numbers (20+ years CISO experience, 20+ team members, 2 leads with 20+ years each) and named technology categories are unique to this company's disclosure.


reasoning: The Audit Committee and Board of Directors are the grammatical subjects discussing cybersecurity oversight responsibilities. No management roles (CISO, CIO, etc.) are mentioned. The specificity is Generic Boilerplate because Audit Committee and Board are standard governance entities, and 'periodic basis' is a vague cadence with no specific dates or other identifiable firm-specific facts.


reasoning: This paragraph describes an actual cybersecurity incident at Change Healthcare (the threat actor gaining access to IT systems), its operational scope (disrupted patient billing and collections), response actions (alternative intermediary identified, resumed some submissions), and includes two specific dates plus a named third-party firm — meeting the threshold for Quantified-Verifiable. While the materiality conclusion appears, the primary purpose is describing the incident and its impact.


reasoning: The paragraph centers on the Board's role in overseeing cybersecurity risk and receiving incident updates, making Board Governance the appropriate category. The language is entirely generic—references to 'prompt and timely information,' 'significant cybersecurity incidents,' and 'ongoing updates' contain no specific dates, named roles (beyond generic 'Board'), named frameworks, or other identifiable firm-specific facts.


reasoning: The Audit Committee is the grammatical subject overseeing cybersecurity risk, making Board Governance the appropriate category. The paragraph contains no specific verifiable facts—Audit Committee is a standard governance structure, CTO is a generic C-suite role, and 'at least annually' is vague cadence language that does not qualify as a specific fact.


reasoning: The paragraph is centered on third-party vendor oversight—specifically annual cybersecurity assessments and information security requirements imposed on vendors—which clearly maps to Third-Party Risk. However, it contains no specific dates, named vendors, named frameworks, dollar amounts, or other verifiable firm-specific facts; the language is entirely generic and could appear in any company's disclosure.


reasoning: The paragraph's main focus is the board-level governance structure, with the Board of Directors having ultimate oversight and the Audit Committee delegated monitoring responsibility. The grammatical subjects of the first two bullet points are board entities, making this Board Governance content. While the CISO is named with qualifications, this is presented as one component within the broader governance framework rather than the primary subject.


reasoning: The paragraph describes the DSEP's functions and processes as the grammatical subject, with the named roles serving as administrators of that plan rather than as persons whose qualifications are the focus. Contains a named internal program (DSEP) and specific role titles that are unique to this company's disclosure.


reasoning: The paragraph is about board-level oversight of cybersecurity: a committee reports to the full Board, the Board receives briefings from management, and Board members get continuing education presentations. The grammatical subjects are governance bodies (the Committee, the full Board, Board members), making Board Governance the appropriate category. All elements are generic boilerplate — 'the Board,' 'Board members,' 'management,' and 'the Committee' are explicitly listed as generic terms in the guidance; the CIO is a standard C-suite role; and phrases like 'continuing education' and 'receive briefings' contain no named programs, dates, frameworks, or other identifying specifics.


reasoning: The paragraph primarily describes the company's internal risk management process (identifying, prioritizing, monitoring, and mitigating risks) with board oversight mentioned as context. No specific frameworks, named roles, dates, or firm-specific details are present.


reasoning: The paragraph describes the company's cybersecurity risk management process and organizational structure (Information Security Team, ERM integration, reporting to CIO), which are internal processes. While it mentions management roles (CIO, Director of Information Security), it does not identify specific individuals or their qualifications—only the function and reporting structure. The paragraph contains no named third-party firms, specific dates, dollar amounts, headcounts, or other verifiable hard facts that would elevate it beyond generic boilerplate language about how a company structures its security function.


reasoning: The paragraph's central subject is third-party vendor oversight (reviewing SOC reports for third-party software), which maps to Third-Party Risk, though the company has no in-house systems to protect. The paragraph contains no dates, dollar amounts, named certifications, headcounts, or other verifiable external facts — Microsoft is mentioned as a generic example, not a specific vendor relationship, and the 'no material incidents' statement is boilerplate materiality language, not incident disclosure. Therefore Generic Boilerplate.


