reasoning: The paragraph is about the person filling the cybersecurity leadership role — the CCO's tenure, experience, and qualifications — satisfying the person-vs-function test for Management Role. It contains two QV-eligible hard facts: a specific date (since 2021) and a specific duration of experience (more than 15 years), reaching the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the CCO's role, their reliance on the Adviser's GHIC, experience, tenure since 2021, 15+ years in financial services.

Category: This is about the person - their qualifications, experience, tenure. The paragraph tells us WHO manages cybersecurity risk and what makes them qualified. This is Management Role.

Specific facts:
- CCO (Chief Compliance Officer) - wait, is CCO a cybersecurity-specific title? The IS list includes "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security, HSE Director overseeing cybersecurity." CCO is not on this list.

But I need to check the NOT list more carefully. It explicitly includes "Chief Compliance Officer" as generic IT leadership that's not cybersecurity-specific, so even though this CCO is described as overseeing cybersecurity, the title itself falls outside the scope. Now I'm looking at what "Adviser's GHIC" refers to in this context. named entity/team. Is this firm-specific? GHIC seems like a specific named group. This could be a named team/committee.
- "since 2021" - specific date
- "more than 15 years" - specific duration

Let me think about specificity:
- CCO is NOT list
- "Adviser's GHIC" - this seems like a named internal program/team with a unique identifier. GHIC likely stands for something specific. This could qualify as firm-specific.
- "since 2021" - specific date → IS list
- "more than 15 years" - specific number of years

So specific facts: "since 2021" (specific date), "more than 15 years" (quantified experience), "Adviser's GHIC" (named team/entity).

I'm identifying two hard verifiable facts here: the 2021 date and the 15+ years of experience. That makes this Quantified-Verifiable material. The paragraph itself is about the person managing cybersecurity risk—their role, qualifications, and experience—so it falls under Management Role.

fact: Adviser's GHIC (named external team/group)

fact: CCO responsible since 2021

fact: More than 15 years in financial services industry


content_category: Risk Management Process

category_confidence: medium

specificity_confidence: medium

reasoning: The paragraph describes the FTC's GLBA Safeguards Rule requirements for financial institutions — naming a specific regulation but describing no company-specific processes, tools, or actions. Per the Case 9 codebook guidance, naming a specific regulation without describing a company-specific program yields Risk Management Process at Sector-Adapted. The December 9, 2022 date is a regulatory effective date applicable to all financial institutions, not a firm-specific fact, so it does not elevate specificity. The trailing 'Risk management and strategy.' appears to be a concatenated section subheader. Category confidence is moderate because this paragraph is borderline with None/Other — it contains zero description of what the company actually does and reads as regulatory background — but the codebook's explicit Case 9 rule directs named-regulation paragraphs to RMP.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph from CapStar Financial Holdings' 10-K Item 1C filing.

The paragraph describes FTC amendments to the GLBA Safeguards Rule requirements for financial institutions. It lists regulatory requirements but doesn't describe what the company specifically does. It's essentially describing external regulatory requirements, not the company's own cybersecurity program.

This is generic regulatory compliance language - it describes what the rule requires of financial institutions generally, not what CapStar specifically does. The last sentence about states and Congress considering new laws is also generic. "Risk management and strategy" at the end appears to be a section header.

Per the codebook's Case 9 guidance on generic regulatory compliance language: "This acknowledges that regulations exist... It does not describe any process, program, or framework the company uses to comply." → None/Other.

The codebook does distinguish between naming a specific regulation with no company-specific program versus purely generic regulatory background. While this paragraph does reference the GLBA Safeguards Rule and FTC, it's really just providing regulatory context rather than describing any actual program or process CapStar uses. That pushes it toward None rather than Risk Management Process. The key distinction is whether naming a specific regulation alone pushes it to Risk Management Process Specificity 2, or if the paragraph needs to describe what the company actually does. The Case 9 guidance suggests that naming a specific regulation like GLBA Safeguards Rule should trigger RMP Spec 2, even if it's just regulatory context without company-specific actions described. The paragraph names GLBA Safeguards Rule and mentions its December 9, 2022 effective date, but it's really just regulatory background—the company isn't describing their own process here. I'm leaning toward None/Other since this reads more like a section header or regulatory context rather than an actual company risk management practice.

