content_category: Board Governance

category_confidence: medium

specificity_confidence: medium

reasoning: The paragraph's grammatical subjects are the Committee and the full Board, describing board-level oversight of cybersecurity including reporting and briefing cadences. The CISO appears only as a presenter to the board in the context of board education, not as the subject of the paragraph describing their qualifications or role. The mention of external experts is generic (unnamed). The 'at least annually' cadence is too vague to constitute a specific fact.

provider: minimax

stage: benchmark


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is a generic introductory statement expressing the company's understanding of cybersecurity importance; it contains no substantive disclosure about governance structures, management roles, processes, incidents, or financial materiality.


content_category: Risk Management Process

reasoning: The paragraph describes the company's own internal cybersecurity training programs and technology-based tools for mitigating risk, which are internal risk management processes. There are no named entities, dates, dollar amounts, named products, or other identifiable facts—only generic references to 'key employees,' 'various trainings,' and 'technology-based tools' that could appear in any filing.


reasoning: The paragraph describes the company's own internal cybersecurity processes — identifying threats, detecting attacks, protecting data, evaluating risks, and making strategic investments — which fits the 'Risk Management Process' category. The paragraph contains no named frameworks (NIST, ISO), no specific tools, no named third-party firms, no dates, and no firm-specific details; it describes generic security practices that could appear in any company's filing.


reasoning: The paragraph describes board-level oversight of cybersecurity risk with the Board of Directors and Audit Committee as the grammatical subjects, making Board Governance the appropriate category. The language consists entirely of generic governance terms (Board of Directors, Audit Committee) with no specific dates, named frameworks, cybersecurity-specific roles, third-party firms, or other identifiable facts—everything is standard boilerplate applicable to any public company.


reasoning: The paragraph's grammatical subject is 'The Committee' (a board committee) and the content describes board oversight of cybersecurity risks through regular management reporting. No firm-specific details are present—no named committees, specific dates, roles, or frameworks—just generic boilerplate language about reporting cadences that could appear in any company's 10-K.


content_category: Strategy Integration

reasoning: This paragraph contains a standalone materiality conclusion ('not aware of any risks from cybersecurity threats that have materially affected the Company') with a cross-reference to Risk Factors, which per the tiebreaker rules classifies it as Strategy Integration even though it is boilerplate language that could appear in any company's filing.


reasoning: The paragraph describes the company's own internal cybersecurity protection mechanisms (monitoring, analysis, remediation, reporting) and vendor testing as a component of their internal risk management program. While vendors are mentioned, they appear only as a tool used by the company to test its own systems, not as the central topic of vendor oversight. No specific dates, dollar amounts, named tools, named frameworks, or other identifiable firm-specific facts are present—the language is entirely generic and could apply to any organization.


reasoning: The Audit Committee is the grammatical subject, and the paragraph describes board-level oversight of cybersecurity risk including reporting cadences and briefing topics. No specific dates, named third-party firms, named tools, or other hard verifiable facts appear—the language uses only generic references ('third-party assessments,' 'incident response plan,' 'annual basis') that could appear in any company's filing.


reasoning: This paragraph contains a materiality disclaimer asserting no cybersecurity incidents have materially affected the company, which qualifies as a standalone materiality conclusion under Strategy Integration. The cross-reference to Item 1A Risk Factors does not change this classification. The language is entirely boilerplate with no named entities, specific dates, frameworks, or other identifying details.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is third-party vendor/service provider oversight of cybersecurity risks, explicitly stating the company maintains a 'risk-based approach and process designed to identify and oversee cybersecurity risks presented by third parties.' All third-party references are generic categories (application providers, hosting companies, cybersecurity consultants, penetration testing firms) without named entities. No specific dates, dollar amounts, headcounts, or named tools/products appear.


reasoning: The paragraph describes the Global Privacy Office's internal processes and functions—managing software, conducting assessments, and following regulatory guidance—without referencing a specific incident, board oversight, or named individuals. No named tools, frameworks, dates, or firm-specific details are present; the description uses generic functional language applicable to any company's privacy operations.


reasoning: The paragraph describes the company's information security program practices (engaging external assessors, evaluating threats, performing forensic reviews), but contains no specific identifiers—no named third-party firms, specific dates, dollar amounts, headcounts, or named tools/standards. 'External assessors and consultants' is generic language for unnamed third parties, and 'information security program' is a standard term with no unique identifier.


reasoning: The paragraph describes the company's internal risk assessment methodology (asset identification, criticality assessment, threat impact analysis, control selection) — a description of internal processes with the process itself as the grammatical subject. No specific framework is named (only 'an internationally recognized information security framework'), no dates, numbers, named tools, or firm-specific details appear.


reasoning: The paragraph's grammatical subject is the CSWAT internal team, describing its composition and functions related to incident management and risk processes; third-party risk and vendor management appear only as items the team reviews, not as the central topic.


reasoning: The paragraph describes an internal process (annual policy review by the Information Security team) without mentioning any board oversight, specific management roles, named frameworks, or incident details. The named entities—Information Security team, Legal Department, Cybersecurity Policy—are all generic terms common to any company's disclosure. No specific dates, numbers, named third-party firms, or named tools are present, making this Generic Boilerplate.


reasoning: This paragraph is a standalone materiality conclusion (no material cybersecurity incidents have impaired operations) with an appended cross-reference to Risk Factors. Per the tiebreakers, materiality disclaimers with no incident narrative map to Strategy Integration, and the cross-reference does not change this classification. The paragraph contains no specific facts—it's entirely boilerplate language that could appear in any company's filing.


reasoning: The paragraph describes the company's general approach to assessing and managing cybersecurity risks, which is an internal process topic. It contains no specific details—no named roles, frameworks, dates, or other identifying facts—making it indistinguishable from boilerplate language found in any company's cybersecurity disclosure.


reasoning: This paragraph provides general background about the company's reliance on technology systems and the types of sensitive data it handles (intellectual property, customer information, etc.), but contains no substantive disclosure about cybersecurity governance, risk management processes, incident response, or any specific cybersecurity program elements. It reads as introductory context-setting material rather than a disclosure under Item 1C requirements.


reasoning: This paragraph describes membership in an external industry group (Data Privacy Board) for benchmarking purposes, not the company's own cybersecurity governance or processes. It contains no substantive disclosure about the company's internal cybersecurity program, oversight mechanisms, or risk management activities.


reasoning: The paragraph's main function is a standalone materiality conclusion (no previous material threats) with no incident narrative. The brief mention of vulnerability acknowledgment and the Risk Factors cross-reference do not change this classification per the tiebreaker rules.


reasoning: The paragraph's primary purpose is a negative materiality conclusion (no incidents have materially impaired operations or financial standing) with a cross-reference to Risk Factors. Per calibration guidance, materiality conclusions—even when followed by cross-references—are classified as Strategy Integration, not None/Other. The paragraph contains no company-specific facts, dates, dollar amounts, named frameworks, or any other identifying details; the language is standard boilerplate applicable to any SEC filer.


reasoning: This paragraph is a negative materiality statement — asserting that no cybersecurity incident has materially affected the company — with no description of an actual incident. Per the tiebreaker rules, a standalone materiality conclusion (even boilerplate) maps to Strategy Integration. It contains no named frameworks, dates, dollar amounts, or other identifiable specifics, making it Generic Boilerplate.


reasoning: This paragraph is a standalone materiality conclusion ('cybersecurity incidents have not materially affected our business to date') paired with forward-looking disclaimers. It contains no description of an actual incident, no specific dates, and no hard verifiable facts. The section header 'Cyber Governance' appended at the end does not change the primary substance, which is a boilerplate materiality statement about the absence of material impact.


reasoning: This paragraph describes the company's own internal cybersecurity program improvements and investments in technical capabilities, detection, and response measures, which falls under internal risk management processes. It contains no named entities, specific dates, dollar amounts, frameworks, or unique identifiers—it is entirely generic language about ongoing security investment that could appear in any company's disclosure.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes—framework adoption, internal assessments, policies, technical controls, and employee training—but does so using entirely generic language with no firm-specific identifiers, dates, dollar amounts, or named tools/firms.


content_category: Incident Disclosure

reasoning: This paragraph describes an actual cybersecurity incident—the MOVEit vendor breach—with specific details about what happened (unauthorized acquisition of names and SSN/tax IDs), when it occurred (June 21, 2023 discovery), and the scope of impact (429,252 affected customers). Multiple hard verifiable facts including specific dates and a precise customer count confirm Quantified-Verifiable specificity.


reasoning: This paragraph is a standalone materiality conclusion stating that no cybersecurity threats or incidents have materially affected the company, with a cross-reference to risk factors appended. Per the tiebreaker rules, a materiality disclaimer (even when boilerplate) classifies as Strategy Integration, not None/Other, since it contains an actual conclusion rather than being a pure cross-reference. The paragraph contains no named entities, frameworks, dates, dollar amounts, or other verifiable facts, making it Generic Boilerplate for specificity.


reasoning: This paragraph describes an actual cybersecurity incident — a ransomware event on May 4, 2022 affecting internal IT systems — including what happened, the scope of impact, and the response actions taken (containment, business continuity activation, system restoration). This clearly fits the 'Incident Disclosure' category as it narrates a specific past event with its timeline and response.


