reasoning: The paragraph is centered on third-party service provider oversight: security risk assessments, security requirements imposed on vendors, and investigating incidents at third-party providers. This squarely fits Third-Party Risk. No specific facts are present — no named frameworks, no specific dates, no dollar amounts, no named third-party firms, and no named products or tools. The language describes generic vendor oversight practices that could appear in any company's disclosure.


content_category: Board Governance

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph centers on board and Audit Committee oversight of cybersecurity risk, with the Audit Committee as the grammatical subject in multiple sentences. The Audit Committee receives updates from management and reports to the full Board. While VP of Strategic Initiatives and CFO are named as those who oversee the program, the paragraph's primary focus is the governance structure, not the qualifications or roles of individual management personnel.

provider: minimax

stage: benchmark


content_category: Risk Management Process

category_confidence: high

reasoning: This paragraph describes the company's own internal cybersecurity program components (governance structure, technical safeguards, incident response, third-party risk, education/awareness) as part of the company's ERM approach. While it references the Board and Audit Committee briefly, the grammatical subject is the Company's processes, not the Board's oversight activities. The paragraph contains no specific dates, dollar amounts, named frameworks, named third-party firms, named tools, or any other verifiable fact that would differentiate this disclosure from any other company's filing.


reasoning: The paragraph's grammatical subject is the board-level cybersecurity sub-committee and its oversight functions (reviews, monitors, discusses), making this a Board Governance disclosure rather than a description of management roles—the CIO and CISO are mentioned as committee members performing board oversight, not as individuals being described.


reasoning: The paragraph centers on the Board of Directors' oversight role in cybersecurity, making Board Governance the appropriate category. The content contains only generic references ('Board of Directors,' 'senior management,' 'cybersecurity policies') with no named committees, specific roles (CISO/CIO/CTO), named frameworks, dates, programs, or other distinguishing details—typical boilerplate language applicable to any company.


content_category: Strategy Integration

reasoning: This paragraph is a standalone materiality conclusion (cybersecurity risks have not had a material impact) with a forward-looking disclaimer and a Risk Factors cross-reference. It contains no incident narrative, no description of actual events, and no discussion of processes, roles, or governance structures. The main thrust is the financial/materiality assessment, which classifies as Strategy Integration per the tiebreaker rules. No specific facts are present—no named frameworks, dates, dollar amounts, roles, or firm-specific identifiers.


content_category: Incident Disclosure

specificity_confidence: medium

reasoning: The paragraph describes an actual cybersecurity incident with specific dates, scope (portions of IT systems), and response actions (containment, investigation, system shutdown, plan activation), making this an Incident Disclosure. While the dates (July 10, 2024 appearing twice) constitute one specific hard fact, the incident narrative itself is unique to this company's disclosure, yielding Firm-Specific rather than the higher Quantified-Verifiable threshold.


content_category: None/Other

reasoning: This paragraph is primarily a forward-looking risk acknowledgment combined with a materiality disclaimer and cross-references to Risk Factors. The first sentence states that no known threats have materially affected the company (boilerplate materiality language), and the remaining content is a risk acknowledgment with appended cross-references. There are no substantive disclosures about governance, processes, incidents, or strategy.


reasoning: The paragraph centers on the audit committee receiving quarterly cybersecurity briefings from management—board oversight is the grammatical subject throughout. No firm-specific facts are present: 'audit committee' is standard governance language, 'at least quarterly' is a vague cadence, 'reporting thresholds' lacks specificity, and 'Information Technology team' and 'General Counsel' are generic roles. The language is standard board-oversight boilerplate that could appear in any company's disclosure.


content_category: Third-Party Risk

reasoning: The paragraph is centered on third-party vendor oversight through a planned vendor risk management program, describing due diligence and contractual requirements for vendors. The use of 'will implement' indicates this is a forward-looking plan with no current specifics, and no named vendors, frameworks, dates, or other identifying details are provided.


reasoning: The paragraph describes cybersecurity insurance coverage, which is a financial/business strategy instrument. It does not describe an actual incident, board oversight activities, or specific risk management processes—it focuses on the existence of insurance as a financial mitigation tool.


reasoning: The paragraph describes the Company's own internal approach to cybersecurity risk management, including threat identification, mitigation, and an incident response plan. It contains no references to board/committee oversight, specific management personnel, or external incidents, making Risk Management Process the appropriate category. The paragraph lacks any firm-specific details—it's standard cybersecurity risk management language that could appear in any company's filing.


reasoning: This paragraph describes the company's internal framework for managing cybersecurity risk (CIS Critical Security Controls) and its alignment with external standards. This is a description of the company's own risk management process, making it a Risk Management Process disclosure. The specificity is Sector-Adapted because it names the CIS framework (a recognized standard listed in the guidelines) but contains no firm-specific facts—all elements (NIST, ISO 27000, FFIEC) are generic external standards that any company could reference.


category_confidence: low

reasoning: The paragraph's primary function is a negative materiality statement ('not aware of having experienced any material cybersecurity incidents') and a cross-reference to Risk Factors. The brief mention of third-party security experts is incidental and generic ('if and when an incident is detected'), not a substantive description of the company's incident response process.


content_category: Management Role

reasoning: The paragraph's grammatical subjects are 'Our CISO' and 'His' (referring to the CISO), with the primary focus on identifying the CISO, describing their qualifications (28+ years experience, master's degree), and their support structure (ISOs, named consultant with specific certifications). This describes WHO manages cybersecurity rather than WHAT processes they perform. The two hard verifiable facts (28 years of experience, master's degree) combined with named certifications (CISA, CISM, QSA, CSP) and the certification claim (ISO 27001) reach the Quantified-Verifiable threshold.


reasoning: This paragraph is a general risk overview warning about potential cybersecurity threats without describing any actual incidents, governance processes, management roles, or internal controls. It explicitly states no material cybersecurity incident has occurred and includes a cross-reference to Risk Factors. This is standard risk-disclosure language that could appear in any company's filing.


reasoning: The paragraph describes internal cybersecurity processes (monitoring, security measures, system audits, incident response planning) with the InfoSec Director as the agent overseeing these functions. While a role title appears, the focus is on what the cybersecurity program does rather than individual qualifications. No hard verifiable facts (dates, dollar amounts, named third-party firms, named tools) are present, but FS-ISAC (Financial Sector Information Sharing and Analysis Center) is a named industry-specific entity, making this sector-adapted rather than generic boilerplate.


reasoning: The paragraph's primary focus is a materiality conclusion (no known material impact from cybersecurity threats) and forward-looking disclaimers about potential future impacts to business operations and financial condition, which aligns with Strategy Integration. The brief mention of third-party service provider incidents serves only as contextual background and is not the central topic, nor does it describe the company's vendor oversight processes.


reasoning: The paragraph describes the company's internal risk management framework and an internal committee structure for risk oversight, with the Executive Director of Information Technology serving as chair. While management is the grammatical subject throughout, the focus is on the internal process and governance mechanism rather than individual qualifications or reporting lines.


reasoning: The paragraph primarily describes the company's general approach to managing cybersecurity risks—detecting unauthorized attempts, implementing controls, and preventing recurrence—which constitutes a Risk Management Process description. The single sentence stating no material incident occurred in 2023 is a brief materiality acknowledgment, but it is not the grammatical focus of the paragraph. The only specific fact is the date range 'December 31, 2023,' which is insufficient alone to elevate specificity beyond Generic Boilerplate; no named frameworks, specific tools, named third parties, or unique organizational details are present.


reasoning: The paragraph describes the company's own internal risk management processes—specifically a security points of contact program and a CISO-chaired security council with a defined monthly cadence and departmental composition. While the CISO is mentioned, the focus is on what the council does (meets, discusses, ensures priorities) rather than the CISO's personal qualifications or background, so Management Role does not apply.


reasoning: The paragraph describes the company's internal risk management structures, policies, and a dedicated cybersecurity organization within operations—characteristics of Risk Management Process. No incident narrative exists (it explicitly states no material incidents). No specific facts (named frameworks, dates, dollar amounts, named firms, certifications) appear that would elevate specificity beyond generic boilerplate.


reasoning: The paragraph centers on board committee oversight of cybersecurity risk, with the Risk Committee as the grammatical subject receiving quarterly briefings from the CISO—this is classic board governance disclosure. The CISO and Risk Committee are firm-specific identifiers; the quarterly cadence and content description of the briefing (alert levels, controls rating, emerging risks) are details specific to this company's governance structure.


reasoning: The paragraph's grammatical subject is the Board of Directors, discussing board-level oversight responsibilities (reviewing and approving ICSPP and ICSIRP, monitoring material risks). While Director Sara A. Schmidt's credentials are mentioned, the context is about her qualification to serve on the board, not about her role within the disclosing company's management structure. The named director, her employer, and her external consortium membership provide firm-specific identification beyond generic board governance language.


reasoning: The paragraph's grammatical subject is the Board of Directors ('the Board of Directors discusses risks and threats,' 'the Board...inquires of management'), making Board Governance the appropriate category. The specificity is Generic Boilerplate because it contains no named committees (the company explicitly has no cybersecurity-specific committee), no named roles (explicitly states no CIO/CISO exists), no specific dates, no frameworks, and no firm-specific details—all elements are generic terms applicable to any SEC filing.