But Case 9 guidance is pretty clear: when a paragraph names a specific regulation like this, even without company-specific details, it should be categorized as Risk Management Process, Specificity 2. That's the right call here, so I'll go with that classification.

fact: GLBA Safeguards Rule (named regulation)

type: framework

fact: December 9, 2022 (regulatory effective date, not a company-specific event)


content_category: Management Role

reasoning: The paragraph identifies the cybersecurity team and focuses on their professional credentials (CISSP, SANS Institute, ISC²), making it primarily about the qualifications of the people managing the program rather than the processes themselves. While the first sentence briefly describes what the team monitors, the dominant content is who these professionals are and what credentials they hold. Specificity reaches Quantified-Verifiable with two QV-eligible facts: the named CISSP certification and the named credentialing institutions (SANS Institute, ISC²) as third-party organizations whose credentials the team holds.

thinking:
Let me analyze this paragraph.

Content: Describes the cybersecurity team's composition and credentials. This is about the people managing the program - their credentials and qualifications.

Category: This is about the team's credentials (CISSP, SANS Institute credentials). It's describing who the people are and their qualifications. This fits Management Role - it's about the personnel and their credentials, not about the processes themselves.

Wait - let me apply the person-vs-function test. The paragraph mentions "a team of professionals who monitor the prevention, detection, mitigation and remediation" - that's process description. But then it pivots to credentials: CISSP, SANS Institute, experienced professionals. The dominant content is about the team's qualifications.

Actually, the first sentence describes what the team does - that's process - but the second sentence focuses on their specific credentials, which is the more substantive part. So this is Management Role, since the paragraph's main point is identifying the team and their qualifications. The QV-eligible facts here are CISSP as a named certification, and SANS Institute along with ISC² as named organizations.

Wait, let me reconsider what counts as QV-eligible. SANS Institute is an institution offering certifications, not a third-party firm being hired. Looking at the criteria again: CISSP is definitely a named certification, and the paragraph mentions "credentials from the SANS Institute" - those are certifications from a named source. CISSP is explicitly named as an example, so that's one clear QV-eligible fact.

But the SANS credentials themselves aren't specifically named - just referenced generically as "credentials from SANS Institute." So I'm counting CISSP as one QV fact, which means this doesn't meet the Quantified-Verifiable threshold of two facts. That puts it in Firm-Specific instead.

fact: CISSP certification held by team members

fact: Credentials from SANS Institute

fact: Credentials from International System Security Certification Consortium (ISC²)


specificity_confidence: high

reasoning: The paragraph describes a management-level committee ('technology steering committee, led by management') and its oversight activities — receiving cybersecurity reports, assessments, and forwarding minutes to the Board. Management Role explicitly covers management committees responsible for cybersecurity. The 'technology steering committee' is a named non-generic committee (analogous to 'Technology Committee' on the IS list), providing one firm-specific fact, but no QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes a technology steering committee receiving reports on cybersecurity monitoring, incident management, remediation, assessments. Minutes go to the Board.

Category: The primary actor is "the technology steering committee, led by management." It describes what reports they receive and that minutes go to the Board. This is about management's role in overseeing cybersecurity through a committee structure, with reporting up to the Board.

The grammatical subject is the technology steering committee. This is a management-level committee receiving reports. The Board is mentioned only as receiving minutes. The paragraph describes the committee's oversight function.

Is this Management Role or Risk Management Process or Board Governance?