reasoning: The paragraph's grammatical subjects are the Board of Directors and Audit Committee, describing board-level governance structures for cybersecurity oversight. While management roles (CISO, CIO) appear, they are members of the Board-established committee rather than the primary topic. The named independent directors with specific committee roles and the specific composition of the Cybersecurity Steering Committee make this firm-specific.


reasoning: The paragraph describes the company's own threat intelligence and information-sharing practices as part of their cybersecurity program—engaging with external communities and firms for awareness of threats. This is the company's internal risk management process, not vendor security oversight. The paragraph is firm-specific because it names specific threat-sharing organizations (H-ISAC, InfraGard) that are not generic boilerplate.


reasoning: The paragraph describes board-level oversight of cybersecurity risk through quarterly reporting from management, making Board Governance the applicable category, though the CIO is mentioned as the report provider. No specific facts are present: 'ITSC' is not a named committee unique to this company, 'quarterly' is a generic cadence, and 'Board of Directors' is standard governance language found in all SEC filings.


reasoning: The paragraph describes the company's internal process for integrating cybersecurity into enterprise risk management, including identification, assessment, monitoring, and mitigation of risks, with no reference to actual incidents or financial impact. While it discusses internal processes, it contains no firm-specific details—no named frameworks, dates, dollar amounts, named roles, or third-party firms.


reasoning: The paragraph describes the company's own internal information systems and cybersecurity policy framework covering multiple security domains (access management, network security, incident response, etc.), which is a description of the company's internal risk management processes. While 'third-party information security' is mentioned, it is merely one component among many—not the central topic. The paragraph contains no named frameworks, specific dates, named tools/products, named third-party firms, specific numbers, or unique identifiers that would distinguish this company from any other filer.


reasoning: The paragraph's primary purpose is a materiality conclusion (prior incidents have not materially affected operations) with a boilerplate acknowledgment of ongoing cybersecurity risks and a cross-reference to Risk Factors. Per the tiebreaker rules, a brief mention of past incidents combined with a materiality conclusion as the main point is classified as Strategy Integration. The cross-reference to Risk Factors is appended to a materiality assessment and does not change the classification.


reasoning: This paragraph describes an actual cybersecurity incident with a specific date, operational scope, response actions (pausing operations, engaging security experts, coordinating with law enforcement), and quantified financial impact — all hallmarks of Incident Disclosure. The presence of a specific date plus two distinct dollar amount ranges yields at least two independently verifiable hard facts, crossing the Quantified-Verifiable threshold.


reasoning: The paragraph's grammatical subject is 'third-party service providers' and the core topic is vendor oversight—specifically describing how the company manages third-party cyber risk through due diligence, monitoring, and incident notification requirements. While this describes a mature program, it uses only generic process descriptions ('phased lifecycle,' 'enterprise issue management process') with no named frameworks, specific dates, dollar amounts, named firms, or other verifiable facts that would elevate the specificity.


reasoning: Paragraph describes a specific cybersecurity incident that occurred in April 2022, detailing what happened (disruption to hospital operations, exfiltration of company and patient data), response actions taken (Security Operations Center enhancements, detection tools, new processes), and financial impact (remediation costs, lost revenues). This is a narrative about a real past event meeting the Incident Disclosure definition.


reasoning: The paragraph centers on the Audit Committee's role in overseeing cybersecurity risk, with the committee as the grammatical subject and descriptions of its meeting cadence and reporting structure to the Board. No firm-specific identifiers appear—Audit Committee and quarterly reporting are standard governance structures, and the listed information categories (incident data, training programs, risk assessments, internal controls, security software, incident response plans) are generic categories found in virtually any 10-K Item 1C disclosure.


reasoning: The paragraph focuses on the company's internal IR Plan and its operational processes (reviewing, testing, updating) rather than governance oversight or incident disclosure. The CITO and CIRO are mentioned in their functional capacity overseeing the plan, not as subjects of biographical discussion. Contains firm-specific identifiers (named IR Plan, specific cybersecurity titles) but no hard verifiable facts like dates, dollar amounts, or named third parties.


reasoning: This paragraph describes the company's own internal cybersecurity risk management program and its integration with enterprise risk management, which is the core of the Risk Management Process category. While it mentions NIST 800-171 as a named framework, it contains no firm-specific details like named roles, specific dates, third-party firm names, or unique identifiers.


reasoning: This paragraph describes the company's practice of conducting annual cybersecurity training for relevant employees—a description of an internal process rather than an actual incident, financial impact, or governance structure. It contains no specific dates, named frameworks, roles, tools, or other firm-specific identifiers.


reasoning: The paragraph focuses entirely on ADP's internal enterprise risk management processes for identifying and mitigating cybersecurity risks. It describes the ERM team's activities and annual assessment cadence, which are ADP's own processes rather than board oversight or incident disclosure. No specific facts are present: 'enterprise risk management program' and 'annual' are generic descriptors with no framework naming, specific dates, named roles, or other distinguishing details that would make this firm-specific.


reasoning: The paragraph describes the company's own internal risk management strategy and processes (tiered risk evaluation, assessments, audits, testing, simulations), which is the core definition of Risk Management Process. The Audit Committee appears only as the recipient of reporting, not as the grammatical subject, so Board Governance does not apply. No specific dates, dollar amounts, named third-party firms, named tools, or cybersecurity-specific roles appear; all elements are standard practices that could appear in any company's disclosure.


reasoning: The paragraph describes the company's own internal security processes (penetration testing, vulnerability assessments, threat intelligence reviews) as part of its risk management strategy. Third-party consultants are mentioned only as a component supporting the internal program, not as the central topic. The paragraph contains no named standards, dates, dollar amounts, headcounts, named products, or named third-party firms—only generic practices like 'regular scans' and 'cybersecurity consultants' with no identifying details.


reasoning: This paragraph states a standalone materiality conclusion that cybersecurity risks have not materially affected the company, which is the defining characteristic of Strategy Integration category per the classification rules. The specificity level is Generic Boilerplate because it contains no firm-specific facts—no named frameworks, roles, tools, dates, or other identifying information—only generic disclaimers about future uncertainty and a cross-reference to Risk Factors.


reasoning: The paragraph describes the company's internal cybersecurity monitoring and incident management processes, with the InfoSec Leadership Team as the grammatical subject. The named internal team composition ('InfoSec Leadership Team') is a specific organizational fact unique to this company, making this Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph describes an actual cybersecurity incident (the July 2018 ransomware attack), including what happened, what systems were affected (Dx information technology systems), investigation findings regarding data exfiltration, and the incident's operational scope. This is narrative incident disclosure, not merely a financial/materiality reference.


reasoning: The paragraph primarily describes the Company's own Information Security Program and internal controls designed to meet regulatory requirements, making it about internal risk management processes rather than specific board oversight actions. While it mentions board/management responsibilities, these are described in the context of regulatory guidelines the program must satisfy, not as the central topic.


reasoning: This paragraph is primarily a materiality disclosure stating that past cybersecurity incidents have not materially affected the company, with the core focus on business/financial impact rather than incident description. Per tiebreaker rules, brief acknowledgment of past incidents combined with a materiality conclusion as the main point maps to Strategy Integration. The paragraph contains no specific facts—only boilerplate language ('computer systems,' 'third parties on which we rely'), vague references ('in the past'), and generic cross-references to Risk Factors that could appear in any company's filing.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes (assessments, security protocols, independent auditors, compliance with laws) but contains no named entities, specific dates, dollar amounts, or other firm-specific details that would distinguish it from any other company's disclosure.


reasoning: The paragraph describes the company's own Cybersecurity Program design and functions (preventing, identifying, investigating, resolving, and mitigating vulnerabilities), which is internal Risk Management Process. Third-party service providers are mentioned only as context within the program's scope, not as the central topic. No specific dates, named frameworks, named tools, dollar amounts, headcounts, or named third-party firms are present.


reasoning: The paragraph describes internal disclosure procedures and compliance programs related to cybersecurity incidents, which falls under the company's own risk management processes. It contains no specific facts—no named frameworks, dates, dollar amounts, headcounts, or named tools/firms—making it standard boilerplate language applicable to any public company.


reasoning: This paragraph is a forward-looking risk disclaimer describing hypothetical cybersecurity threats and their potential impacts rather than describing any actual cybersecurity program, process, or disclosed incident. It contains no board governance content, no management role descriptions, no actual risk management processes, no incident narrative, and no strategy integration—it merely acknowledges that cybersecurity events 'may' or 'could' occur. As such, it is a standard risk factor disclosure with no substantive cybersecurity governance or management disclosure.


reasoning: This paragraph is a general introductory statement about cybersecurity threats facing the company and its ecosystem. It does not describe any actual incident, governance structure, management role, internal process, vendor oversight practice, or financial/materiality assessment. It is a contextual risk acknowledgment with no substantive disclosure.


reasoning: The paragraph describes the company's own cybersecurity risk assessment and testing processes using third parties as internal tools — fitting Risk Management Process. No specific facts are present (no named firms, dates, dollar amounts, headcounts, or named frameworks), making this Generic Boilerplate.