reasoning: The paragraph's grammatical subjects are the company's internal processes (vulnerability assessments, penetration tests, risk assessments, recovery protocols), not individual people or the board. While the CISO is mentioned in the final sentence, the primary focus is on describing what the company's cybersecurity program does, not the person's qualifications in isolation — the Person-vs-Function test is satisfied because the paragraph still makes sense as a process description even with the CISO mention removed.


reasoning: The paragraph's grammatical subject is the Audit Committee and its oversight function, meeting cadence, and governance structure. While management roles (CCO/CAO, CISO) appear, they are contextualized within the board's oversight mechanism rather than as the primary topic. The specificity comes from named cybersecurity-specific roles, the specific composition of meeting attendees, and the defined meeting frequency.


reasoning: The paragraph is about the qualifications, credentials, backgrounds, and tenure of named executives (CISO, CDIO, CEO, CFO, GC) — the grammatical subjects are the persons and their career histories. Per the PERSON-VS-FUNCTION test, this is Management Role content. It contains multiple hard verifiable facts: specific years of experience (25, 20, 30, 15, 18), named credentials (engineering degree, master's degrees in economics, law, management, finance), and cybersecurity-specific titles (CISO, CDIO), meeting the Quantified-Verifiable threshold of two or more hard facts.


reasoning: The paragraph describes the company's own internal information security processes for managing cybersecurity risks, which falls under Risk Management Process. It contains no named frameworks, specific roles, named programs, or other unique identifiers that would elevate it beyond generic boilerplate language applicable to any company's cybersecurity disclosure.


reasoning: The paragraph's primary purpose is a materiality conclusion (no material impact to date) with a forward-looking disclaimer and a cross-reference to Risk Factors. It does not describe any specific incident, board oversight activities, management roles, or internal processes in detail — it merely acknowledges their existence. This aligns with Strategy Integration as the dominant content type per the tiebreaker rules.


reasoning: The paragraph describes the company's own internal cybersecurity risk management program, including how its Risk Management, Legal, and Information Security departments oversee third-party risks. Third-party vendors are discussed as objects of the company's oversight process rather than as subjects, making this Risk Management Process. The paragraph contains no specific verifiable facts, named standards, or firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity governance structure and processes, including reporting lines, ERM integration, internal audit assessments, and review boards — all internal processes rather than board governance, incident disclosure, or third-party oversight. While it names several internal committees, the processes described (periodic reporting, control assessments, initiative reviews) are standard enterprise practices without hard verifiable facts such as specific dates, dollar amounts, headcounts, named third-party firms, or named tools.


reasoning: The Director of Compliance is the grammatical subject and the paragraph describes their function of providing cybersecurity briefings to the board, making this a Management Role disclosure. However, the paragraph lacks any specific verifiable facts—no named committees (Board of Directors is generic), no specific dates, no named tools/third parties, or cybersecurity-specific titles beyond the generic Director of Compliance—and relies entirely on boilerplate governance language applicable to any regulated entity.


reasoning: The paragraph's grammatical subjects are the CISO and CTO, describing their roles, responsibilities, and reporting line to the Risk Committee. While it mentions processes (Incident Response Plan, training), these are framed as duties of the CISO role, not as standalone internal processes. The CISO is a cybersecurity-specific role (one of the key identifiers on the IS list), and the Risk Committee is a named non-generic committee, making this at least Firm-Specific. No hard verifiable facts (dates, dollar amounts, named third parties, named products) are present, so it falls short of Quantified-Verifiable.


reasoning: The paragraph describes the company's own cybersecurity risk management processes and shared oversight between the Board and senior management. While board and management are mentioned, they serve as components of the internal process description rather than being the primary focus. The language is entirely generic boilerplate with no specific titles (CISO/CIO), named committees, frameworks, dates, or other identifying details.


reasoning: This paragraph is a materiality disclaimer stating no material cybersecurity incidents occurred during the reporting period, combined with a forward-looking caveat and a cross-reference to Risk Factors. Per tiebreaker rules, a materiality conclusion (even a negative one) classifies as Strategy Integration, not None/Other. The paragraph contains no specific facts—no named entities, dates, dollar amounts, frameworks, or tools—making it standard boilerplate language applicable to any company.


reasoning: The Board of Directors is the primary grammatical subject, with board oversight activities (receiving updates, participating in discussions) constituting the main topic. Employee training is mentioned only briefly as an additional element. No cybersecurity-specific titles (CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security), named frameworks, or hard verifiable facts are present. The reference to 'Vice President of Information Services' is an IT role, not a cybersecurity-specific title per the classification criteria. All content is standard governance language applicable to any company's disclosure.


reasoning: The paragraph describes the company's internal security assessment processes (vulnerability scans, threat intelligence, third-party assistance) as components of its own risk management program. Third parties are mentioned only as one element supporting the company's internal efforts, not as the central topic. Contains no named frameworks, dates, dollar amounts, named tools, or any other specific fact that would identify this disclosure as unique to this company.


reasoning: This paragraph is a forward-looking risk disclaimer describing hypothetical consequences of potential future IT system compromise. It contains no substantive disclosure about actual cybersecurity incidents, governance practices, or risk management processes—only speculative outcomes that could apply to any company.


reasoning: The paragraph describes the company's own internal cybersecurity processes (technical safeguards, incident response planning, TPRM, training) — standard internal risk management content. While it mentions 'Information Security and Privacy team,' this is an internal designation without external verifiable specificity. No named frameworks (NIST, ISO), no dates, no third-party firm names, no dollar amounts, no named tools or certifications appear, making this a generic boilerplate description of common cybersecurity practices.


reasoning: The paragraph describes the company's own internal risk management processes and activities (integrated risk management, multi-faceted approach, penetration testing, employee training, monitoring regulations) without identifying any specific named individuals, committees, tools, firms, or programs. It focuses on what the company's processes DO rather than who manages them or specific details about those processes. The language is generic cybersecurity risk management boilerplate applicable to any company.


reasoning: The grammatical subject is the IT Team Director, a management role, discussing cybersecurity risk reporting to the CFO, CEO, and General Counsel. No named third-party firms, specific dates, dollar amounts, or cybersecurity-specific titles (CISO, CIO, CTO) are present. All roles mentioned (CFO, CEO, General Counsel) are generic C-suite/executive titles found at any company.


reasoning: The paragraph describes board-level oversight of cybersecurity risk, with the Board of Directors, Nominating and Governance Committee, and Audit Committee as grammatical subjects. However, it contains only generic governance language (standard board committees, 'quarterly' cadence without specific dates) that appears verbatim in virtually every public company's Item 1C disclosure, providing no firm-specific detail that would differentiate this disclosure.


reasoning: The paragraph describes cross-functional team oversight of cybersecurity risk management, which is an internal process topic. However, the specific team names (IT, Information Security, Product Security, Compliance, Legal) are generic departmental identifiers common to any company and contain no specific individuals, named programs, dates, or verifiable external facts, making this Generic Boilerplate.


reasoning: The dominant focus of this paragraph is a materiality conclusion stating no cybersecurity incidents have materially affected the company, which is the primary disclosure purpose of Item 1C. While it briefly references internal monitoring processes, the main point is the absence-of-impact determination, making Strategy Integration the correct category. The paragraph contains no named entities, dates, dollar amounts, or other identifying facts—it could appear in any company's filing unchanged.


reasoning: The paragraph is about management's role in cybersecurity oversight with named management titles (Head of Security, Head of Global Privacy, etc.) and describes escalation to the Audit Committee. The grammatical subject is management, not the board, making this Management Role rather than Board Governance.


reasoning: This paragraph is a standalone materiality assessment with no incident narrative — it states that no material cybersecurity incidents were identified and no threats have materially affected the business. Per tiebreaker rules, a materiality conclusion without an incident description is classified as Strategy Integration, not Incident Disclosure. The language is entirely boilerplate with no named entities, dates, frameworks, or firm-specific facts.


reasoning: The paragraph's grammatical subject is the CFO, describing the CFO's responsibilities for cybersecurity oversight, with the Board mentioned only briefly as the recipient of updates. The named 'Coalition management platform' elevates this to Firm-Specific rather than Generic Boilerplate, as it identifies a specific product this company uses for risk management.


reasoning: The paragraph describes the company's own internal methodology for managing third-party cybersecurity risk—namely its risk-weighted approach, case-by-case assessment, due diligence, and contractual safeguards—which aligns with Risk Management Process. However, it contains no specific dates, dollar amounts, headcounts, named frameworks, named products, or any other hard verifiable facts; all language is generic boilerplate applicable to any company's vendor risk program.


reasoning: Although the paragraph describes internal training programs (Risk Management Process territory), the inclusion of cybersecurity insurance—a topic explicitly listed under Strategy Integration—shifts the primary category toward Strategy Integration. The paragraph lacks any firm-specific details: no named frameworks, tools, specific dates, amounts, or other uniquely identifying facts.


