reasoning: The paragraph describes the company's internal cybersecurity training program, including phishing exercises, awareness training, and specialized training for sensitive roles — all internal processes. No named frameworks, cybersecurity-specific roles, dates, tools, or other IS-list facts are present; 'phishing exercises,' 'cybersecurity awareness training,' and 'periodic basis' all fall on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity training program - phishing exercises, awareness training, specialized training for sensitive roles. This is about internal processes.

Category: Risk Management Process - describes internal cybersecurity training processes.

Specificity: No named frameworks, no named roles (CISO etc.), no specific dates, no named tools, no numbers. "phishing exercises" and "cybersecurity awareness training" are common practices on the NOT list. "third parties who have access to Company email" - mentions third parties but as part of internal training, not vendor oversight. "periodic basis" is generic cadence.

No IS-list facts. No named standards. → Generic Boilerplate.


content_category: Board Governance

category_confidence: medium

specificity_confidence: high

reasoning: The Board of Directors is the grammatical subject performing the primary action — approving the hiring of a CISO — making this a Board governance decision. The CISO and ERM framework description provide context for why the Board acted, but the Board's approval is the paragraph's central disclosure. Specificity is Firm-Specific: 'In 2024' is a specific date and CISO/CIO are cybersecurity-specific titles on the IS list, but only one QV-eligible hard fact (the year) prevents Quantified-Verifiable.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: The Board approved hiring a CISO reporting to the CIO, to support information security and the three lines of defense ERM framework. Then describes the ERM framework including cybersecurity risk.

Category analysis:
- The Board approved hiring a CISO - this is a Board governance action
- But the paragraph then shifts to describing the CISO's reporting line and the ERM framework
- The primary action: Board approved hiring. But the substance is about the management structure (CISO reporting to CIO) and the risk management framework.
- The Board is the grammatical subject of the first clause. But what's the dominant topic?

- The Board's decision to hire a CISO is the governance action, but the paragraph really centers on establishing the CISO role within the management structure and explaining how it fits into the ERM framework. The Board action is the trigger, but the focus shifts to the management role and risk management process that follows. The paragraph really centers on describing the company's risk management framework—the three lines of defense and the processes for identifying, assessing, mitigating, and monitoring risks. The CISO hiring and Board approval serve as context for why this framework exists, but the substance is about how the company actually manages cybersecurity risk operationally. This feels like Risk Management Process is the primary category, even though there's a governance element woven in at the start. I'm working through whether this is really about Board Governance or the Management Role itself. The Board approved the hire and set the reporting structure, but the core disclosure is that a CISO position was created—that's the substantive news. The person-versus-function test confirms it's about the role, not an individual. For the specificity check, I have concrete details: the 2024 date, the CISO title, and the CIO reporting line, though "three lines of defense" is a framework concept rather than a named standard. Counting only hard verifiable specifics for the QV assessment, I've got the date and the two specific titles.

fact: In 2024 (timing of Board approval)

fact: Chief Information Security Officer (CISO)

fact: Chief Information Officer (CIO)


content_category: Risk Management Process

category_confidence: high

reasoning: The paragraph describes the company's incident response process — what happens when an incident occurs, who investigates, who is notified, and who reviews reports. The CISO and CRO are mentioned as attributions within the process flow, not as the paragraph's subject in terms of their credentials or background (person-vs-function test → function). Multiple firm-specific facts exist (CISO, ITSC, ERMC, Board Risk Committee) but no QV-eligible hard facts (no dates, amounts, named firms, or tools), so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes incident response program, CISO coordinates response, CRO informs senior management and board chairs, incident reports reviewed by ITSC, ERMC, and Board Risk Committee.

Category: This is about the company's incident response process - what happens when an incident occurs. The CISO and CRO are mentioned as attributions for who does what in the process. The paragraph is about the function/process, not about the people. → Risk Management Process

Specific facts:
- CISO (cybersecurity-specific role) → IS list
- CRO - Chief Risk Officer? That's not on the cybersecurity-specific titles list explicitly. Let me check...

The IS list includes CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security, and HSE Director overseeing cybersecurity, but CRO isn't there. It's more of a generic executive title like CFO or COO, not cybersecurity-specific. Board Risk Chair and Board Audit Committee Chair are generic governance roles. ITSC and ERMC are named internal committees with unique identifiers, while Board Risk Committee is a specific named committee that appears on the IS list.

So I'm identifying the firm-specific facts: CISO, ITSC, ERMC, and Board Risk Committee. There are no dates, dollar amounts, headcounts, named third-party firms, products, or certifications, so this isn't QV. Since it contains IS-list facts, it's Firm-Specific.

fact: CISO coordinates incident response

fact: ITSC reviews incident reports

fact: ERMC reviews incident reports

fact: Board Risk Committee reviews incident reports


content_category: Strategy Integration

reasoning: The paragraph makes an explicit materiality assessment stating cybersecurity threats have not materially affected the company's business strategy, results of operations, or financial condition — this is Strategy Integration per Rule 6. While it mentions specific years (2024, 2023, 2022), these are generic reporting period references in boilerplate materiality language that could appear in any filing unchanged.


content_category: Management Role

reasoning: The paragraph is about the person filling the cybersecurity leadership role — their title, years of experience, and general background. It passes the person-vs-function test: the content is about who the person is, not what the program does. Specificity is Firm-Specific: the cybersecurity-specific title (VP of Product and Enterprise Security) and 30 years of experience are IS-list facts, but only one QV-eligible fact (the specific number of years), falling short of the two needed for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: About a VP of Product and Enterprise Security - their responsibility and experience. This is about the person - their title, years of experience, background.

Category: Management Role - the paragraph is about who the person is, their qualifications and experience.

Specific facts:
- "Vice President of Product and Enterprise Security" - cybersecurity-specific title → IS list
- "over 30 years of experience" - specific number → QV-eligible
- No named individual, no named certifications, no named firms

QV check: "over 30 years" is a specific number (QV-eligible). That's one QV fact. Need two for QV. The role title is IS but not QV-eligible.

Since there's only one QV-eligible fact here, this falls into the Firm-Specific category.

fact: over 30 years of experience in cybersecurity and information technology roles

type: quantified


reasoning: The CISO is mentioned as brief attribution in the opening clause, but the paragraph's substantive content describes the company's cybersecurity program processes: controls, monitoring tools, incident response, employee training, and secure coding training. Applying the person-vs-function test, removing the CISO reference leaves a complete process description, so this is Risk Management Process. Two QV-eligible hard facts exist: a named certification (CISM) and a specific number of years of experience (over 10 years).

thinking:
Let me analyze this paragraph.

The paragraph starts by mentioning the CISO with credentials (CISM, 10+ years experience), but then the bulk of the paragraph describes the cybersecurity program's processes: controls, tools, monitoring, incident response, training. This is the person-vs-function test - the CISO is mentioned as attribution, then the paragraph describes what the program does.

Category: Risk Management Process (the bulk is about processes, tools, controls, training)

Specific facts:
- CISO (cybersecurity-specific title) → IS list
- "Certified Information Systems Security Manager" (CISM certification) → QV-eligible

- Over 10 years of related experience → QV-eligible (specific number)

So I have two hard verifiable facts here: the CISM certification and the decade-plus of experience. That makes this Quantified-Verifiable. But the dominant content is still the Risk Management Process description. The CISO credentials are just the opening attribution. If I remove "Our cybersecurity program is led by our CISO..." the paragraph still fully describes the program's processes and controls. That confirms Risk Management Process as the category.

fact: CISO (Chief Information Security Officer)

fact: Certified Information Systems Security Manager (CISM)

fact: over 10 years of related experience


reasoning: While the opening sentences describe the dual-CISO structure, credentials, and scope split (Management Role content), the dominant communicative purpose is the cybersecurity program's processes — controls, monitoring, incident response, training, and compliance activities occupy the majority of the paragraph. Applying the person-vs-function test: removing the CISO details leaves a complete process description. Specificity reaches Quantified-Verifiable with two QV-eligible hard facts: named certifications (CISM) and specific years of experience (over 15 years).

thinking:
Let me analyze this paragraph carefully.

The paragraph starts by describing two CISOs with specific credentials and experience, then transitions into describing the cybersecurity program's processes.

**Content Category Analysis:**
- Opens with Management Role content (two CISOs, CISM certifications, 15+ years experience, split scope structure)
- But then the bulk of the paragraph describes the cybersecurity program: controls, tools, monitoring, incident response, training

The person-vs-function test: If I remove the CISO descriptions, the paragraph still describes a full cybersecurity program. However, the opening ~4 sentences are specifically about who these people are, their credentials, and how their roles are structured.

The remaining ~8 sentences describe processes. Risk Management Process is dominant by volume, but I need to weigh whether the opening management structure is substantial enough to shift the primary category. The dual-CISO setup with their certifications and split responsibilities across infrastructure and information security is actually quite detailed and foundational to understanding the program's governance. So this paragraph sits between Management Role and Risk Management Process, with the opening establishing the management structure and the rest detailing how the program operates.

