reasoning: The paragraph describes internal cybersecurity processes — an executive committee for cyber risk, an incident response plan, and escalation procedures. CIO and ISD are mentioned as participants/leaders, but the substantive content is about what the committee and plan do (the function), not about who these people are (the person). Removing the role titles, the paragraph still reads as a process description. CIO and ISD are cybersecurity-specific titles on the IS list, elevating specificity to Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes an executive leadership committee for cybersecurity risk, mentions CIO and ISD participate, describes incident response plan led by CIO and ISD, escalation to CEO and Board.

Category: This is about internal processes - committee structure, incident response plan, escalation procedures. The CIO and ISD are mentioned as participants/leaders but the paragraph is about what the processes are, not about who these people are. This is Risk Management Process.

Wait - "ISD" - this likely means Information Security Director or similar. Let me check the IS list. "Director of IT Security" is on the IS list. ISD could be "Information Security Director" which would be a cybersecurity-specific title.

CIO is on the IS list as a cybersecurity-specific role, and ISD likely is too. Both are named roles from the firm-specific list, so this falls under Firm-Specific. But the paragraph itself is describing processes and procedures - what the committee does, how incidents escalate - rather than facts about the roles themselves. There are no QV-eligible facts like dates, dollar amounts, or headcounts here.

fact: CIO (Chief Information Officer)

fact: ISD (Information Security Director)


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The Board and its committees (primarily the BSRC) are the grammatical subjects throughout, describing delegation of cybersecurity oversight, committee composition, meeting cadence, and reporting protocols — all hallmarks of Board Governance. The BSRC is a named non-generic committee unique to this company, and CISO/CIO are cybersecurity-specific roles, yielding Firm-Specific. However, no QV-eligible hard facts (dates, dollar amounts, headcounts, named firms/tools) appear, so it does not reach Quantified-Verifiable.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity, delegation to BSRC, committee composition, meeting cadence, reporting from CISO/CIO to the board committee.

Category: Board Governance — the Board and its committees are the grammatical subjects throughout.

Specific facts:
- Business Security and Resiliency Committee (BSRC) — named non-generic committee ✓
- CISO mentioned — cybersecurity-specific role ✓
- CIO mentioned — cybersecurity-specific role ✓

QV check: No specific dates, dollar amounts, headcounts, percentages, named third-party firms, named products/tools, or named certifications. CISO and CIO are named roles (Firm-Specific triggers) but don't count toward QV. BSRC is a named committee, also doesn't count toward QV.

This lands as Firm-Specific with three triggers.

fact: CISO

fact: CIO


content_category: Management Role

reasoning: The entire paragraph is about the people who lead the Information Security Program — their experience, career backgrounds, qualifications, and reporting arrangements (CRO's prior roles, CIO's 25+ years, CISO departure and interim arrangement). This is squarely about the persons, not the function. Multiple QV-eligible hard facts: specific date (November 2024), specific years of experience (20+ years for CRO, 25+ years for CIO, 20+ years average for direct reports).

thinking:
Let me analyze this paragraph from Truist Financial Corp's 10-K filing.

This paragraph is about the people who lead the Information Security Program - their experience, backgrounds, and qualifications. It describes the CRO, CIO, and CISO roles and the individuals' credentials.

Content Category: Management Role - the paragraph is entirely about the people (CRO, CIO, CISO) and their qualifications, experience, and backgrounds. This is clearly about the persons, not the function.

Specific facts:
- CRO (named role - but this is Chief Risk Officer, not cybersecurity-specific... wait, they mention CRO "previously served as our interim CIO" - CRO is generic C-suite)

- CIO and CISO are both cybersecurity-specific titles per the IS list
- Multiple quantified experience metrics: more than 20 years in banking, over 25 years total, over 20 years for direct reports
- Specific date mentioned: November 2024 departure of the CISO
- Interim CISO arrangement noted

So the QV-eligible facts here are the specific dates and the quantified years of experience across the leadership team.

fact: More than 20 years of banking experience (CRO)

type: quantified

fact: Over 25 years of experience leading technology teams (CIO)

fact: Departure of CISO in November 2024

fact: CIO's direct reports have on average over 20 years of experience


content_category: Risk Management Process

reasoning: The paragraph describes the company's own internal cybersecurity audit processes and use of external consultants for maturity assessments — all internal process topics. No facts from the IS list are present: 'Corporate Audit Department' is a generic department name, 'external consultants' are unnamed, 'regular basis' is a generic cadence, and 'maturity assessment' is a common practice. No named frameworks, roles, firms, dates, or specifics.

thinking:
Let me analyze this paragraph.

Content: Describes internal audit team for IT/cybersecurity, use of external resources, and external maturity assessments.

Category: This is about the company's own internal processes - audit team, external consultants for assessments. The external consultants serve the company (Rule 3). → Risk Management Process

Specificity: Let me check for specific facts.
- "Corporate Audit Department" - this is a named internal department but is it unique? It's a generic department name.
- "dedicated team responsible for IT and information security (including cybersecurity) audits" - describes a team but no specifics

- "external consultants" - unnamed, on the NOT list
- "regular basis" - generic cadence, on the NOT list
- "maturity assessment" - common practice

No named frameworks, no named roles from the IS list, no specific dates, no named firms or tools. Everything here is generic → Generic Boilerplate (1)


reasoning: The paragraph describes how TEP's cybersecurity team manages risk using specific threat intelligence sources and monitoring activities. While team certifications are mentioned, the dominant content is about processes (identify, assess, manage, respond to risk, network monitoring, vulnerability scanning), making this Risk Management Process rather than Management Role. Multiple QV-eligible hard facts are present: named certifications (CISSP, GICSP) and named external organizations (E-ISAC, CISA).

thinking:
Let me analyze this paragraph.

Content: Describes TEP's Enterprise Cybersecurity team, their certifications (CISSP, GICSP), and their use of threat intelligence sources (E-ISAC, CISA) and internal tools for risk management activities.

Category: This is about the cybersecurity team's composition and what they do. The person-vs-function test: the paragraph mentions certifications of team members but primarily describes what the team does (uses threat intelligence, monitors, scans). It's a mix - team credentials + process description. The dominant content is about the team's activities and tools. But the team composition and certifications are significant. Let me think...

Actually, the paragraph starts by identifying WHO manages cybersecurity risk (Enterprise Cybersecurity team with certifications), then describes WHAT they do (use threat intelligence, monitoring, scanning). The process description is dominant - the certifications are mentioned as qualifiers but the bulk is about activities. This feels like Risk Management Process with incidental team credentials.

Wait - "Management Role" requires it to be about the person/people. Here it's about a team, not a specific named individual. The team's certifications are mentioned but the paragraph is primarily about processes. → Risk Management Process.

Specificity: CISSP is a named certification that qualifies for QV eligibility, and GICSP is also mentioned.

Looking at the other elements - E-ISAC and CISA are named organizations, which also count as QV-eligible. That gives me multiple hard verifiable facts: two certifications plus two named third-party organizations. This crosses the threshold for Quantified-Verifiable.

fact: CISSP certification

fact: GICSP certification

fact: Electricity Information Sharing and Analysis Center (E-ISAC)

fact: Cybersecurity and Infrastructure Security Agency (CISA)


content_category: Strategy Integration

reasoning: The paragraph contains an explicit materiality assessment ('has not...experienced a cybersecurity incident materially affecting or reasonably likely to materially affect the Corporation'), which per Rule 6 is Strategy Integration regardless of the generic risk language preceding it. The specific date 'December 31, 2024' is one IS-list fact, making it Firm-Specific but not QV (only one hard verifiable fact).

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. Cybersecurity is integrated into risk management strategy (generic)
2. Cyber threats are present and growing (generic risk language)
3. Materiality assessment: "Through December 31, 2024, the Corporation has not... experienced a cybersecurity incident materially affecting..."

The materiality assessment is the key substantive content here. Per Rule 6, any paragraph that explicitly assesses whether cybersecurity risks/incidents have "materially affected" the company is Strategy Integration.

Specificity: "Through December 31, 2024" is a specific date. That's one fact from the IS list. So Firm-Specific. Only one QV-eligible fact, so not QV.

fact: Through December 31, 2024


reasoning: The paragraph is about the people on the cybersecurity team — their experience level, backgrounds, and certifications — making it Management Role (person-focused, not function-focused). It contains a specific quantified fact (20+ years average experience) and a named team (Information Security and Privacy team), but only one QV-eligible hard fact (the years figure); the certifications are unnamed ('cybersecurity certifications' is generic), so it lands at Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph describes the qualifications and experience of the Information Security and Privacy team members - their average experience, certifications, and training.

Content category: This is about the people - their experience, credentials, background. It's describing who the team members are and what makes them qualified. This fits Management Role (person-focused).

Specific facts:
- "Information Security and Privacy team" - this is a named team, but is it a cybersecurity-specific title? It's a specific team composition.
- "average of more than 20 years" - specific number (years of experience)
- "cybersecurity certifications" - generic (doesn't name which certifications)

- "regular training programs" - generic cadence

So I'm looking at what qualifies as a QV-eligible fact here. The "more than 20 years of experience" is a specific number that counts. The team name itself is firm-specific, but the certifications and training cadence are both described generically without specifics. That gives me one QV-eligible fact, and I'd need at least two for this to qualify.

fact: Information Security and Privacy team

fact: average of more than 20 years of experience


reasoning: The paragraph's primary purpose is a materiality assessment ('not experienced a cybersecurity incident that resulted in a material effect on our business strategy, results of operations, or financial condition'), making it Strategy Integration per Rule 6. The 2020 incident is referenced to support the materiality conclusion, not as an incident narrative. The specific year (2020) and description of a publicly announced intrusion is one firm-specific fact, reaching Firm-Specific but not QV (only one hard verifiable fact).

thinking:
Let me analyze this paragraph.