reasoning: The Board of Directors is the grammatical subject throughout, describing its ultimate oversight role and the Audit Committee's delegated responsibility. Although the CISO is mentioned, the paragraph focuses on board-level governance structure (what the board does, what the committee monitors) rather than the CISO's personal qualifications or function. CISO's presence makes it Firm-Specific (cybersecurity-specific title), but the topic is board governance, not management role.


reasoning: This paragraph is a standalone materiality conclusion stating that cybersecurity risks have not and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which maps to Strategy Integration per the tiebreaker rules. The cross-reference to risk factors is appended to the materiality assessment and does not change the classification. No specific facts, dates, dollar amounts, named firms, or named tools are present — only standard boilerplate language.


reasoning: The paragraph provides a detailed narrative of a specific cybersecurity incident (June 2018, unauthorized access to email system, forged electronic payment disbursements totaling $10 million), including what happened and the financial scope. While a materiality conclusion is included, it is secondary to the substantive incident description, making Incident Disclosure the primary category.


reasoning: The paragraph's primary purpose is a materiality assessment and business-strategy conclusion (threats have not materially affected the company, no assurance controls will prevent future losses, no cyber insurance coverage). While past incidents are mentioned, no details are provided about what happened, when, or scope—the main point is financial/operational impact, not incident description. This qualifies as Strategy Integration per the tiebreaker rule for brief incident mentions combined with materiality conclusions. All content is generic boilerplate with no named entities, dates, amounts, or framework references.


reasoning: The paragraph describes the company's own internal cybersecurity program (frameworks, plans, policies, and review processes), with no mention of board governance, named management personnel, actual incidents, or financial/materiality impacts. It contains no specific facts: 'cyber security frameworks' are unnamed, 'outside cybersecurity experts' are unnamed, and 'monthly' is a generic cadence rather than a specific date.


reasoning: The paragraph centers on the CISO role, describing specific qualifications (20+ years of experience) and the named Enterprise Security Council composition with specific departments. The CEO's unique biographical credential (Deputy Secretary of Defense) further distinguishes this disclosure. While the paragraph also touches on internal processes, the CISO's credentials and specific organizational structure (Enterprise Security Council with named departments) make Management Role the primary category.


reasoning: The paragraph describes the company's own cybersecurity program and internal processes (policies and procedures), with external service providers mentioned only as a supporting resource for enhancing those internal processes—not as the central topic of vendor oversight. No specific dates, named entities, frameworks, dollar amounts, headcounts, or other identifying details are present.


reasoning: This paragraph is a pure cross-reference directing readers to Item 1A for cybersecurity risk disclosures. It contains no substantive cybersecurity content, only referencing where the disclosure lives in the filing. The materiality language describes what Item 1A covers, not a conclusion being made here.


reasoning: The paragraph describes the company's own internal risk management processes—risk assessment, incident response procedures, employee training, and ongoing monitoring—all centered on the company's internal operations rather than vendor oversight. No specific dates, dollar amounts, named frameworks (NIST, ISO, etc.), named tools, or third-party firms are mentioned; all described practices (risk assessment, incident response, training) are common to virtually any filing.


reasoning: The paragraph describes the company's internal incident review and escalation process (cross-functional committee with IT/Finance/Legal departments, escalation to Audit Committee/Board), which is a risk management procedure. While it mentions departments and committees, none contain the identifying specifics from the IS list—no named internal programs with unique identifiers, no specific roles beyond generic titles, no named third parties, no dates, and no quantifiable metrics. The language is standard governance boilerplate applicable to any company's cybersecurity disclosure.


reasoning: The paragraph's grammatical subjects are the Board, Audit Committee, and Nominating & Corporate Governance Committee overseeing cybersecurity, making Board Governance the applicable category. The content describes standard board committee structure and vague reporting cadences with no hard verifiable facts, named internal programs, or unique firm-level details, qualifying it as Generic Boilerplate.


reasoning: The paragraph's grammatical subject is the CISO as a person, with specific biographical details (CISSP certification, 20+ years of experience) that distinguish this from a generic description of a role or function. The Audit Committee is mentioned briefly as supporting context rather than as the primary topic.


reasoning: The grammatical subject is 'CEO and management' who are actively engaged in overseeing cybersecurity threats, making this about the management function rather than board-level governance. The Board is mentioned only as a recipient of updates, not as the overseeing body. No cybersecurity-specific roles (CISO/CTO/CIO), named committees, or firm-specific details are present.