reasoning: This paragraph is a pure cross-reference directing readers to Item 1A and Item 7 for cybersecurity information. It contains no substantive disclosure about any cybersecurity program, process, or incident.


content_category: Management Role

reasoning: The paragraph centers on the Enterprise Security Director as the grammatical subject, describing her responsibilities, qualifications, credentials, and reporting structure to the ERSC and AOC. This is a Management Role disclosure. The specificity is Firm-Specific due to the cybersecurity-specific role title and named certification; it falls short of Quantified-Verifiable because the 'over 26 years' is an approximate soft number and the committees are internal organizational identifiers rather than external hard facts.


reasoning: The paragraph describes the company's own internal process for conducting risk assessments and implementing safeguards, which is the core of risk management process disclosure. No specific frameworks, roles, dates, numbers, tools, or firm-specific details are mentioned—it is entirely generic language that could appear in any company's 10-K filing.


reasoning: The paragraph focuses on the company's own cybersecurity program, framework alignment, internal security controls, and risk management processes; while third-party oversight is mentioned, it is framed as part of the company's internal processes rather than as a standalone topic. The disclosure is Sector-Adapted because it names the NIST 800 Cybersecurity Framework, which is a recognized standard, though the remaining content describes generic security practices applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity training and exercise programs, which falls under Risk Management Process. However, all practices mentioned (phishing exercises, tabletop exercises, safety meetings, awareness training) are common security practices without any specific dates, named frameworks, tools, or firm-specific details.


reasoning: The paragraph describes the company's own internal cybersecurity processes and controls, including risk assessments, policies, and training programs, making it a Risk Management Process disclosure. The paragraph names the NIST Cybersecurity Framework and Cyber Risk Institute Cyber Profile (a recognized standard and derivative profile), but contains no firm-specific details—no named tools, specific dates, headcounts, dollar amounts, or unique practices beyond common security measures like phishing simulations.


reasoning: The paragraph describes management's organizational approach to cybersecurity governance (multi-disciplinary, three lines of defense model) and incident response procedures, which are internal processes rather than identifying specific management roles or individuals. The specificity is Generic Boilerplate because 'three lines of defense' is a widely-used risk management concept, 'Management' is referenced generically without naming cybersecurity-specific roles (CISO, CTO), and no dates, dollar amounts, named tools, named third-party firms, or other identifiable facts are present.


reasoning: This paragraph describes the company's internal security awareness and training programs, which are the company's own risk management processes. While it mentions types of training (phishing tests, mandatory education), all language is generic and could appear in any company's filing—no named programs, frameworks, dates, numbers, or firm-specific details are provided.


reasoning: The paragraph describes the company's own internal risk assessment process using third-party experts alongside the internal audit team. The third-party experts are tools used within the company's process rather than the subject of vendor oversight requirements, making this about internal risk management. The paragraph contains no named entities, specific dates, named frameworks, or other identifying facts—it describes a generic practice applicable to any company conducting risk assessments.


reasoning: The paragraph centers on the Board of Directors' oversight of cybersecurity through its named RAC and TEC committees, making Board Governance the primary category. The CISO is mentioned only as a reporting mechanism within the board's oversight structure, not as a subject to be described. The disclosure contains firm-specific facts including the company's unique committee names (RAC, TEC), the specific composition of management-level committees, and the CISO title.


reasoning: The paragraph's grammatical subject is the Risk Committee (a board committee) and describes board-level oversight structure and reporting lines to the Board. While the CISO and management committees are mentioned, they serve as components of the governance structure rather than the primary subject. The paragraph contains firm-specific internal committee names (EROC, TSRC, ORC) and the capitalized 'Management Committees' governance structure, which are unique to this company's disclosure.


reasoning: The paragraph describes the company's internal risk assessment and management processes for product cybersecurity within a specific business unit (E-Systems), including alignment with internal policies and industry standards. This focuses on the company's own processes rather than board oversight or individual management roles.


reasoning: The paragraph's grammatical subjects are the Board of Directors and Audit Committee, and it describes their oversight cadence (quarterly updates to Audit Committee, annual update to Board). Per the tiebreaker rules, board oversight as the main focus takes precedence. The paragraph contains CISO and CIO titles, which qualify as cybersecurity-specific roles on the IS list, making this at least Firm-Specific rather than Generic Boilerplate.


reasoning: While the paragraph briefly references the 2017 incident, its primary purpose is forward-looking risk language about potential future security compromises and their possible material adverse effects on financial condition—not a substantive description of the incident itself. This is standard risk disclosure boilerplate.


reasoning: The paragraph describes the company's own cybersecurity risk management activities (risk assessments, tabletop exercises, audits) with third parties serving as supplements to internal processes, making Risk Management Process the appropriate category. All third parties are unnamed ('external security firm,' 'audit firm'), the year reference ('During 2024') lacks month-level specificity, and tabletop exercises and audits are common practices without any firm-specific identifiers, resulting in Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its integration with the Enterprise Risk Management process—clearly a description of the company's own risk management processes rather than board governance, management role qualifications, or incident disclosure.


reasoning: The paragraph describes the company's own internal cybersecurity risk management activities—risk assessments, vendor engagement for technical reviews, roles/responsibilities matrix, threat intelligence sharing, and employee training/testing. The board is not the grammatical subject, no management individual's qualifications are discussed, no actual incident is described, and vendors are mentioned only as supporting components of internal processes rather than as the central oversight topic.


reasoning: The paragraph describes Vista's internal cybersecurity risk management processes—monitoring, incident response, security awareness training, and review of SOC reports for outsourced systems. No board oversight, specific management roles, or external vendors as the central topic; the third-party reference is incidental to the company's own internal review process. No specific facts remain after filtering: SOC 1 Type 2 is a standard audit report type (not a firm-specific identifier), no named frameworks, tools, roles, dates, or numbers are present, making this indistinguishable from any company's generic cybersecurity risk management disclosure.


reasoning: This paragraph is a general introductory statement describing the company's dependence on IT systems and data processing. It does not discuss any substantive cybersecurity governance, risk management processes, incidents, or strategic considerations—it lacks any specific facts about governance bodies, named roles, processes, frameworks, or material assessments. This is essentially background context that could appear in virtually any company's filing unchanged.


reasoning: The paragraph describes the company's own internal risk management processes, including its risk assessment methodology, security monitoring, training, and maturity monitoring. While third-party risk monitoring is mentioned, it appears as one component of internal processes rather than the central topic. The company names two specific frameworks (NIST CSF, CMMI) but otherwise describes generic security practices without any firm-specific details—no named tools, dates, headcounts, dollar amounts, or named third-party firms.


reasoning: This paragraph is a forward-looking materiality disclaimer asserting the absence of material cybersecurity impacts, with a cross-reference to Risk Factors. It contains no substantive disclosure about the company's cybersecurity program, governance, or processes—only a negation of material effects.


reasoning: The paragraph centers on the Compliance Committee's oversight function and how cybersecurity risk management information flows to the Board—making Board Governance the primary category. The Compliance Committee (a named committee) is the grammatical subject throughout, and while the CIO is mentioned, it is as one member of the committee, not as the focal point. The named committee with specific composition and quarterly meeting cadence provide firm-specific details.


reasoning: Although a 2020 incident is mentioned, the primary purpose of this paragraph is a negative materiality conclusion (no material effect as of the filing date) rather than an incident narrative—the incident mention is brief and incidental to the main point. This aligns with the Strategy Integration category where materiality conclusions are the main focus.


reasoning: The paragraph's primary purpose is a materiality conclusion — stating that past incidents have not materially affected the company and that ongoing risks could affect future operations. The brief acknowledgment of past incidents serves as context for the materiality assessment, not as an incident narrative. The final sentence is a pure cross-reference with no substantive disclosure.


reasoning: The paragraph describes an actual cybersecurity incident (February 3, 2025 systems outage) including what happened (unlawful network access, encryption of critical applications, file exfiltration) and response actions (activated incident response plan, engaged internal teams and third-party experts). The presence of a specific date qualifies it as Firm-Specific (one hard fact), but no second hard verifiable fact (e.g., named third-party firm, specific dollar amount, or named tool) elevates it to Quantified-Verifiable.


reasoning: The paragraph describes FTI's internal cybersecurity capabilities and how their client-facing cybersecurity team supports the company's own security posture—a description of internal risk management processes. While external consultants are mentioned, they are only referenced as supplemental support within the company's own incident response process, not as the central topic.


reasoning: The paragraph describes the company's internal information security program, annual risk assessment process, and general cybersecurity controls. No specific persons, named frameworks, dates, third-party firms, tools, or other identifying details are present—only generic descriptions of processes that could appear in any company's disclosure.


reasoning: The paragraph's grammatical subjects are the Board of Directors and Audit Committee, and its primary focus is on board/committee oversight responsibility and the cadence of updates received. While management roles (CIO, General Counsel) are mentioned, they appear in a supporting context about what they report to the board, not about their qualifications or credentials. No specific facts are present—no named frameworks, programs, dates, or verifiable details—just generic boilerplate about standard board oversight and management reporting.


reasoning: The paragraph focuses on the company's own internal processes—specifically the CIRT's incident response strategies and the CIO's role in monitoring third-party providers—which are internal risk management activities. While third-party providers are mentioned, they are discussed as subjects being assessed by the CIO, not as vendors with imposed security requirements.