Content: Materiality assessment ("not experienced a cybersecurity incident that resulted in a material effect"), references a past 2020 incident, and cross-references Risk Factors.

Category: The primary purpose is a materiality assessment - Strategy Integration per Rule 6. There's mention of a past incident (2020 malware), but it's used to support the materiality conclusion, not as an incident narrative.

Specificity: Let me check for facts:
- "2020" - specific date (year)
- "systems intrusion" with "malware" - but these are generic incident terms
- Cross-reference to Risk Factors - not a fact

- The 2020 date is the only concrete, verifiable fact here, which makes this Firm-Specific rather than Quantified Value since it needs at least two specific facts.

fact: 2020 publicly announced systems intrusion with malware


reasoning: The paragraph primarily describes the company's internal risk assessment process — mapping, prioritizing, and mitigating information security risks — making Risk Management Process the dominant category. Third-party risks are mentioned as one component (not the central topic), the Board reference is brief, and the hypothetical incident language and cross-reference to Risk Factors are secondary. No named frameworks, cybersecurity-specific roles, named tools, dates, or quantified facts appear; all language is generic and transferable to any company.

thinking:
Let me analyze this paragraph.

Content: Risk assessments, mapping/prioritizing information security risks, risk mitigation strategies, mentions third-party service providers as a component, references Board and management review, includes hypothetical incident language, and ends with a cross-reference to Risk Factors.

Category: The dominant content is about the company's internal risk assessment and mitigation processes. Third parties are mentioned as one component. The Board mention is brief. The hypothetical incident language and cross-reference are secondary. → Risk Management Process

Specificity: Let me check for specific facts:
- No named frameworks
- No cybersecurity-specific titles (just "Board" and "management" - generic)

- No named tools, firms, dates, numbers
- "ransomware attacks" - common practice language
- Cross-reference to Item 1A - not a specific fact

Everything here is generic. No named standards, no firm-specific facts. → Generic Boilerplate


reasoning: The first sentence describes CISO/CIO credentials and reporting lines (Management Role content), but the bulk of the paragraph describes the team's processes: continuous monitoring, penetration testing, tabletop exercises, DR simulations, incident response escalation paths. Applying the person-vs-function test, removing the CISO/CIO attribution leaves a complete process description, so the dominant purpose is Risk Management Process. Two QV-eligible hard facts: '25 years' (CISO experience) and 'over 25 years' (CIO experience) reach the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph starts by describing the CISO (25 years experience, reports to CIO with 25+ years) - this is Management Role content. Then it shifts to describing processes: continuous monitoring, detection, prevention, testing, tabletop exercises, penetration testing, DR simulations, incident response procedures, escalation paths.

Person-vs-function test: The first sentence is about the people (CISO credentials, CIO credentials, reporting line). But the rest of the paragraph is about what the program does. The dominant content is the processes and procedures - that's the bulk of the paragraph.

So this is Risk Management Process with incidental management role attribution at the start.

Now I'm identifying the specific facts that qualify as quantified or named: the CISO and CIO titles are cybersecurity-specific roles, both have quantified experience (25 years and over 25 years respectively), and there's a named team called "Security, Compliance and Data Protection" that represents a specific organizational unit. The experience numbers are concrete facts that could be verified.

Looking at the category more carefully, I should focus on what the paragraph is actually describing. Even if I remove the credential titles, the core content is about risk management processes, so that's the primary category. The two specific experience durations—25 years and over 25 years—are the quantified-verifiable facts here.

fact: CISO leads the team

fact: CISO has 25 years in business risk management and cybersecurity

fact: CIO has over 25 years in information technology and security roles

fact: Reports to the Chief Information Officer (CIO)


reasoning: The first sentence attributes leadership to a CISO with 29 years of experience, but the remainder of the paragraph describes internal processes: continuous monitoring, detection, tabletop exercises, penetration testing, SOC escalation procedures, and incident reporting paths. Applying the person-vs-function test, removing the CISO attribution leaves a complete process description, making Risk Management Process the dominant category. Specificity is Firm-Specific: CISO (cybersecurity-specific title) and 29 years (specific number) are IS-list facts, but only the 29-years figure is QV-eligible, falling short of the two-fact QV threshold.

thinking:
Let me analyze this paragraph.

Content: Led by CISO with 29 years experience, then describes processes - monitoring, detection, prevention, mitigation, remediation, testing, tabletop exercises, penetration testing, SOC procedures, escalation paths.

Category: The first sentence is about the CISO (person - 29 years experience). But the rest of the paragraph is about processes and procedures. Apply the person-vs-function test: remove the CISO attribution and the paragraph still describes processes. The dominant content is Risk Management Process.

Specificity:
- CISO = cybersecurity-specific title (IS list) → Firm-Specific

- 29 years of experience is a specific number that qualifies for QV
- SOC is just a generic term for Security Operations Center, not a named product
- "Wiley" appears to be a company self-reference, which doesn't count

So I've got one QV-eligible fact with the 29 years, but CISO itself is on the IS list as a Firm-Specific trigger even though it's not QV-eligible. That makes this Firm-Specific overall.

fact: CISO

fact: 29 years of experience in business risk management and cybersecurity


reasoning: The paragraph describes the company's internal cybersecurity program — framework alignment, priorities (prevention, protection, detection), approach (monitoring, training, risk assessments), and cyber insurance. This is squarely Risk Management Process. It names two recognized frameworks (NIST CSF, IEC 62443) but contains no firm-specific facts from the IS list — no named roles, tools, dates, headcounts, or third-party firms — so it remains Sector-Adapted.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity program alignment with frameworks (NIST CSF, IEC 62443), program priorities, approach to threats, and cyber insurance.

Category: Risk Management Process - describes internal processes, framework adoption, monitoring, training, risk assessments. The cyber insurance mention is minor. Primary content is about the company's own internal cybersecurity program.

Specificity: Names NIST CSF and IEC 62443 - these are recognized frameworks. Is there anything firm-specific beyond naming frameworks? IEC 62443 is a specific framework for Industrial Control Systems - this is a named standard. But does naming two frameworks make it firm-specific or sector-adapted?

The codebook is clear: naming standards like NIST CSF and IEC 62443 qualifies as Sector-Adapted, even though IEC 62443's focus on industrial control systems hints at the company's OT environment. Without firm-specific details like named roles, dates, tools, or headcounts, everything else reads as generic practice—monitoring, training, risk assessments, and unspecified cyber insurance. This lands at Sector-Adapted (2).

fact: National Institute of Standards and Technology Cyber Security Framework (NIST CSF)

type: framework

fact: International Electrotechnical Commission 62443 (IEC 62443)


content_category: None/Other

reasoning: This paragraph defines 'cybersecurity risk' in generic terms and notes that threats are growing in number and sophistication — a truism applicable to any company. It contains no substantive disclosure about governance, processes, incidents, or strategy; it is introductory/definitional language with no actionable cybersecurity content.

thinking:
Classifying this paragraph.

This is a definitional paragraph about cybersecurity risk and a generic statement about growing threats. No specific processes, no board/management details, no incident, no strategy. It's general business language.

Content: Defines "cybersecurity risk" generically, notes growing threats. No substantive disclosure.

Category: None/Other - this is generic definitional language about what cybersecurity risk is, not describing any program, governance, or specific disclosure.

Wait - let me reconsider. It does mention cybersecurity risk in the context of the bank's operations. But it's really just a definitional preamble. No processes, no governance, no specifics.

So I'm marking this as None/Other with a generic boilerplate specificity rating of 1.


reasoning: The paragraph describes the company's use of independent third parties to assess its own security programs — external assessors serving the company's internal processes (Rule 3). The ROC is a named non-generic committee qualifying as a firm-specific fact; however, the assessment types listed (penetration testing, tabletop exercises, etc.) are common practices and the third parties are unnamed, so no second hard verifiable fact reaches QV.

thinking:
Let me analyze this paragraph.

Content: Describes engaging third parties to assess their security programs, lists types of assessments, mentions review with management and ROC, participation in forums.

Category: This is about the company's own internal processes - using external assessors to evaluate their program. The third parties here serve the company (Rule 3: "External assessor hired to test the company → Risk Management Process"). So Risk Management Process.

Specificity: Let me check for specific facts.
- "ROC" - this appears to be a named committee (Risk Oversight Committee?) - that's a non-generic committee name → Firm-Specific
- No named frameworks, no named firms, no dates, no dollar amounts, no headcounts

- The assessment types listed (penetration testing, tabletop exercises, etc.) are common practices, not specific items
- "third parties and cyber experts" are unnamed entities
- "management" is generic

ROC is the only firm-specific fact here - a named non-generic committee. That's enough to classify this as Firm-Specific overall.

fact: ROC (Risk Oversight Committee) reviews assessment findings


reasoning: The paragraph describes the company's internal cybersecurity program: framework adoption (NIST CSF), certification status (ISO 27001:2022), and annual enterprise-wide risk assessment integrated with ERM. Board and management are mentioned but as context for the risk assessment process, not as the primary subject. Holding ISO/IEC 27001:2022 certification is a firm-specific verifiable fact beyond merely naming the standard, pushing this above Sector-Adapted to Firm-Specific. Only one QV-eligible hard fact (the certification claim), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity program frameworks (NIST CSF), ISO 27001 certification, annual ERA process, cybersecurity as key risk. This is about internal processes and frameworks.