The key distinction is that this committee is explicitly led by management and receives reports about cybersecurity activities—it's describing a management-level oversight structure rather than individual credentials or a board-level governance body. This leans toward Management Role since it's a named management committee with defined oversight responsibilities. The committee's role in receiving and distributing reports is fundamentally about governance structure rather than technical processes, so Management Role fits. The "Technology steering committee" is specific enough to count as firm-specific language, though there are no QV-eligible facts like dates or dollar amounts to consider.

fact: Technology steering committee


content_category: Board Governance

category_confidence: high

reasoning: The audit committee and board of directors are the grammatical subjects receiving cybersecurity updates and incident reports, making this Board Governance. All entities mentioned (audit committee, board, management) are generic per the NOT list, with no named frameworks, specific roles, dates, or firm-specific facts.

thinking:
Let me classify this paragraph.

Content: The audit committee receives updates from management, receives info on risks. The board receives info on incidents meeting thresholds.

Category: Board Governance - the audit committee and board are the grammatical subjects receiving information about cybersecurity oversight.

Specificity: Let me check the facts:
- "audit committee" - generic, on the NOT list
- "board of directors" - generic
- "management" - generic
- "established reporting thresholds" - vague

No named frameworks, no specific facts from the IS list. This is Generic Boilerplate.


content_category: Third-Party Risk

reasoning: The paragraph's primary communicative purpose is third-party risk oversight — conducting security assessments of all third-party providers before engagement. The Executive Director of IT mention is subordinate attribution (describing who performs the assessments), and the closing materiality disclaimer is a secondary element. No IS-list facts remain after filtering: 'Executive Director of IT' maps to the NOT-list's generic IT leadership titles ('Director of IT'), 'industry cybersecurity standards and frameworks' names no specific standard, and the materiality sentence is boilerplate language.

thinking:
Let me analyze this paragraph carefully.

This paragraph contains multiple topics:
1. Third-party risk oversight - security assessments of third-party providers
2. Management role mention - Executive Director of IT
3. Materiality disclaimer - "have not encountered cybersecurity challenges that have materially impaired"

Let me determine the dominant category. The paragraph starts with "Oversee Third-party Risk" and the bulk of the content is about conducting security assessments of third-party providers. Then there's a mention of the Executive Director of IT, and finally a materiality disclaimer.

The third-party risk assessment is the central topic. The management role mention is subordinate (it's describing who performs the assessments as part of the third-party risk process). The materiality disclaimer at the end is a secondary element.

I'm seeing two sections here that got merged together - one on third-party risk oversight and another on cybersecurity threats - but the third-party risk content clearly dominates. The category is Third-Party Risk, focused on how we assess external parties' security posture before bringing them on. Now I need to evaluate whether the Executive Director of IT title is specific enough to count as a cybersecurity-specific role.

Looking at the codebook, generic IT leadership titles like "Director of IT" and "Head of IT" don't qualify as specific facts. "Executive Director of IT" falls into that same bucket - it's a general IT title, even though the paragraph mentions this person oversees the cybersecurity function. The rest of the content is pretty thin: no named frameworks beyond vague references to "industry standards," no specific firms, dates, or numbers, and the materiality statement reads like boilerplate. So after filtering out what doesn't meet the specificity threshold, there aren't any IS-list facts left.


content_category: Strategy Integration

reasoning: The paragraph contains an explicit materiality assessment ('these risks have not materialized into any instances or series of instances that have had a material adverse effect on our business'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No specific facts from the IS list are present — 'phishing attacks' is a common practice, the cross-reference is metadata, and all other language is boilerplate.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses cybersecurity risks, makes a materiality assessment ("have not materialized into any instances... that have had a material adverse effect"), mentions past minor incidents (phishing attacks), and cross-references Risk Factors.

Category: The key content is the materiality assessment - "these risks have not materialized into any instances or series of instances that have had a material adverse effect on our business." Per Rule 6, any paragraph with an explicit materiality assessment is Strategy Integration. The cross-reference doesn't change this.

Specificity: Let me check for specific facts. "phishing attacks" - common practice/generic.