reasoning: This paragraph describes the company's internal cybersecurity practices including patch management, software maintenance, employee training, and third-party security reviews. The reference to 'Fuel Tech's data' appears to be a filing error (the company is VIVIC CORP.), but the language itself describes standard cybersecurity hygiene practices with no unique firm identifiers, dates, dollar amounts, named frameworks, or named tools/products.


reasoning: The paragraph primarily describes the company's internal risk management process (risk assessments, safeguard implementation, monitoring effectiveness) rather than focusing on the qualifications or background of the named individual. The Senior Director title and CFO reporting line are firm-specific organizational facts, not merely generic role references.


reasoning: The paragraph's grammatical subjects are executive officers and a third-party consultant, focusing on organizational management structure and personnel qualifications (the SOC Manager's certifications and background), which is the core of Management Role. No named entities, dates, dollar amounts, named third-party firms, or named products/tools are present—only generic role descriptions that could appear in any company's filing.


reasoning: The paragraph describes the company's own internal safeguards (employee training, incident response reviews, business continuity) and processes, making Risk Management Process the appropriate category. However, all elements are generic—'technical and organizational safeguards,' 'incident response capability reviews,' 'business continuity mechanisms,' and 'internal and external experts' contain no named frameworks, tools, firms, dates, or other distinguishing details, rendering this Generic Boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity risk management program elements (risk assessments, internal security team, training, incident response plan, third-party oversight as one component), making 'Risk Management Process' the most applicable category. The paragraph contains no firm-specific details: no named roles (CISO/CIO/CTO), no specific dates, no named frameworks (NIST/ISO), no named third-party firms, no internal program names with unique identifiers, and no quantified metrics—it's a textbook description of standard cybersecurity program components that could appear in any company's disclosure.


reasoning: The paragraph's grammatical subject is the Vice President, IT Security, and the majority of substantive content describes this individual's biographical qualifications (years of experience, degree, certifications) rather than the internal processes themselves. While the paragraph transitions into process descriptions, the biographical framing establishes this as a description of the management role, not a standalone process description.


reasoning: This paragraph is a standalone materiality conclusion stating that no cybersecurity risks or incidents materially affected the company in 2024, with a forward-looking disclaimer and a cross-reference to Risk Factors. Per the tiebreaker rules, a materiality conclusion (even with a cross-reference appended) classifies as Strategy Integration, not None/Other. No specific facts are present—the year reference 'In 2024' is not a hard date, and the paragraph contains no named entities, frameworks, tools, third-party firms, dollar amounts, or percentages.


reasoning: This paragraph is a standalone materiality conclusion with no description of any actual incident—it simply states that cybersecurity threats have not materially affected the company to date. Per the tiebreaker rules, materiality disclaimers without incident narratives are classified as Strategy Integration. The cross-reference to Risk Factors does not change this classification. The paragraph contains no specific dates, dollar amounts, named firms, named tools, or other verifiable facts—it is purely boilerplate language that could appear in any company's filing.


reasoning: While the paragraph opens with board-level governance language, the substantive content focuses on identifying a specific management team (CFO, Senior Director of IT, SVP QA) with defined responsibilities for assessing/managing material cybersecurity risks and supervising both internal personnel and external consultants. The naming of these specific management roles and their operational scope is the central disclosure, making this a Management Role classification.


reasoning: The paragraph describes the company's internal cybersecurity governance structure and incident management processes, focusing on what the crisis management team and disclosure committee DO rather than individual qualifications or background. The grammatical subject is the team/committee function, not specific named individuals. The inclusion of a named 'cyber incident disclosure committee' and cybersecurity-specific roles (CIO, CISO) provides firm-specific organizational detail beyond generic boilerplate governance language.


reasoning: This paragraph is primarily a risk acknowledgment and threat description that culminates in a cross-reference to the Risk Factors section. While it briefly mentions implementing an 'Information Security Program,' this is in the context of describing threats rather than substantively detailing the company's risk management processes, frameworks, or governance structure.


reasoning: The paragraph describes the company's internal Testing, Training & Exercise (TT&E) program and its components (procedures testing, IRT training, tabletop exercises, phishing simulations), which is an internal risk management process. It does not describe a specific incident, nor does it focus on board oversight or management roles. The paragraph names NIST Special Publication 800-84 as the framework adopted, which elevates it from Generic Boilerplate to Sector-Adapted, but contains no firm-specific facts (no named internal programs, dates, numbers, or unique identifiers).


reasoning: The paragraph's dominant focus is the ISMS Committee's composition and responsibilities for managing cybersecurity risks (internal processes), with the CIO serving as the reporting vehicle to that committee rather than being the primary subject; however, the CIO's specific tenure and prior experience are described, making this borderline with Management Role.


reasoning: The paragraph primarily describes internal management committee structures (IT Steering Committee and IT Subcommittee) and their composition, roles, and responsibilities for managing cybersecurity risk—making Risk Management Process the most fitting category. While the board is mentioned as having representatives on the IT Steering Committee, the committee itself is a management-level body, not a board committee. The paragraph is Firm-Specific because it names multiple cybersecurity-relevant roles (CISO, CTO, Chief Risk Officer, Director of Internal Audit), specific internal committee names, and detailed compositional facts that uniquely identify this company's disclosure, though it does not reach the two-or-more hard verifiable fact threshold needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and processes (enterprise-wide information security program, technologies, controls), with the CISO mentioned as the manager of this function rather than as a standalone subject of biographical focus. The CISO title qualifies as a cybersecurity-specific role from the IS list, giving this paragraph Firm-Specific status despite otherwise generic boilerplate language.


reasoning: The paragraph describes internal cybersecurity processes (monitoring, security measures, audits, incident response plan) rather than describing the qualifications or personal background of the CISO/CIO, making it about the function rather than the person. The paragraph contains one specific fact (cybersecurity-specific titles CISO and CIO), which meets the threshold for Firm-Specific, but lacks hard verifiable facts such as specific dates, dollar amounts, named third-party firms, or named tools/products that would elevate it to Quantified-Verifiable.


reasoning: The paragraph's primary purpose is a materiality conclusion — stating that cybersecurity threats have not materially affected the company and that ongoing risks are reasonably likely to do so if realized. This is standard forward-looking risk acknowledgment language that appears across many SEC filings.


reasoning: The paragraph describes a generic practice of keeping management informed about cybersecurity posture without identifying specific roles (e.g., CISO), committees, or processes—this is boilerplate language about governance practices rather than specific oversight mechanisms. No named entities, frameworks, dates, or other identifying details are present.


reasoning: The paragraph's grammatical subject is 'our board of directors,' and the topic is board oversight of cybersecurity risk through regular management presentations. No specific facts are present—no named frameworks, specific dates, named products/tools, dollar amounts, or named third-party firms. The language about 'regular basis,' 'prevailing cybersecurity threats,' and 'vulnerability assessments' is standard boilerplate applicable to any company's disclosure.


reasoning: The paragraph primarily describes the company's own internal cybersecurity risk management processes integrated into the ERM program, including policies, standards, and practices. While the Board is mentioned briefly as part of the oversight structure, the grammatical focus is on the company's internal processes and the CISO's functional role rather than board governance specifically.


reasoning: The paragraph primarily describes internal risk assessment and audit processes for identifying cybersecurity vulnerabilities, which falls under Risk Management Process. While it mentions the Director of Information Technology and the Board's oversight role, these are referenced in the context of the risk management process rather than as standalone descriptions of management qualifications or board governance structure. No specific dates, dollar amounts, named frameworks, third-party firms, or unique firm-specific facts are present.


reasoning: The paragraph describes Leidos's internal monitoring infrastructure, detection systems, and escalation procedures with a named CSIRT team — clearly an internal risk management process rather than board governance or an actual incident. CSIRT is a specific team identifier, making this firm-specific rather than generic boilerplate.


reasoning: The paragraph describes the company's internal monitoring and vulnerability detection tool (Coalition Control) and its functions, which constitutes a description of the company's own security processes rather than board oversight, management roles, vendor requirements, or incident details.


reasoning: The paragraph's primary focus is board oversight activities (Audit Committee reporting, board briefings on cyber risk management), with the board and committee as grammatical subjects. The CISO is mentioned incidentally as a presenter to the board, not as the subject being described. The CISO title qualifies as a cybersecurity-specific fact, making this firm-specific rather than generic boilerplate.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity and the quarterly reporting cadence from management to the board, making Board Governance the primary category. The content contains no specific facts: the Audit Committee is a standard board committee (not cybersecurity-specific), 'quarterly' is a generic cadence without specific dates, and there are no named cybersecurity roles, frameworks, third-party firms, or verifiable numbers.


reasoning: Although the paragraph describes a past incident (June 2018 unauthorized access to email system), the primary purpose is a standalone materiality conclusion — that cybersecurity risks have not materially affected the company — making this Strategy Integration. The paragraph contains two hard verifiable facts (specific date and specific dollar amount), qualifying as Quantified-Verifiable.