Category: Risk Management Process - describes framework adoption, risk assessment methodology, ERM integration.

Specificity:
- Names NIST CSF → framework
- "ISO/IEC 27001:2022 certified" → This is a certification claim, not just naming the standard. Per the IS list: "We maintain ISO 27001 certification" is Firm-Specific.

- "annual enterprise-wide risk assessment (ERA)" → This is a generic description of an internal process, not a unique identifier or named program that would be Firm-Specific.

Checking for QV facts: no specific dates beyond "annual," no dollar amounts, headcounts, or percentages, no named third-party firms, products, or tools, and no individual certifications.

The key IS fact here is the ISO/IEC 27001:2022 certification claim, which qualifies as Firm-Specific, while NIST CSF is just a sector-adapted framework reference.

The ISO certification is organizational rather than individual, so it doesn't meet the QV criteria that specifically requires named certifications held by individuals like CISSP or CISM. That leaves me with one Firm-Specific fact overall.

fact: ISO/IEC 27001:2022 certified

fact: NIST Cybersecurity Framework


reasoning: The paragraph describes what a dedicated cybersecurity unit does — implement controls, assess/report risks, consult with ERM — making it about internal processes, not the person leading them. The SVP of Enterprise Strategy and Execution is mentioned as attribution but is not a cybersecurity-specific title per the IS list (not CISO/CTO/CIO/VP of IT Security), and no named frameworks, dates, tools, or other specific facts are present, so this remains Generic Boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph describes a dedicated unit led by the SVP of Enterprise Strategy and Execution. It describes what this unit does (implement controls, assess/report risks, consult with ERM unit).

Category: The paragraph describes internal processes - implementing controls, assessing risks, reporting, consulting with ERM. The SVP title is mentioned as attribution for who leads the unit. Using the person-vs-function test: if I remove "led by the SVP of Enterprise Strategy and Execution," the paragraph still describes the unit's functions. So this is Risk Management Process.

Wait - actually, the SVP title is the primary organizational detail here.

But the paragraph is really about the unit's functions and responsibilities, not about the person themselves. There's no background, credentials, or board reporting structure mentioned. The SVP title is just a general corporate role, not a cybersecurity-specific one like CISO or CIO, so it doesn't carry specialized significance here. This is Risk Management Process.


reasoning: The paragraph describes the company's internal cybersecurity program: framework adoption (NIST CSF five pillars), deployed tools, policy review processes, and third-party expert engagement as a component of the internal program. Third parties are mentioned as one element supporting internal processes, not as the central topic. The NIST framework is named, but all other details (firewalls, MFA, tabletop exercises, penetration testing, unnamed third-party experts) are common practices on the NOT list with no firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity program - NIST framework, tools deployed, policies, third-party experts engaged. This is about internal processes and methodology.

Category: Risk Management Process - describes framework adoption, tools, monitoring, testing, etc. Third parties are mentioned as one component of internal processes, not as the central topic.

Specificity: Names NIST framework → at least Sector-Adapted. Any firm-specific facts? Let me check the IS list:
- "National Institute of Standards and Technology" = NIST framework → named standard
- No cybersecurity-specific titles (CISO, CTO, etc.)

- No named committees, dates, tools by name, firms, headcounts, or dollar amounts
- "Davey's policies" is a company self-reference → NOT list
- The tools mentioned (firewalls, MFA, anti-malware) are common practices → NOT list
- Third-party experts are unnamed → NOT list

So: named framework (NIST) but nothing firm-specific beyond that → Sector-Adapted.

fact: National Institute of Standards and Technology (NIST) framework


reasoning: The paragraph describes the company's internal cybersecurity processes: incident response plan, risk assessments, vulnerability scanning, penetration testing, training, and IT team monitoring/reporting. All content is about what the company does internally to manage cyber risk. No named frameworks, no named tools/firms, no specific dates or numbers — every element appears on the NOT list (generic program names, common practices, unnamed consultants, generic team references).

thinking:
Let me analyze this paragraph from Cavco Industries' 10-K filing.

Content: Describes the company's cybersecurity program including incident response plan, training, risk assessments, vulnerability scanning, penetration testing, IT team monitoring and reporting.

Category: This is clearly about internal cybersecurity processes - Risk Management Process.

Specificity: Let me check for specific facts:
- "incident response plan" - generic program name (NOT list)
- "IT team" - generic
- "cybersecurity consultants" - unnamed (NOT list)
- "leadership team" - generic
- "threat modeling, vulnerability scanning and penetration testing" - common practices (NOT list)

- No named frameworks, no named tools, no specific dates, no named firms, no specific numbers, no named standards

This is generic boilerplate with no substantive details.


reasoning: The paragraph is about the company's cybersecurity program — frameworks, monitoring, incident response, training, audits, and layered defenses. The CISO is mentioned as attribution but the substantive content describes internal processes and program activities, making this Risk Management Process per the person-vs-function test. Specificity is Firm-Specific: the company claims ISO 27001 certification (a verifiable firm fact beyond merely naming the standard), names cybersecurity-specific roles (CISO, CIO), and integrates with ISO 13485. However, QV-eligible hard facts (dates, dollars, headcounts, named third-party firms, named tools) do not reach two, so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes the CISO's organization monitoring and managing cybersecurity risks, program alignment with NIST CSF, ISO 27001 certification, ISO 13485 integration, layered defenses, monitoring, incident response, training, business continuity, auditing.

Category: The CISO is mentioned as attribution at the start, but the paragraph is overwhelmingly about what the program does - processes, frameworks, tools, training, audits. This is Risk Management Process per the person-vs-function test.

Specificity:
- CISO = cybersecurity-specific title → IS list ✓

- CIO = cybersecurity-specific title → IS list ✓
- NIST CSF = named framework
- ISO 27001 certification = holding certification is firm-specific
- ISO 13485 = named standard
- "managed detection and response service provider" = unnamed, NOT list
- "third-party vendors" = unnamed, NOT list

Now I'm looking at what counts as a hard verifiable fact for QV eligibility—dates, dollar amounts, headcounts, named third-party firms, named products, and named certifications held by individuals. The ISO 27001 certification and ISO 13485 are both certification claims specific to the firm.

But wait, the QV list specifically calls out individual certifications like CISSP, CISM, or CEH. Company-level certifications don't qualify. So while I have multiple firm-specific facts like the CISO and CIO titles plus these certifications, I'm not seeing two hard verifiable facts that meet the QV threshold.

This looks like it should be categorized as firm-specific rather than QV-eligible.

fact: CIO

fact: Certified to ISO 27001

fact: ISO 13485 (QMS integration)


reasoning: The paragraph describes the company's own internal cybersecurity assessment processes — engaging external consultants and integrating cybersecurity into internal control assessments. External consultants and auditors serve the company's program (Rule 3), making this Risk Management Process rather than Third-Party Risk. No named firms, frameworks, dates, or specific facts are present; all entities are generic ('external consultants', 'independent registered public accounting firm', 'periodically').

thinking:
Let me analyze this paragraph.

Content: Discusses external consultants assessing cybersecurity program, internal control assessments related to cybersecurity, and independent auditor auditing internal controls.

Category: This is about the company's own internal processes - risk assessment methodology, external assessments. The external consultants serve the company (Rule 3). The auditors are part of internal control assessment. This is Risk Management Process.

Specificity: Let me check for specific facts:
- "external consultants" - generic, on the NOT list
- "independent registered public accounting firm" - generic, unnamed
- "periodically" - generic cadence
- "annual assessment" - generic cadence

- No named frameworks, no named firms, no specific dates, no numbers

This is Generic Boilerplate.


reasoning: The paragraph describes Amgen's internal cybersecurity processes — risk assessment, employee training, monitoring, and incident response — making it Risk Management Process. It names two uniquely identified internal teams (DTI and CDT) which are firm-specific, but contains no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes Amgen's cybersecurity risk management approach, naming specific internal teams (DTI, CDT) and their functions - risk assessment, training, monitoring, incident response.

Category: Risk Management Process - describes internal processes, teams, and activities. The DTI and CDT are organizational units, not individual management roles.

Specific facts:
- "Digital, Technology & Innovation (DTI)" - named internal program with unique identifier
- "Cybersecurity & Digital Trust (CDT)" - named internal program with unique identifier

These are named internal programs/teams with unique identifiers (abbreviations), which qualifies under the IS list.

The rest of the content uses only generic role titles and descriptions without any named frameworks, dates, dollar amounts, or third-party references. So I'm categorizing this as Firm-Specific (3) since the two named internal programs don't qualify for QV eligibility.

fact: Digital, Technology & Innovation (DTI) function

fact: Cybersecurity & Digital Trust (CDT) team


content_category: Third-Party Risk

specificity_confidence: medium

reasoning: The entire paragraph is about oversight of external vendors — annual reviews, remediation/replacement process, and documentation — making Third-Party Risk the clear category. The mention of specific departmental roles ('Risk and Information Security employees') is a firm-specific team composition detail, but there are no named standards, dates, dollar amounts, or named firms to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes third-party vendor risk management - annual reviews, cybersecurity/business continuity requirements, remediation process, documentation. The central topic is vendor oversight.

Category: Third-Party Risk - the entire paragraph is about oversight of external vendors.