For specificity, the two CISOs with named roles, CISM certifications, and "over 15 years of experience" are all verifiable facts. The organizational split between CISO-BIS and CISO-CIS is firm-specific, while "monthly security awareness training" is more generic. That gives me two solid quantified-verifiable facts: the certifications and the years of experience.

fact: Two Chief Information Security Officers (CISOs)

fact: Certified Information Systems Security Managers (CISM)

fact: Over 15 years of related experience

fact: Dual-scope structure: CISO - BIS (Business Information Security) and CISO - CIS (Compliance Information Security)


reasoning: The paragraph is a mixed Management Role / Risk Management Process paragraph. Applying the person-vs-function test: removing the CISO's credentials, the remaining content still describes the security organization's responsibilities, the CIRT team, and the incident response plan — substantive process content that is the majority of the paragraph (~4 sentences RMP vs. ~2 sentences on CISO credentials). Two QV-eligible hard facts: specific number of years (35) and named certification (ITIL).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Corporate information security organization led by CISO
2. CISO's qualifications (35 years experience, prior roles, degrees, certifications)
3. What the organization does (manages security structure, prevention, resilience)
4. CIRT team description
5. Incident response plan notification chain

The person-vs-function test: The paragraph starts by naming the CISO role and then spends significant text on the CISO's qualifications (35 years, prior roles as SVP/CIO and VP/CIO, degrees, ITIL certification). But then it shifts to describing what the organization does - managing security structure, CIRT team, incident response plan.

This is a mixed paragraph with roughly equal weight between the CISO's detailed background and the organizational processes. The credentials are prominent—35 years of experience, prior executive roles, advanced degrees—but the process description covering the security structure, incident response team, and notification procedures takes up comparable space. It's borderline, though the CISO's qualifications do stand out as particularly detailed. Looking at the word count more carefully, the process descriptions actually take up more space than the CISO credentials section. The codebook's guidance about primary communicative purpose suggests the paragraph is fundamentally about describing the security organization and its operational structure, with the CISO's background serving as supporting context. So Risk Management Process is the dominant category here. I'm going back and forth on this, but let me apply the codebook test more rigorously. If I strip out the CISO credentials and background, the remaining content still clearly describes substantive processes—the security organization's responsibilities, incident response, threat detection. That suggests Risk Management Process is the right category. The CISO qualifications are detailed, but the primary communicative purpose seems to be explaining the organization's security functions and processes rather than establishing the CISO's credentials. I'll go with RMP. Looking at the breakdown, this is clearly a Risk Management Process disclosure dominated by the incident response details. The CISO's background qualifies as Quantified-Verifiable based on the specific 35 years of experience and named ITIL Certification, while the degrees and other details don't meet that threshold. So the overall specificity rating is Quantified-Verifiable.

fact: Over 35 years of experience

fact: ITIL Certification

fact: Cybersecurity incident response team (CIRT)


reasoning: The paragraph describes the company's internal cybersecurity awareness training program—mandatory training, online modules, topic coverage, phishing campaigns—all of which are common security practices. No named frameworks, tools, roles, dates, or other facts from the IS list are present; all details (annual training, phishing simulations, awareness campaigns) appear on the NOT list as common practices.

thinking:
Classify this paragraph.

Content: Describes cybersecurity awareness training program - mandatory annual training, online modules, topics covered, phishing campaigns. This is about internal processes.

Category: Risk Management Process - describes internal cybersecurity training processes.

Specificity: No named frameworks, no named roles, no specific dates, no named tools. Training topics listed are common practices. "Phishing awareness campaigns" and "security awareness training" are on the NOT list as common practices. No IS-list facts present.

→ Generic Boilerplate (1)


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of third-party providers' cybersecurity — security assessments before engagement, ongoing monitoring, periodic due diligence renewals — making Third-Party Risk the dominant category. Despite describing a structured program, it names no specific frameworks, tools, firms, or quantified details; 'Global IT' is a company self-reference (internal department), not a specific fact per the IS list. All language is generic enough to apply to any company.

thinking: Third-party risk management program description.


reasoning: The paragraph mentions the CISO and CIO as attribution but its substantive content describes internal processes: monitoring, security measures, system audits, vulnerability identification, and incident response planning. Applying the person-vs-function test, removing the role titles leaves a complete process description, so this is Risk Management Process. CISO and CIO are cybersecurity-specific titles on the IS list, elevating to Firm-Specific, but no QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes CISO and CIO being informed about cybersecurity developments, CISO implementing monitoring processes, security measures, system audits, and incident response plan. This is about what the program does - processes, monitoring, audits, IR planning. The CISO/CIO are mentioned as attribution but the substance is about processes.

Category: Risk Management Process (person-vs-function test: remove the role titles and it's still a process description)

Specific facts:
- CISO (cybersecurity-specific title) ✓
- CIO (cybersecurity-specific title) ✓

- The rest—regular monitoring, security measures, system audits, incident response plan—are all generic terms without firm-specific details. Since I have two named cybersecurity roles that appear on the IS list but aren't QV-eligible, this falls under Firm-Specific.

fact: CISO

fact: CIO


reasoning: The paragraph describes the company's own internal cybersecurity processes — employee training, phishing tests, awareness initiatives, and real-time monitoring. The external vendor mention is one component of the internal program, not the central topic, so Third-Party Risk does not apply. No named frameworks, no cybersecurity-specific roles, no specific dates or numbers, and no named vendors or tools — all items are generic practices or unnamed entities from the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes internal security training programs and an external vendor for monitoring. The primary content is about the company's own internal processes (training, phishing tests, awareness programs). The vendor mention is one component of internal processes, not the central topic.

Category: Risk Management Process (internal processes - training, phishing tests, awareness, monitoring)

Specificity: Let me check facts:
- "phishing tests" - common practice, NOT list
- "security awareness training" - common practice, NOT list
- "external vendor" - unnamed, NOT list
- No named frameworks, no named roles, no specific dates, no numbers

- No IS-list facts, no named standards. This is generic boilerplate.


reasoning: The paragraph's primary communicative purpose is describing how the Audit Committee and Board stay informed about cybersecurity risks through senior management's reporting chain. While senior management is the grammatical subject in most sentences, they are described as the conduit for board-level oversight, not in terms of their qualifications or identity. No IS-list facts are present: CFO is generic C-suite, Audit Committee is standard governance, 'quarterly' is a generic cadence, and 'information technology department' is not a cybersecurity-specific title.

thinking:
Let me analyze this paragraph.

The paragraph describes how senior management informs the Audit Committee about cybersecurity risks. Let me determine the category and specificity.

Category analysis:
- The paragraph describes the flow of information: IT department → CFO → senior management → Audit Committee → Board
- The primary topic is the reporting/briefing structure between management and the board
- The Audit Committee receives updates from senior management - this is about the oversight structure
- Senior management is the grammatical subject in most sentences, but the purpose is describing how information flows to the Audit Committee/Board
- "Senior management plays a pivotal role in informing the Audit Committee" - the frame is about informing the board committee

- This is a borderline case between Board Governance and Management Role. The paragraph describes management reporting to the Audit Committee, but the overall frame emphasizes the Committee's oversight mechanism. Since the communicative purpose centers on how the board gets informed about cyber risks through the reporting chain, this leans toward Board Governance rather than describing management's qualifications or internal responsibilities.

Looking back at Rule 2 more carefully: the grammatical subject is senior management and the IT department, but the paragraph's primary focus is the Audit Committee's oversight function. The CFO is mentioned generically and falls outside the specific role indicators. Given that the paragraph's purpose is explaining how the board stays informed about cybersecurity risks, I'm categorizing this as Board Governance.

Checking the specificity markers: "Audit Committee," "CFO," "quarterly," "Board," and "senior management" are all generic terms without named frameworks or IS-list items. The CFO is a generic C-suite reference, and there are no cybersecurity-specific titles present.

This points to Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity training program and awareness newsletter — both are internal risk management activities. No named frameworks, cybersecurity-specific roles, tools, dates, or other IS-list facts are present; 'monthly' is a generic cadence and 'security awareness training' is a common practice on the NOT list.

thinking:
Classify this paragraph.

Content: Describes internal cybersecurity training and awareness programs - mandatory training scaled to roles, internal newsletter published monthly.

Category: Risk Management Process - describes internal cybersecurity processes (training, awareness programs).

Specificity: Let me check for specific facts.
- "periodic mandatory training" - generic practice
- "internal newsletter on a monthly and ad-hoc basis" - "monthly" is a generic cadence
- No named frameworks, tools, firms, roles, dates, or numbers

No IS-list facts. No named standards. → Generic Boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity processes — security tools, monitoring, detection, penetration testing, and incident response planning. Third-party vendors are mentioned as components of the internal program, not as the central topic (Rule 3). No named frameworks, tools, firms, roles, dates, or specific numbers appear; all references are generic ('various security tools', 'third-party vendors', 'incident response plan').

thinking:
Let me analyze this paragraph.

Content: Describes internal security tools, monitoring, detection, third-party vendors for security services, penetration testing, incident response plan. This is about the company's own internal cybersecurity processes.

Category: Risk Management Process - describes internal processes, tools, monitoring, IR planning. Third parties are mentioned as components of the internal program, not as the central topic.