reasoning: The paragraph centers on the Director of IT as the grammatical subject, detailing their qualifications, certifications, tenure, and reporting structure to the CFO. The CIRT is mentioned in the context of being led by this person, making the management role the primary focus rather than the internal process itself.


reasoning: The paragraph focuses on describing CINTAS's internal cybersecurity risk management processes, including framework adoption (NIST), policies, and procedures. While the NIST framework is named (making it Sector-Adapted), no firm-specific facts such as named roles, specific dates, dollar amounts, or unique program identifiers are present—all elements are generic boilerplate applicable to any company.


reasoning: The paragraph's primary focus is on identifying the CISO as the individual responsible for cybersecurity and describing their reporting line to the IT/Cybersecurity Committee, making Management Role the appropriate category. The mention of the IT/Cybersecurity Committee and CISO title provides firm-specific identification, though the paragraph contains no hard verifiable facts (dates, dollar amounts, named tools/third parties) to reach Quantified-Verifiable.


reasoning: The paragraph focuses on identifying named management roles (CISO, CIO, CFO), their qualifications (35 years experience, MIS degree), and their specific reporting relationships and responsibilities. The grammatical subjects are the named officers and their department, making Management Role the primary category. The 35 years of experience and specific reporting hierarchy (CISO→CIO, CISO informing both CIO and CFO) provide firm-specific details beyond generic boilerplate.


reasoning: The paragraph focuses on the Board's oversight structure, committee meeting cadence, and board reporting mechanisms for cybersecurity — with the Board and Audit Committee as the grammatical subjects throughout. While CISO and CIO are mentioned, they appear as reporting participants to the board, not as the primary subject. The paragraph contains five specific facts: two cybersecurity-specific titles (CISO/CIO), two specific cadences (twice a year, annually), and a specific year (2023), making this Firm-Specific rather than generic boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity processes—specifically an Incident Response Policy and monitoring procedures—making Risk Management Process the appropriate category. The presence of a named internal program (Incident Response Policy) and a cybersecurity-specific role (VP Infrastructure and Security) elevates this beyond generic boilerplate, though no named external frameworks or verifiable external facts are present.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes integrated with their enterprise risk management (ERM) program, including risk assessments and compliance activities. All elements are generic and unquantified, with no named frameworks, specific dates, tools, or other identifying details.


reasoning: This paragraph describes the company's internal approach to identifying and overseeing third-party cybersecurity risks as part of their broader risk management efforts. While third-party risk is the topic, it is presented as a component of the company's internal processes rather than as a standalone, detailed third-party oversight program. The language is generic and could apply to any company.


reasoning: While the paragraph identifies the CIO as leading the cybersecurity function, the primary focus is on the organizational structure and the existence of an Information Security Incident Response Plan, which is an internal process. The named plan is a firm-specific identifier, distinguishing this from generic boilerplate.


reasoning: The paragraph centers on the Audit Committee's oversight activities—receiving quarterly reports and engaging directly with management on cybersecurity risk. While the Audit Committee is generic, the mention of CISO (a cybersecurity-specific title per the IS list) elevates it to Firm-Specific. The paragraph describes what the board does, not what the CISO does as a person, so Board Governance is the correct category over Management Role.


reasoning: The paragraph's grammatical subject is the CAO, and the primary focus is on this person's qualifications, tenure, and career history within the company — she has 24 years of experience and has held specific roles including CIO. This is about the person's background rather than describing what the cybersecurity function does (processes, tools, frameworks), which would be Risk Management Process.


reasoning: The paragraph focuses on the identification and qualifications of named management roles (Acting CISO, Acting CIO) and their specific reporting relationships rather than describing an internal process. While the ERMC is mentioned, it serves as context for the CIO's accountability structure rather than being the primary subject.


reasoning: The paragraph describes the company's own internal cybersecurity risk management approach based on a named framework (NIST CSF), focusing on what processes the company uses to identify and manage cybersecurity risks. It references NIST CSF by name, which qualifies as a recognized standard under the specificity rules, but contains no firm-specific details such as named roles, specific dates, dollar amounts, or named internal programs.


reasoning: The paragraph's main subject is the company's internal risk assessment and monitoring processes, with the CISO mentioned in an oversight capacity rather than as the topic of discussion. The mention of a named cybersecurity-specific role (VP of Information Security/CISO) provides sufficient firm-specific detail to distinguish this from generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity assessment, audit, and training practices with 'We' as the grammatical subject, focusing on what the company's own processes do rather than naming specific roles, committees, or frameworks. All elements are common practices (internal audits, third-party expertise, threat intelligence feeds, annual training) without named third-party firms, specific dates, named internal programs, or cybersecurity-specific titles.


reasoning: The paragraph's grammatical subjects are the CISO and the Cyber Security Office team, with the primary focus on identifying the management structure, reporting relationships, and team qualifications/certifications. This describes WHO is responsible for cybersecurity rather than detailing specific processes or frameworks they employ.


reasoning: The paragraph's grammatical subject is the Audit and Finance Committee and its oversight responsibilities, making Board Governance the primary category. While management roles (CDTO and CISO) are mentioned, they serve a supporting role as the parties who manage the program and brief the board. The paragraph is Firm-Specific because it names the cybersecurity-specific roles (CDTO, CISO) and a non-generic committee (Audit and Finance Committee), which distinguishes it from generic boilerplate about board cybersecurity oversight.


reasoning: The paragraph describes organizational responsibility for cybersecurity risk management, focusing on which roles drive the program and are responsible for risk oversight. However, all named roles (General Counsel, Assistant General Counsel, CEO, department leaders, IT leaders) are standard corporate positions that appear across virtually all companies, and no unique organizational structures, reporting lines, or specific qualifications are disclosed. The language describes a generic management structure without any firm-specific identifying details.


reasoning: The paragraph centers on the CISO's qualifications, credentials, career history, and reporting line to the COO — all hallmarks of Management Role classification. While the paragraph also touches on processes and third-party engagement, the grammatical subjects of key sentences are the named individuals (CISO, COO) and their personal attributes (30 years experience, CISO of two retailers, 20 years digital transformation), with no board-level oversight mentioned.


reasoning: The paragraph's primary subject is the ERC, a named cross-functional oversight forum with delegated authority from the BRC. The CISO and other officers are mentioned briefly as participants in this governance structure. Two firm-specific facts are present: the named ERC committee and the interim CISO role.


reasoning: The paragraph describes the company's own internal cybersecurity practices (employee training, cyber insurance, vendor contract review procedures), which constitutes the company's internal risk management processes. While third-party vendors are mentioned, they appear as part of the company's own internal contract review process, not as the central topic of vendor risk management. No named entities, specific dates, dollar amounts, or framework names are present.


reasoning: The paragraph describes Honda's internal risk assessment processes, reporting structures to a Risk Management Officer/Committee, and monitoring of cybersecurity threats—all internal risk management processes. The grammatical subjects (cybersecurity supervisory divisions, Risk Management Officer) are discussed in the context of company processes rather than as individuals with personal credentials, placing this squarely in Risk Management Process.


reasoning: The paragraph centers on the Caterpillar CIO's qualifications, tenure, career history, and how she leads a cross-functional team—characteristics of Management Role. While the team manages cybersecurity processes, the main grammatical subject is the person and her credentials, not the processes themselves. Specific facts include the September 2020 appointment date, 25-year tenure, prior CIO role for Financial Products Division, and named team composition, making this Firm-Specific rather than generic boilerplate.


reasoning: The paragraph is primarily a forward-looking disclaimer with a cross-reference to Risk Factors; the brief mention that the company has not experienced recent material incidents is subordinated to the disclaimer language rather than serving as a standalone materiality conclusion.


reasoning: The paragraph's grammatical subjects are the CIO and SDIS, focusing on their reporting relationships and the SDIS's qualifications (15+ years experience, CISSP, CISM, degree), which aligns with the PERSON-VS-FUNCTION test for Management Role. While responsibilities are mentioned, they are attributed to the role rather than describing independent company processes.


reasoning: The paragraph describes the company's internal cybersecurity incident response processes and escalation procedures, with the grammatical subject focused on the company's own workflows rather than board oversight, a named executive's qualifications, or a third-party vendor program. The presence of a named role (VP of Tech) and specific team composition elevates this from generic boilerplate to firm-specific.


reasoning: The paragraph describes internal security processes (phishing simulations, security policies, training, and testing) rather than focusing on a specific management person's qualifications or background, making it about the function rather than the individual. This is Generic Boilerplate because it contains no specific facts—no named frameworks, roles, dates, tools, third-party firms, or numbers—just standard cybersecurity practices that could appear in any company's disclosure.


reasoning: The paragraph is about a specific individual (Starbucks' CISO), describing their qualifications, tenure, and career history across multiple industries. Under the person-vs-function test, the paragraph remains meaningful when considering the CISO's credentials and background as the central subject, not merely mentioning the role in passing while describing processes.


reasoning: This paragraph describes the company's internal cybersecurity incident response procedures, including the activation of the CIRT, escalation chain, materiality assessment committee, and board notification process. It is not describing an actual incident, so it is Risk Management Process rather than Incident Disclosure.