reasoning: The paragraph focuses centrally on third-party vendor oversight—specifically the company's limited ability to monitor service provider cybersecurity and the responsibility of vendors for their own programs—making Third-Party Risk the appropriate category. The content contains no named vendors, specific dates, frameworks, tools, or verifiable facts; it relies entirely on generic boilerplate disclaimers about third-party risk that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes—enterprise security controls, training, assessments, vulnerability management, and third-party oversight—all of which are internal processes rather than board governance, specific management roles, or incident disclosure. The specificity is Sector-Adapted because it names the NIST Cybersecurity Framework, a recognized standard, but contains no firm-specific facts that would uniquely identify this company's disclosure.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors. It contains no substantive cybersecurity governance or risk management disclosure—it is purely a navigational element with embedded risk language that serves as a header/citation, not actual disclosure content.


reasoning: The paragraph describes Management's role in overseeing cybersecurity risk and reporting incidents to the board, making 'Management Role' the appropriate category. The content contains no firm-specific facts—no named cybersecurity roles (CISO, CTO, CIO), no specific dates, no named frameworks, tools, or third-party firms—just generic references to 'Management,' 'board of directors,' and 'cybersecurity incidents,' making this purely boilerplate language that could appear in any company's disclosure.


reasoning: The paragraph's primary grammatical focus is on the COO as an individual with specific credentials (30 years of experience) and a defined reporting function to the board, making Management Role the appropriate category. The board's involvement is mentioned in a subordinate clause describing the program review cycle.


reasoning: The paragraph describes the company's own internal approach to overseeing third-party cybersecurity risks, making it about the company's risk management process rather than vendor-specific oversight requirements. No specific dates, dollar amounts, named frameworks, roles, tools, or other verifiable facts are present.


reasoning: The paragraph describes the general nature of an incident response assessment (determining nature, scope, and impact) but provides no specifics about an actual incident, no named personnel, no specific tools, no dates, and no organizational details. This is a generic description of an incident assessment process that could appear in any company's disclosure.


reasoning: The paragraph describes the company's internal risk assessment and safeguard monitoring processes, with the IT consultant mentioned as the responsible function rather than a person with named qualifications or credentials. No named frameworks, specific dates, named third-party firms, tools, certifications, or other distinguishing firm-specific details are present.


reasoning: Paragraph focuses on board and committee oversight of cybersecurity risk, with board as the grammatical subject, making Board Governance the appropriate category. The content contains no hard verifiable facts—no specific dates, named firms, dollar amounts, percentages, or named tools—only generic language about director backgrounds and training that could appear in any company's disclosure.


reasoning: The paragraph focuses on the company's own cybersecurity policies, standards, and practices integrated into ERM — describing internal processes and framework adoption — with only a brief mention of Board oversight as background context, making Risk Management Process the primary category.


reasoning: The paragraph's primary focus is on cybersecurity risk management activities—implementing risk assessment processes, integrating cybersecurity into overall risk strategy, reviewing security assessments—rather than identifying specific management personnel. The COO and Senior Vice President for Operations are general business roles (not cybersecurity-specific titles like CISO or CTO), and the described responsibilities are standard governance functions that apply broadly. No named frameworks, specific dates, named programs, or other distinguishing details are present.


reasoning: The paragraph describes board-level oversight responsibilities with 'Board of Directors' and 'Audit Committee' as the grammatical subjects. While it references cybersecurity risk assessment and management, it does so only in the context of board governance structure, not the company's internal processes themselves. The specificity is Generic Boilerplate because it contains no named cybersecurity-specific roles (CISO, CTO, CIO), no specific committee names beyond standard 'Audit Committee,' no dates, no named third-party firms, no named products/tools, and no specific numbers or certifications.


reasoning: The paragraph describes the company's own internal cybersecurity risk assessment and mitigation structure, with senior management leading and involving IT staff and a third-party partner—placing it in Risk Management Process rather than Third-Party Risk, as the vendor is described as a component of the company's internal process. The paragraph contains no named entities, frameworks, specific dates, or hard verifiable facts; '21 years of experience' refers to an unnamed third-party partner (not a named firm like Mandiant or CrowdStrike) and functions as descriptive context rather than a standalone verifiable external fact.


reasoning: The paragraph is primarily about the VP of IT as a person—their title, qualifications (20 years experience, degrees), and leadership role in cybersecurity oversight—which anchors it in Management Role. While cybersecurity frameworks are mentioned, they appear briefly as context for the VP's oversight activities rather than being the central topic. The VP's specific credentials and background elevate this beyond generic boilerplate.


reasoning: The paragraph focuses on identifying who (the sole executive officer and director) is responsible for cybersecurity oversight and notes his lack of cybersecurity expertise, which is about the management role rather than board governance or internal processes. There are no named frameworks, specific dates, dollar amounts, named roles beyond generic titles, or any other verifiable facts that would elevate specificity beyond generic boilerplate. This is characteristic of SPACs/shell companies disclosing minimal cybersecurity governance structures before commencing operations.


reasoning: The paragraph describes the company's cybersecurity risk management approach, including framework adoption (NIST CSF), technical controls, and monitoring processes, with IHM (the property manager) as the executing entity. The grammatical subject is the company's processes, not the board or a named management role.


reasoning: The paragraph describes the company's own internal cybersecurity program design, controls, systems, and incident procedures, which is core to Risk Management Process. While NIST is named as a framework, the paragraph contains no firm-specific identifiers (no named roles, dates, dollar amounts, or unique company details), making it Sector-Adapted rather than Firm-Specific.


reasoning: The paragraph describes the composition of the Bank's Technology and Operations Committee, which is an internal governance structure overseeing technology and security risk management processes; while it mentions specific roles (CIO, CISO), it is fundamentally about the committee's organizational structure for risk oversight rather than individual qualifications or reporting lines.


reasoning: The paragraph describes the company's internal technical security architecture (cloud database setup, network isolation, firewall), which is an internal risk management process. It contains two named technical elements (AWS RDS, port 80) meeting the Quantified-Verifiable threshold.


reasoning: The paragraph's primary grammatical subject and framing is the board's oversight responsibility for cybersecurity risk management, with management role details functioning as supporting information about the governance structure. The named role 'Vice President of Operations' is not a cybersecurity-specific title per the annotation guidelines (CISO, CTO, CIO, VP of IT/Security, etc.), so it does not elevate to Management Role. No specific dates, dollar amounts, named frameworks, third-party firms, or quantifiable metrics are present, and the language is standard boilerplate that could appear in any company's filing.


reasoning: Paragraph is a forward-looking risk disclaimer describing potential cybersecurity threats and their possible material impacts, containing no description of an actual incident, no named frameworks, no specific dates, and no firm-specific details—only generic language applicable to any financial institution.


reasoning: The paragraph describes the company's cybersecurity monitoring and vulnerability scanning activities performed by an IT Service Provider, which constitutes internal risk management processes. It does not describe an actual incident, board governance, or third-party vendor oversight requirements. No specific facts were identified—the 'IT Service Provider' is an unnamed generic entity, and 'security tools,' 'network infrastructure,' and 'real time' are vague descriptors without product names, dates, or verifiable quantities.


reasoning: The paragraph's grammatical subject is the VP, ISS function, and the majority of content describes what that function does (testing controls, risk assessments, reporting, monitoring, third-party due diligence) — making this about internal processes rather than the person's qualifications or credentials. The Board of Directors appears only briefly as part of the three-lines-of-defense framework, not as the primary subject. While the paragraph contains the cybersecurity-specific title 'VP, ISS,' it lacks any hard verifiable facts (no specific dates, dollar amounts, headcounts, named third-party firms, or named products/tools), rendering it generic boilerplate that could apply to many financial institutions.


reasoning: The paragraph describes the company's own internal incident response and recovery planning processes, including plan documentation, testing, and data backups—all hallmarks of internal risk management. No specific cybersecurity roles, named committees, incidents, financial impacts, or vendor oversight are discussed.


reasoning: The paragraph explicitly discloses that the company has not adopted any formal cybersecurity risk management program or processes, placing it squarely in the None/Other category per the guidance for companies disclosing the absence of a cybersecurity program. The materiality statement at the end is standard boilerplate with no incident narrative.


reasoning: The paragraph's primary focus is on the CISO as a person—their specific title, detailed qualifications (MS degree, named certifications), career history (thirty years of experience), and reporting structure—making this a Management Role disclosure. The paragraph contains multiple hard verifiable facts: named certification bodies (ISC2, IAPP), specific degree (MS in Cybersecurity Operations), specific tenure (thirty years), and specific reporting line to named roles (Executive Vice President and Chief Innovation Officer, Executive Committee, CEO), satisfying the Quantified-Verifiable threshold of two or more hard facts.


reasoning: The paragraph describes the company's own internal risk assessment activities and technical safeguards (MFA, PAM, vulnerability scanning, patch management, etc.), which are the company's internal processes for managing cybersecurity risk. No named frameworks, specific dates, named tools, or unique identifiers appear—the listed controls are common security practices applicable to any organization.


reasoning: The paragraph is primarily about oversight requirements imposed on third-party service providers (detailed questionnaires, annual attestation reviews), which is the core of Third-Party Risk classification. While vendors are described as part of the internal cybersecurity program, the specific requirements imposed ON them (questionnaire completion, annual independent attestation reviews) and the stated purpose of ensuring vendor controls meet company security requirements clearly center on vendor oversight rather than general internal processes.