Specificity: Let me check for facts:
- "annual reviews" - generic cadence
- "third-party vendors" - generic
- "Risk and Information Security employees" - this is a specific team/department composition mentioning specific departments

Wait, let me re-check. "Risk and Information Security employees" - is this a specific team composition? It names specific departments (Risk, Information Security). Per the IS list: "Specific team/department compositions: 'Legal, Compliance, and Finance'" - so naming specific departments like "Risk and Information Security" would qualify as firm-specific.

No named frameworks, no dates, no dollar amounts, or named firms/tools. The only concrete detail here is the specific departmental composition - "Risk and Information Security employees" - which identifies how the firm structures this function, making it firm-specific.

fact: Risk and Information Security employees acknowledge third-party risk assessments


category_confidence: medium

reasoning: The paragraph contains an explicit materiality assessment ('We have not had any material cybersecurity breaches or incidents and have not incurred any material expenses, penalties or settlement costs'), which per Rule 6 makes it Strategy Integration. While it opens with ERM integration and threat enumeration, the core communicative purpose is the materiality conclusion and forward-looking impact assessment. No named frameworks, specific dates, named roles, or other IS-list facts are present.

thinking:
Let me analyze this paragraph.

Content: It discusses ERM integration of cyber risks, lists threat types, cross-references Risk Factors, makes a materiality assessment ("We have not had any material cybersecurity breaches..."), and includes forward-looking risk language.

Category: The paragraph contains multiple elements:
- ERM integration mention (Risk Management Process)
- List of threat types (generic)
- Cross-reference to Risk Factors (None/Other)
- Materiality assessment - "We have not had any material cybersecurity breaches or incidents and have not incurred any material expenses" (Strategy Integration)
- Forward-looking disclaimer language

The materiality assessment is a key element here.

Looking at the structure more carefully, the explicit materiality conclusion about whether incidents and expenses have materially affected the company is the dominant purpose here. Per the codebook, when a paragraph explicitly assesses materiality of cybersecurity risks or incidents, that's Strategy Integration. Even though there's ERM language at the start, the materiality statement is what drives the categorization.

Now checking the specificity—there's just generic program language, threat type lists, and section references with no named frameworks, dates, dollar amounts, or specific roles. This is clearly Generic Boilerplate.


reasoning: The paragraph contains explicit materiality assessments — 'have not experienced any material cybersecurity incidents' and 'may materially affect our business strategy, results of operations or financial condition' — making it Strategy Integration per Rule 6, even though it ends with a cross-reference to Risk Factors. No named frameworks, specific dates, named roles, or other firm-specific facts are present; the language is standard boilerplate that could appear in any filing.

thinking:
Let me analyze this paragraph.

Content: This paragraph makes a materiality assessment ("have not experienced any material cybersecurity incidents", "may materially affect our business strategy, results of operations or financial condition"), then cross-references Risk Factors. Per Rule 6, materiality disclaimers → Strategy Integration. The paragraph explicitly assesses whether cybersecurity risks have materially affected the company.

Specificity: No named frameworks, no firm-specific facts. "Past fiscal year" is a generic cadence. Everything here is boilerplate materiality language. → Generic Boilerplate.


reasoning: The paragraph describes the management committee structure for cybersecurity: who chairs them (CISO, Chief Privacy Officer), their composition, meeting cadence, and reporting lines. The primary content is organizational structure and leadership roles, not specific risk management processes or tools. Multiple named non-generic committees and cybersecurity-specific roles make this Firm-Specific; only one QV-eligible fact (approximately 20 departments) prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes management committees - Security and Technology Risk Leadership Committee, Privacy and Data Governance Committee, their chairs (CISO, Chief Privacy Officer), composition, meeting cadence, and reporting to Data Security and Privacy Governance Committee.

Category: This is about management committees responsible for cybersecurity. The grammatical subjects are the committees, not the board. These are management-level committees. The paragraph describes who leads them and how they're structured - this is about organizational structure and reporting lines at the management level. Management Role fits - it's about the structure of management oversight, committee composition, reporting lines.

Actually, let me reconsider.

The key question is whether this focuses on the people and their organizational relationships or on the actual processes and methodologies they employ. Looking at the content, it's really about who chairs these committees, how they're composed, and how they report up the chain. There's no mention of specific risk frameworks, tools, or management processes - just the structural arrangement of oversight. This is definitely Management Role, describing the governance structure and accountability lines rather than the substance of what those committees actually do. Looking at the "approximately 20 departments" fact, that's a quantified headcount, which makes it Firm-Specific rather than QV-eligible.

fact: CISO chairs the Security and Technology Risk Leadership Committee

fact: Privacy and Data Governance Committee

fact: Chief Privacy Officer chairs the Privacy and Data Governance Committee

fact: approximately 20 departments represented


reasoning: The paragraph describes the company's overall cybersecurity program: engaging third parties to support internal processes (assessors serving the company → RMP per Rule 3), deploying internal technical safeguards, and managing third-party/fourth-party risks as components of the broader program. While the third-party risk management content is substantial, it is presented as one component of the company's internal cybersecurity program alongside technical controls and external assessments. The IT/Cybersecurity Committee is a named non-generic committee on the IS list, pushing specificity to Firm-Specific; however, no second QV-eligible hard fact is present.

thinking:
Let me analyze this paragraph from Trico Bancshares' 10-K filing.

The paragraph covers multiple topics:
1. Engaging third parties for cybersecurity services (risk assessments, program enhancements, user verification)
2. Technical safeguards (firewalls, IDS/IPS, EDR, etc.)
3. Third-party risk management program
4. Fourth-party risk consideration

The dominant topic: This is a mixed paragraph. It starts with third-party engagements supporting the company's own processes, then describes internal technical safeguards, then shifts to third-party risk management. The third-party risk management program discussion (identifying risks from third-party providers, fourth-party risks) takes up roughly the latter half.

Now I'm applying the classification rules. The first part about engaging external parties to support the company's own cybersecurity processes falls under Risk Management Process, as does the technical safeguards section describing internal controls. But the latter portion focusing on oversight of vendors and fourth-party risks clearly belongs to Third-Party Risk. Since the paragraph is split between these two categories, I need to determine which dominates—and it looks like the third-party risk management discussion takes up enough space to make this primarily a Third-Party Risk paragraph. I'm counting through the sentences more carefully to see where the emphasis really falls. The paragraph does dedicate substantial space to third-party risk management—sentences 4-7 cover identifying risks from third-party providers, enterprise-wide risk assessment engagement, reporting structures, and fourth-party risks. That's significant coverage, but the opening sentences establish internal processes and technical safeguards as the foundation. Given that the paragraph begins with and maintains focus on the company's own cybersecurity processes, with third-party risk management presented as one component within that broader program, Risk Management Process seems like the right fit. The named IT/Cybersecurity Committee pushes this to Firm-Specific, though the technical safeguards themselves are standard practices. Since the paragraph's main thrust is describing the company's overall cybersecurity program as an integrated approach, Risk Management Process remains the right category.

fact: IT/Cybersecurity Committee of the board


reasoning: The paragraph's primary content is the management committee's structure, composition (CIO, CISO, named departments), and reporting lines to both the Enterprise Risk Committee and the board's IT/Cybersecurity Committee — this is organizational architecture for cybersecurity management. While oversight activities are mentioned, they are subordinate to describing who sits on the committee and how it reports. Multiple firm-specific facts (named non-generic committees, CISO/CIO roles, specific departmental composition) but no QV-eligible hard facts reaching the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the IT/Cybersecurity Committee, its composition, meeting cadence, and reporting structure. Let me determine category and specificity.

**Category Analysis:**
- The paragraph starts with "Our board of directors has approved various management committees including the IT/Cybersecurity Committee" - but the primary actor throughout is this management committee, not the board itself.
- The committee is "chaired by the CIO" and includes the CISO - these are management roles.
- The committee's activities: oversight of risk management strategy, standards, policies, practices, controls, mitigation efforts.
- Reports to the Enterprise Risk Committee (management level).

- The CISO reports to the board's IT/Cybersecurity Committee.

This is fundamentally about the management committee's structure and function—who comprises it, what responsibilities it holds, and how it connects within the organizational hierarchy. The board's approval and receipt of reports are mentioned, but the focus is on the committee itself as the primary subject. I'm trying to determine whether this falls under Management Role or Risk Management Process, and the person-versus-function test suggests it's primarily describing the committee's composition and oversight activities rather than a specific individual's responsibilities. I'm checking the codebook definition—Management Role covers management committees responsible for cybersecurity, which this clearly is. The primary focus here is the committee's structure, composition, and reporting relationships rather than individual credentials, so that classification fits. Now I'm working through the specificity analysis, identifying the named committees, specific roles like the CIO and CISO, and the detailed team composition across information technology, risk, compliance, operations, and human resources.

fact: CIO chairs the committee

fact: CISO is a member and reports to the board committee

fact: Committee includes information technology, risk, compliance, operations, and human resources/training

fact: Enterprise Risk Committee (management-level)

fact: IT/Cybersecurity Committee of the board of directors


content_category: Incident Disclosure

reasoning: The paragraph primarily describes actual cybersecurity incidents the company has experienced — unauthorized access, fraud attempts, compromised credentials, customer data exposure — and highlights a specific 2023 third-party vendor incident involving the MOVEit Transfer zero-day vulnerability. While the final sentence is a materiality disclaimer (Strategy Integration), the dominant communicative purpose is incident narrative across multiple real events. Two QV-eligible hard facts: a specific date (2023) and a named product/tool (MOVEit Transfer).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes past cybersecurity incidents - unauthorized access, fraud attempts, compromised credentials, customer data exposure, and specifically mentions a 2023 third-party vendor incident involving MOVEit Transfer zero-day vulnerability. It concludes with a materiality disclaimer.