reasoning: The paragraph describes the cybersecurity team's activities and processes (monitoring, vulnerability scans, penetration tests, incident escalation), with Mr. Daly and the team as functional subjects rather than individuals being profiled for their personal qualifications. All activities mentioned are standard cybersecurity practices with no firm-specific identifiers. While Mr. Daly is named, the paragraph does not describe his personal background, credentials, or career history — it describes what the cybersecurity function does, making Risk Management Process the appropriate category. No framework names, specific dates, dollar amounts, named third-party firms, or named products appear.


reasoning: The paragraph focuses on the CISO's function and reporting structure within the organization, describing how cybersecurity information flows from the CISO up through management to the board committee. The CISO and the named Cybersecurity Executive Steering Body provide firm-specific identifiers, though the overall structure described is fairly common corporate governance.


reasoning: The paragraph's grammatical subject is consistently 'management team' throughout, describing their supervisory responsibilities, information-receiving role, and reporting cadence to the board — making this fundamentally about management's role in cyber oversight rather than board governance itself. The presence of named internal bodies (Disclosure Committee, Information Security team) elevates this beyond generic boilerplate to firm-specific.


reasoning: The paragraph primarily describes the company's cybersecurity risk management program structure and internal processes, including technical controls, monitoring, and third-party services. While the CTO and CISO roles are mentioned, the focus is on what the program does rather than the individuals' personal qualifications or backgrounds.


reasoning: The paragraph describes both board and management roles, but the named management officers (CLO, CTO, Information Security Manager) are specific to this company's structure, and the operational management section contains more substantive detail than the board oversight description. The named Information Security Manager is a cybersecurity-specific role.


reasoning: The paragraph describes the company's own internal cybersecurity processes and framework alignment (NIST CSF, C2M2), which is Risk Management Process. It names two specific recognized frameworks (NIST Cybersecurity Framework and C2M2 from U.S. Department of Energy), making it Sector-Adapted rather than generic boilerplate, while containing no firm-specific or quantified facts that would elevate it further.


reasoning: The CDO is the grammatical subject and the paragraph describes the management role's responsibilities for directing cybersecurity activities. No specific qualifications, reporting lines, named frameworks, dates, or other differentiating details are provided—just a generic description of a senior role's function that could apply to any company.


reasoning: The paragraph describes the company's OWN internal processes for evaluating and mitigating third-party cybersecurity risks—conducting pre-engagement and periodic risk assessments, maintaining security standards, and having committees review identified risks. The third-party providers are the object of the company's evaluation process, not an independent topic. The language is entirely boilerplate with no named entities, specific dates, named frameworks, or unique identifiers.


reasoning: The paragraph's primary focus is on the materiality conclusion ('did not have a material impact') and the resulting business decision (accelerated IT initiatives), not on describing the incident itself. The brief mention of the ransomware attack serves as context for the business impact, making this Strategy Integration per the tiebreaker guidance.


reasoning: The paragraph describes a procedural incident response framework with IRT and CIEC as the grammatical subjects performing standardized governance activities, rather than describing an actual past incident or a named individual's qualifications. No named third-party firms, specific dates, dollar amounts, or framework standards are present.


reasoning: The paragraph's grammatical subjects are the CISO and the reporting hierarchy (CISO → CIO → Senior Management Committee), making this fundamentally about management's organizational role in cybersecurity governance. The CISO and CIO are cybersecurity-relevant management roles. While the Audit Committee is mentioned, it functions as a reporting recipient rather than the actor, so Board Governance does not apply. The paragraph is Firm-Specific because it identifies the CISO (cybersecurity-specific title) and describes a unique organizational structure with four named divisions and a Senior Management Committee—not generic boilerplate.


reasoning: The paragraph's grammatical subject is the CTO, describing their reporting function and role in cybersecurity oversight to the Audit and Finance Committee and executive leadership. While the board committee is mentioned, it serves as the recipient rather than the actor, making this a management role disclosure.


reasoning: The paragraph describes the company's own cybersecurity assessment and monitoring processes, including vulnerability management, internal audits, and third-party maturity assessments, making Risk Management Process the primary category. While it mentions third parties, they are engaged to assess the company's own program, not as the subject of vendor/supplier security oversight.


reasoning: The paragraph's grammatical subjects are the Board and its committees (Governance and Compliance Committee, Technology Committee) overseeing cybersecurity risk, with the CISO mentioned only in the context of reporting to these committees—making Board Governance the primary category. The paragraph achieves Firm-Specific through the CISO title and two named non-generic committees, but lacks the two hard verifiable facts (specific dates, dollar amounts, named third-party firms, or named products) required for Quantified-Verifiable.


reasoning: This paragraph contains only forward-looking disclaimer language ('reasonably likely to materially affect') and a cross-reference to the Risk Factors section, with no substantive disclosure about governance, processes, roles, or incidents. Per the tiebreaker rules, pure cross-references with no materiality conclusion are classified None/Other, and since there are no specific facts present, the specificity is Generic Boilerplate.


reasoning: This paragraph describes an actual cybersecurity incident with specific dates (December 30, 2022 breach discovery; January 6 and February 10, 2023 filings), operational impact (production delays, delayed shipments), and response actions (initiated protocols, engaged experts, completed data recovery). It reads as an incident narrative rather than a process description, making Incident Disclosure the appropriate category.


reasoning: The paragraph describes the company's internal cybersecurity risk management framework and the standards that guide it, which is a description of internal processes. While the company uses commonly referenced frameworks (NIST, ISO), the specific version numbers of certifications sought (27001:2013, 27017:2015) and the specific attestation types (SOC 2 Type 1 and Type 2) provide firm-specific detail beyond mere framework naming.


reasoning: This paragraph describes the company's internal security improvements implemented after an incident (zero trust hardening, quarterly awareness training, MFA for PAM, EDR solutions), which is an internal risk management process. It does not describe what happened in the incident itself, only the response measures taken. No named frameworks (NIST, ISO), products, third-party firms, specific dates, dollar amounts, or other identifying details are present—only generic security practices that could appear in any company's disclosure.


reasoning: The paragraph describes Everest's internal cybersecurity risk management processes including its SOC operations, incident response escalation procedures, vulnerability management, and testing practices. No actual cybersecurity incident is described, so it is not Incident Disclosure. The Board and CISO are mentioned only as escalation endpoints, not as the grammatical subject of the paragraph. The paragraph contains only standard security function names (SOC, CSIRT, CISO) without any quantifiable details, named products, specific dates, dollar amounts, named third-party firms, or named internal programs with unique identifiers. All practices described (intrusion detection, vulnerability scans, penetration testing, NIST assessments) are common industry-standard activities that could appear in any company's disclosure.


reasoning: The paragraph is about specific named individuals (Information Security Director, CIO) and their qualifications, tenure, and reporting relationships—making this Management Role per the person-vs-function test. The paragraph would not make sense without referencing these specific people and their credentials. It contains Firm-Specific facts including cybersecurity-specific titles, reporting structure, named internal teams (CIRT, CIC), and specific years of combined experience.


reasoning: The paragraph describes the company's internal cybersecurity risk management structure and processes, with the ISC as the grammatical subject performing monitoring, decision-making, and policy oversight functions. The CISO appears as the committee chair within this process framework rather than as a standalone individual being described.


reasoning: The paragraph's primary focus is describing how the company identifies cybersecurity risks through its ERM program (a named internal program = specific fact). The materiality statement ('We have not had any material cybersecurity breaches') is a boilerplate disclaimer, not a substantive incident disclosure, so Incident Disclosure does not apply.


reasoning: The paragraph describes an actual cybersecurity incident (the May 2023 MOVEit attack at subsidiary Umpqua Bank), including what happened, when it occurred, response actions taken (network removal, decommissioning, forensics engagement), and confirmed scope/outcome — all hallmarks of incident disclosure. Two hard verifiable facts are present: specific date (May 2023) and named product (MOVEit), meeting the Quantified-Verifiable threshold.


reasoning: The paragraph is fundamentally about board and Audit Committee oversight of cybersecurity, with those entities as the grammatical subjects. However, it explicitly names two cybersecurity-specific management roles (CIDO and Senior Director, Global IT Security) who brief the board, which satisfies the Firm-Specific threshold under the guidance that CISO/CIO/CTO-level titles qualify as specific facts.


reasoning: The paragraph primarily focuses on identifying the CISO and describing their qualifications (CISSP certification, leadership of a team with 50+ years combined experience), which constitutes substantive information about a management role rather than just a passing mention. While board committee oversight is present, it serves as context for the team's governance structure rather than the main disclosure point.


reasoning: The paragraph focuses on the CISO as a person — detailing their career history (14 years at a prior company, promotion in 2013), reporting line (to CIO), and responsibilities — making Management Role the primary category. Two or more hard verifiable facts are present: specific year 2013 and specific duration of 14 years.


reasoning: The paragraph describes management-level committee structures (ORMC, ERMC) and their risk management processes for cybersecurity oversight—identifying, measuring, managing, monitoring, and reporting risks. While the Board is mentioned, it appears only as a recipient of escalations, not as the primary subject. No specific dates, dollar amounts, named tools, or other verifiable facts unique to American Express are present; the language describes standard corporate governance practices applicable to any financial institution.