reasoning: The paragraph describes the company's own internal security safeguards (firewalls, intrusion detection/prevention, anti-malware, external service providers for testing), which is a description of internal risk management processes rather than oversight of third-party vendors. All described elements are generic security measures with no named products, named third-party firms, specific dates, or quantified details, making this standard boilerplate language applicable to any company.


reasoning: The paragraph describes what Exelon's cybersecurity function DOES (threat intelligence collection, detection tools, vulnerability management, incident response coordination, regulatory compliance) rather than the CISO's personal qualifications, tenure, or background — the CISO is mentioned as the grammatical subject but the content focuses on organizational processes, making Risk Management Process the correct category. The paragraph names several regulatory frameworks (NERC CIP, TSA Security Directives) and industry programs (CRISP, E-ISAC) but lacks any firm-specific facts that would uniquely identify this as Exelon's disclosure; the listed tools and practices are standard utility sector cybersecurity measures.


reasoning: The paragraph describes the company's internal process for assessing and reporting cybersecurity threats through the MAT committee, including convening triggers and communication responsibilities — a description of the company's own risk management process rather than board oversight or management personnel specifics.


reasoning: The paragraph's grammatical subjects are the COO and CFO, who are identified as key intermediaries in the cybersecurity reporting chain, making this primarily about management's role in cybersecurity oversight rather than the Board's oversight role. The specificity is Generic Boilerplate because COO and CFO are generic C-suite roles (not cybersecurity-specific), 'Board' is a standard governance body, and 'information technology providers' are unnamed third parties—no specific facts unique to this company appear.


reasoning: The paragraph describes the company's own internal incident response planning and procedures, with the grammatical subject being 'We' and 'Our incident response and management plans.' The mention of the Board is incidental (as a notification recipient), not the subject of governance oversight. No specific dates, named frameworks, cybersecurity-specific roles (CISO/CTO), named third-party firms, or other hard facts appear—only generic descriptions of standard IR planning that could appear in any company's disclosure.


reasoning: Paragraph describes an actual cybersecurity incident (February 2023 ransomware attack) including what happened (network servers encrypted), response actions (internal IT + third-party teams restored servers, restored from backups), operational scope (minimal disruption to manufacturing, sales, order processing, distribution), and that no ransom was paid. Contains one firm-specific fact (specific month/year).


reasoning: The paragraph describes the company's internal governance and risk management structure for cybersecurity, with IT and C&RM teams as the grammatical subjects responsible for establishing policies and procedures, and Internal Audit providing independent validation. The four named professional certifications (CISSP, CISM, CRMA, CRISC) distinguish this from generic boilerplate, making it firm-specific rather than sector-adapted.


reasoning: The paragraph describes the RCOC's oversight responsibilities, with the board committee as the grammatical subject performing governance functions. While 'Risk and Compliance Oversight Committee' is a named committee, the oversight activities described (overseeing cybersecurity programs, reviewing risk exposure, updating the full board) are standard governance functions that could appear in any company's filing. No hard verifiable facts (dates, dollar amounts, headcounts, named third-party firms, or named tools) are present, and the named committee alone does not elevate this beyond boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management structure and oversight processes, including a management-led cybersecurity committee (not a board committee) with specific cross-functional composition. While it mentions governance roles, the focus is on the company's own risk management processes and team deployment, not board-level oversight.


reasoning: The grammatical subject is the Board of Directors and its Risk and Information Security Committee, discussing their oversight responsibilities for cybersecurity risk—this is board governance content. The paragraph contains no specific verifiable facts: no named frameworks, tools, dates, dollar amounts, headcounts, or named third-party firms. The committee name 'Risk and Information Security Committee' is more specific than 'Audit Committee' but does not elevate the paragraph beyond generic boilerplate language about board oversight duties that could appear in any company's disclosure.


reasoning: The paragraph describes the company's internal process for identifying and responding to security incidents, including monitoring systems, detecting deviations, collecting evidence, and documenting findings. This is clearly about the company's own risk management processes. No specific facts are present—the language ('IT systems,' 'deviations from normal operations,' 'document everything') is generic and could appear in any company's disclosure.


reasoning: This paragraph is a forward-looking risk factor disclaimer describing hypothetical cybersecurity threats and their potential consequences, not a description of actual incidents, governance processes, or management roles. It contains no specific facts—no dates, named entities, dollar amounts, specific tools, or firm-unique details—and consists entirely of generic boilerplate language about cybersecurity risks.


reasoning: The paragraph describes an actual cybersecurity incident with specific details including the date (June 2023), scope (two employee email accounts), notification timing (early September 2023), and financial impact ($25,000). Per the tiebreaker rules, when a paragraph describes what happened in an incident with dates, access details, scope, and response actions, it qualifies as Incident Disclosure rather than Strategy Integration.


reasoning: The paragraph describes an actual cybersecurity incident (information exfiltration from accessed IT systems) and the ongoing investigation into its scope, making it an Incident Disclosure. However, it contains no specific verifiable facts—no dates, named firms, named tools, dollar amounts, or other unique identifiers—making it Generic Boilerplate.


reasoning: This paragraph discusses the ongoing status of an actual cybersecurity incident referenced elsewhere in the filing, describing current investigation findings and the continuing scope of affected data/systems review. However, it contains no firm-specific details—no dates, named firms, tools, or quantifiable metrics—making it standard incident-status language that could appear in any company's disclosure.


reasoning: The paragraph describes general security controls and mitigation measures for managing cybersecurity risks, which falls under internal risk management processes. However, the language is entirely generic boilerplate—no named frameworks, tools, roles, dates, or any other identifiable company-specific information that would elevate it beyond generic.


reasoning: The paragraph's primary grammatical subjects are the Board and Audit Committee overseeing cybersecurity risk, which is the defining characteristic of Board Governance. Although CEO and CFO responsibilities are mentioned, they are presented in the context of implementing the Board's oversight framework rather than as the main topic. The content contains no specific facts—all entities (Audit Committee, CEO, CFO) are generic, cadences are vague ('regular'), and no named frameworks, tools, dates, or numbers are present, making this standard boilerplate governance language.


reasoning: The paragraph describes the company's own internal incident response policy and plan processes (triage, assess severity, escalate, contain, investigate, remediate) with no mention of board governance, management roles, vendors, or actual incidents. This is a description of internal cybersecurity risk management procedures. All elements are generic and could appear in any company's filing—no named frameworks, specific dates, dollar amounts, named third parties, named tools, or firm-specific identifiers are present.


reasoning: The paragraph centers on management's responsibility for cybersecurity risk management, explicitly identifying R. LaDuane Clifton as the CFO/Secretary/Treasurer who is responsible for assessing and managing material cybersecurity risks. While the Board is mentioned, it serves as context for the management structure rather than being the primary subject. The specific mention of a named individual with cybersecurity responsibility and the team composition makes this a Management Role disclosure.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes: integration into broader ERM, internal team collaboration, vulnerability detection processes, and incident notification procedures. No specific incident is described, no board oversight is the subject, and no vendor oversight requirements are discussed. The mention of 'Head of Information Security' is a cybersecurity-specific role that elevates specificity beyond generic boilerplate, but the paragraph lacks hard verifiable facts (specific dates, dollar amounts, named third-party firms, or named tools) that would reach Quantified-Verifiable.


reasoning: The paragraph's main thrust is a materiality/risk assessment conclusion ('we believe the risk of significant cybersecurity incidents is minimal') rather than a description of governance structures or processes. While the CEO is mentioned, the paragraph functions as a risk posture statement, not a description of the management role or internal processes.


reasoning: The paragraph describes the company's internal cybersecurity approach (risk-based approach and policies), which falls under Risk Management Process, but all language is completely generic boilerplate with no named frameworks, specific processes, roles, or other identifiable company-specific details.


reasoning: The paragraph's grammatical subject is 'Our Board' and it describes the board's oversight role over cybersecurity risk, fitting the Board Governance category. The language is entirely generic—no named committees (e.g., 'Audit Committee' or 'Cybersecurity Committee'), no specific titles (CISO/CIO/CTO), no dates, named frameworks, or other identifiable specifics. This is standard boilerplate applicable to any public company.


reasoning: The paragraph describes the company's internal cybersecurity processes—monitoring/detection systems, incident response practices, and employee training—but all language is generic and boilerplate. No named frameworks, specific dates, dollar amounts, named roles, named products, or other firm-specific facts are present. The paragraph could apply to virtually any company's filing unchanged.


reasoning: The grammatical subject throughout the paragraph is the Chief Security Office/Chief Security Officer, describing their function (metrics framework, reporting cadence, communication responsibilities) rather than describing what the board does independently. The named parent entity Deutsche Bank Group and the specific committee name provide firm-specific identification beyond generic governance language.


reasoning: The paragraph identifies specific management roles (VP of Risk Management, MSSP personnel, external audit personnel) and details their professional certifications and qualifications. Per the Person-vs-Function test, the paragraph is about who holds what credentials rather than what processes those individuals execute. The certification claims represent specific organizational facts about this company's personnel qualifications.