Specificity: Let me check for specific facts.
- No named frameworks (NIST, ISO, etc.)
- No named roles (CISO, CIO, etc.)
- No named tools or products
- No named third-party firms (just "third-party vendors")

- No specific dates or numbers
- "Penetration testing at least annually" is standard practice with a generic cadence
- "Incident response plan" is a generic program name

All the language here is boilerplate—"various security tools," "third-party vendors," "penetration testing," "incident response plan," "monitoring and detection tools"—nothing specific enough to appear on the IS list. This falls under Generic Boilerplate.


reasoning: The paragraph opens with an explicit materiality assessment ('have not identified any cybersecurity threats that have materially affected...') and reaffirms it, making Strategy Integration the dominant category per Rule 6. The acknowledgment of past cyberattacks is vague ('in the past'), the risk language is generic, and the cross-reference to Item 1A is ancillary. No named frameworks, roles, dates, or firm-specific facts appear—all language is boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph starts with a materiality assessment ("have not identified any cybersecurity threats that have materially affected..."), acknowledges past cyberattacks without specifics, then transitions into generic risk language, and ends with a cross-reference to Item 1A.

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

Specificity: No named frameworks, no specific dates, no named roles, no firm-specific facts. Everything is generic boilerplate language. → Generic Boilerplate.


reasoning: The paragraph's primary communicative purpose is an explicit materiality assessment ('have not identified risks... that have materially affected... our business strategy, results of operations or financial condition'), which per Rule 6 is Strategy Integration. The cross-reference to Risk Factors and forward-looking language are secondary. No firm-specific facts are present — all language is boilerplate materiality disclaimer found across thousands of filings.

thinking: Materiality assessment is the dominant content here.


reasoning: The paragraph primarily describes internal cybersecurity processes: incident response planning, refining response procedures, defining communications channels, and identifying material breaches. Cyber insurance is mentioned but as one component of the broader process description, not as the central topic (which would be Strategy Integration). No named frameworks, specific roles from the IS list, named firms, dates, or quantified facts are present — all entities are generic (unnamed carrier, 'senior management', 'Board of Directors').

thinking:
Let me analyze this paragraph.

Content: Describes incident response plan, cyber insurance, working with insurance carrier to refine procedures, communications channels, material breach identification, reporting to management and board.

Category: The paragraph covers multiple topics - incident response plan (RMP), cyber insurance (Strategy Integration), and working with carrier to refine procedures. The dominant content is about the company's internal processes - incident response planning, refining procedures, communications channels. The insurance mention is one component. The board mention is incidental. → Risk Management Process

Specificity: Let me check for specific facts:
- "incident response plan" - generic program name → NOT list

- "cyber insurance" - mentioned but no specifics → generic
- "cyber insurance carrier" - unnamed → NOT list
- "senior management" - generic → NOT list
- "Board of Directors" - generic → NOT list
- No named frameworks, no named roles, no dates, no numbers, no named firms/tools

This is generic boilerplate with no concrete details or named entities.


reasoning: The paragraph describes how the Board of Directors is kept informed about cybersecurity — through regular reviews by management and a risk-based escalation process. The board is the recipient of oversight information, making board oversight the primary communicative purpose. The CIO is mentioned as a cybersecurity-specific role (IS list), qualifying as Firm-Specific, but 'regularly' is a generic cadence and no second hard verifiable fact exists for QV.

thinking:
Let me analyze this paragraph.

The paragraph describes management (including CIO) reviewing cybersecurity with the Board and an escalation process. The primary actor is "Management" - they review, provide updates, and follow escalation processes. The Board is the recipient of these reports.

Category: The grammatical subject is "Management, including the CIO" - they are the ones performing actions (reviewing, providing updates, following escalation process). But the content is about the reporting relationship between management and the board. The paragraph describes what management does in relation to the board.

Per Rule 2: "Management role reports TO the board" → Management Role. But also "CISO reports quarterly to the Board on..." → Management Role (management is primary actor).

Actually, I'm realizing this is more about the governance structure and oversight mechanism than about the CIO's individual role or qualifications. The paragraph focuses on how the board receives cybersecurity information and maintains oversight, which points toward Board Governance rather than a specific management position.

Looking at the tiebreaker: the board is the central entity here—it's mentioned twice as the recipient of reports, and the paragraph describes the escalation process for emerging risks. That's clearly about the board's oversight function.

For specificity, the CIO is a firm-specific title from the IS list, but "regularly" is just generic cadence with no named frameworks or dates, so this would be Firm-Specific without a second hard verifiable fact.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and their integration into ERM, which is squarely Risk Management Process. No named frameworks, roles, tools, or firm-specific details are present — entirely generic language that could apply to any company.


reasoning: The paragraph describes duties and responsibilities delegated to a board-level Cybersecurity Committee by the Board, making Board Governance the dominant category. The Cybersecurity Committee is a named non-generic committee on the IS list, elevating specificity to Firm-Specific, though the rest of the content is generic charter language about regulatory compliance obligations.

thinking:
Let me analyze this paragraph from Cohen & Co Inc.'s 10-K filing.

This describes the duties of a "Cybersecurity Committee" - it's about performing activities required by law and carrying out responsibilities delegated by the Board. It's describing the committee's charter/mandate.

Category: This is about Board Governance - it describes a board-level committee's responsibilities and duties delegated by the Board.

Specificity: "Cybersecurity Committee" is a named non-generic committee (on the IS list). That's one firm-specific fact. No QV-eligible facts (no dates, dollar amounts, named firms, etc.). So Firm-Specific.

fact: Cybersecurity Committee


reasoning: The paragraph describes penetration testing on internal/external networks to identify vulnerabilities — an internal security process. Per Rule 3, external assessors hired to test the company are Risk Management Process, not Third-Party Risk. No named firms, frameworks, dates, or IS-list facts are present; 'third-party cyber-security experts' and 'penetration testing' are both on the NOT list.

thinking:
Classify this paragraph.

Content: describes penetration testing by third-party experts on networks/systems to identify vulnerabilities. This is about the company's own internal security processes - the third-party experts are serving the company (Rule 3). So Risk Management Process.

Specificity: No named frameworks, no named firms ("third-party cyber-security experts" is generic), no dates, no specific facts from the IS list. Common practices (penetration testing) don't qualify. → Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes: incident response planning, third-party audits, employee training, and periodic testing. The third-party consultant is a component of the internal program, not the central topic, so this is Risk Management Process rather than Third-Party Risk. The named internal program 'Incident Response Plan (IRP)' with its distinguishing abbreviation qualifies as a firm-specific fact, but there are no QV-eligible hard facts (no dates, amounts, named firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes the company's Incident Response Plan, third-party consultant involvement, employee training programs. This is about internal cybersecurity processes.

Category: Risk Management Process - describes IRP, audits, training, testing. The third-party consultant is mentioned as a component of internal processes, not as the central topic of vendor oversight.

Specificity: Let me check for specific facts.
- "Incident Response Plan ("IRP")" - This is a named internal program with a unique identifier (IRP abbreviation). ✓ IS list item.
- "third-party consultant" - generic, ✗ NOT list

- "annual trainings" - generic cadence
- "periodic testing" - generic

So I've identified one firm-specific fact: the named Incident Response Plan (IRP). There are no quantifiable facts like dates, dollar amounts, headcounts, named firms, tools, or certifications that would qualify for QV.

fact: Named internal program: Incident Response Plan ("IRP")


reasoning: The Board of Directors is the central actor across both sentences — reviewing and updating the Information Systems Security Program annually and receiving reports from the COO. While the COO's experience (30 years) is described, this detail is subordinate to the governance frame of Board oversight. COO is a generic C-suite title (NOT list), but '30 years of experience' is a specific quantified fact, yielding one IS-list fact and thus Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two sentences:
1. "The Information Systems Security Program, reviewed and updated annually by the Board of Directors, is our benchmark for protecting the Company's confidential information."
2. "The COO, with over 30 years of experience in operations and information security, reports security incidents and updates to the Board as needed."

Category analysis:
- Sentence 1: Mentions the "Information Systems Security Program" reviewed by the Board. This touches Board Governance (Board reviews/updates the program) and Risk Management Process (the program itself).
- Sentence 2: The COO with 30 years of experience reports to the Board.

The COO is a generic C-suite title, not cybersecurity-specific, so that's not a signal. The real focus here is the Board's involvement — they're reviewing the security program in the first sentence and receiving reports in the second. Both sentences center on Board Governance as the dominant theme. I'm wrestling with how to categorize this paragraph since it straddles two categories — the Board's annual review of the program points toward Board Governance, while the COO's 30 years of experience and reporting relationship suggest Management Role. The key question is whether the paragraph is primarily about the governance structure itself (Board oversight and reporting lines) or about the person filling the management role. Given that both the Board's review and the COO's reporting to the Board are mentioned, the governance framework seems to be the dominant frame, even though the COO's qualifications are also present.

Now I'm checking whether "Information Systems Security Program" is specific enough — it's a named program but fairly generic without additional identifiers.

Looking at the specificity criteria: COO is on the NOT list as generic C-suite, "Board of Directors" is generic, and "annually" is a generic cadence. The only hard verifiable fact here is "over 30 years of experience" as a quantified number, which puts this in the Firm-Specific category.


reasoning: The paragraph opens with a materiality-adjacent assessment ('not aware of any previous cybersecurity incidents of any significance') and closes with a strategic risk judgment ('management does not believe that there is a reasonably likely risk'). The cross-reference to Risk Factors and general industry context (aerospace/defense) are subordinate to these materiality conclusions, making Strategy Integration the dominant category per Rule 6. No specific facts from the IS list are present — 'management' is generic, industry references are general, and the risk factor titles are cross-reference metadata.

thinking:
Let me analyze this paragraph.