Content category: This is a mix of Incident Disclosure and Strategy Integration. The paragraph describes actual incidents (unauthorized access, fraud, data exposure, MOVEit Transfer incident) and ends with a materiality assessment. The dominant content is describing what happened - multiple incidents, their nature, and a specific named incident. But the final sentence is a materiality conclusion.

Per the tiebreakers: "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure." The bulk of the paragraph describes incidents. The materiality sentence is appended but the dominant purpose is incident narrative.

I'm reconsidering whether this is really a detailed incident disclosure or more of a summary across multiple incidents. The paragraph does reference actual events with the MOVEit Transfer incident specifically named in 2023, so the core content is still describing what happened. I'll stick with Incident Disclosure as the primary category since the majority of the text focuses on describing actual incidents.

Looking at specificity, I have "2023" as a specific year and "MOVEit Transfer" as a named product, which both count. The "zero-day vulnerability" language is more generic, and the materiality statement at the end doesn't add specific factual details.

So I'm identifying two hard verifiable facts here—the specific date and the named product—which qualifies this as Quantified-Verifiable.

fact: In 2023, a third-party vendor experienced an incident

fact: MOVEit Transfer file sharing software


reasoning: The paragraph's central topic is vendor/supplier security oversight — requiring vendors to meet security standards and imposing contractual security obligations on third parties. No named frameworks, specific roles, dates, numbers, or other facts from the IS list are present; 'industry standard security protections' and 'vendor management program' are generic.

thinking:
Classify this paragraph.

Content: About vendor management program, security risk assessments for vendors, contractual requirements for third-party compliance. Central topic is oversight of external parties' cybersecurity.

Category: Third-Party Risk - vendor oversight is the central topic.

Specificity: No named standards, no specific facts from the IS list. "vendor management program" is generic. "industry standard security protections" is vague. No named frameworks, no specific roles, no dates, no numbers.

→ Generic Boilerplate


reasoning: The paragraph describes the company's internal cybersecurity training program for employees—an internal process activity. Despite the label 'Mandatory Cyber Training,' this is a generic program name describing common security awareness training practices. No named frameworks, cybersecurity-specific roles, specific dates, or other IS-list facts are present; 'security awareness training' and 'onboarding' are standard practices at any company.

thinking:
Classify this paragraph about Six Flags' mandatory cyber training.

Content: Describes mandatory cybersecurity training for all team members during onboarding and ongoing throughout the year. This is about the company's internal cybersecurity processes/practices.

Category: Risk Management Process - describes internal training processes.

Specificity: Let me check the facts:
- "Mandatory Cyber Training" / "Cybersecurity Training" - generic program name
- "All Six Flags team members" - company self-reference
- "onboarding process" - generic
- "throughout the year" - generic cadence

No named frameworks, no specific facts from the IS list. Common practices like "security awareness training" are on the NOT list.

This is generic boilerplate—no specific details or frameworks that would distinguish it from standard security training language.


reasoning: The paragraph describes the company's cybersecurity incident response plan, the composition of its incident response team, and tabletop exercises — all internal processes. The CISO and DPO are mentioned as attribution for who leads the team, but the substantive content is about the process itself (person-vs-function test: remove the role names and it still reads as a process description). Two cybersecurity-specific roles (CISO, DPO) qualify as IS-list facts for Firm-Specific, but named roles are not QV-eligible, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes incident response plan, incident response team led by CISO and DPO, tabletop exercises. This is about internal processes.

Category: Risk Management Process - describes IR plan, IR team composition, tabletop exercises. The CISO/DPO are mentioned as attribution for who leads the team, but the paragraph is about the process.

Specificity:
- CISO = cybersecurity-specific title → IS list ✓
- DPO (Data Protection Officer) = cybersecurity-specific title → IS list ✓
- "incident response plan" = generic program name → NOT list

- "tabletop exercises" = common practice → NOT list
- "periodic" = generic cadence → NOT list

So I have CISO and DPO as specific facts, but named roles aren't QV-eligible. DPO isn't explicitly on the IS list, though it's a cybersecurity/data protection specific title similar to "Information Security Officer," so I'll treat it as such. This gives me Firm-Specific (3) - CISO and DPO are specific facts but not QV-eligible.

fact: CISO

fact: DPO (Data Protection Officer)


reasoning: The paragraph is entirely about the person — her experience (34 years, 23 years), educational background, and how she stays current on threats. This is the person-vs-function test: remove the person details and there is no substantive process description remaining. Two specific numerical durations (34 years, 23 years) are QV-eligible hard verifiable facts.

thinking:
Management Role - about the person's background, experience, credentials.

Facts: "Executive Vice President, Senior Operations Officer" - this is a specific title but is it cybersecurity-specific? It's more of an operations role. Let me check... The IS list includes "cybersecurity-specific titles: CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security, HSE Director overseeing cybersecurity." This is EVP/Senior Operations Officer - not clearly cybersecurity-specific per the IS list.

But wait - "34 years of experience" is a specific number (quantified), "23 years" is another specific number. These are QV-eligible as "years of experience as a specific number."

The two specific numbers - 34 years total and 23 years in the current role - give me two hard verifiable facts that qualify as Quantified-Verifiable. This paragraph is purely about the person's background and role, so it falls under Management Role.

fact: 34 years of experience in operations and technology

fact: 23 years in the role of Senior Bank Operations Officer


reasoning: The paragraph describes the company's use of external assessors and consultants to evaluate and test its own cybersecurity systems and incident response plan. Per Rule 3, external assessors hired to test the company are Risk Management Process, not Third-Party Risk. No named firms, frameworks, dates, roles, or other specific facts appear — 'cybersecurity assessors and consultants' are unnamed entities on the NOT list, and 'IRP' is a generic program name.

thinking:
Let me analyze this paragraph.

Content: Describes engaging external experts for evaluating/testing cybersecurity systems. The central topic is use of third-party assessors/consultants to help the company's own program.

Per Rule 3: "External assessor hired to test the company" → Risk Management Process (they serve the company). This isn't about imposing requirements ON vendors; it's about using external experts to evaluate the company's own systems.

Category: Risk Management Process

Specificity: No named frameworks, no named firms, no specific dates, no named roles, no specific facts. "external experts," "cybersecurity assessors and consultants" are unnamed entities (on the NOT list). "IRP" is just "incident response plan" abbreviated - generic program name. No IS-list facts.

This falls into generic boilerplate territory since it lacks any concrete details or named entities.


reasoning: The paragraph primarily narrates an actual cybersecurity incident — the MOVEit Transfer breach — describing what happened, scope of customer data exposure, vendor remediation (patches), customer notification, and operational impact. While it closes with a materiality statement and insurance mention, the dominant content is the incident narrative. Three QV-eligible hard facts: specific date (2023), named third-party firm (Progress Software Corporation), and named product (MOVEit Transfer).

thinking:
Let me analyze this paragraph carefully.

This describes an actual cybersecurity incident - the MOVEit Transfer breach. Let me identify the content and facts.

Content: Describes an incident involving MOVEit Transfer, a third-party vendor, customer data exposure, response actions, and concludes with materiality assessment and insurance.

The paragraph primarily describes what happened in an incident: the MOVEit breach, how it affected the bank, customer data exposure, vendor response, customer notification. There's also a materiality statement and insurance mention at the end.

Category tiebreaker: The paragraph DESCRIBES what happened (MOVEit incident, vendor involvement, patches, customer notification, investigation). The materiality and insurance sentences are subordinate. → Incident Disclosure.

Now I'm checking for specific, verifiable facts that would qualify this for quantified-verifiable classification. I can identify three key facts: the year 2023, the named vendor Progress Software Corporation, and the specific product MOVEit Transfer. That gives me three QV-eligible facts, which pushes this toward Quantified-Verifiable classification.

fact: during 2023

fact: Progress Software Corporation

fact: MOVEit Transfer

fact: 2023 fiscal year


reasoning: The paragraph describes the company's internal cybersecurity monitoring technologies (firewalls, endpoint protection, MFA, MDR) and processes, with third-party risk mentioned as one component rather than the central topic, making Risk Management Process dominant. Despite detailed-sounding language, no named frameworks, named products/tools, named firms, specific dates, or quantified facts are present — 'next generation firewalls,' 'Managed Detection and Response,' and 'vendor risk assessments' are all generic practices that could appear in any company's filing.

thinking:
Let me analyze this paragraph.

Content: Describes technologies and processes - next gen firewalls, endpoint protection, MFA, MDR, plus third-party risk processes including info sharing, vendor risk assessments, collaboration with federal agencies.

Category: This is primarily about the company's internal cybersecurity processes and technologies. Third-party risk is mentioned but as one component. → Risk Management Process

Specificity: Let me check for specific facts.
- "next generation firewalls" - generic practice
- "advanced endpoint and email protection" - generic
- "multi-factor authentication" - generic practice
- "Managed Detection and Response" - generic capability, not a named product/tool

- "industry information sharing groups" - unnamed
- "vendor risk assessments" - generic
- "federal agencies" - unnamed

No named frameworks (NIST, ISO, etc.), no named tools/products, no cybersecurity-specific titles, no dates, no numbers. Everything here is generic practices and capabilities. → Generic Boilerplate


reasoning: The paragraph describes S&T's internal Information Security Program objectives, processes, and ERM integration — all hallmarks of Risk Management Process. No named frameworks, cybersecurity-specific roles, dates, tools, or other IS-list facts appear; the program descriptions (protecting data, monitoring threats, business continuity) are generic practices that could apply to any company.

thinking:
Classify this paragraph.