reasoning: The paragraph centers on the Board's oversight responsibilities and management-to-board reporting cadence (quarterly updates on cybersecurity risks and incidents), making Board Governance the primary category. However, all statements use 'We expect' language describing planned future practices rather than current operational realities, and no firm-specific details are present—no named committees, specific dates, named programs, or unique organizational facts—resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the company's general internal processes for incident response and recovery planning, which falls under risk management activities rather than describing an actual incident or naming specific roles/frameworks. No specific dates, named tools, third-party firms, or firm-unique details are present, making this standard boilerplate language applicable to any company's disclosure.


reasoning: This paragraph is a standalone materiality conclusion stating that past cybersecurity incidents have not had a material adverse effect, with no description of actual incidents (no dates, scope, or what occurred). The reference to 'past cybersecurity incidents' is incidental to the main point of assessing financial impact, which is the defining characteristic of Strategy Integration. The language is entirely boilerplate—'material adverse effect,' 'business, operations or financial condition,' and forward-looking disclaimers are standard formulations that could appear in any company's filing.


reasoning: The paragraph states an absence of material cybersecurity incidents (negative disclosure) and contains a cross-reference to risk factor disclosures at Item 1A. There is no substantive disclosure about board oversight, management roles, internal processes, or actual incidents—only boilerplate language about potential future risks and a cross-reference, which classifies as None/Other.


reasoning: The paragraph's primary focus is describing a specific past cybersecurity incident (the 2021 ransomware attack), including what happened (external actor accessed network data) and its consequences (class action lawsuit in settlement), which meets the criteria for Incident Disclosure as the dominant content category.


reasoning: The paragraph's grammatical subject is the board of trustees, and it focuses on board-level oversight of cybersecurity risk as well as the specific expertise of two named trustees. This is Board Governance content. The naming of specific individuals (Nathaniel A. Davis and Patricia L. Gibson) with specific cybersecurity expertise qualifies this as Firm-Specific rather than Generic Boilerplate, as no other company's disclosure would have these same named trustees with these particular qualifications.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its approach to identifying, assessing, and mitigating data/system risks—this is a description of internal processes. No board or management roles are mentioned as the grammatical subject, no actual incident is described, and no vendor-specific oversight is the central topic.


reasoning: The paragraph describes a cybersecurity incident—what happened (disruptions, limited access), response actions taken (systems taken offline, restored), and approximate timeline (within a week)—which is the defining characteristic of Incident Disclosure. However, it contains no specific verifiable facts: no named products/tools, no third-party firms, no specific dates, no dollar amounts, and no hard metrics. The vague reference to 'a week' is approximate, not a specific duration.


reasoning: The paragraph primarily describes the company's own internal cybersecurity program structure and risk management processes (ERM integration, framework adoption), with roles mentioned as components of that structure rather than as the central focus. Board governance is mentioned but only as oversight context for ERM, not as the main subject.


reasoning: The paragraph combines a generic commitment statement with a negative disclosure (no incidents), neither of which constitutes an actual incident narrative, financial materiality assessment, or substantive description of board oversight processes.


reasoning: The paragraph describes internal incident-handling processes — how the VP of IT and IT security team receive notifications, assess criticality, formulate responses, and engage the Audit Committee — which is the company's own risk management workflow rather than board oversight or executive qualifications. The VP of IT title and incident response plan are firm-specific identifiers that distinguish this disclosure from generic boilerplate.


reasoning: The paragraph primarily describes the company's internal cybersecurity governance structure and oversight processes (the committee composition, meeting cadence, and reporting line), which maps to Risk Management Process rather than Board Governance since this is a management-level committee, not the board itself. The past incidents are mentioned only as context for why these controls exist, not as the central topic. The committee composition with specific named roles (EVP of Technology, Director of IT, General Counsel) provides firm-specific organizational detail beyond generic boilerplate.


reasoning: This paragraph is a generic definition/explanation of Denial of Service attacks as a threat type, containing no information about the company's own cybersecurity program, governance, incidents, or processes. It is educational content that could appear verbatim in any company's filing and does not constitute substantive disclosure.


reasoning: The paragraph describes the company's own internal cybersecurity risk management processes and framework adoption, which is the core of the Risk Management Process category. It is not about board governance, management roles, or an actual incident.


reasoning: This paragraph is a forward-looking disclaimer about potential future incidents with a cross-reference to the Risk Factors section. It contains no substantive cybersecurity disclosure—no incident description, governance details, processes, or specific facts about the company's cybersecurity posture.


reasoning: This paragraph describes the company's internal Enterprise Information Systems Security Policy and its objectives—creating an ISMS, protecting CIA triad, maintaining security controls, and managing cyber risks. These are the company's own internal processes, fitting 'Risk Management Process.' The paragraph contains no named external standards (NIST, ISO 27001), no specific dates, no named tools or firms, and no unique identifiers—it describes generic security framework objectives that could appear in any company's filing.


reasoning: The paragraph describes the company's own internal information security processes for managing cybersecurity risk to their systems and data, which falls under Risk Management Process. While 'third party hosted services' appears, it is listed as an asset being protected rather than a topic about vendor security oversight or contractual requirements. The paragraph contains no specific dates, dollar amounts, named frameworks, tools, or other uniquely identifying facts—it is entirely generic language about cybersecurity risk management that could appear in any company's filing.


reasoning: The paragraph centers on the Director of Information Security's role, reporting structure, and committee participation, with the last substantive sentence entirely focused on this management role. While the Board is mentioned earlier, it serves as context for the Director's reporting relationship to the Risk Committee rather than being the main subject. The Director of Information Security is a cybersecurity-specific title, and the named committee memberships (Operational Risk, IT Steering, and Risk Committees) provide firm-specific organizational detail.


reasoning: The paragraph describes a real cybersecurity incident (fraudulent email leading to erroneous wire transfer), specifying when it occurred, the financial scope, and the response actions taken—core elements of Incident Disclosure. It contains two independently verifiable hard facts (specific date range and dollar amount), meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes an information technology department's responsibilities for managing internal cybersecurity processes (risk assessment, security controls, incident response), which aligns with the 'Risk Management Process' category as it focuses on the company's own internal functions rather than a specific named management role or incident disclosure. The specificity is Generic Boilerplate because it uses entirely standard organizational language ('information technology department') and generic process descriptions ('cybersecurity risk assessment processes,' 'security controls') with no named frameworks, specific roles, dates, numbers, or other distinguishing facts.


reasoning: The paragraph explicitly focuses on vendor oversight processes (security assessments before engagement, ongoing monitoring for compliance), making Third-Party Risk the central topic per the 'central topic' tiebreaker. However, all described practices are standard boilerplate language with no named vendors, specific tools, named programs, or unique identifiers—any company could paste this unchanged. The closing materiality statement is a brief acknowledgment rather than the main focus, so it does not shift the category to Strategy Integration.


reasoning: The paragraph describes board committee oversight of cybersecurity risk, specifically detailing how the Audit and Reserves Committee receives updates from the VP of Information Technology. The mention of the 'Audit and Reserves Committee' (a specific committee name, not generic 'Audit Committee') and the named VP role make this firm-specific.


reasoning: The paragraph describes the company's own internal information security program (ISP) and its control domains, focusing on what the company's cybersecurity function does rather than naming individuals, describing an incident, or discussing board oversight. While 'Service Provider Management' appears as one of many domains, it is incidental to the main topic of the company's own security posture. All domain names listed (Data Protection, Account and Access Control Management, etc.) are standard security categories with no unique identifiers, named frameworks, or firm-specific details.


reasoning: The paragraph describes cybersecurity controls and processes (threat intelligence, incident-response, information sharing) but uses only generic industry terminology without any named frameworks, specific products, named third-party firms, dates, or quantified metrics. All security practices mentioned are common across the industry and could appear in any company's disclosure.


reasoning: The paragraph's grammatical subject is the Cybersecurity Committee (a board-level committee), describing its composition, role, and oversight function—this is governance of cyber risk at the board level. While individual member qualifications are discussed, they serve to explain committee competence, making board governance the primary focus. The named Cybersecurity Committee with four members and the specialized Director of IT role (Infrastructure and Flight Systems) provide firm-specific details beyond generic governance language.


reasoning: The paragraph describes the company's cybersecurity measures (prevention, detection, response) and their review cadence, which falls under Risk Management Process. However, it contains only generic, non-specific language ('these measures,' 'regularly reviewed') with no named frameworks, roles, dates, tools, or other identifying details that would elevate it beyond boilerplate.


reasoning: The paragraph's grammatical subject is the informational technology consultant and it emphasizes their qualifications (25 years of experience), making it primarily about the management role rather than the process itself. However, the specificity is Generic Boilerplate because 'informational technology consultant' is not a cybersecurity-specific title, and 'over 25 years of experience' is a vague, non-verifiable soft fact with no hard external facts that could be independently confirmed.


reasoning: The paragraph describes management's supervisory processes for cybersecurity threat management (briefings, threat intelligence, security tool alerts) — these are internal risk management functions. No specific persons, named frameworks, dates, dollar amounts, or named third-party firms appear; all references are generic (e.g., 'external consultants,' 'security tools deployed'), making this Generic Boilerplate.