Content: Management says no previous incidents, acknowledges risk, mentions aerospace/defense industry context, cross-references risk factors, and concludes with a materiality-like assessment.

Category: The paragraph contains a materiality assessment - "management does not believe that there is a reasonably likely risk of these issues" and "not aware of any previous cybersecurity incidents of any significance." This is a strategic judgment about cyber risk impact. Per Rule 6, materiality assessments → Strategy Integration. The cross-reference is appended to the materiality assessment, not standalone.

Specificity: Let me check for specific facts. "aerospace and defense industries" - general industry context.

The company self-reference, mentions of prime contractors, and risk factor cross-references are all generic without named frameworks, specific dates, or defined roles. This is Generic Boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity evaluation and assessment processes — system security reviews, audits, monitoring, and upgrades. No named frameworks, tools, firms, dates, specific roles, or quantified details are present; all language ('routinely evaluate,' 'regularly implement,' 'annual general controls audit') is generic and could apply to any company.

thinking:
Classify this paragraph.

Content: Describes internal evaluation processes - system security assessments, audits, monitoring, cyber insurance application process. This is about the company's own internal processes.

Category: Risk Management Process - describes internal cybersecurity evaluation, audits, monitoring processes.

Specificity: Let me check for specific facts:
- No named frameworks
- No named roles (cybersecurity-specific)
- No named tools/products
- No named firms
- No specific dates
- No specific numbers
- "cyber insurance application process" - mentions cyber insurance but in context of assessment, not strategic/financial impact
- "annual general controls audit" - generic program name

- The language throughout relies on generic terminology like "routinely evaluate," "regularly implement upgrades," "security controls," "audits and assessments," and "monitor IT systems" - all standard boilerplate without any named standards or company-specific details.

Specificity: Generic Boilerplate (1)


reasoning: The paragraph describes the company's incident response plan and its constituent processes (triage, assess severity, investigate, escalate, contain, remediate). Third-party providers are mentioned as one component of the internal program, not as the central topic, so this is Risk Management Process per Rule 3. No named frameworks, tools, firms, roles, dates, or other specific facts appear — all language is generic and interchangeable across filings.

thinking:
Classify this paragraph.

Content: Describes an incident response plan and its processes (triage, assess, escalate, contain, remediate, etc.) and mentions third-party providers as a component. This is about internal processes.

Category: Risk Management Process - describes IR plan processes. Third parties mentioned as one component.

Specificity: No named frameworks, no named roles, no specific dates, no named firms/tools. Generic practices described. → Generic Boilerplate.


reasoning: The paragraph describes the company's internal incident response structure — team responsibilities, escalation procedures, and plan organization. The brief board notification mention is subordinate to the process description. No named frameworks, no cybersecurity-specific titles from the IS list ("Information Security team" is a generic team name), no dates, numbers, or named firms — all language is generic and could apply to any bank.

thinking:
Let me analyze this paragraph.

Content: Describes the Information Security team's role as incident response team, the incident response plan structure, escalation procedures, and board notification.

Category: This is about internal cybersecurity processes - incident response planning, escalation, team responsibilities. The board mention is brief and subordinate. → Risk Management Process

Specificity: Let me check for specific facts:
- "Information Security team" - this is a team name but generic
- "Incident Response Plan" - generic program name
- "The Board is notified immediately" - generic governance

No named standards, no firm-specific facts from the IS list. The "Information Security team" is not on the IS list as a cybersecurity-specific title. No dates, no numbers, no named tools/firms.

This looks like generic boilerplate language without any concrete details or company-specific information.


reasoning: The paragraph's primary communicative purpose is describing how the Audit Committee and Board of Directors receive cybersecurity oversight through quarterly/periodic briefings. While the 'IT security management team' is the grammatical subject, the content focuses on the oversight mechanism (meeting cadence, topics covered) rather than the qualifications or identity of any management role holder. No specific facts from the IS list are present: 'Audit Committee' and 'Board of Directors' are generic governance, 'quarterly' is a generic cadence, 'certain key functional leaders' names no cybersecurity-specific title, and the briefing topics listed are standard.

thinking:
Let me analyze this paragraph.

The paragraph describes an "IT security management team" led by "certain key functional leaders" reporting to the Audit Committee and Board. The primary actors are management figures reporting upward. But who is the grammatical subject? "Our IT security management team" - this is management reporting to the board.

The content: management team reports to Audit Committee and Board about cybersecurity program updates, risks, protocols, and initiatives. Topics include security, infrastructure, tooling, compliance.

This is about the reporting relationship between management and the board. The grammatical subject is the IT security management team (management). But the content is about briefing the board. Let me check the tiebreaker rules:

The management team is the grammatical subject doing the reporting, so by Rule 2, this should be classified as a Management Role. The paragraph focuses on what the management team reports to the board, not on the board's oversight function itself. I'm working through whether this is Management Role or Board Governance. The grammatical subject is the management team reporting to the board, which would normally point to Management Role, but there's no description of their qualifications or credentials—just what they report and to whom. The core purpose seems to be explaining how the board receives cybersecurity oversight, which feels more like Board Governance. Since the specificity is low (generic "IT security management team" and "Audit Committee"), I'm leaning toward Board Governance as the primary focus here is the oversight mechanism itself.

Looking at the details more closely, nothing here is specific enough to be anything other than Generic Boilerplate. There are no named roles from the cybersecurity list, no frameworks, no concrete dates—just vague references like "certain key functional leaders" and generic cadences like "quarterly." This is standard governance language without substance.


reasoning: The paragraph's primary content describes what the Information Security Program and cybersecurity management program do — preventing, detecting, responding to attacks, managing vulnerabilities, governance, and compliance. The CIO attribution and board committee oversight are secondary structural details. Applying the person-vs-function test: removing the CIO and committee references, the paragraph still functions as a process description. Specificity is Firm-Specific due to the CIO (a cybersecurity-specific title on the IS list) and the IT Committee (a named non-generic committee), but neither qualifies as a QV-eligible hard fact.

thinking:
Let me analyze this paragraph.

Content: Describes the Information Security Program and cybersecurity management program, what they do (preventing, detecting, responding to cyber-attacks, managing vulnerabilities, governance, compliance). Then mentions CIO manages both programs, reports to CEO, overseen by IT Committee and Audit Committee.

Category: This is primarily about the company's internal cybersecurity processes - what the program does. The CIO mention is attribution, and the board/committee mention is secondary. The bulk of the paragraph describes the program's functions. → Risk Management Process

But wait - there's a mix. Let me apply the person-vs-function test. Remove "managed by our CIO who reports to CEO" - the paragraph still describes processes. The last sentence adds governance structure but the dominant content is about what the programs do.

The core of this is still the program's functions and responsibilities, so Risk Management Process is the right fit. Now I'm checking the specific entities: CIO is definitely on the information security list, IT Committee appears to be a named committee, and CEO is excluded from the list, so I won't flag that.

For the QV threshold, named roles and committees don't count as hard facts, so I have zero QV-eligible facts here. Both the CIO and IT Committee are on the IS list though, which makes this Firm-Specific overall.

fact: Chief Information Officer (CIO) manages both programs

fact: Board's Information Technology (IT) Committee oversees the programs


reasoning: The paragraph enumerates multiple components of the company's internal cybersecurity program — assessments, layered controls, monitoring tools, and third-party due diligence. While third-party risk management is mentioned, it is one item among many internal process elements, so the dominant category is Risk Management Process. The named 'Information Technology Steering Committee' is a non-generic committee (not a standard Audit Committee), qualifying as a firm-specific fact, but no second hard verifiable fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a list of cybersecurity activities - IT Steering Committee, assessments, controls, monitoring tools, third-party risk management, due diligence on vendors.

Category: This is primarily about the company's internal cybersecurity processes. It lists multiple components of their risk management program. Third-party risk is mentioned but as one component among many. The dominant topic is Risk Management Process.

Specificity: Let me check for specific facts:
- "Information Technology Steering Committee" - this is a named non-generic committee (Technology Committee equivalent) → IS a specific fact
- No named frameworks, no dates, no dollar amounts, no named tools, no named firms

- General practices like "assessments," "monitoring," "detective tools" are generic

The IT Steering Committee stands out as a named committee that fits the company's governance structure alongside their Technology, Cybersecurity, Risk, and ERM committees—not a standard Audit Committee. That single specific fact makes this Firm-Specific.


reasoning: The paragraph describes the company's internal cyber risk management program and its alignment with recognized standards. It names NIST CSF and ISO 27001 but says the program is 'consistent with' these frameworks rather than claiming certification, and provides no firm-specific details beyond that.

fact: NIST Cybersecurity Framework

type: framework


reasoning: The paragraph's primary framing is about the board's oversight responsibility for cybersecurity risk and the reporting relationship between management and the board — the board is the entity being reported to (or not). Management's role and a third-party IT firm are mentioned but subordinate to the governance structure. No firm-specific facts from the IS list: 'board of directors' is generic, 'management' is generic, and the third-party IT firm is unnamed.

thinking:
Let me analyze this paragraph.

The paragraph discusses board oversight (board responsible for risk), management's decision about reporting cadence, and mentions a third-party IT firm. The primary subject is about the governance structure - specifically how the board and management interact regarding cybersecurity oversight.