Content: Describes the company's Information Security Program - policies, procedures, controls, risk assessment, ERM integration, objectives (protecting data, updating program, maintaining security team, business continuity).

Category: Risk Management Process - describes internal cybersecurity processes, ERM integration.

Specificity: Let me check for specific facts.
- "Information Security Program" - generic program name, no unique identifier
- "Enterprise Risk Management, or ERM Program" - generic
- No named frameworks, no named tools, no specific dates, no headcounts, no named roles (CISO etc.)
- "IT security professionals" - generic

- All objectives listed are common practices, no IS-list facts, no named standards → Generic Boilerplate (1)


reasoning: The paragraph describes the company's internal risk assessment methodology — identifying threats, evaluating likelihood and impact, and assessing sufficiency of controls. All language is generic (no named frameworks, tools, roles, dates, or firm-specific details) and could appear in any company's filing unchanged.

thinking:
Classify this paragraph.

Content: Describes internal risk assessment processes - identification of threats, likelihood assessment, sufficiency of controls. This is clearly Risk Management Process.

Specificity: No named frameworks, no named roles, no dates, no firm-specific facts. "Regular risk assessments," "material change in business practices," "internal and external risks" - all generic. This is Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and monitoring processes (information security program, risk identification, likelihood/severity assessment), which maps to Risk Management Process. No named frameworks, specific roles, dates, or firm-specific details are present — the language could apply to any company.


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected') regarding cybersecurity risks, making it Strategy Integration per Rule 6. The cross-reference to Risk Factors does not change the classification. No specific facts from the IS list are present — all language is boilerplate.


reasoning: This multi-topic paragraph's primary communicative purpose is describing the corporation's overall cybersecurity program — frameworks adopted (NIST, ISO 27001, FFIEC), policies and procedures, and governance structure. The CTO/CRO credentials and board oversight content are subordinate to the program description. Applying the person-vs-function test, removing the CTO/CRO qualifications leaves a coherent program description. Specificity is Firm-Specific: multiple IS-list facts (CTO role, named non-generic committees EERM/BERM, 50 years combined experience) but only one QV-eligible hard fact (50 years), falling short of the two needed for Quantified-Verifiable.

thinking:
This is a long, multi-topic paragraph. Let me analyze it.

Content spans: frameworks (NIST, ISO 27001/27002, FFIEC), policies/procedures, management roles (CTO, CRO with 50 years combined experience), named committees (EERM, BERM), board oversight, KRIs.

Dominant category: This paragraph covers Risk Management Process (frameworks, policies), Management Role (CTO, CRO, experience), and Board Governance (BERM, board reviews). The paragraph starts with the framework/process, then moves to who leads it (CTO/CRO with qualifications), then committees and board oversight.

The paragraph's main point is establishing the cybersecurity program's foundation through established frameworks and policies, with experienced leadership and formal governance structures overseeing the whole operation. The CTO and CRO bring substantial expertise, while the committees and board provide the oversight layer that ties everything together. The person-versus-function test clarifies this for me—while the CTO and CRO credentials are mentioned, they're really just supporting details within a larger description of the program structure itself. If I stripped out those qualifications, the core message about the framework, policies, committees, and board oversight would remain intact. So Risk Management Process is the dominant category here, with the specificity of named frameworks like NIST and ISO 27001/27002 reinforcing that focus.

For quantified value, the "50 years of combined experience" is a concrete number, and the named committees (EERM, BERM) add specificity too. Though I should note that CRO isn't actually on the cybersecurity-specific titles list—it's more of a generic executive role—whereas CTO clearly qualifies.

Looking at what I have: one quantified fact and multiple firm-specific details, but that single QV-eligible fact isn't enough to meet the threshold of two. So this falls into Firm-Specific classification.

fact: NIST

fact: FFIEC

fact: Chief Technology Officer (CTO)

fact: Chief Risk Officer (CRO)

fact: over 50 years of combined experience

fact: Executive Enterprise Risk Management Committee (EERM)

fact: Board Enterprise Risk Management Committee (BERM)


reasoning: The paragraph opens with the board approving and delegating incident response authority, then describes the reporting chain back to the board (ISO/CIO → IRT including CEO → board, Chief Legal Counsel → board). Per Rule 2, 'Board delegates responsibility to management' signals Board Governance; the board's delegation and ultimate oversight frame the entire paragraph. The Information Security Officer and CIO are cybersecurity-specific titles on the IS list, yielding Firm-Specific, but no QV-eligible hard facts (named roles don't count toward QV).

thinking:
Let me analyze this paragraph.

The paragraph describes the board delegating incident response to an Incident Response Team, then describes the reporting chain: ISO and CIO lead the team, report to the team which includes the CEO, CEO reports to the board, and Chief Legal Counsel communicates regulatory matters to the board.

Category: This is about reporting lines and organizational structure for incident response. The board is mentioned but mainly as the delegating authority. The primary content is about the management reporting structure - who reports to whom, who leads what. The grammatical subjects shift between the board, ISO/CIO, CEO, and Chief Legal Counsel. The dominant content is the management reporting chain and structure.

The opening sentence frames this as board action—delegating responsibility to management—which makes this fundamentally about board governance and oversight. Even though the bulk of the paragraph details the management reporting chain, the communicative purpose is showing how the board maintains control through structured information flow back up the hierarchy.

Looking at the specificity markers: the Information Security Officer and Chief Information Officer are firm-specific cybersecurity roles, while the Incident Response Team, CEO, and Chief Legal Counsel are generic titles. That gives me three firm-specific facts with no quantifiable data, dates, or named entities—so this lands at Firm-Specific (3).

fact: Information Security Officer assigned as Incident Response Team leader

fact: Chief Information Officer assigned as Incident Response Team leader


reasoning: The paragraph's primary content is the management reporting structure for incident response: the ISO and CIO lead the Incident Response Team, report to a team including the CEO, who escalates to the board. While the board opens and closes the paragraph (delegating authority and receiving reports), the bulk describes management roles, assignments, and reporting lines. The ISO and CIO are cybersecurity-specific titles on the IS list, making this Firm-Specific; however, no QV-eligible hard facts (dates, dollar amounts, named firms, headcounts) are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the board delegating incident response to an Incident Response Team, then describes the reporting chain: ISO and CIO lead the team, report to the team which includes the CEO, CEO communicates to the board, and Chief Legal Counsel communicates regulatory compliance matters to the board.

Category: This is about reporting lines and management structure for incident response. The board is mentioned but primarily as the entity that delegated and receives reports. The primary content is about the management structure - who the Incident Response Team leaders are, reporting lines, etc. The grammatical subjects shift between the board, the ISO/CIO, CEO, and Chief Legal Counsel.

I'm identifying the key signals here: the board's delegation action, the ISO and CIO's leadership roles, and the reporting chain flowing upward. The paragraph's main purpose is establishing the organizational hierarchy for incident response, with the board bookending the structure at the start and end. This is fundamentally about how incident response governance flows through the management chain up to board oversight. Now I'm checking which roles are cybersecurity-specific: the ISO and CIO both qualify for the IS list, while the CEO and Chief Legal Counsel are generic titles that don't. Since I have two IS-specific roles, this lands in Firm-Specific. For quantitative value, these are just named positions without any dates, dollar amounts, headcounts, or certifications attached, so that confirms Firm-Specific at level 3.


reasoning: The paragraph primarily describes an actual cybersecurity incident — unauthorized activity detected on a specific date, response actions taken (activating IRP, engaging experts, notifying law enforcement), and ongoing monitoring. The trailing materiality assessment is subordinate to the incident narrative. Two specific dates (October 9 and October 16, 2024) are QV-eligible hard verifiable facts, reaching the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes an actual cybersecurity incident (October 9, 2024), the response actions taken, and then concludes with a materiality assessment.

Content category: The paragraph describes what happened (detected unauthorized activity, activated IRP, engaged experts, notified law enforcement) AND makes a materiality assessment. The dominant content is the incident narrative - most of the paragraph describes the incident and response. The materiality statement is at the end. Per the tiebreaker: "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure"

Specificity:

I'm checking which facts are specific enough to qualify. The incident date and filing date are both concrete, and the Cyber Incident Response Plan is a named internal program with a unique identifier. The references to third-party experts and law enforcement lack specificity. With two specific dates identified, this qualifies as quantified-verifiable content.

fact: October 9, 2024 — date incident was identified

fact: October 16, 2024 — date of Form 8-K filing

fact: Cyber Incident Response Plan ("IRP") — named internal program with unique identifier


reasoning: Two of three sentences describe the incident itself — its disclosure date, ongoing investigation, and attribution to cybercrime threat actors — making incident narrative the dominant content. The materiality assessment in the final sentence is supplementary. However, the incident description is thin (no scope, systems, or response actions), so confidence is moderate; a case could be made for Strategy Integration under the 'brief mention + materiality conclusion' tiebreaker. Only one QV-eligible fact (specific date), so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph contains:
1. A specific date: "February 22, 2024" - disclosure of incident
2. Description of what happened: cybersecurity incident, cybercrime threat actors
3. A materiality assessment: "not determined the incident is reasonably likely to materially impact our financial condition or results of operations"

This is a mixed paragraph - it references an actual incident AND makes a materiality assessment.