reasoning: The paragraph describes the integration of cybersecurity risk management into the enterprise risk management (ERM) program, which is an internal risk management process. While substantive, it contains no specific facts—no named frameworks, dates, roles, or verifiable details that would distinguish this disclosure from any other company.


reasoning: The paragraph describes a specific cybersecurity incident (February 14, 2025 unauthorized third-party access) including what systems were affected (email systems) and the operational impact (misdirected vendor payments). This goes beyond a brief mention—it provides substantive incident narrative including scope and consequences. The materiality conclusion at the end is secondary to the incident description itself.


reasoning: The paragraph describes the company's internal cybersecurity monitoring processes, vulnerability assessments, and incident response planning, all of which are internal risk management processes. While the CISO is mentioned as the grammatical subject performing these activities, the paragraph focuses on what the function does (monitoring, deploying safeguards, incident response) rather than the CISO's qualifications or background, making Management Role inappropriate. The paragraph contains no specific dates, dollar amounts, named third-party firms, or unique firm identifiers—it describes generic security measures and team composition that could appear in any company's filing.


reasoning: This paragraph describes a specific cybersecurity incident with concrete dates (February 23 and February 28, 2023), system impact scope (internal servers, IT telephony), data exfiltration, and documented response actions (incident response activation, engagement of experts, law enforcement notification). The two specific dates constitute two independently verifiable hard facts, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal approach to managing cybersecurity risks, using vendors as resources within that process. The vendors listed (threat intelligence, consultants, penetration testing firms) are generic categories without named entities, making this internal process description rather than third-party risk oversight. The language is generic boilerplate that could appear in any company's disclosure—no named firms, tools, dates, or specific frameworks.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities—senior executives protecting systems, coordinating incident responses, engaging an MSP, and holding regular meetings. No actual cybersecurity incidents are described, no specific management roles (CISO/CIO) are named, and no financial or materiality impacts are discussed. This is standard generic language about internal processes.


reasoning: The paragraph's grammatical subject is 'Oblong's Director of IT,' identifying a management role responsible for cybersecurity, which fits the Management Role category. The content describes the person's experience and responsibilities, but the described activities (monitoring for threats, investigating security events) are generic cybersecurity practices applicable to any organization. No firm-specific identifiers, named frameworks, certifications, or other specific facts are present, making this Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and monitoring processes (re-designing safeguards, monitoring effectiveness, managing risks) with the IT consultant mentioned as the handler of these processes rather than as a qualified individual whose credentials are the focus. No specific frameworks, tools, dates, dollar amounts, or named third-party firms appear—all process descriptions are generic.


reasoning: The paragraph describes the company's own internal cybersecurity processes (scans, penetration tests, vulnerability assessments, tabletop exercises) and engagement of external service providers. However, it contains no named frameworks, no named third-party firms (only generic 'leading cybersecurity firms'), no specific dates, numbers, or other verifiable facts — all practices mentioned are common industry activities without any firm-specific details.


reasoning: This paragraph is a non-occurrence statement asserting no material cybersecurity incidents have happened, combined with a generic forward-looking commitment to monitoring. It contains no description of actual incidents, no specific processes, no named frameworks, roles, dates, or other substantive details. It reads as boilerplate 'nothing to report' language with no substantive cybersecurity disclosure.


reasoning: The paragraph describes the company's internal approach to cybersecurity—engaging external firms for security engineering, assessments, and control audits—which constitutes the company's own risk management processes. Although external firms are mentioned, they are described as resources the company uses rather than vendors whose security posture the company oversees, so Third-Party Risk does not apply. No specific firms, dates, frameworks, or other identifying details are provided, making this standard boilerplate language.


reasoning: The CISO is the grammatical subject, and the paragraph describes the management role's function within the governance structure (supervising and assisting the ERMC). While it describes processes, the focus is on establishing who is responsible for cybersecurity oversight, not on the internal risk management processes themselves.


reasoning: This paragraph is fundamentally a forward-looking risk disclaimer (explicitly referencing Item 1A Risk Factors) rather than a description of an actual cybersecurity program or governance structure. While it mentions cybersecurity measures in general terms (security technologies, internal controls, disaster recovery), all items are generic boilerplate with no specific frameworks, named processes, dates, or firm-specific details. It reads as risk factor language rather than substantive Item 1C disclosure about the company's actual cybersecurity oversight or processes.


reasoning: The paragraph describes the company's internal access management controls and processes, including provisioning, least-privilege methodology, and routine access reviews—this is internal security process documentation. Third-party environments are mentioned only as a component of the internal process, not as the central topic of vendor security oversight. The paragraph contains no named standards, tools, dates, dollar amounts, headcounts, or other verifiable specifics that would elevate it beyond generic security language.


reasoning: The paragraph describes the company's internal incident response process—assessing/classifying incidents by severity, escalating to executive leadership, and notifying the Board—which is a description of the company's own risk management procedures. The language is entirely generic ('global incident response process,' 'senior executive leadership,' 'as appropriate') and could appear in any company's 10-K filing without modification.


reasoning: The paragraph describes the company's own vendor management program—its own internal processes for assessing and managing third-party cybersecurity risks. While vendors are mentioned, they are the object of the company's internal process, not the subject of independent vendor-side requirements. The described practices (security questionnaires, reviews, audits, contractual obligations) are standard, generic vendor oversight activities with no specific dates, named frameworks, named tools, or unique identifiers.


reasoning: The paragraph describes the company's internal governance structure for cybersecurity oversight—specifically management committees, their chairs, their composition, and their meeting cadences. While it references board-level oversight, the grammatical subject is the management committee structure and their risk management activities (identification, monitoring, assessment, oversight of risk management strategy), making Risk Management Process the appropriate category. The named committees (IT Steering Committee, Operational Risk Management Committee, Innovation and Technology Committee) and specific roles (CISO, CIO, Chief Operational Risk Management Officer) with concrete meeting frequencies distinguish this as firm-specific rather than generic boilerplate.


reasoning: The primary focus is a materiality conclusion about 2023 (no material threats) with a brief mention of a 2022 incident and costs. Under the tiebreaker rule, a brief mention of a past incident alongside a materiality conclusion as the main point classifies as Strategy Integration. The June 2022 date provides one firm-specific fact, though the incident description is minimal and costs are described only qualitatively as 'considerable' without amounts.


reasoning: The paragraph's grammatical subjects are management roles (ERM committee, cybersecurity committee, CTO, COO, chief compliance officer) and describes their specific composition and reporting relationships. While it touches on processes (oversight, risk assessment), the primary focus is identifying WHO holds cybersecurity oversight responsibilities. The paragraph contains firm-specific organizational structure (separate cybersecurity and ERM committees) and specific role compositions not found in generic filings.


reasoning: The paragraph centers on vendor oversight (assessment of third-party providers, SOC 2 review, contractual notification requirements), which maps to Third-Party Risk. While the opening phrase references the company's own risk management process, the substantive content describes requirements and controls imposed on vendors. The mention of SOC 2 reports elevates this to Sector-Adapted, but no firm-specific identifiers (named vendors, specific dates, named programs, or named personnel) are present.


reasoning: This paragraph focuses on insurance reimbursements and a materiality conclusion regarding a Data Incident, not on describing the incident itself. Per the tiebreakers, paragraphs that discuss financial cost, insurance, or materiality of an incident WITHOUT describing the event are classified as Strategy Integration. The language is standard boilerplate materiality language ('has not had a material impact,' 'materially affected') that contains no named entities, dates, dollar amounts, or other specific facts unique to Caesars.


reasoning: This paragraph is a standalone materiality conclusion stating that known cybersecurity threats and prior incidents have not materially affected the company, followed by a cross-reference to Risk Factors. As a materiality disclaimer without any incident narrative or description, it falls under Strategy Integration per the tiebreaker rules. The cross-reference to Risk Factors does not change this classification. There are no firm-specific facts, named entities, dates, or framework mentions—just generic boilerplate language.


reasoning: This paragraph describes the company's general threat intelligence monitoring activity as part of its internal security operations, which is a risk management process. However, it contains no specific details—no named threat intelligence sources, no specific tools or products, no dates, no named third-party firms, and no quantifiable information—that would distinguish it as firm-specific. The language is entirely generic boilerplate that could appear in any company's cybersecurity disclosure.


reasoning: The paragraph describes the company's own internal cybersecurity processes (threat hunting, monitoring, penetration testing, third-party evaluations) as part of their risk management program. While it mentions third-party service providers, it does so as a component of the company's internal review process rather than as a standalone discussion of vendor oversight requirements. There are no hard verifiable facts—no specific dates, dollar amounts, named cybersecurity firms, named tools, or specific headcounts. The named entities (U.S. government, law enforcement, customers, defense industry participants) are broad categories of partners, not named third-party verification firms. All activities described (monitoring, penetration testing, framework audits) are common industry practices applicable to any defense contractor.


reasoning: The paragraph's grammatical subjects are 'our CISO' and 'which committee' describing reporting lines and committee structure. While it mentions internal processes (monthly reviews, policies), the central focus is establishing CISO responsibility and reporting relationships between management-level bodies. This aligns with Management Role rather than Risk Management Process because the CISO is explicitly identified as the grammatical subject responsible for the described function.