The board is mentioned as responsible for overseeing risk, but the paragraph is really about management's determination that regular board reports aren't necessary. The grammatical subject shifts between board and management.

Looking at dominant category: The paragraph discusses board oversight responsibility, management's reporting decisions to the board, and mentions a third-party IT firm. The primary communicative purpose is about the governance/oversight structure - specifically the decision NOT to have regular board briefings. This is about the board-management oversight relationship.

Management is the primary actor here, making decisions about reporting frequency, though the board's oversight role is also mentioned. The core theme is governance and how cybersecurity oversight flows between these two entities, so I'd categorize this as Board Governance. As for specificity, the paragraph relies entirely on generic references—the full board of directors, unnamed management, an unidentified third-party IT firm—with no specific frameworks, roles, dates, or tools mentioned.


reasoning: The paragraph's grammatical subjects throughout are management figures (CTO and Cybersecurity Management Board), and it describes their responsibilities — monitoring, participating in processes, escalating incidents — and the CTO's reporting line to the Risk and Cybersecurity Committee. While cybersecurity processes are referenced, they serve to define the management structure's role rather than describe the processes themselves. Three firm-specific facts (CTO, Cybersecurity Management Board, Risk and Cybersecurity Committee) but none are QV-eligible (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: The CTO and Cybersecurity Management Board monitor cybersecurity incidents through risk management processes, incident response plans, and the CTO reports to the Risk and Cybersecurity Committee quarterly.

Category: This describes management's role in monitoring and managing cybersecurity. The grammatical subjects are CTO and Cybersecurity Management Board. It describes what they do (monitor, manage, report). This is about the function/process rather than the person's credentials. But the primary actors are management figures. Let me think...

The paragraph describes what the CTO and Cybersecurity Management Board DO - monitor prevention, mitigation, detection, remediation through processes. It also mentions reporting to the Risk and Cybersecurity Committee.

This is really about the management function and their operational oversight activities. When I strip away the management titles, what remains are the processes themselves—monitoring, incident response, escalation to committees. So this falls under Risk Management Process rather than a description of the CTO's credentials or qualifications. Looking at the core content without the management figures, I'm seeing process descriptions—monitoring, prevention, mitigation, detection, remediation through incident response plans. The CTO and board are really just attributions for who executes these processes rather than the focus itself. So this lands as Risk Management Process, not Management Role.

But wait, that second sentence shifts things entirely—it's purely structural, describing who reports to whom. The paragraph's real purpose is laying out the management hierarchy for cybersecurity oversight. I'm changing my assessment to Management Role.

Now checking specificity: CTO is a cybersecurity-specific title from the codebook, Cybersecurity Management Board is a named non-generic committee, Risk and Cybersecurity Committee is also a named non-generic committee. Quarterly is just a generic cadence. So I have CTO as a named role and two named committees to flag.

For QV scoring, named roles and committees don't count as hard verifiable facts—there are no dates, dollar amounts, headcounts, or named external firms or tools here. This lands as Firm-Specific at level 3.

fact: CTO

fact: Cybersecurity Management Board

fact: Risk and Cybersecurity Committee


reasoning: The paragraph describes a generic risk assessment process (identify, assess, evaluate, consider severity and likelihood) performed by 'senior management.' Applying the person-vs-function test, the content is about the risk evaluation function, not about who the managers are—no named roles, credentials, or reporting lines are provided. All language is boilerplate with no named frameworks, specific facts, or firm-specific details.

thinking:
Classify this paragraph.

Content: Senior management identifies, assesses, and evaluates risks including cybersecurity. They consider severity and likelihood based on company knowledge and experience.

Category: This describes management's role in risk assessment. The grammatical subject is "senior management." But it's describing a process (identify, assess, evaluate risks, consider severity and likelihood). The person-vs-function test: this is about the function/process, not about who the people are. No credentials, no named roles, no reporting lines. It's describing a generic risk assessment process performed by management.

Actually, "senior management" is the subject and they're describing what management does - but it's really about the risk assessment process.

There's no mention of specific people, credentials, or named roles—just a generic description of how risk management operates. This falls into the Risk Management Process category, and since there are no frameworks, no defined roles beyond the vague "senior management," and no concrete details, it's generic boilerplate.


reasoning: The paragraph describes internal risk assessment processes, audits, and role delineation for cybersecurity — all internal process content. 'Director of Information Technology' is a generic IT title (equivalent to 'Director of IT' on the NOT list), not a cybersecurity-specific role. No named frameworks, no firm-specific facts remain after filtering.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessments, audits, vulnerability identification, and role delineation for cybersecurity. The Director of Information Technology is mentioned. The primary content is about internal processes.

Category: Risk Management Process - describes internal risk assessment and audit processes. The Director of IT is mentioned as attribution, not as the primary subject.

Wait - "Director of Information Technology" - is this a cybersecurity-specific title? Looking at the IS list: "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security, HSE Director overseeing cybersecurity." "Director of Information Technology" is not exactly "Director of IT Security" - it's more of a general IT title. The NOT list says: "Head of IT", "IT Manager", "Director of IT" are generic IT leadership titles. "Director of Information Technology" is essentially "Director of IT" which is on the NOT list.

So this lacks any specific frameworks or named methodologies - just generic language around annual processes. The specificity here is boilerplate at best.


reasoning: The paragraph is framed around the governance structure and board oversight of cybersecurity, with the Board of Directors as the primary institutional actor receiving reports and ensuring accountability. CEO and Director of IT are mentioned alongside the board but in service of describing the oversight/governance arrangement. No facts from the IS list survive filtering: 'Director of IT' is generic IT leadership (NOT list), 'CEO' is generic C-suite (NOT list), 'Board of Directors' and 'Audit Committee' references are generic governance, and cadences ('regular', 'periodic') are vague — leaving no firm-specific markers.

thinking:
Let me analyze this paragraph.

Content category: This paragraph describes board oversight and governance of cybersecurity. The Board of Directors is a primary actor, along with CEO and Director of IT. It discusses briefings, reports to the board, and governance structure. The board is the primary frame - "governance structure" and oversight. But it also mentions CEO and Director of IT.

The grammatical subject in the first sentence includes Board of Directors, CEO, and Director of IT together. The paragraph is about the governance structure - briefings, reports to the board, accountability. This is Board Governance.

Wait - "Director of IT" - is this a cybersecurity-specific title? Per the IS list: "Director of IT Security" is listed, but "Director of IT" is not.

Looking at the NOT list, I see that "Head of IT", "IT Manager", and "Director of IT" are all classified as generic IT leadership, not cybersecurity-specific roles. When I check the other elements - "Board of Directors" and "Chief Executive Officer" are generic governance and C-suite positions, while "regular briefings" and "periodic reports" are just generic cadences with no specificity. There are no named frameworks, specific dates, named firms, or concrete numbers anywhere in this paragraph. After filtering out all the generic language, nothing specific remains - this is just boilerplate governance language.


reasoning: The Board is the grammatical subject throughout, performing oversight of cybersecurity risk and receiving updates — classic Board Governance. The CFO is generic C-suite (NOT list), 'annual' is a generic cadence, and 'Aemetis' is a company self-reference; no IS-list facts remain after filtering, so this is Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity, receives annual updates from CFO. Board is the grammatical subject throughout.

Category: Board Governance - clear, board is the subject performing oversight.

Specificity: Let me check facts:
- "Chief Financial Officer" - this is generic C-suite (CFO is on the NOT list)
- "annual" - generic cadence
- "Aemetis" - company self-reference
- No named frameworks, no specific dates, no cybersecurity-specific roles

CFO is explicitly on the NOT list as generic C-suite. No IS-list facts remain.

This falls into Generic Boilerplate since all the substantive details are either generic terms or excluded categories.


reasoning: The paragraph describes the company's overall cybersecurity management arrangement — what activities are performed (antivirus/antimalware, BCDR, vulnerability management, PCI compliance) and who performs them (management + unnamed service provider). The CEO mention is incidental attribution (generic C-suite, no credentials), the third-party is a component of the internal program (unnamed, so not Third-Party Risk as central topic), and the board's limited involvement is subordinate. The substantive content is about the function/processes, not the person or the board. PCI is a named standard triggering Sector-Adapted, but no IS-list facts (CEO is generic C-suite, service provider is unnamed) push it to Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes management oversight (President & CEO), third-party service provider role, specific activities (antivirus, antimalware, BCDR, vulnerability management, PCI compliance), board's limited involvement.

Category: This is tricky. It mentions management, third-party, board, and risk management processes. The dominant topic seems to be describing the overall governance and operational structure. Let me think about what's primary.

The paragraph describes:
1. Management team including President & CEO oversees cybersecurity
2. They work with a third-party service provider
3. What the service provider does (antivirus, BCDR, vulnerability management, PCI compliance)

4. Board has limited involvement
5. Management would escalate to board

The primary communicative purpose is describing how cybersecurity is managed - it's a mix of management role and risk management process. The grammatical subjects are "management team" and "Service Provider."

The person-vs-function test: This is about the function/structure, not about the person's credentials. The CEO is mentioned but no qualifications are given. The paragraph describes what gets done (processes) and who does it (management + service provider).