reasoning: This paragraph is a forward-looking risk disclaimer with a cross-reference to Risk Factors. While it briefly mentions incident history ('no material cybersecurity incidents'), this is incidental to the primary purpose of hedging against future risk, not a substantive materiality assessment or incident disclosure. Pure forward-looking disclaimers paired with cross-references fall under None/Other.


reasoning: The paragraph's grammatical subject is the company's THIRD-PARTY PROVIDER oversight process, including due diligence requirements and contractual obligations imposed ON vendors. Per the tiebreaker rule, requirements imposed on vendors = Third-Party Risk. While third-party risk management is discussed, there are no named external firms, specific dates, dollar amounts, or products/tools that would elevate to Firm-Specific or Quantified-Verifiable. The mention of SOC reports and ISO certifications as evaluation criteria names recognized standards but contains nothing unique to BOKF.


reasoning: The paragraph focuses on board committee oversight of cybersecurity, specifically naming the Audit Committee and QRC as recipients of cybersecurity updates from named management roles (CIO, CISO, VP of Product Security). While management roles are mentioned, they serve as the agents reporting to the board, making board governance the central topic.


reasoning: The paragraph's grammatical subject is the CDIO and VP of Platforms, Infrastructure, and Cybersecurity—their identification and qualifications are the central focus, not the internal processes they oversee. The specific technical credentials ('over 20 years of related experience' and 'technical leadership roles at notable multinational organizations') describe the persons' backgrounds, making this a Management Role disclosure.


reasoning: The paragraph focuses on the CISO's qualifications, credentials, and professional background (CISA certification, 30 years of experience, leadership history at publicly-traded companies), making this a Management Role disclosure rather than a discussion of processes or activities.


reasoning: The Audit Committee is the grammatical subject and central topic of the paragraph, describing its primary responsibility for cybersecurity oversight and its composition — hallmarks of Board Governance. The named roles (CIO, CSIRT, SVP) provide firm-specific identity beyond generic boilerplate.


reasoning: The paragraph centers on board/committee oversight of cybersecurity risk, with the Audit Committee as the grammatical subject in multiple sentences and the Board receiving reports through the Audit Committee. While the CIO is mentioned with expertise details, the primary focus is on governance structure rather than the individual in the role. The paragraph contains one firm-specific fact (named SIRT team) and names security standards (NIST, ISO, COBIT, ITIL) which elevates it to at least Sector-Adapted; the SIRT naming is sufficient for Firm-Specific.


reasoning: The paragraph describes the company's own internal security controls and processes (risk treatments, vulnerability management, security awareness program), not the board's oversight role, not a disclosed incident, and not vendor management. The VP of Information Security is mentioned in the context of program design/oversight rather than personal qualifications, so Management Role does not apply. The named Security Awareness Program with specific annual training requirements provides firm-specific detail beyond generic boilerplate.


reasoning: The paragraph describes an internal governance process—management's cross-functional evaluation of cybersecurity program effectiveness and executive committee review through an 'executive security council'—which falls under risk management process rather than incident-specific disclosure. The language is generic enough to apply to any large enterprise; no named frameworks (NIST, ISO), specific programs, named individuals, or hard verifiable facts are present, making this Generic Boilerplate.


reasoning: This paragraph describes an actual cybersecurity incident with a specific date (September 23, 2023), scope (internal IT infrastructure, business applications, billing systems), operational impacts (order processing/logistics disruptions, lost and deferred revenues), and remediation activities. Although it includes a materiality conclusion, the primary purpose is describing the incident itself, not assessing its financial materiality in isolation.


reasoning: The paragraph describes board-level cybersecurity oversight, with the Board and Audit Committee as the grammatical subjects, reporting cadences, and the role of the enterprise risk team. This is clearly Board Governance. The content contains no specific verifiable facts: 'Audit Committee' is a standard committee (explicitly excluded as non-generic), 'annual' and 'quarterly' are vague cadences without specific dates, 'enterprise risk team' and 'full Board' are generic governance terms, and no named frameworks, third-party firms, tools, dates, or figures are present.


reasoning: The paragraph describes internal cybersecurity processes including SLA coverage scope, security controls for unsupported applications, and disaster recovery planning. It does not discuss board governance, individual management qualifications, actual incidents, or financial/materiality impacts — making Risk Management Process the appropriate category. No specific verifiable facts (named firms, dates, dollar amounts, headcounts, named tools) appear, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the company's internal cybersecurity monitoring, detection, and defense activities—clearly a Risk Management Process topic. However, all elements are standard industry practices (threat intelligence monitoring, vulnerability scans, penetration testing, 24/7 coverage) with no named frameworks, tools, third-party firms, dates, or other specific facts that would differentiate this disclosure.


reasoning: The paragraph focuses on the CISO as a person — detailing their qualifications, credentials, tenure since 2012, and background — making Management Role the primary category. The specificity is Quantified-Verifiable because it contains multiple independently verifiable facts: a specific hire year (2012) and four named professional certifications (CISM, CISA, CDPSE, CCNA), exceeding the two-fact threshold.


reasoning: The paragraph describes the company's own incident response capabilities that incorporate third-party providers as a supplemental component, which is characteristic of internal risk management processes. The language is entirely generic—no named providers, specific dates, dollar amounts, or other identifiable facts.


reasoning: The paragraph's grammatical subjects are the board enterprise risk committee, cybersecurity subcommittee, and board of directors, making Board Governance the primary category; however, all details describe standard board oversight practices with no firm-specific identifiers, dates, named frameworks, or unique operational facts.


reasoning: The paragraph describes the qualifications, career history, credentials, and tenure of named management roles (VP/GM of High Performance Products and VP of Managed Services), focusing on who these people are and their professional backgrounds rather than what cybersecurity processes they oversee.


reasoning: This paragraph describes an actual cybersecurity incident (November 2022 attack) with detailed narrative including what happened, operational impact, response actions, scope of breach (PII access), litigation history, and resolution status. It contains at least two hard verifiable facts (specific dates: November 2022 and January 2024), meeting the Quantified-Verifiable threshold.


reasoning: This paragraph is a cross-reference directing readers to the Risk Factors section (Item 1A) for cybersecurity threat disclosures. It contains no substantive disclosure about the company's cybersecurity program, governance, or processes—it merely defers to another section.


reasoning: The paragraph centers on board oversight through the IT/Cybersecurity Committee, including board approval of the committee structure and reporting relationships between management and board-level committees. While specific management roles (CIO, CISO) are mentioned, they appear as part of the governance structure rather than as the primary focus. Named internal committee (IT/Cybersecurity Committee), specific reporting cadence, and departmental composition distinguish this from generic boilerplate.


reasoning: This paragraph is a forward-looking disclaimer about cybersecurity strategy limitations with a cross-reference to Risk Factors. It contains no substantive disclosure about actual cybersecurity governance, processes, or incidents—it merely states that no system is entirely secure and directs readers elsewhere for risk information.


reasoning: The paragraph describes the company's internal monitoring process for cybersecurity risks (briefings, threat intelligence, security tool alerts), with the CISO and Sr. Director serving as the grammatical subjects leading these efforts. Per the person-vs-function test, the focus is on what management does (monitoring through various means) rather than who the persons are (their credentials/background), making this Risk Management Process. The presence of cybersecurity-specific titles (CISO, Sr. Director of Information Security) elevates this to Firm-Specific, as these are not generic roles found in every company's disclosure.


reasoning: The paragraph's primary focus is on the CISO role and its qualifications, reporting structure, and responsibilities, with the CISO and CIDO serving as the grammatical subjects throughout most of the paragraph. While board governance and third-party risk are mentioned, they are secondary to the management role description. The disclosure contains firm-specific organizational details including the CISO/CIDO titles, specific 15+ years qualifications, detailed reporting lines, and named internal team (governance, risk & compliance).


reasoning: The paragraph describes the company's own internal cybersecurity processes (department composition, training, penetration testing, monitoring, EDR/SIEM, NIST framework adoption), with third-party providers mentioned only as supporting resources within the company's program, not as the central topic.


reasoning: The paragraph describes an actual past cybersecurity incident from April 2022, including specific details about operational disruption and data exfiltration scope, as well as remediation actions taken. The two hard verifiable facts (specific month/year date and named Security Operations Center) meet the Quantified-Verifiable threshold.


reasoning: The paragraph's grammatical subjects are named management roles (CIO, CISO) and named committees (InfoSec Steering Committee, InfoSec Governance Review Board), with the primary focus being organizational structure and role responsibilities rather than detailed process descriptions. The content names specific internal structures (Cyber Fusion Center) and governance bodies unique to IFF, making it firm-specific.


reasoning: This paragraph is a forward-looking materiality disclaimer combined with a cross-reference to Risk Factors. It contains no description of actual incidents, no details about board/management roles, no discussion of internal processes, and no substantive cybersecurity disclosure beyond a generic acknowledgment that systems 'periodically experience directed attacks.' The absence of material incidents is not itself a disclosure of an incident or process.