reasoning: The paragraph describes board-level cybersecurity oversight structure with the Board and Audit Committee as the grammatical subjects throughout, which is the defining characteristic of Board Governance. The paragraph contains no firm-specific facts: 'Audit Committee' is a standard committee (not a named Cybersecurity or Technology Committee), 'at least quarterly' is a common reporting cadence with no specific dates, and there are no named roles, tools, frameworks, or other identifying details that would distinguish this disclosure from any other company's filing.


reasoning: The paragraph describes the company's internal cybersecurity processes—the information security team's threat monitoring, evaluation, investigation, and mitigation activities, plus the data privacy team's policy responsibilities. These are generic internal processes without reference to a specific person, named framework, or verifiable details. No named third-party firms, specific tools, dates, or financial materiality language are present.


reasoning: The paragraph covers board governance, management roles, and risk management processes, but the dominant content focuses on specific named roles (Chief Digital and Technology Officer, Chief Information Officer, third-party CISO consultant) and their individual qualifications and experience levels — making Management Role the primary category despite audit committee oversight also being present.


reasoning: This paragraph is a generic regulatory compliance disclaimer stating that the company is subject to cybersecurity/data protection regulations and that non-compliance could result in penalties. It contains no substantive disclosure about board governance, management roles, internal processes, actual incidents, third-party oversight, or financial impact—only a boilerplate warning about regulatory obligations that could apply to any regulated entity.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes, including risk assessments, vulnerability management, penetration testing, and incident response planning, with no mention of board governance, specific management roles, actual incidents, or financial materiality. Category is Risk Management Process.


reasoning: The paragraph describes the company's internal cybersecurity awareness and risk assessment processes (personnel notifications, educational notices, consultant reporting structure) but contains no named third-party firms, specific dates, dollar amounts, or other verifiable facts that would distinguish it as firm-specific. The mention of 'expert consultants' is generic (unnamed), and the CFO reporting line is a standard governance structure found across companies.


reasoning: The paragraph describes the company's own internal cybersecurity program and processes (defense, detection, remediation, policies, crisis response plan) without referencing the board, specific management personnel, vendors, or a real incident. This is internal risk management description, making Risk Management Process the appropriate category. The language is entirely generic boilerplate with no specific dates, named frameworks, named roles, specific tools, or any fact unique to this company.


reasoning: The paragraph describes the reporting structure for cybersecurity risks to board committees—a process-oriented description. Management is the grammatical subject, but the focus is on the risk reporting mechanism rather than management qualifications or roles. No specific frameworks, dates, titles, tools, or other verifiable facts are present; both 'Enterprise Risk and Compliance Committee' and 'Audit Committee' are standard governance structures without unique identifiers.


reasoning: The paragraph discusses cybersecurity insurance coverage as a financial protection measure, with a standard disclaimer about potential insufficiency. No actual cybersecurity incident is described, and no firm-specific details are provided—this is generic boilerplate about cyber insurance that could appear in any company's disclosure.


reasoning: The paragraph describes the company's internal incident response structure and monitoring processes, focusing on how the Cyber Incident Response Team and Executive Vice President of IT coordinate threat response and report to the Board — this is a description of the company's own risk management processes. While it mentions named internal programs (IRT, Cybersecurity Plan), these are organizational constructs rather than hard verifiable facts, and the roles and structures described (CFO, COO, CLO on a response team, multidisciplinary teams, real-time monitoring, Board reporting) are generic corporate cybersecurity governance practices found across many filings.


reasoning: The paragraph describes internal incident management processes, cross-functional review mechanisms, and escalation procedures without referencing any actual cybersecurity incident or named individuals. All described elements (incident management teams, cross-functional working group, senior management, outside counsel) are generic governance structures common to any company's disclosure.


reasoning: The paragraph is about the CISO as a person—their qualifications, credentials, and career history—making Management Role the appropriate category. The paragraph contains multiple hard verifiable facts: the specific number of years of experience (over 20 years) and four named professional certifications (CISSP, CISM, PCI ISA, PCIP), which exceeds the two-fact threshold for Quantified-Verifiable classification.