I'd say Risk Management Process is dominant - it describes the overall cybersecurity management structure and activities. The management mention is incidental (no credentials, no background), and the third-party service provider is really just part of the operational structure being outlined. The board escalation pathway rounds out the governance framework, so this is fundamentally about how the organization manages cybersecurity operationally and escalates issues up the chain. PCI is a named standard, which points to Sector-Adapted, but I need to check if there are any firm-specific facts that would push this to the Internal Structure level. The CEO reference is generic C-suite, the service provider is unnamed, and there are no specific dates, named tools, or headcounts—nothing from the Internal Structure list. This is Sector-Adapted at Level 2.

fact: PCI (Payment Card Industry) compliance


reasoning: The paragraph splits between management responsibility ('IT Manager and executive team' managing cybersecurity risks day-to-day) and board oversight of general risk management. Management's cybersecurity-specific responsibility is the primary clause, with the board's role described as general 'risk management' oversight rather than cybersecurity-specific governance. 'IT Manager' is explicitly on the NOT list as generic IT leadership, 'executive team' and 'Board of Directors' are generic, and no frameworks, dates, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: "The Company's IT Manager and executive team is responsible for the day-to-day management of cybersecurity risks, while the Company's Board of Directors has responsibility for oversight of risk management."

Category: This mentions both management (IT Manager) and board oversight. The IT Manager is the grammatical subject of the first clause, and the Board is the subject of the second. It's split fairly evenly. The "IT Manager" is a generic IT title (not cybersecurity-specific per the IS/NOT list - "IT Manager" falls under "Generic IT leadership (NOT cybersecurity-specific)"). The board mention is also generic.

Looking at Rule 2, this is a dual-subject paragraph where management handles day-to-day cybersecurity responsibilities while the board provides oversight. Since "IT Manager" is explicitly on the NOT list for cybersecurity-specific titles, and the board's role is described generically as "risk management" oversight rather than cybersecurity-specific oversight, both subjects are treated at a high level. The paragraph covers both management and board roles, so it falls into the dual-subject category. roughly equally. The first clause about IT Manager and executive team managing cybersecurity risks day-to-day is slightly more about management. But the board oversight is also present. Given the split, I'd say Management Role since the IT Manager/executive team is the first subject and the cybersecurity-specific responsibility is attributed to them, while the board's role is described as general "risk management" oversight.

Actually, re-reading: "IT Manager and executive team is responsible for day-to-day management of cybersecurity risks" - this is about management's role. "Board of Directors has responsibility for oversight of risk management" - this is about board oversight but of general risk management, not specifically cyber.

The dominant content is about who manages cybersecurity risks day-to-day (management) with board oversight being secondary and general. I'll go with Management Role.

But "IT Manager" is on the NOT list for specificity, so even though it's describing management's role in cybersecurity, the language is too generic—no frameworks, no specific facts. That makes this Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program — risk assessment, continuous monitoring, security tools, MFA, VPC architecture, and access controls — squarely fitting Risk Management Process. The SOC certification claim (holding a certification, not merely naming the standard) is a firm-specific fact, but it is the only qualifying fact, so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity risk management program - risk assessment, monitoring, tools, controls, training, MFA, VPC, access controls.

Category: Risk Management Process - describes internal processes, tools, methodologies.

Specificity: Let me check facts:
- "SOC-certified" - this is a certification claim ("Our cybersecurity risk management program is SOC-certified"), which is more than just naming a standard. This is a firm-specific fact (holding certification).
- "virtual private cloud (VPC)" - this is a generic architecture term, not a named product/tool

- "multifactor authentication", "continuous monitoring", "internal audits", "employee training" - these are all standard industry practices, not firm-specific claims

So I'm finding just one firm-specific fact here: the SOC certification claim. That puts this at Level 3.

fact: Cybersecurity risk management program is SOC-certified


reasoning: The paragraph briefly attributes cybersecurity leadership to the CFO but then primarily describes internal processes: cross-departmental approach, quarterly updates to executive leadership, update content (initiatives, threat assessments, pen test findings, KPIs). Removing the CFO attribution, the paragraph still functions as a process description, so it fails the person-vs-function test for Management Role. CFO is generic C-suite (NOT list), 'quarterly' is a generic cadence, and practices like vulnerability/penetration testing are common — no named frameworks or firm-specific facts survive filtering.

thinking:
Let me analyze this paragraph.

Content: Describes management's role in cybersecurity risk management. The CFO is identified as leading cybersecurity risk assessment. Cross-departmental approach, quarterly updates to executive leadership.

Category: The paragraph describes management's role - the CFO spearheads cybersecurity. But then it goes on to describe processes (quarterly updates, cross-departmental approach, what updates include). The person-vs-function test: the CFO is named as attribution, but most of the paragraph describes the process of updates, cross-departmental approach, content of updates. However, the CFO being the one who "spearheads" cybersecurity is notable - it's about who fills the role. But the bulk of the paragraph is about processes.

Reading through again, the CFO mention is really just a brief attribution at the start. The substance of the paragraph focuses on the processes themselves—the cross-departmental structure, the quarterly cadence, what gets reported. If I swap out the CFO reference for "the Company," the paragraph still conveys the same procedural information. Since the CFO is on the generic C-suite exclusion list anyway, and the dominant content here is about how the process works rather than who specifically leads it, this falls into the processes category.

Now checking the specificity: CFO is explicitly excluded, quarterly updates is a generic cadence, cross-departmental approach is generic, vulnerability and penetration tests are standard practices, and there are no named frameworks, specific dates, or tools mentioned. Nothing concrete remains after filtering. This is Generic Boilerplate with a specificity score of 1.


specificity_confidence: medium

reasoning: The paragraph describes the company's internal cybersecurity review process (risk assessment results, action plans for vulnerabilities). While 'IT Director' is mentioned, it serves as attribution for who performs the review — the substantive content is about the process itself. 'IT Director' is a generic IT title not on the IS list (not cybersecurity-specific like CISO/CIO), and 'annual' is a generic cadence, so specificity remains Generic Boilerplate.


reasoning: The paragraph describes internal cybersecurity functions — risk assessment, security controls, and incident response — assigned to a generic 'team comprised of IT personnel.' Using the person-vs-function test, the content is about the functions (what the team directs), not about any individual's qualifications or credentials. No named roles, frameworks, dates, or firm-specific facts are present.

thinking:
Classify this paragraph.

This describes an internal team responsible for cybersecurity processes. The grammatical subject is "A team comprised of IT personnel" — this is about management/team structure responsible for cybersecurity functions.

Content: It describes a team and what they're responsible for (risk assessment, security controls, incident response). This is about internal processes/structure.

Category consideration:
- Management Role? It describes a team, not a specific person's qualifications/credentials.
- Risk Management Process? It describes processes (risk assessment, security controls, incident response).

The paragraph lists what the team does — risk assessment processes, security controls, response to incidents. But it's really describing the team composition/responsibility, not the processes themselves in detail.

I'm torn between Management Role and Risk Management Process. The paragraph names no specific person or credentials, just generic IT personnel and their functions. Since it's really enumerating the functions themselves — risk assessment, controls, incident response — rather than focusing on who these people are, Risk Management Process seems like the better fit.

Looking at the specificity now: there are no named frameworks, no actual role titles, no concrete details. Everything is generic boilerplate language.


reasoning: The paragraph contains two explicit materiality assessments — that cybersecurity risks 'have not previously materially affected us' and are not 'reasonably likely to materially affect us, including our business, strategy, results of operations or financial condition.' Per Rule 6, materiality disclaimers are Strategy Integration even when boilerplate. The brief vendor cyberattack mention and cross-reference to Risk Factors are subordinate to the materiality conclusions. No named standards, firm-specific facts, or verifiable details are present.

thinking:
Let me analyze this paragraph.

Content: Makes materiality assessments ("have not previously materially affected us", "do not expect the risks... are reasonably likely to materially affect us"), mentions vendor cyberattacks briefly, and has a cross-reference to Risk Factors.

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

Specificity: No named standards, no specific facts from the IS list. Generic boilerplate materiality language. The cross-reference is noise. → Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes, safeguards, and organizational measures (antivirus, firewalls, VPNs, penetration testing, phishing testing, patching, training, monitoring). The brief insurance mention at the end is subordinate to the dominant process description. Despite listing many practices, all are common/generic (on the NOT list) with no named frameworks, no named tools/vendors, no specific dates, headcounts, or firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal cybersecurity processes - policies, procedures, technical safeguards, organizational measures. Lists specific practices like antivirus, IDS/IPS, VPNs, firewalls, email security, patching, training, phishing testing, penetration testing, access reviews, monitoring. Mentions cybersecurity insurance briefly at the end.

Category: Risk Management Process - clearly about the company's own internal processes and safeguards. The insurance mention is brief and subordinate.

Specificity: Let me check the facts:
- Lists many common practices (antivirus, firewalls, VPNs, penetration testing, phishing testing, etc.) - these are all on the NOT list as common practices

- "cybersecurity insurance" - mentioned generically, no specifics
- No named frameworks, no named roles, no specific dates, no named tools/firms, no headcounts

Everything here is generic boilerplate with no firm-specific details or named standards.


reasoning: The paragraph's primary communicative purpose is a materiality assessment ('not aware of any cybersecurity threats or incidents that have materially affected our business strategy, results of operations, or financial condition'), which is Strategy Integration per Rule 6. The third-party incident mention is contextual framing, and the cross-reference and forward-looking disclaimer are noise. No specific facts are present — no named firms, dates, amounts, roles, or standards — making this Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: The paragraph mentions third-party providers experiencing incidents, then makes a materiality assessment ("not aware of any cybersecurity threats or incidents that have materially affected our business strategy, results of operations, or financial condition"), followed by a forward-looking disclaimer and a cross-reference.