Per the tiebreakers:
- "Brief mention of a past incident + materiality conclusion as the main point → Strategy Integration"
- vs. "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure"

The incident details are sparse—just that it occurred on February 22, 2024, and involved cybercrime threat actors—while the materiality assessment forms the main conclusion. This leans toward Strategy Integration since the paragraph emphasizes the financial impact determination rather than describing the incident itself. The paragraph's main purpose is describing the incident itself—when it happened, that it's under investigation, and who's believed responsible—with the materiality assessment playing a supporting role. Two of the three sentences focus on the incident details, so this should be classified as Incident Disclosure. For specificity, there's only one hard verifiable fact: the February 22, 2024 date qualifies as QV-eligible, but "cybercrime threat actors" is generic and there are no named firms or products, making this Firm-Specific overall.

fact: February 22, 2024 — date incident was disclosed


reasoning: The paragraph is entirely about the CISO as a person — her experience, prior roles, and responsibilities at previous employers. This is the person, not the function. 'Nearly two decades' counts as a specific duration and CISO is a cybersecurity-specific role, yielding two hard facts for QV.

fact: CISO

fact: nearly two decades of cybersecurity experience


reasoning: The paragraph describes the company's internal incident response processes — policies, procedures, triage workflow, escalation, remediation — making it Risk Management Process. It contains firm-specific facts: a uniquely named 'Brighthouse Response Team' and an enterprise-level risk committee, but no QV-eligible hard verifiable facts (no dates, amounts, named firms, or tools).

thinking:
Let me analyze this paragraph.

Content: Describes company-wide policies, incident response plan, cross-departmental response team, reporting to risk committee. This is about internal processes.

Category: Risk Management Process - describes IR planning, policies, procedures, triage processes. The mention of the response team reporting to a risk committee is subordinate to the process description.

Specific facts:
- "Brighthouse Response Team" - this is a named internal program/team with a unique identifier
- "enterprise-level risk committee" - referenced as "above", but it's a risk committee (named non-generic committee? It says "enterprise-level risk committee" - this could be a Risk Committee which is on the IS list)

- Both the Brighthouse Response Team and the enterprise-level risk committee are IS-list items, so this qualifies as Firm-Specific. There are no quantifiable values like dates, dollar amounts, headcounts, or named third parties.

fact: Brighthouse Response Team (named cross-departmental incident response team)

fact: Enterprise-level risk committee


reasoning: The paragraph contains an explicit materiality assessment ('we do not believe our strategy, operations, and financials have been materially affected by risks from cybersecurity threats'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No named frameworks, roles, dates, firms, or other specific facts are present — the language is standard boilerplate materiality disclaimer.

thinking:
Let me analyze this paragraph.

Content: Discusses business impact of cybersecurity, mentions materiality assessment ("we do not believe our strategy, operations, and financials have been materially affected"), cross-reference to Risk Factors.

Category: Strategy Integration - contains explicit materiality assessment per Rule 6.

Specificity: Let me check for facts. No named frameworks, no specific dates, no dollar amounts, no named roles, no named firms. The materiality disclaimer is boilerplate language. Cross-reference is noise. → Generic Boilerplate.


reasoning: The paragraph describes the company's own internal technical safeguards, vulnerability assessments, and threat intelligence processes — all core risk management activities. No named frameworks, tools, roles, dates, or any firm-specific details are present; the language is entirely generic and could apply to any financial institution.

thinking:
Classify this paragraph.

Content: Describes technical safeguards - assessing, deploying, evaluating, improving based on vulnerability assessments, threat intelligence, incident response experience. All internal processes, no specific details.

Category: Risk Management Process - describes internal cybersecurity processes.

Specificity: No named frameworks, no specific roles, no dates, no numbers. "Technical Safeguards" as a heading isn't a unique program name. Generic practices described. → Generic Boilerplate.


reasoning: The grammatical subject is 'Our management,' which has 'primary responsibility' for cybersecurity risk, with board oversight mentioned as subordinate context. However, the paragraph describes no specific person, role title, credentials, or reporting structure — it is entirely generic language about management responsibility that could apply to any company.

thinking:
Classify this paragraph.

The paragraph says management has primary responsibility, subject to board oversight. The grammatical subject is "Our management" - describing management's responsibility. But it also mentions board oversight.

Category: This is about management's responsibility with board oversight mentioned. The primary actor is "Our management." Per Rule 2, "Management role reports TO the board" → Management Role. But wait - this doesn't describe any specific person, credentials, or reporting lines. It's a generic statement about management responsibility.

Actually, looking more carefully: the paragraph describes management's responsibility and board oversight in general terms. The grammatical subject is "Our management." Per the tiebreaker rules, management as main focus → Management Role.

But I'm realizing this is just boilerplate language - no named roles, specific people, or credentials. Both "management" and "board of directors" are generic terms that don't meet the specificity threshold, so this falls into Generic Boilerplate.


reasoning: The paragraph is entirely about the persons filling the CIO and CISO roles — their experience, backgrounds, industries served, reporting lines, and responsibilities. This is a textbook Management Role paragraph per the person-vs-function test. Two quantified years-of-experience figures (20+ years for CIO, 15+ years for CISO) meet the QV threshold.

thinking:
Management Role - about the persons (CIO and CISO), their backgrounds, experience, reporting lines.

Specific facts:
- CIO (cybersecurity-adjacent, but per the IS list, CIO is a cybersecurity-specific title) - named_role
- CISO - named_role
- "over 20 years of experience" - quantified
- "over 15 years of work experience" - quantified
- Reports to CEO (reporting line)
- CISO reports to CIO (reporting line)

QV check: "over 20 years" + "over 15 years" = two quantified facts → Quantified-Verifiable

fact: CIO role identified

fact: CISO role identified

fact: CIO has over 20 years of experience

fact: CISO has over 15 years of work experience


reasoning: The paragraph describes engaging external parties to audit, assess, and improve the company's own cybersecurity controls and processes. Per Rule 3, external assessors hired to test/serve the company are Risk Management Process, not Third-Party Risk (which requires imposing requirements ON vendors). No named firms ('leading global security providers' is unnamed), no named frameworks, no specific dates or numbers — all details are generic.

thinking:
Let me analyze this paragraph.

Content: Describes engagement of third-party consulting services for audits, assessments, and threat intelligence. The central topic is about using external parties to evaluate and improve the company's cybersecurity program.

Category: This is about using third parties to serve the company's own cybersecurity program - external assessors hired to test/evaluate the company. Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." However, this is heavily about third-party engagement... but the third parties here are serving the company's internal processes, not about imposing requirements ON vendors. This is Risk Management Process.

The language here is vague and generic—no specific vendors are named, no frameworks are referenced, and the cadence is just described as "annually" without concrete details or metrics. This reads like standard boilerplate language.


reasoning: The paragraph's central topic is oversight of third-party cybersecurity risks — describing a vendor risk management program with risk assessment, due diligence, contractual provisions, and monitoring. No named frameworks, tools, firms, dates, or other IS-list facts are present; 'security risk assessment questionnaire tools' is a generic practice description.

thinking:
Third-party risk management is the central topic.

Specificity: No named frameworks, no named tools, no firm-specific facts. "security risk assessment questionnaire tools" is generic. No IS-list items present.

Generic Boilerplate.


reasoning: The paragraph opens with an explicit materiality assessment ('have not materially affected or are reasonably likely to affect us, including our business strategy, results of operations or financial condition'), which per Rule 6 makes this Strategy Integration. The remainder is generic risk language and a cross-reference to Risk Factors, neither of which overrides the materiality conclusion. No named frameworks, roles, tools, dates, or other specific facts appear — company self-references and boilerplate risk language are on the NOT list.

thinking:
Let me analyze this paragraph.

The paragraph opens with a materiality assessment ("have not materially affected or are reasonably likely to affect us, including our business strategy, results of operations or financial condition"). Then it cross-references Risk Factors and discusses general risk language about threats.

Category: The dominant content is the materiality disclaimer in the first sentence. The rest is generic risk language. Per Rule 6, materiality assessments → Strategy Integration.

Specificity: Let me check for specific facts. No named roles, no specific dates beyond "as of the date of this report" (generic), no dollar amounts, no named frameworks, no named tools. The cross-reference to Item 1A is generic.

The mention of "Caterpillar products" is just a company self-reference, so this is standard boilerplate language.


reasoning: The paragraph describes the company's own internal cybersecurity processes: monitoring, testing safeguards, workforce training, and tabletop exercises. All details are generic practices (training, tabletop exercises, monitoring) with no named frameworks, tools, roles, dates, or firm-specific facts.

thinking:
Let me classify this paragraph.

Content: Describes internal cybersecurity processes - monitoring, testing, training, tabletop exercises. This is about the company's own internal processes.

Category: Risk Management Process

Specificity: No named frameworks, no named roles (just "executives" and "incident response professionals" which are generic), no specific dates, no named tools. "Tabletop exercises" are common practices on the NOT list. No firm-specific facts after filtering.

→ Generic Boilerplate


reasoning: The paragraph's communicative purpose is describing how the Audit Committee and Board of Directors maintain oversight of cybersecurity through structured briefings. While the Chief Trust Officer is the grammatical subject in most sentences, the content describes the board-level oversight mechanism — briefing cadence, content, and escalation paths. 'Chief Trust Officer' is a cybersecurity-specific title qualifying as a firm-specific fact, but cadences ('quarterly', 'annually') and 'Audit Committee' are generic and do not elevate specificity further.

thinking:
Let me analyze this paragraph.