reasoning: This paragraph is a standalone materiality conclusion stating that cybersecurity threats have not materially affected the company, which falls under Strategy Integration per the tiebreaker rules. It contains no incident narrative, no specific facts about the company's cybersecurity posture, and only includes a cross-reference to Risk Factors. All language is standard boilerplate that could appear in any company's filing.


reasoning: The paragraph describes an actual cybersecurity incident — unauthorized access to an employee's email account with fraudulently diverted funds — including what happened, the scope (employee email), and the operational/financial impact (immaterial, no revenue disruption). This is clearly an incident narrative, not a process description. The specificity is Firm-Specific because it references a company-specific event in a specific year (2024), but lacks the two or more hard verifiable facts (specific month+year or exact date, dollar amounts, named third-party firms, or named products) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes, including risk assessment programs, monitoring, vulnerability management, and disaster recovery testing. While the Board is mentioned, it appears in a review/oversight capacity rather than as the grammatical subject of board governance activities. The paragraph contains no firm-specific facts—no named internal programs with unique identifiers, no specific dates, no named third-party firms, no specific headcounts or dollar amounts. The ISO and NIST framework references are standard boilerplate; the company does not claim certification in either.


reasoning: This paragraph is a boilerplate materiality disclaimer stating no known cybersecurity threats have materially affected the company, combined with a forward-looking risk acknowledgment and a cross-reference to Risk Factors — no description of actual incidents, processes, or specific firm details.


reasoning: The paragraph describes the company's internal security function and its responsibilities (risk assessment, security controls, incident response), which are the company's own processes rather than governance, vendor oversight, or incident details. It contains only generic role titles and process descriptions with no named frameworks, specific dates, named tools, or firm-specific details that would elevate the specificity.


reasoning: The paragraph primarily describes the company's internal risk assessment and safeguard monitoring processes (risk assessment cadence, safeguard evaluation, effectiveness monitoring), with the CIO mentioned as designated personnel managing these processes rather than as a standalone subject of discussion about qualifications or background. The inclusion of the CIO title and specific reporting structure elevates this beyond generic boilerplate.


reasoning: The paragraph's primary function is a standalone materiality conclusion stating no material cybersecurity incidents have been identified to date, with appended boilerplate risk disclaimers about the sophistication of cyber threats and detection limitations. No actual incident is described, no specific controls or processes are named, and no firm-specific details appear—this is a generic materiality statement consistent with standard SEC disclosure language.


reasoning: The paragraph's grammatical subject is 'Our board of directors' and the topic is board-level oversight of cybersecurity risk, making Board Governance the correct category. The content contains no specific facts—no named committees beyond 'board of directors,' no specific cadences (only 'periodic'), no named roles, dates, or other identifying details—making it indistinguishable from any standard company's disclosure.


reasoning: The paragraph's grammatical subjects are the Board and the Audit Committee, which are explicitly board-level entities. The content describes board oversight structure and committee responsibilities for cybersecurity risk, fitting the Board Governance category. However, all elements are standard governance language ('Board,' 'Audit Committee,' 'cybersecurity policy') that could appear in any company's disclosure with no named frameworks, specific dates, named roles beyond standard titles, or other distinguishing details—qualifying it as Generic Boilerplate.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management approach—cross-functional coordination, associate training, regular reviews/tests, and internal audit involvement—rather than on the CISO's personal qualifications or background. The third-party engagement is mentioned as a component of the overall risk management process, not as a standalone vendor oversight topic.


reasoning: The paragraph's grammatical subjects are the Board and the Audit and Risk Committee, describing their oversight roles over cybersecurity risk. There are no specific facts from the IS list—no cybersecurity-specific titles (CISO/CIO/CTO), no specific dates, no named third-party firms, no named products/tools, and no unique identifiers. 'Audit and Risk Committee' is a standard committee variant (Audit Committee is explicitly listed as generic), and 'Response Team' is an unnamed generic entity.


reasoning: The paragraph discusses the board of directors' oversight role for risks, which falls under Board Governance. However, it is entirely generic boilerplate with no named committees, no cybersecurity-specific details, no briefing cadence, and no unique firm-specific facts.