reasoning: The paragraph's grammatical subject is the Audit Committee throughout, describing its oversight role, briefing cadence, and discussions with the CISO, which is the defining characteristic of Board Governance content. The specificity is Firm-Specific rather than Sector-Adapted because the CISO title appears on the IS list of specific facts, though the paragraph contains minimal other firm-specific details beyond this passing reference to the role.


reasoning: This paragraph describes the company's own internal cybersecurity program across multiple dimensions (governance, technical safeguards, incident response, third-party risk, education). While it touches on board oversight and third-party risk management, the primary subject is the company's internal risk management processes and program structure. The paragraph contains several firm-specific details including a named sector-specific threat intelligence group with weekly meetings, a third-party risk management service with specific functional capabilities, and references to 2023 activities (third-party audit firm penetration test, FBI-led training, comprehensive vendor review) that distinguish this from generic boilerplate.


reasoning: This paragraph's primary purpose is a materiality conclusion ('has not materially affected us') with a brief acknowledgment of past threats and a cross-reference to risk factors. Per the tiebreakers, brief mention of past incidents combined with a materiality conclusion as the main point classifies as Strategy Integration. The paragraph contains no specific dates, named entities, dollar amounts, frameworks, or other verifiable facts—it is entirely boilerplate language applicable to any company.


reasoning: The paragraph describes the company's own internal cybersecurity team, their responsibilities, and the processes used to manage cyber risks—including safeguards, monitoring, training, and third-party assessments. While the CIO is mentioned briefly as the team leader, the paragraph's primary focus is on what the cybersecurity function does internally, not on the person's qualifications or reporting structure.


reasoning: The paragraph focuses on the qualifications, credentials, education, and career history of the CISO and CIO—making Management Role the primary category. While cybersecurity risk management is mentioned, the grammatical subjects are the persons themselves, and the paragraph would be hollow without their biographical details. The specificity is Firm-Specific because it contains multiple named educational institutions, certifications, a named prior employer, and a specific timeframe for the CISO role—all unique identifiers that distinguish this company's disclosure.


reasoning: This paragraph describes internal data protection practices (encryption of various data types) without referencing board oversight, specific incidents, or vendor oversight, making Risk Management Process the most applicable category. The paragraph contains no named frameworks, tools, dates, dollar amounts, or other identifiable specifics—it is entirely composed of generic statements about encryption practices that could appear in any company's disclosure.


reasoning: The paragraph describes internal governance, risk, and compliance processes (policies, standards, systems of control), fitting Risk Management Process, but contains only generic references to 'industry best practices' and 'regulatory requirements' with no named frameworks, specific dates, dollar amounts, or other identifying details.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including risk assessments, security controls, incident response, and third-party risk processes as integrated components of the company's own framework. While third-party risk is mentioned, it is presented as a component of the internal program rather than as a standalone third-party oversight topic.


reasoning: The paragraph's grammatical subjects are the cybersecurity team and security steering committee, with the primary focus on their organizational functions (implementing practices, reviewing risk profiles, threat detection). While a named role is mentioned with experience credentials, the 15 years serves as context for leadership qualification rather than the main topic. The named internal committee and specific departmental composition make this Firm-Specific rather than Generic Boilerplate.


reasoning: The paragraph discusses financial implications of cybersecurity incidents (insurance coverage, cost exposure) and contains a forward-looking disclaimer about material adverse effects, which aligns with Strategy Integration. It contains no named entities, specific dates, dollar amounts, or other firm-specific facts—only generic boilerplate language about cybersecurity insurance and risk factor cross-references.


reasoning: The paragraph describes a real cybersecurity incident (May 2022 ransomware attack) including what happened (network disruption, certain systems impacted), response actions (engaged forensic experts, notified law enforcement, restored systems), and the fact that no ransom was paid—meeting the criteria for Incident Disclosure. The specific month/year date qualifies as a firm-specific fact, though the absence of named third-party firms or hard numbers limits it to Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes the company's own internal cybersecurity policies, framework adoption (NIST CSF 2.0, ISO 27001), certification processes, and third-party audits—classic Risk Management Process content. While it names multiple standards (NIST, ISO, UL, FDA guidance, HSCC JSP), the specific facts that elevate this to Firm-Specific are the concrete certification achievement and audit timeline, which are verifiable firm facts beyond merely naming the standard.


reasoning: This paragraph describes an actual cybersecurity incident with specific dates (October 31, 2023, and the related Form 8-K filing dates), what happened (unauthorized access to systems), what was obtained (personal information of current and former customers), and response actions taken (containment measures, system shutdowns, law enforcement notifications, engaging cybersecurity experts). The incident narrative and scope description clearly identify this as an Incident Disclosure.


reasoning: The paragraph describes the biographical qualifications and credentials of named individuals (Mr. Madigan, Mr. James) who lead cybersecurity, with multiple specific hard facts (60 years experience, two specific degree programs). This is Management Role because the executives are the grammatical subjects and their personal credentials are the substantive content, not the processes they oversee.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and its integration into overall risk governance, with board oversight as a component. No specific cybersecurity incidents, named personnel, frameworks, or verifiable facts are provided.


reasoning: The paragraph does not describe an actual cybersecurity incident (attempts were prevented, no breach), but rather serves as a forward-looking disclaimer acknowledging general threats with a cross-reference to Risk Factors. No substantive disclosure about specific incidents, processes, roles, or governance is provided.


reasoning: The paragraph's grammatical subjects are the Board and senior management engaged in cybersecurity briefings and strategy discussions, placing this squarely in Board Governance. The identification of specific cybersecurity-specific roles (CIO and CISO) elevates this beyond generic boilerplate into Firm-Specific territory, as these titles are unique to this company's disclosure rather than standard generic governance language.


reasoning: The paragraph's central message is a materiality conclusion ('such incidents have not materially affected... our business strategy, results of operations, or financial condition'), which classifies it as Strategy Integration per the tiebreaker rules. The cross-references to Risk Factors are appended to this materiality assessment, so they do not change the classification. No specific facts are present—'third-party vendors' is generic, and there are no named frameworks, dates, dollar amounts, named roles, or other identifying details.


reasoning: This paragraph is a direct cross-reference to the Risk Factors section (Item 1A) and contains no substantive cybersecurity disclosure. It merely redirects readers to look elsewhere for information about cybersecurity risks, with no actual details about governance, processes, incidents, or strategy.


reasoning: The paragraph describes the company's own internal risk management processes (yearly risk assessments, incident response team, response plan) rather than naming a management role as the primary subject. While the CISO is mentioned, the paragraph focuses on the processes and structure they lead, not the person's qualifications or background.


reasoning: The paragraph describes an actual past cybersecurity incident (February 16, 2022 intrusion) with narrative about what happened (network disruption, affected certain systems) and response actions taken (engaging internal and external resources). The mention of the same incident again at the end of the paragraph reinforces this is describing a real disclosed event, not merely speculating about future risks. The incident is firm-specific to Century Aluminum's experience.


reasoning: This paragraph is a biographical summary of a business segment executive (Senior VP of AFP segment) that contains no cybersecurity content whatsoever—it does not address cybersecurity oversight, risk management, incidents, or governance. It appears to be standard executive biography, not cybersecurity disclosure.


reasoning: The paragraph centers on named cybersecurity management roles (Director of Enterprise Information Security, Information Security Officer) and their specific qualifications, with board oversight mentioned only briefly as context. The 30 and 22 years of experience are firm-specific facts about identifiable individuals in cybersecurity-specific roles.


reasoning: The paragraph centers on named roles (CISO, CRO) and their qualifications, reporting relationships, and oversight responsibilities. While the paragraph contains some Risk Management Process elements (IR plan, team composition), the grammatical subject of most sentences is the CISO/CRO and their roles/expertise, making Management Role the primary category. The three independent directors on the Enterprise Risk Committee and named team composition constitute firm-specific organizational details, though the certifications referenced are not actually named in the text.


reasoning: The paragraph describes the company's own internal cybersecurity processes and procedures (incident response plan, technical reviews, patch management) without referencing board oversight, a named individual, or a real incident. These are generic practices applicable to any company without firm-specific identifiers.


reasoning: The paragraph's grammatical subject is the Vice President of Information Technology and Security and CIO, focusing on this person's qualifications, reporting structure, and responsibilities for cybersecurity incident oversight. The specific title (cybersecurity-specific, not generic C-suite) and years of experience provide firm-specific identifying facts.


reasoning: Paragraph describes an actual March 2021 cybersecurity incident, including incident cause, response actions (forensic investigation, system restoration), operational scope (brewery operations, production, shipments), and quantified financial impact ($2.4M). Since it describes what happened rather than assessing financial materiality, Incident Disclosure applies. Two hard verifiable facts (specific date + dollar amount) qualify it as Quantified-Verifiable.


reasoning: The paragraph describes internal cybersecurity reporting structures and incident escalation procedures—the company's own processes for handling cybersecurity incidents and compliance reporting. While it mentions roles like the BCC and CLO, no individuals are named with qualifications or backgrounds, and no hard verifiable facts (dates, dollar amounts, headcounts, named external firms, or specific tools) appear. The language follows a standard template that could apply to many public companies.