reasoning: The paragraph is a standalone materiality conclusion stating that cybersecurity threats have not materially affected the company, with no description of any actual incident. The cross-reference to Risk Factors is appended to the materiality statement, making this primarily a Strategy Integration disclosure per tiebreaker rules.


reasoning: The paragraph describes the company's own internal cybersecurity risk management activities, with third-party providers mentioned as a resource used within those processes. No specific vendors, tools, frameworks, or other identifying details are named, making this entirely generic boilerplate language.


reasoning: This paragraph centers on a standalone materiality conclusion ('no such incident has had any such impact to date') and cross-references to Risk Factors, making Strategy Integration the appropriate category per tiebreaker rules. While it briefly mentions developing 'protocols, controls, and systems,' these are entirely generic terms with no named frameworks, roles, dates, products, or other identifiable specifics that would elevate the specificity.


reasoning: The paragraph describes the company's internal processes for gathering cybersecurity threat intelligence and informing long-term strategy through consultation with specific cybersecurity roles (CDO, CISO) and the Audit Committee, making it primarily about Risk Management Process rather than any single role's function.


reasoning: This paragraph is a standard forward-looking risk disclaimer using boilerplate materiality language ('reasonably likely to materially affect us') that could appear in virtually any SEC filing. It contains no description of actual cybersecurity incidents, governance processes, management roles, or risk management activities—only a generic acknowledgment of cybersecurity threat risks.


reasoning: The paragraph describes the company's integration of cybersecurity into its enterprise risk management framework and mentions identifying/mitigating known threats, which are internal processes rather than board governance, management roles, or incident disclosure. There are no specific dates, named frameworks, tools, roles, or other verifiable facts—the language is standard forward-looking risk management boilerplate.


reasoning: The paragraph describes a concrete cybersecurity incident with what happened (fraudulent email → erroneous wire transfer), scope ($0.7M), and response actions (procedural review with outside consultant), fitting the incident narrative requirements for Incident Disclosure. The specific dollar amount provides one hard verifiable fact, making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph's central topic is vendor/supplier security oversight, describing due diligence processes and contractual obligations imposed on third parties — fitting Third-Party Risk. The language is entirely generic (no named frameworks, specific vendors, tools, dates, or firm-unique identifiers) and could appear in any company's filing unchanged.


reasoning: The paragraph centers on a materiality conclusion (no material cybersecurity incident in FY2023) and discusses potential business/financial impacts of future incidents, which aligns with Strategy Integration. While it references a specific fiscal year, the remainder is generic risk acknowledgment language without named frameworks, specific tools, named third parties, or other hard verifiable facts.


reasoning: The paragraph's grammatical subjects are the company's third-party service providers, focusing on requirements imposed on them (due diligence, contractual obligations, external audits) rather than describing the company's own internal processes. This is vendor oversight as the central topic, not a component of internal processes.


reasoning: This paragraph is an introductory risk acknowledgment statement about cybersecurity importance and evolving threats, containing no actual incident narrative, specific governance processes, named roles, or financial materiality conclusions. It functions as preamble language rather than substantive disclosure, fitting the None/Other category.


reasoning: While the CEO (a management role) is the grammatical subject, the paragraph's main focus is the Audit Committee's oversight of cybersecurity risk through regular briefings—this aligns with Board Governance. However, the CEO is a generic C-suite role (not cybersecurity-specific), and the Audit Committee is a standard committee, yielding low category confidence. No specific facts are present: the CEO is generic, the Audit Committee is standard, cadence is vague ('minimum frequency of once per year' is not a specific date or quantified number), and the briefing topics are generic descriptors without named programs or verifiable details.


reasoning: The grammatical subjects are the CISO and Cybersecurity Committee, both management-level roles/entities, with the paragraph describing their oversight function over cybersecurity policies and processes. The CISO title and named Cybersecurity Committee provide firm-specific identification of these roles rather than generic boilerplate governance language.


reasoning: The paragraph describes the company's internal security framework (EISF) and its harmonization with multiple industry standards, which is an internal risk management process. The named standards (NIST, ISO 27001, FERPA, PCI DSS, GLBA, CCPA, GDPR) are all commonly referenced frameworks without any company-specific implementation details, no named third-party firms, no specific dates, no dollar amounts, no headcounts, and no certifications beyond mere naming of the standards.


reasoning: While the paragraph opens with board oversight context, the substantive disclosure focuses on identifying a specific named role (Director of Information Technology and Data Management Systems) and their qualifications and reporting line. This makes Management Role the primary category.


reasoning: This paragraph describes an actual cybersecurity incident with two specific dates (Feb 23 and Feb 28, 2023), a named entity (DISH Network), affected systems (internal servers and IT telephony), response actions, and data extraction scope—meeting the definition of Incident Disclosure. The two specific dates qualify this as Quantified-Verifiable.


reasoning: The paragraph focuses on identifying the CIO and VP of Information Security and describing their qualifications/experience, making Management Role the appropriate category. While it names cybersecurity-specific roles, it contains no hard verifiable facts—no specific dates, dollar amounts, named third-party firms, or named products/tools—so it remains Generic Boilerplate.


reasoning: The paragraph describes the company's internal risk assessment and escalation process for cybersecurity threats, including the hierarchical workflow and who participates in threat evaluation and response planning—this is an internal management process, not board governance or a disclosed incident.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment process through a cross-functional Cybersecurity Council meeting quarterly, with input from specific cybersecurity leadership roles. This is about internal governance processes, not board oversight or an actual incident. The named internal body and specific departmental composition distinguish it from boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity team structure, its expertise composition, and day-to-day responsibilities for implementing the cybersecurity program. While named roles (CIO, Director of Cybersecurity) appear, they are grammatical objects (being supported) rather than the subject—the focus is on the team's function, not the individuals' qualifications. This qualifies as Risk Management Process.


reasoning: The paragraph provides a detailed narrative of an actual cybersecurity incident from 2021, including the nature of the attack (malware), response actions (quarantine, server rebuild), and measurable impacts (1,700 cancellations, $16M loss). This is not a brief mention of a past incident with a materiality conclusion as the main point—it substantively describes what happened. Contains multiple independently verifiable hard facts (specific year, specific cancellation count, specific dollar amount, specific recovery period) qualifying as Quantified-Verifiable.


reasoning: The paragraph describes Hilltop's own risk management process—specifically how the company uses third-party experts to evaluate and test its internal systems. Third parties are a component of Hilltop's process, not the central topic of vendor oversight. No named third-party firms, specific dates, dollar amounts, or named tools appear; the cadences mentioned ('each year,' 'at least every two years,' 'more than three years') are generic organizational policies without verifiable hard facts, making this Generic Boilerplate.


reasoning: The paragraph's grammatical subject and primary focus is on the management structure for cybersecurity—identifying the CIO and director of IT roles, their qualifications (extensive experience), reporting lines, and responsibilities. While annual assessments and audits are mentioned, they serve as supporting context for the management discussion rather than the central topic.


reasoning: The paragraph's primary purpose is a materiality conclusion—that cyber threats have not materially affected the Company since 2017—framed by a brief acknowledgment of past incidents from 2016-2017. The incidents are mentioned only as context for why the framework was strengthened, not as an incident narrative; therefore, this is Strategy Integration under the tiebreaker rule for brief incident mentions with materiality as the main point. The named years 2016 and 2017 are firm-specific facts, but only one hard fact is present (not two+), so specificity is Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes the company's own internal cybersecurity processes and programs (training, monitoring, vulnerability management), with no mention of the board or named management individuals as grammatical subjects, making this a Risk Management Process disclosure. All elements listed are generic cybersecurity practices with no named frameworks, specific dates, dollar amounts, headcounts, named third-party firms, or unique firm-specific identifiers.


reasoning: The paragraph describes the company's internal incident response and vulnerability management policies, including escalation procedures and reporting to the Audit Committee — these are the company's own internal processes. While specific roles are mentioned (CFO, Executive Director of IT, VP of Finance), they are described in the context of what the process does, not as a focus on the persons themselves. The specificity is Generic Boilerplate because the roles named are either generic C-suite titles (CFO, VP of Finance) or not cybersecurity-specific (Executive Director of IT), and the Audit Committee is a standard committee — none of these constitute firm-specific facts under the classification criteria.


reasoning: This paragraph is a standalone materiality conclusion stating that no cybersecurity threats have materially affected the company, with a cross-reference appended. Per the tiebreaker rules, materiality disclaimers are classified as Strategy Integration even when boilerplate; the appended cross-reference does not change this classification. The paragraph contains no named frameworks, dates, dollar amounts, named tools, or other specific facts — all language is generic SEC boilerplate.


reasoning: The paragraph focuses on the company's own internal processes for reviewing, auditing, and assessing its cybersecurity program—the Information Security Program's periodic reviews, audit procedures, and annual risk maturity assessment. While the Board of Directors is mentioned, it appears as the recipient of reports and approver, not as the active governance subject. The mention of the FFIEC Cybersecurity Assessment Tool elevates this from generic boilerplate to sector-adapted, as FFIEC is a recognized federal banking framework.