reasoning: The paragraph focuses on board/audit committee oversight of cybersecurity risk, which is the grammatical subject. However, all elements are generic: Audit Committee is a standard board committee, the CIO is a standard corporate role (not cybersecurity-specific), and 'incident response plan' and 'periodic reports' are boilerplate language with no firm-specific details.


reasoning: This paragraph describes an actual cybersecurity incident from 2019 — specifically a wire fraud scheme involving compromised employee email and unauthorized wire transfer — including incident details (what happened, the mechanism of compromise), and response actions taken (MFA implementation, enhanced controls and training). This clearly meets the Incident Disclosure criteria of describing a real event with narrative, scope, and response actions.


reasoning: The paragraph describes the company's internal vendor management program and its processes for evaluating third-party cybersecurity risks. While vendor oversight is mentioned extensively, it is presented as an internal process component rather than a standalone third-party risk management discussion. The paragraph contains no named frameworks, specific dates, dollar amounts, named third-party firms, or other hard verifiable facts.


reasoning: This is a forward-looking risk factor paragraph describing the potential business and financial impact of cybersecurity threats, with no mention of an actual incident, specific management roles, named processes, or any firm-specific details—it reads as standard cybersecurity risk disclosure applicable to any company with sensitive data.


reasoning: The paragraph primarily describes the company's incident response plan structure (team composition, lifecycle phases, documentation templates) which is an internal risk management process. The physical security incident mentioned is explicitly labeled a 'physical security incident' rather than a cybersecurity incident, and the negative statement about no material cybersecurity incidents is boilerplate. No cybersecurity-specific titles, named frameworks, specific dates, or other firm-specific facts are present.


reasoning: The paragraph describes the company's internal Cybersecurity Incident Management Team (CIMT), its organizational composition, leadership structure, and operational responsibilities for incident response. This is an internal risk management process, with the team as the grammatical subject and focus throughout.


reasoning: The paragraph describes the company's own internal cybersecurity processes, specifically intelligence sharing, collaboration mechanisms, and resource allocation approaches, which constitutes the company's risk management framework rather than incident disclosure, third-party vendor oversight, or governance structures.


category_confidence: low

reasoning: This paragraph is biographical background on Duncan Fulton (Chief Corporate Officer) detailing his career history and qualifications, but it does not describe any cybersecurity governance, oversight, or processes. It appears to be background/qualifications information rather than substantive cybersecurity disclosure, despite appearing in Item 1C. Contains no cybersecurity-specific role, framework, tool, or verifiable fact relevant to cybersecurity.


reasoning: This paragraph is a standalone materiality conclusion stating that no material cybersecurity risks have affected the company in 2024, which is a Strategy Integration topic per the tiebreaker rules for materiality disclaimers. The cross-reference to Risk Factors is appended to this conclusion and does not change the classification. The paragraph is Generic Boilerplate because it contains no named entities, frameworks, dates (beyond a vague fiscal year), or any other fact that would identify this as specific to Accel Entertainment.


reasoning: The paragraph describes the company's own internal risk assessment program and annual audit processes, with third-party service providers appearing only as objects of the company's oversight activities. No named firms, dates, dollar amounts, or recognized cybersecurity frameworks (NIST, ISO, SOC 2, etc.) are present, making it standard boilerplate.


reasoning: The paragraph describes the company's own cybersecurity program components (risk identification, assessment, management, incident response, change management) — an internal process — making it Risk Management Process. The only specific fact present is the reference to the NIST Cybersecurity Framework, which qualifies it as Sector-Adapted rather than Generic Boilerplate.


reasoning: The paragraph describes the Company's internal security infrastructure and tools (MFA, firewalls, IDS/IPS, vulnerability testing, IAM, 24x7 SOC) — all internal risk management processes. No named standards, tools, dates, dollar amounts, or named third-party firms are present; all items are common cybersecurity practices found in generic disclosures.


reasoning: The paragraph's grammatical subject is the Board/Audit Committee and describes their oversight cadence, which maps to Board Governance. The specificity is Generic Boilerplate because while 'fiscal year 2024' provides a filing-period context, there are no named cybersecurity-specific roles, unique committees, named frameworks, or hard verifiable facts—'Audit Committee' is standard governance, and 'periodic reports' is vague cadence language.