reasoning: The paragraph describes the company's own internal processes for identifying, assessing, and managing cybersecurity risks, including monitoring tools, audits, threat assessments, vulnerability scans, and tabletop exercises. While 'officers and IT vendors' are mentioned, they are incidental to the main focus on internal processes. No named standards, specific tools, dates, dollar amounts, or other hard verifiable facts are present.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes and their integration into the overall risk management system, including the frameworks used. While the board and management are mentioned as subjects, the substantive content focuses on the processes and recognized frameworks (NIST, ISO) that govern the cybersecurity program.


reasoning: The paragraph's grammatical subject is the board of directors throughout, describing its oversight function over cybersecurity risk management. The content is entirely standard governance language—'board of directors,' 'audit committee,' and 'executive officers' are all generic entities that appear across virtually all 10-K disclosures. There are no named frameworks, specific dates, dollar amounts, cybersecurity-specific roles (CISO/CIO/CTO), or other distinguishing facts.


reasoning: The paragraph describes CSB's internal cybersecurity controls and defensive approach (layered defense, monitoring tools, alert systems), which is characteristic of Risk Management Process disclosures. The content contains no named frameworks, specific tools, dates, numbers, or other uniquely identifiable facts—it uses entirely generic security terminology that could appear in any company's filing.


reasoning: The paragraph describes the company's own internal cybersecurity monitoring and assessment processes, which is the grammatical subject of the disclosure. No actual incident is described, no specific person is named, no vendor oversight is central, and no board or financial materiality is discussed.


reasoning: The paragraph describes the company's internal cybersecurity governance structure including an executive committee, local Information Security Officers per business unit, cyber risk dashboards, and annual certification processes. This is management-level risk management infrastructure, not board governance or an incident narrative.


reasoning: The paragraph describes the company's own internal risk assessment processes and risk register maintenance. It contains no mention of specific management roles, named persons, or incident descriptions, making Risk Management Process the appropriate category. The language is entirely generic boilerplate with no specific dates, named frameworks, products, third-party firms, or other identifiable facts.


reasoning: This paragraph is a standalone materiality conclusion stating no cybersecurity risks materially affected the company during the reporting period, with a forward-looking disclaimer and a cross-reference to Risk Factors — all standard boilerplate language with no description of actual incidents, internal processes, or governance structures.


reasoning: The paragraph focuses on the qualifications, credentials, educational backgrounds, and career histories of named individuals (CISO, CIO, CRO, CEO, General Counsel), making Management Role the appropriate category. It contains firm-specific facts including the CISM certification with a specific year (2005), the CRO's named CERT Certificate in Cybersecurity Oversight, and specific tenure numbers (17 years at Associated Bank, 30+ years in IT/banking) that uniquely identify these individuals' credentials rather than being generic boilerplate.


reasoning: This is a standalone negative materiality conclusion ('we have not identified any cybersecurity threats...that have materially affected') with only a cross-reference to Risk Factors appended. Per the tiebreakers, materiality disclaimers are classified as Strategy Integration even when boilerplate, and the cross-reference does not change that classification since no substantive disclosure accompanies it.


reasoning: Paragraph is about the CISO and cybersecurity team members' qualifications, credentials, and career histories—identifying persons and their backgrounds rather than describing processes or frameworks they implement—making it Management Role. Contains two hard verifiable facts (CISO's 20+ years experience and team's 100+ combined years).


reasoning: The paragraph's dominant theme is Board oversight of cybersecurity (receiving briefings, overseeing ERM), making Board Governance the appropriate category. The paragraph contains specific named cybersecurity-related management roles and a defined reporting structure to the board, qualifying it as Firm-Specific rather than generic boilerplate.


reasoning: The paragraph describes DFIN's internal cybersecurity training programs, simulations, and tabletop exercises—all internal risk management processes. While it mentions '2023' and cadences like 'monthly' and 'quarterly,' these are generic timeframes without specific dates, and the security practices described (phishing simulations, tabletop exercises, IT training) are standard practices that appear across virtually all company disclosures.


reasoning: The paragraph describes how the company's enterprise risk management team, CSO, and IT risk management team collaborate to evaluate cybersecurity risks—these are internal processes, not board governance or third-party oversight. While the CSO role is mentioned, the paragraph lacks any named individual, specific dates, dollar amounts, named third-party firms, or named tools that would elevate it beyond generic boilerplate describing standard enterprise risk management practices.


reasoning: This paragraph is a standalone materiality conclusion ('have not materially affected...as of December 31, 2023') with a cross-reference to Risk Factors appended to it. Per the tiebreaker rules, a cross-reference appended to a materiality assessment does not change the classification. The paragraph contains no incident narrative, no description of what happened, and no firm-specific operational details—it is purely a boilerplate statement about lack of material impact.


reasoning: The paragraph describes the company's general approach to managing cybersecurity risks through implemented information security processes. No specific management roles (CISO, CTO), named committees, dates, frameworks, tools, or other identifiable details are present—entirely standard SEC disclosure language that could appear in any company's filing.


reasoning: This paragraph discusses external state regulatory trends and the Company's general awareness/monitoring of them, without describing any substantive aspects of the Company's own cybersecurity program, governance structure, or incident history. It is a forward-looking regulatory landscape statement that contains no firm-specific details.


reasoning: The board of directors is the grammatical subject throughout the paragraph, and the content describes board oversight of cybersecurity risk management activities, which is the definition of Board Governance. The paragraph contains no specific facts—'board of directors,' 'regularly reported,' and 'risk management' are all generic governance terms that appear in virtually every cybersecurity disclosure.


reasoning: This paragraph contains a standalone materiality conclusion ('have not materially affected our Company, including our business strategy, results of operations, or financial condition') paired with a cross-reference to risk factors. As per the tiebreaker rules, a cross-reference appended to a materiality assessment does not change the classification to None/Other — the main purpose is conveying the financial impact assessment, making Strategy Integration the correct category. The language is entirely boilerplate with no firm-specific details, named frameworks, dates, or other identifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity processes — how the function identifies and assesses risks and what technical/organizational measures are implemented to mitigate threats. While it mentions the CFO and MSSP, these are described as components of the process rather than as persons with qualifications or vendor oversight as the central topic. No named frameworks, tools, dates, dollar amounts, or other verifiable specifics appear — only generic security practices (incident detection, network security controls, monitoring) that could appear in any company's disclosure.


reasoning: The paragraph describes the company's own information security program evaluating third-party risks — this is an internal process topic. While third-party vendor oversight is mentioned, it is framed as a component of the company's risk management activities rather than as standalone vendor security requirements or contractual standards. The language lacks any named frameworks, specific dates, dollar amounts, named vendors, or unique identifiers that would elevate it beyond generic boilerplate.


reasoning: This paragraph describes what happened in a cybersecurity incident (potential exfiltration of personal information by ransomware actors) and response actions taken (notifications to individuals and regulators), which meets the threshold for Incident Disclosure. However, it contains no specific verifiable facts—no dates, named third parties, affected data counts, dollar amounts, or specific tools/frameworks—making it Generic Boilerplate.


reasoning: The paragraph's grammatical subjects are the CISO and CIO, and the primary focus is on these individuals' qualifications, experience levels, and credentials (person-focused), rather than describing the processes or activities of a cybersecurity program. The tiebreaker applies: while CISO responsibilities are mentioned, the paragraph emphasizes the person's background and tenure, not what the program does.


reasoning: The paragraph describes the Cybersecurity Department's operational activities (framework implementation, auditing, vulnerability testing, training) rather than identifying a specific individual or focusing on board governance. The CIS framework is named as the specific benchmark, which elevates this beyond generic boilerplate.


reasoning: This paragraph is a forward-looking risk factor statement ('could disrupt') describing hypothetical future cybersecurity incidents, not an actual incident narrative or description of the company's cybersecurity governance. It lacks any reference to the company's specific processes, board oversight, management roles, or financial impact.


reasoning: The paragraph describes the company's internal risk assessment process involving the GRC team and enterprise risk professionals collaborating to identify cybersecurity threats. This is clearly about the company's own internal risk management processes (Risk Management Process), not about board oversight, a named executive's qualifications, a specific incident, or third-party vendor requirements.


reasoning: This is a forward-looking risk factor statement describing hypothetical future consequences ('could lead to'), not a description of actual cybersecurity governance, processes, incidents, or strategy. It contains no substantive disclosure about the company's cybersecurity program.


reasoning: The paragraph describes an actual cybersecurity incident (the February 16, 2022 intrusion that caused network disruption and impacted certain systems), including detection, investigation, and response actions. While it also includes forward-looking risk language and a materiality disclaimer, the core content is an incident narrative with specific date, nature of breach, and response taken.


reasoning: The paragraph describes the company's internal incident response plan with defined protocols, escalation timelines, and responsibilities, which is an internal risk management process; the CIO is mentioned briefly as part of the governance structure, but the substantive disclosure focuses on the process rather than individual management roles or qualifications.


reasoning: The paragraph focuses on the CISO (a management role) as the grammatical subject, describing their responsibilities, team composition, and personal qualifications. Per the person-vs-function test, the paragraph is primarily about the person (their tenure, experience) rather than what the security function does — the focus is on the CISO's background rather than internal processes. The CISO title is a cybersecurity-specific role that qualifies as a firm-specific identifier.