Category: The dominant content is the materiality assessment → Strategy Integration (per Rule 6). The third-party mention is context, not the central topic. The cross-reference doesn't change the classification.

Specificity: Let me check for facts:
- No specific dates beyond "as of the date of this report" (generic)
- No named firms, tools, amounts

- No cybersecurity-specific roles or named standards

This is boilerplate materiality language → Generic Boilerplate (1)


reasoning: The Board of Directors is the grammatical subject throughout, describing its ultimate risk oversight responsibility and delegation of cybersecurity oversight to the Audit Committee. No facts from the IS list are present — 'Board of Directors,' 'Audit Committee,' and 'senior management' are all on the NOT list, and no named frameworks, cybersecurity-specific roles, dates, or other firm-specific details appear.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity risks, delegation to Audit Committee, reporting patterns. The Board is the grammatical subject throughout. This is Board Governance.

Specificity: Let me check facts.
- "Board of Directors" - generic (NOT list)
- "Audit Committee" - generic (NOT list)
- "Senior management of Mullen" - company self-reference, generic
- No named frameworks, no specific dates, no named roles from IS list, no specific numbers

No IS-list facts remain. No named standards. → Generic Boilerplate.


reasoning: The paragraph describes two management roles — the Director of IT Infrastructure (with experience and certifications) and the CISO — along with their qualifications and reporting lines. The primary content is about who these people are and their credentials, making it Management Role. While the CISO sentence touches on program responsibilities, the overall focus is on the persons and reporting structure. Specificity is Firm-Specific: multiple IS-list facts (CISO, CIO, 20 years of experience) but only one QV-eligible hard fact (the specific number of years), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes two management roles - Director of IT Infrastructure (experience, certifications, reporting to CIO) and CISO (responsibilities). This is about the people and their roles/qualifications.

Category: Management Role - the paragraph is about who these people are, their qualifications, and reporting lines. The person-vs-function test: the paragraph describes credentials (20 years experience, certifications) and reporting structure. While the CISO sentence mentions program responsibilities, the overall paragraph is about the people.

Specific facts:
- Director of IT Infrastructure (cybersecurity-specific? It's "Director of IT Infrastructure" - this is more of a general IT title, not on the IS list)

- "over 20 years of experience" is a specific number that qualifies, but the professional security certifications aren't named so they don't count as QV-eligible facts
- CIO and CISO both appear on the IS list as cybersecurity-specific titles
- So I've got one hard QV-eligible fact and two IS list matches, but the certifications are too vague to count

Now I'm checking whether "Director of IT Infrastructure" qualifies as IS-eligible. The IS list has "Director of IT Security" which is cybersecurity-specific, but "Director of IT Infrastructure" is broader general IT work, similar to what's on the NOT list. That doesn't seem to meet the cybersecurity-specific requirement.

So my count is: one QV-eligible fact ("over 20 years"), and three IS facts (CISO, CIO, and "over 20 years" again), which makes this Firm-Specific overall. Let me verify the QV-eligible count one more time—no specific dates, dollar amounts, headcounts, named third-party firms, named products, or named certifications. Just the years of experience.

fact: Director of IT Infrastructure

fact: over 20 years of experience


reasoning: The paragraph describes the company's own internal cybersecurity measures, processes, policies, employee training, incident response planning, and framework alignment — all hallmarks of Risk Management Process. Third-party providers are mentioned as a component supporting internal processes, not as the central topic. Multiple named standards (NIST, COSO, ISO 27001) are referenced, but no firm-specific facts appear: no cybersecurity-specific titles, no named tools/vendors, no specific dates or numbers, and the incident response plan has no unique identifier. This places it at Sector-Adapted.

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity processes - technical/physical/organizational measures, employee training, third-party providers supporting internal processes, framework alignment (NIST, COSO, ISO 27001), incident response plan, SEC monitoring.

Category: Risk Management Process - describes the company's own internal processes, frameworks, tools, methodologies. Third parties are mentioned as one component of internal processes (Rule 3).

Specificity: Names NIST, COSO, ISO 27001 - these are recognized standards → at least Sector-Adapted. Any firm-specific facts? No cybersecurity-specific titles, no named committees, no specific dates, no named tools, no specific numbers. "Well-established information security incident response plan" is a generic program name. Third-party service providers are unnamed.

This lands at Sector-Adapted since it references industry-standard frameworks without disclosing company-specific implementation details.

fact: National Institute of Standards and Technology (NIST)

fact: Committee of Sponsoring Organizations (COSO)

fact: International Organization for Standardization 27001 (ISO 27001)


reasoning: The paragraph's primary communicative purpose is a materiality assessment — explicitly stating that cybersecurity threats have not materially affected business strategy, results of operations, or financial condition. Per Rule 6, this is Strategy Integration even though it includes a cross-reference to Risk Factors and generic forward-looking risk language. No specific facts from the IS list are present; 'certain cybersecurity incidents' is a vague quantifier, 'service providers' is unnamed, and the cross-reference is noise.

thinking: Materiality assessment is the primary content here.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, with third-party oversight mentioned as one component of the broader program (Rule 3: third parties as one component → RMP). No named frameworks, roles, tools, dates, or quantified details are present — entirely generic language that could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes internal processes for managing cyber risks, mentions third-party oversight as a component. The paragraph covers both internal processes and third-party risk management.

Category: The paragraph starts with internal processes ("assessing, identifying, and managing material risks"), says they're "integrated into our overall risk management systems," and then mentions third-party oversight as one component. Per Rule 3: "Third parties mentioned as ONE component of internal program → Risk Management Process." So this is Risk Management Process.

Specificity: Let me check for specific facts:
- No named frameworks
- No named roles
- No named tools
- No dates

- No numbers
- "third-party service providers" is generic
- "security assessments" is generic
- "monitoring procedures" is generic
- "certain third-party providers" is vague

This is Generic Boilerplate.


reasoning: The paragraph's primary content describes internal cybersecurity processes: risk assessment, monitoring, security tools, tabletop exercises, and monthly employee training. The CIO is mentioned with 'over a decade of experience' and reporting to the Board, but these are subordinate to the dominant process description. Applying the person-vs-function test, removing the CIO attribution leaves a coherent process description. CIO is a cybersecurity-specific title on the IS list, triggering Firm-Specific, but 'over a decade' is too vague for a QV-eligible quantified fact and no other hard verifiable facts (named firms, tools, specific dates, certifications) are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Risk assessment and monitoring processes
2. Security tools
3. CIO role and reporting
4. CIO qualifications
5. Simulations and exercises
6. Employee training

This is a mixed paragraph. Let me apply the dominant category test.

The paragraph describes internal processes (risk assessment, monitoring, testing, security tools, simulations, tabletop exercises, employee training) with a CIO mention in the middle. The person-vs-function test: the CIO is mentioned with "over a decade of experience" and responsibility for the program. But the bulk of the paragraph is about what the company does — processes, tools, exercises, training.

Actually, let me count the sentences more carefully. Looking at the breakdown: four sentences focus on risk management processes and activities, while two sentences are about the CIO's role and qualifications. That makes risk management processes the dominant category. Now I'm checking the specificity of the CIO title — it's listed as a cybersecurity-specific role, so that would be firm-specific.

For the quantifiable verification check, I need two hard facts. The CIO is a named role but that doesn't count. "Over a decade" is too vague, and there are no named firms, tools, specific dates, dollar amounts, or named certifications mentioned. So this doesn't meet the QV threshold.

That puts this at Risk Management Process with Firm-Specific classification, which is a 3.

fact: Chief Information Officer (CIO) is responsible for the information security program


content_category: None/Other

reasoning: The paragraph is a forward-looking disclaimer ('there can be no assurance') about hypothetical future investment needs, not a description of any actual program, process, or materiality assessment. It lists generic categories of potential future spending (systems, personnel, technologies, consultants, training) without describing what the company actually does, and closes with a cross-reference to Risk Factors. There is no substantive cybersecurity disclosure content — no materiality conclusion, no process description, no governance detail.

thinking:
Let me analyze this paragraph.

Content: Discusses potential future material effects from security breaches, potential future investments needed, and cross-references Risk Factors. No actual incident described, no specific processes, no board/management details.

Category: This is forward-looking/hypothetical language about potential investments and a cross-reference. There's no materiality assessment (it says "no assurance" not "have not materially affected"). No substantive disclosure of processes, governance, or incidents. The cross-reference at the end points to Risk Factors. This is essentially generic risk language + cross-reference → Strategy Integration or None/Other?

Looking more carefully: "There can be no assurance the Company will not experience material effects" - this is NOT a materiality assessment.

The paragraph is just boilerplate risk language with a cross-reference to Risk Factors. It mentions hypothetical future investments in systems, personnel, and training, but these are all speculative rather than describing actual cybersecurity strategies or programs. I'm categorizing this as None/Other with Specificity 1 since there are no concrete facts or substantive disclosures here.


reasoning: The paragraph describes the company's internal cybersecurity awareness training program — online modules, phishing simulations, and training topics — which are internal risk management activities. Third-party training providers are mentioned as a component of the internal program, not as the central topic of vendor oversight. No named frameworks, specific roles, dates, tools, or other facts from the IS list are present; the training topics listed (phishing, viruses, insider threats) are common practices on the NOT list.

thinking:
Classify this paragraph.