reasoning: The paragraph describes the company's internal cybersecurity processes (continuous monitoring, security tools, employee training) with no reference to a specific person's role, a named incident, or vendor oversight requirements. All elements are generic cybersecurity program descriptions applicable to any company.


reasoning: The paragraph's grammatical subjects are the Director of Information Technology, Chief People Officer, Chief Legal Officer, and CFO — management roles that provide reports and participate in meetings — rather than the board or audit committee itself, making Management Role the more appropriate category. However, the paragraph contains no specific dates, dollar amounts, named third-party firms, named products/tools, or cybersecurity-specific titles (the Director of IT is IT-focused but not explicitly a cybersecurity role like CISO), and the governance structure described (audit committee oversight, periodic reports) is generic boilerplate applicable to any public company.


reasoning: The paragraph describes the company's internal security testing processes (penetration testing, vulnerability assessments, classification of findings) — core risk management activities performed by the information security function.


reasoning: This paragraph is a general introductory statement about the importance of cybersecurity to the company's operations. It contains no substantive disclosure about board oversight, management roles, specific processes, third-party risk, incidents, or financial impact—it merely establishes that cybersecurity is important to the company's commercial success. No specific facts are present.


reasoning: The paragraph primarily describes the company's general approach to cybersecurity risk management—policies, standards, processes, and practices for assessing and managing cyber risks. While the board is mentioned as providing oversight, the central topic is the company's own internal risk management framework rather than board governance specifically. There are no specific facts present: no named frameworks (NIST, ISO), no named roles (CISO, CTO), no specific dates, no named tools or third-party firms, and no specific programs or certifications. All language is generic boilerplate that could appear in any company's disclosure.


reasoning: This paragraph is a forward-looking risk acknowledgment/disclaimer that uses standard cybersecurity risk language (material adverse effect, normal course of business) without describing any specific incidents, processes, governance structures, or firm-specific details. It contains no named frameworks, dates, dollar amounts, or other verifiable facts.


reasoning: The paragraph focuses on the management team's composition and oversight role for cybersecurity, making 'Management Role' the primary category. The specificity is Generic Boilerplate because while it describes organizational structure (multiple departments including IT, finance, legal, and operations), these are standard business functions with no cybersecurity-specific titles (CISO/CIO/CTO), named committees, specific dates, named programs, or other identifiable firm-specific facts—it's standard organizational language applicable to any company.


reasoning: The paragraph describes management team members (President of P&T, CDO, senior-most cybersecurity employee) as the grammatical subjects leading cybersecurity processes, with their specific responsibilities outlined. This is management oversight of cybersecurity rather than board governance or internal technical processes, making Management Role the appropriate category.


reasoning: The paragraph primarily describes the company's information security program and its functions (overseeing risk, ensuring CIA of assets, implementing controls) rather than focusing on the CISO's personal qualifications or background. The CISO is mentioned as the program leader, but the bulk of content describes what the program does. CISO is a cybersecurity-specific role, making this firm-specific rather than generic boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity risk assessment and management processes, including risk identification, internal audits, vulnerability scans, and incident monitoring — all internal processes rather than external relationships or financial strategy.


reasoning: The paragraph's grammatical subject is the Chief Risk Officer and describes the creation and responsibilities of a management role, including its interaction with the CISO for cybersecurity oversight. While cybersecurity is discussed, the focus is on the role and reporting relationship, not on internal processes. The mention of CISO and the specific year 2024 make this firm-specific rather than generic boilerplate.


reasoning: The paragraph's grammatical subjects are the Board of Directors and the Audit Committee, making Board Governance the appropriate category. While a 'VP IT' role is mentioned, it functions as part of the governance flow (reporting to the Audit Committee) rather than as the central subject. The disclosure contains no named frameworks, specific dates, dollar amounts, named tools, or other verifiable specifics—only standard governance structures and vague cadences ('at least annually,' 'periodic reports') that appear in virtually every 10-K filing.


reasoning: While the paragraph mentions the CIO's credentials and internal processes, the primary structural focus is on the Board's governance structure—specifically the shift of cybersecurity oversight from the full Board to the Sustainability & Safety Committee in 2025, along with the detailed reporting cadences to both the committee and the full Board. This governance change and the board-centric reporting framework are the central organizing theme of the disclosure.