The cross-reference to Item 1A Risk Factors and the lack of any named frameworks, specific dates, roles, or dollar amounts confirms this is generic boilerplate language rather than substantive disclosure.


reasoning: The paragraph describes how cybersecurity risk assessment and management are integrated into the company's overall ERM processes, with management evaluating and prioritizing risks — this is about the function/process, not about the people. The Audit Committee reporting is subordinate to the process description. No IS-list facts are present: 'IT manager' is a generic IT title (not cybersecurity-specific like CISO/CIO), 'Audit Committee' is on the NOT list, and 'management team' is generic.

thinking:
Let me analyze this paragraph.

Content: Describes integration of cybersecurity into ERM, IT manager working with management, reporting to Audit Committee.

Category: This is about risk management processes - how the company assesses and manages cyber risks, integrates into ERM. The Audit Committee mention is subordinate. The IT manager mention is about what the function does, not about the person. → Risk Management Process

Specificity: Let me check for specific facts.
- "IT manager" - this is a generic IT title, not on the IS list (not CISO/CTO/CIO/VP of Security)
- "Audit Committee" - explicitly on the NOT list

- "management team" - also generic
- No frameworks named, no dates, no numbers, no named tools or firms

This lacks any IS-list facts or named standards, so it's generic boilerplate.


reasoning: The paragraph's primary frame is the board of directors' oversight of cybersecurity risk management, with the SVP of IT described as the mechanism supporting that oversight — fitting 'Board delegates responsibility to management → Board Governance.' The SVP of Information Technology is a cybersecurity-adjacent leadership title on the IS list (VP of IT/Security), making this Firm-Specific, but there is only one qualifying fact so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph mentions the board's oversight but then shifts to describing the SVP of IT who leads the cybersecurity team and what they do. Let me apply the decision rules.

The grammatical subject starts with "our board of directors' oversight" but the main clause is about how it's "supported by our SVP of IT." The paragraph then describes what the SVP's team does: publishing policies, conducting risk assessments, ensuring compliance.

This is a mixed paragraph. The board is mentioned but the primary content is about the management role (SVP of IT) and what they do. Per the tiebreaker: "Board oversight mentioned briefly + management roles as main focus → Management Role."

Actually, I'm reconsidering the framing here. The board's oversight is the main topic, and the SVP role is presented as the mechanism supporting that oversight. Even though the paragraph describes what the SVP's team does, the organizational structure and governance framework is what's really being explained. This points toward Board Governance.

But I should check the tiebreaker rule—it says if board oversight is mentioned briefly with management roles as the focus, it's Management Role. The board mention here isn't brief though; it's the grammatical subject framing the entire statement. So Board Governance seems right.

Now I'm looking at whether "Senior Vice President of Information Technology" is a cybersecurity-specific title or a broader IT role, which affects how specific the categorization should be.


reasoning: The paragraph is overwhelmingly about the people filling cybersecurity leadership roles — the COTO, IT Director, and ISO — detailing their tenure, experience, certifications, and reporting lines. This is the person, not the function. Multiple QV-eligible hard facts are present: specific years of experience (25+, 8+, 10, 15+) and named certifications (CISSP, CISM), far exceeding the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

This paragraph describes multiple management roles and their qualifications at QNB Corp. Let me break it down:

1. IT Department manages cybersecurity
2. COTO - reports to CEO, 8+ years at QNB, 25+ years experience, MBA in MIS, CISSP
3. IT Director - 10 years at QNB, 15+ years in tech, numerous certifications
4. ISO - CISSP, CISM, supervises training, access reviews, monitors controls
5. Reporting to Information Technology Committee and Information Security Committee
6. COTO reports to Board quarterly

7. Now I'm identifying the key roles and credentials: the COTO and ISO are the named security positions with specific certifications like CISSP and CISM, while the IT Director is a more generic role, and I'm noting the quantified experience metrics like 8+ years tenure and 25+ years total experience along with the MBA in MIS.

8. I'm seeing multiple verifiable facts here—the named certifications (CISSP, CISM) and the years of experience (8+, 10, 15+, 25+)—which easily gives me 2+ hard verifiable facts, so this qualifies as Quantified-Verifiable.