Content: describes cybersecurity training programs - awareness training, phishing simulations, learning modules, training topics. Uses third-party training programs but the central topic is the company's own internal training process, not vendor oversight.

Category: Risk Management Process - describes internal security awareness training practices.

Specificity: No named frameworks, no firm-specific facts from the IS list. "Third-party" is unnamed. Training topics (phishing, viruses, etc.) are common practices. → Generic Boilerplate.


reasoning: The paragraph's thesis is that oversight responsibility is shared among the BOD, Audit Committee, and management team — an organizational governance framing. The Audit Committee is described as implementing policies and updating the BOD, making it the primary actor in the oversight structure. The management team and third-party CISO conducting assessments is subordinate to that governance frame. The use of a third-party (outsourced) CISO is a firm-specific fact, but no second QV-eligible hard fact is present.

thinking:
Let me analyze this paragraph.

Content: Describes shared oversight between BOD, Audit Committee, and cybersecurity management team. Mentions a third-party CISO conducting assessments. Employees report suspicious activity.

Category: This spans Board Governance, Management Role, and Risk Management Process. The paragraph describes oversight responsibility shared by BOD, Audit Committee, and management team. It mentions a third-party CISO conducting assessments. The dominant theme is the overall governance/oversight structure.

The board/Audit Committee is mentioned but the paragraph also heavily describes the management team and processes. The Audit Committee "implements policies" and "updates BOD" - that's Board Governance.

The cybersecurity management team and third-party CISO conducting assessments represents the Risk Management Process component. Looking at the overall structure, the paragraph's primary focus is establishing the oversight hierarchy - the BOD and Audit Committee set direction while the management team executes assessments. This makes it fundamentally a Board Governance paragraph with embedded Risk Management Process elements, since the governance structure determines how risk management gets executed. The management team and third-party CISO handle the actual assessments and risk management, while employees feed concerns back through reporting channels. The third-party CISO detail is firm-specific since it's an outsourced role, but there's no other quantifiable or named framework information here, so this stays Board Governance with just one firm-specific data point.

fact: third-party chief information security officer (CISO)


reasoning: The paragraph describes the company's internal risk assessment processes — the Information Security Program, risk assessments using the FFIEC CAT, vulnerability assessments, penetration testing, and how assessment results inform decisions. Management and Board are mentioned briefly as consumers of the data, not as primary actors. It names recognized regulatory frameworks (FFIEC, FDIC) and the FFIEC CAT assessment tool, which are industry-standard for the banking sector, but contains no facts unique to THIS company (no named individuals, specific dates, headcounts, or firm-specific tools). 'Information Security team' is a generic team description, and 'internal and external auditors' are unnamed entities on the NOT list.

thinking:
Let me analyze this paragraph from FS Bancorp's 10-K Item 1C filing.

Content Category: This paragraph describes the company's internal cybersecurity risk assessment processes - the Information Security Program, risk assessments, use of FFIEC CAT, vulnerability assessments, penetration testing, etc. The primary topic is the company's own internal processes. Management and Board are mentioned briefly at the end but as consumers of the risk assessment data, not as the primary subject. → Risk Management Process

Specific facts:
- FFIEC - named regulatory body (framework/standard)
- FDIC - named regulatory body
- "FFIEC Cybersecurity Assessment Tool" ("FFIEC CAT") - this is a named tool/program with a unique identifier

- "Information Security team" - this is a cybersecurity-specific team reference

Now I'm determining the classification levels. FFIEC CAT is a publicly available regulatory tool rather than something proprietary to the firm, so that's more of a sector-adapted standard. The Information Security team is just a generic functional team name without firm-specific characteristics. to naming NIST or ISO 27001. But "Information Security team" is essentially a cybersecurity-specific team, which the IS list flags as firm-specific. The real question is whether FFIEC CAT—an external, publicly available assessment tool—counts as a named firm-specific tool or as a sector-adapted framework like NIST CSF. Since it's industry-wide and not company-proprietary, I'm leaning toward Sector-Adapted, though the parenthetical abbreviation makes it look like a named identifier. FFIEC CAT is an industry-standard assessment tool that all banks use, so naming it shows sector knowledge but doesn't indicate company-specific practices. I'm settling on Sector-Adapted for the Risk Management Process classification.

fact: FFIEC (Federal Financial Institutions Counsel)

fact: FDIC

fact: FFIEC Cybersecurity Assessment Tool (FFIEC CAT)


reasoning: The paragraph contains an explicit materiality assessment ('have not encountered cybersecurity challenges that have materially impacted our strategic plan, operations, or financial standing'), which per Rule 6 is Strategy Integration even though a cross-reference to Risk Factors is appended. No named standards, dates, roles, or firm-specific facts are present, so specificity is Generic Boilerplate.

thinking:
Classify this paragraph.

Content: "We have not encountered cybersecurity challenges that have materially impacted our strategic plan, operations, or financial standing. For additional information, see 'Risk Factors.'"

This contains a materiality assessment ("have not...materially impacted our strategic plan, operations, or financial standing") plus a cross-reference. Per Rule 6 and the codebook, a materiality assessment makes this Strategy Integration, even with the cross-reference appended.

Specificity: No named standards, no firm-specific facts, boilerplate materiality language. → Generic Boilerplate.


reasoning: The paragraph describes the company's incident response planning and regular evaluation of those plans, which are internal cybersecurity processes. No named frameworks, specific roles, dates, or other facts from the IS list are present — 'incident response plans' and 'regular basis' are both generic.

thinking:
Classify this paragraph.

Content: describes incident response plans and their evaluation. This is about internal processes.

Category: Risk Management Process - describes IR planning and evaluation.

Specificity: No named frameworks, no specific facts from the IS list. "incident response plans" is generic. "regular basis" is a generic cadence. → Generic Boilerplate.


reasoning: The paragraph's central topic is oversight of third-party cybersecurity risks — vendors, service providers, and external users. While it mentions a 'risk-based approach' (which could suggest Risk Management Process), the entire paragraph is framed around third parties and their systems, making Third-Party Risk the dominant category. No named frameworks, specific roles, dates, or firm-specific facts are present — the language is entirely generic and could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity policies (access security, change management, incident management, business continuity) and their annual review process. The third-party consultant for SOX compliance is incidental, not central vendor oversight. No cybersecurity-specific named roles, no recognized cybersecurity frameworks (SOX is financial reporting, not on the named standards list), no named firms, dates, or other IS-list facts — all items are generic practices, unnamed entities, and generic cadences.

thinking:
Let me analyze this paragraph.

Content: Describes company-wide policies (access security, system change management, etc.), annual review process, and mentions a third-party consultant for SOX compliance.

Category: This is about internal cybersecurity processes - policies, procedures, review processes. The third-party mention is incidental (SOX compliance, not vendor oversight). → Risk Management Process

Specificity: Let me check facts:
- "Company-wide policies" - generic program name (NOT list)
- "access security, system change management, development lifecycle, incident management and business continuity/disaster recovery" - common practices
- "annual internal review process" - generic cadence

- "appropriate members of management" - generic
- "third-party consultant" - unnamed entity (NOT list)
- "Sarbanes Oxley requirements" - this is a regulatory/compliance standard, but it's not a cybersecurity framework. SOX is a financial reporting standard. Not on the named standards list (NIST, ISO 27001, SOC 2, etc.)

No IS-list facts found. No named standards from the cybersecurity list. → Generic Boilerplate


reasoning: The paragraph's central topic is oversight of third-party service providers and the vendor management process used to assess cybersecurity risks associated with them, making Third-Party Risk the dominant category. No named frameworks, specific roles, dates, tools, or other IS-list facts are present — the description of 'different levels of assessment' is generic and could apply to any company.

thinking:
Classify this paragraph.

The paragraph discusses how the company uses third-party service providers and describes their vendor management process with different levels of assessment based on risk. The central topic is oversight of external parties' cybersecurity - this is Third-Party Risk.

Specificity: No named frameworks, no named roles, no specific dates, no named firms/tools. "different levels of assessment" is generic. No IS-list facts. → Generic Boilerplate.


reasoning: The paragraph describes the company's practice of engaging external assessors to evaluate its own internal cybersecurity efforts — per Rule 3, external assessors hired to test the company are Risk Management Process, not Third-Party Risk. The Audit Committee mention is subordinate. No named firms, frameworks, dates, or IS-list facts are present; 'third-party consultants,' 'periodically,' and 'Audit Committee' all appear on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Engaging third-party consultants for independent assessments of IT security, sharing results with Audit Committee.

Category: The central topic is engaging third parties to assess internal security efforts. But is this Third-Party Risk or Risk Management Process? The third parties here are serving the company (external assessors hired to test the company) → Rule 3 says this is Risk Management Process. There's also a mention of Audit Committee at the end.

The primary content is about the company's own process of getting assessments done. Third parties are a component of internal processes. → Risk Management Process.

Specificity: Let me check facts:

- "third-party consultants and service providers" — unnamed, NOT list
- "Audit Committee" — NOT list (generic governance)
- "Information Systems" — generic
- "periodically" — generic cadence
- No named frameworks, no specific facts from IS list

→ Generic Boilerplate (1)