reasoning: The paragraph describes the board of directors' cybersecurity risk oversight function as the grammatical subject throughout, focusing on board-level governance structure rather than management processes or individual roles. The content contains only generic references (board of directors, executive officers, audit committee) with no specific named committees, dates, roles, or other firm-specific details that would distinguish this disclosure from any other public company's governance description.


reasoning: The paragraph describes an actual cybersecurity incident—what data was accessed/extracted, what was not accessed, and response actions taken—clearly qualifying as Incident Disclosure. However, all details use vague quantifiers ('certain,' 'a limited number of') with no specific dates, named third-party firms, named tools, or other hard verifiable facts, making it generic boilerplate that could appear in any company's disclosure.


reasoning: This paragraph provides general introductory language about why data security matters to business operations but does not describe any actual cybersecurity governance, processes, incidents, or strategy. It is essentially motivational/justifying preamble rather than substantive disclosure.


reasoning: The paragraph describes the company's own cybersecurity assessment and monitoring processes—external audits, penetration testing, and process adjustments—which are internal risk management activities. While the Board is mentioned as a recipient of assessment results, it is not the grammatical subject driving the process.


reasoning: The paragraph is about the qualifications, credentials, experience, and career backgrounds of named management individuals (Head of Cybersecurity, VP Information Security), making Management Role the appropriate category. The paragraph contains multiple hard verifiable facts: two specific year counts of experience (25+ years, 30+ years) and several named professional certifications (CISM, CRISC, CISSP), meeting the Quantified-Verifiable threshold of two or more independently verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity team's structure and processes (detection, assessment, classification, reporting), which constitutes internal risk management processes. The grammatical focus is on what the CIRT does rather than the qualifications of a named individual, so Management Role does not apply.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes (risk assessments, threat analysis, security tools, tabletop exercises, training) rather than focusing on individual qualifications or biographical details of management. While CIO and CISO titles appear, they function as process managers rather than as persons being described. Per the tiebreaker guidance, 'Internal processes mentioning vendors as one component → Risk Management Process,' even though no vendors are present here, the emphasis on internal processes over personnel credentials supports this category.


reasoning: The CEO is the primary grammatical subject, with primary focus on executive management structure and decision-making authority over cybersecurity. The Board/Audit Committee is mentioned only as providing 'oversight' rather than actively driving cyber governance. No cybersecurity-specific roles (CISO/CTO/CIO) are named, no specific frameworks, tools, dates, or named third-party firms appear, making this boilerplate governance language applicable to any company.


reasoning: The paragraph is entirely about the board's oversight responsibilities for cybersecurity risk management, making Board Governance the appropriate category. However, it contains only generic boilerplate language—references to 'the Board,' 'management,' and 'material risk exposure' are standard formulations that appear in virtually every company's disclosure with no specific dates, named frameworks, named roles (beyond generic 'management'), or other identifying facts.


reasoning: This paragraph centers on a brief materiality conclusion ('Risks from cybersecurity threats have not materially affected us') and forward-looking impact statements about potential future incidents, making Strategy Integration the appropriate category. The cross-reference to Risk Factors is appended to this materiality assessment and does not change the classification. There are no specific facts present—no dates, dollar amounts, named frameworks, products, tools, or third-party firms—just boilerplate language about cybersecurity risks and potential material effects that could appear in any company's filing.


reasoning: The paragraph describes the company's internal processes for assessing third-party cybersecurity risks as part of its broader risk management program. Per the tiebreaker guidance, third-party oversight mentioned as a component of internal processes maps to Risk Management Process, not Third-Party Risk. The paragraph contains no firm-specific identifiers—only generic references like 'risk management program' and 'service providers' with no named frameworks, dates, roles, tools, or other unique details.


reasoning: The paragraph's grammatical subject is the Board/Audit Committee, describing board-level oversight of cybersecurity (reporting cadences, briefings received, committee expertise). While the CTO is mentioned, it is only as a presenter TO the board, not as a focus on the management role itself. All content is generic boilerplate with no specific dates, named third-party firms, named frameworks, or other firm-specific details that would distinguish this disclosure.