The paragraph describes briefing cadence from the Chief Trust Officer to the Audit Committee and Board. The primary actors are the Chief Trust Officer (providing briefings) and the Audit Committee/Board (receiving them).

The grammatical subject alternates between "Our Chief Trust Officer" and "Our Audit Committee." The paragraph is about oversight structure - how the board/committee gets informed about cybersecurity. The Board/Audit Committee are the recipients of oversight briefings, and the Chief Trust Officer is providing them.

This is a borderline Board Governance vs Management Role case. The paragraph describes the flow of information TO the board/committee. The Audit Committee and Board are the oversight bodies being briefed. But the Chief Trust Officer is the grammatical subject in most sentences.

The Chief Trust Officer is the grammatical subject in most sentences, so the paragraph emphasizes what the CTO does—briefing the board quarterly. But the underlying purpose is describing the board's oversight mechanism and how it receives cybersecurity information, which pulls toward Board Governance classification.

Looking at the tiebreaker rule, the main focus is the board oversight structure rather than management operations, so this should be Board Governance. For specificity, only "Chief Trust Officer" qualifies as a firm-specific fact; the other elements like "Audit Committee," "quarterly," and "annually" are generic governance terms.

fact: Chief Trust Officer


reasoning: The paragraph describes internal cybersecurity processes (design, implement, maintain safeguards; monitor effectiveness) but uses entirely generic language with no named frameworks, roles, tools, or firm-specific details.


reasoning: The paragraph describes the cybersecurity team's qualifications — collective experience and certifications — making it about who the people are (Management Role per the person-vs-function test). It contains two or more hard verifiable facts: a specific quantified duration (approximately 35 years collective experience) and multiple named certifications (CISM, CISSP, CEH), reaching the QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the cybersecurity team's collective experience and certifications. This is about the people/team credentials, not processes.

Category: Management Role - describes qualifications and credentials of the cybersecurity team members.

Specificity: Let me check facts:
- "approximately 35 years of collective experience" - specific number (quantified)
- CISM, CISSP, CEH, Certified Penetration Tester - named certifications

QV check: 35 years collective experience (quantified) + named certifications (CISSP, CISM, CEH) = 2+ hard verifiable facts → Quantified-Verifiable

fact: Certified Information Security Manager (CISM)

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Ethical Hacker (CEH)

fact: Certified Penetration Tester


reasoning: The paragraph's dominant content is the narrative of a real cybersecurity event: Change Healthcare's incident, the company's response actions (severing connections, conducting forensics), scope of impact (payment claims submission), and timeline. While it opens with a general no-material-compromise statement and closes with a materiality assessment, the bulk of the text describes what happened, when, and how the company responded — classic Incident Disclosure. Four QV-eligible hard facts (two specific dates + two named firms) place specificity at Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. No material compromise to date (materiality assessment)
2. Routine unauthorized access attempts (generic)
3. Vendor compromises mentioned
4. Specific Change Healthcare incident - detailed narrative with dates, actions, forensics
5. Materiality assessment of the Change Healthcare incident

This is complex. Let me think about the dominant category.

The paragraph describes a specific third-party incident (Change Healthcare/UnitedHealth Group), the company's response actions, forensic investigation, and concludes with a materiality assessment. The bulk of the paragraph is about what happened with the Change Healthcare incident - the narrative of the event, response actions, and impact assessment.

So this is really about how the company responded to a third-party breach notification—they got word from Change Healthcare in February 2024, immediately disconnected, ran forensics on their own systems, found no compromise, and determined the impact was limited to payment processing. The key point is that while the breach happened to a vendor, the disclosure focuses on what the company did about it and why it doesn't materially affect them.

I'm counting the specific, verifiable facts here: the February 21st notification date, the February 28th follow-up date, and the named third parties (Change Healthcare and UnitedHealth Group). That gives me four concrete, checkable data points, which puts this in the Quantified-Verifiable category.

fact: February 21, 2024 — date Change Healthcare notified them

fact: Change Healthcare (named third-party firm / subsidiary of UnitedHealth Group)

fact: UnitedHealth Group (named parent company)

fact: February 28, 2024 — date of forensic assessment conclusion


reasoning: The board's Compliance and Quality of Care Committee is the grammatical subject with primary oversight responsibility, and the paragraph details the reporting structure, review cadence, and board participation in exercises — all hallmarks of Board Governance. Specificity is Firm-Specific: the named non-generic committee and CIO role are IS-list facts, and '23 NIST cyber hygiene controls' is a specific number, but only one QV-eligible hard fact (the number 23) prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the "Compliance and Quality of Care Committee" of the board overseeing cybersecurity. The board committee is the primary subject of oversight. The CIO reports to the committee. The committee and board review/approve plans. Board members participate in exercises.

Category: Board Governance - The board committee is the grammatical subject with primary responsibility for oversight. The CIO reporting is subordinate to the board's oversight structure.

Specificity analysis:
- "Compliance and Quality of Care Committee" - named non-generic committee → IS fact
- "CIO" - CIO is on the IS list as cybersecurity-specific title → IS fact

- "NIST framework" - named standard → IS fact
- "23 NIST cyber hygiene controls" - specific number with quantified controls → QV-eligible
- "quarterly reports" and "at least annually" - generic reporting cadences, not specific dates → not QV-eligible

The key QV-eligible fact here is the specific count of 23 controls, which represents a measurable quantity. The CIO role itself isn't QV-eligible, but the numbered controls are. So "23" is a specific number and counts as QV-eligible. Looking through the rest of the statement, I don't see any other QV facts—no dates, dollar amounts, named firms, products, certifications, years of experience, or universities. That gives me only one QV fact, which isn't enough for the QV classification. For IS facts, I've got the named committee, the CIO title, the specific number, and the NIST framework reference, which points to Firm-Specific rather than QV.

Actually, "chief compliance officer" isn't on the IS list since it's not cybersecurity-specific, so this falls under Board Governance and Firm-Specific.

fact: Compliance and Quality of Care Committee has primary oversight responsibility

fact: CIO provides quarterly reports to the committee

fact: 23 NIST cyber hygiene controls

fact: NIST framework assessments


reasoning: The paragraph covers both board oversight and management roles, but the dominant content is about the management team — the CIO's 34 years of experience, the CISO supporting the CIO, team composition, and certifications. Per Rule 2, the CIO is the primary actor providing reviews to the committee, making this Management Role over Board Governance. Two QV-eligible hard facts: specific date (January 2025) and specific years of experience (34 years).

thinking:
Let me analyze this paragraph carefully.

This is a complex paragraph covering multiple categories. Let me break it down:

1. "Our management is responsible for the ongoing assessment..." - Management Role
2. "Our board of directors through its audit and compliance committee oversees..." - Board Governance
3. "Our chief information officer ("CIO") periodically provides this review to the audit and compliance committee, with the most recent review conducted in January 2025." - This is about the CIO reporting TO the board committee, so it could be Board Governance or Management Role. The CIO is the actor providing the review.
4. "The CIO, who has more than 34 years of experience in IT and cybersecurity, is supported by a chief information security officer and various employees..." - Management Role (person's qualifications, team composition)

5. The team members also hold various cloud, security and privacy certifications, which further reinforces the Management Role category since it's describing the qualifications and expertise of the management personnel.

The paragraph starts with management responsibility, then board oversight, then shifts to CIO details. The dominant content seems to be about the management roles - the CIO's experience, the CISO supporting, team composition and their certifications. But there's also significant board governance content.

Looking at the grammatical subjects: management, board/audit committee, CIO, CIO again, these individuals. The latter half focuses on the CIO and team and their qualifications.

Per Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). Here the CIO provides reviews to the audit and compliance committee - the CIO is the primary actor in that sentence.

The paragraph's dominant content is about management - the CIO's experience (34 years), the CISO supporting, team composition, certifications. Management Role is dominant.

Now looking at the specific facts: CIO and CISO are both cybersecurity-specific titles, January 2025 is a specific date, and the CIO has more than 34 years of experience. The audit and compliance committee is essentially the Audit Committee, which doesn't qualify. So I have two QV-eligible facts - the January 2025 date and the 34 years of experience.

fact: CIO (Chief Information Officer)

fact: CISO (Chief Information Security Officer)

fact: Most recent review conducted in January 2025

fact: More than 34 years of experience in IT and cybersecurity


reasoning: The paragraph describes Occidental's internal cybersecurity processes — strategy, monitoring, penetration testing, vulnerability scanning, audits, physical safeguards, and policies. Vendor/supplier risk is mentioned as one component at the end, not the central topic, so Rule 3 keeps this as Risk Management Process. It names the NIST framework but contains no firm-specific facts from the IS list (no named roles, tools, dates, or numbers), so it is Sector-Adapted.

thinking:
Classify this paragraph.

Content: Describes Occidental's cybersecurity strategy, program alignment with NIST, monitoring, testing, policies, audits, physical safeguards, and vendor risk assessment. The dominant topic is the company's internal cybersecurity processes. Vendor risk is mentioned but as one component at the end.

Category: Risk Management Process (internal processes are the central topic; vendor mention is one component per Rule 3)

Specificity: Names NIST framework → Sector-Adapted. Any firm-specific facts? No cybersecurity-specific titles, no named committees, no specific dates, no named tools, no named firms, no specific numbers. "NIST framework" triggers Sector-Adapted. Nothing on the IS list beyond that.

→ Sector-Adapted

fact: NIST framework