reasoning: The paragraph's primary focus is on board and committee oversight structure for cybersecurity risk, with the board and Audit Committee as the grammatical subjects conducting oversight. While the CDC (a named committee) has management-level membership, it is introduced as part of the board's governance mechanism. The named committee, its specific team composition, and defined responsibilities for materiality assessment and disclosure recommendations are firm-specific facts that distinguish this disclosure from generic boilerplate governance language.


reasoning: The paragraph describes the company's own internal processes for monitoring and responding to cybersecurity incidents—the incident response plan and its mechanisms for evaluation, escalation, and reporting. While an ISO title appears, the paragraph focuses on what the plan does rather than the person's qualifications or background, making this Risk Management Process.


reasoning: The paragraph's grammatical subjects are the board of directors and the audit committee, with management discussed as the reporting entity rather than the primary topic. The content describes the board-level oversight structure for cybersecurity risk, including the Audit Committee's designation and update cadences, which is the hallmark of Board Governance disclosures. There are no specific facts present: the Audit Committee is a standard governance body, 'regular' and 'periodic' updates are vague cadences, and the CEO is a generic C-suite role with no cybersecurity-specific title or named internal program.


reasoning: The paragraph describes a specific incident (November 2023 Cybersecurity Incident), including what happened (operations disruption, exfiltration of employee and patient data), the scope of impact (business interruption, remediation costs), and post-incident remediation actions (SOC visibility, detection tools, vulnerability management expansion, AI-based technologies), which clearly meets the criteria for Incident Disclosure.


reasoning: This paragraph consists entirely of forward-looking risk disclaimers about potential future cyber-attacks and their hypothetical impacts. It contains no description of actual cybersecurity incidents, board governance structures, management roles, internal processes, or third-party oversight—only speculative language about what 'could' happen. The reference to 'evolving market dynamics' and 'cybersecurity standards' is boilerplate and not tied to any specific framework or company action.


reasoning: The Audit Committee (a standard board committee) is the grammatical subject describing its oversight role over cybersecurity risk, which is the defining feature of Board Governance. The paragraph contains only generic boilerplate language—'reviews and oversees,' 'policies and procedures,' 'cybersecurity risk assessment and management'—with no named frameworks, specific dates, named roles, or other identifying details.


reasoning: This paragraph is a standalone materiality conclusion stating that the company is not aware of any material cybersecurity risks that have materially affected the company—per the tiebreaker rules, this is Strategy Integration even though it's boilerplate. It contains no hard verifiable facts: no specific dates, dollar amounts, named firms, named tools, or cybersecurity-specific roles. The only references are to the company's own filing and risk factor sections, which are not specific facts.


reasoning: The paragraph centers on board-level cybersecurity oversight, describing how the Audit Committee interacts with management to oversee the cybersecurity program, making Board Governance the appropriate category. The paragraph reaches Firm-Specific because 'Director of Information Technology' is a cybersecurity-specific title that meets the IS criteria, even though the Audit Committee itself is a standard generic governance body.


reasoning: The paragraph focuses on Blue Owl's own internal cybersecurity processes and systems (monitoring, vulnerability management, technical safeguards) rather than describing board oversight or individual qualifications. While management roles are mentioned, the primary subject is what the program does, not who the person is. The named ISG Policy and specific role titles (CTO, Head of Technology Infrastructure) distinguish this from generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes (vulnerability management, training, incident response planning, and vendor oversight) as integral components of its overall security program. While third-party risk management is mentioned, it appears as one element within the broader internal risk management framework rather than as the central topic. All elements described—vulnerability scans, penetration testing, awareness training, phishing simulations, tabletop exercises, and documented incident response procedures—are generic security practices that could appear in any company's disclosure.


reasoning: The grammatical subject throughout is 'our management team' (CEO, COO, CAO), and the paragraph describes their responsibility and authority for cybersecurity oversight, making this fundamentally about a management role rather than describing internal technical processes. The named executives (CEO, COO, CAO) are generic C-suite roles without cybersecurity-specific titles, and while incident response processes are mentioned, they are described at a high level without any specific framework, named program, or hard verifiable facts that would distinguish this company.


reasoning: The paragraph describes the qualifications, background, and experience of a named management role (Vice President of IT), making 'Management Role' the primary category. The VP of IT title is on the cybersecurity-specific roles list, and 'over thirty years' is a specific quantifier, together making this Firm-Specific rather than generic boilerplate.