9. The overall category is Management Role since the content focuses on people, their credentials, experience, and organizational structure.

fact: COTO (Chief Operations/Technology Officer) role

fact: ISO (Information Security Officer) role

fact: COTO has over 25 years of experience in banking technology and operations

type: quantified

fact: COTO has been with QNB Bank for over 8 years

fact: CISSP certification (held by COTO and ISO)

fact: CISM certification (held by ISO)

fact: MBA in Management Information Systems

fact: IT Director has 10 years at QNB Bank

fact: IT Director has over 15 years in technology industry

fact: Information Technology Committee

fact: Information Security Committee


reasoning: The paragraph describes the company's internal cybersecurity program structure and processes — policies, procedures, risk assessments, monitoring, framework adoption, and mitigation strategies. While it names the ISO, CIO, and IT Steering Committee, these are incidental attributions; the dominant content is about what the program and committee do (the function), not about the people's credentials or backgrounds. Applying the person-vs-function test, removing the role titles leaves a complete process description. Multiple IS-list facts (cybersecurity-specific roles ISO and CIO, named non-generic IT Steering Committee) establish Firm-Specific, but no two QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes the IS Program, led by ISO under CIO, overseen by IT Steering Committee. The IT Steering Committee's responsibilities are described in detail - approving IT strategic plan, monitoring vendors, cybersecurity threats, risk assessments, making recommendations to the Board.

Category: This is primarily about Risk Management Process. The paragraph describes the company's internal cybersecurity program structure and processes. While it mentions the ISO, CIO, and IT Steering Committee, the bulk of the content is about what the program and committee DO (processes, monitoring, risk assessments, frameworks). The person-vs-function test: removing the role titles, the paragraph still describes processes.

The IT Steering Committee functions as a management body focused on executing processes—identifying risks, approving strategies, and monitoring threats—rather than being defined by the individuals who serve on it. The specific roles like ISO and CIO are cybersecurity-focused titles that belong in the IS list, and the IT Steering Committee itself is a named committee within the IS governance structure.

Looking at the verifiability question, I don't have concrete facts like dates, financial figures, or third-party vendor names that would satisfy the QV threshold. But I do have multiple IS-list items here—the ISO role, the CIO role, and the IT Steering Committee—which makes this firm-specific content.

fact: Information Security Officer (ISO)

fact: Chief Information Officer (CIO)

fact: IT Steering Committee

fact: Information Security (IS) Program — named with abbreviation


reasoning: The paragraph describes the company's own internal risk assessment processes—assessing risks of unauthorized access, evaluating security controls, and using frameworks to monitor and minimize risk—which are core Risk Management Process activities. It names the FFIEC as a recognized regulatory framework, triggering Sector-Adapted, but contains no firm-specific facts (no named roles, dates, tools, or quantified details).

thinking:
Classify this paragraph.

Content: Describes risk assessment processes, frameworks (FFIEC mentioned by name), monitoring, strategy development for information security. This is about internal processes.

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

Specificity: FFIEC (Federal Financial Institutions Examinations Council) is a named recognized standard/framework → Sector-Adapted. No firm-specific facts beyond that. "IS Program" is a generic program name. No specific roles, dates, numbers, tools.

Wait - "IS Program" could be a named internal program. But it's just "Information Security Program" abbreviated - that's generic.

The presence of FFIEC as a named framework confirms this is Sector-Adapted rather than generic.

fact: Federal Financial Institutions Examinations Council (FFIEC)


reasoning: The paragraph contains a cross-reference to Risk Factors followed by an explicit materiality assessment ('have not identified any breaches... that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition'). Per Rule 6, the materiality conclusion makes this Strategy Integration despite the cross-reference. No specific facts beyond boilerplate materiality language.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. A cross-reference to Risk Factors
2. A materiality assessment ("To date we have not identified any breaches... that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition")

Per Rule 6 and the codebook: "Any paragraph that explicitly assesses whether cybersecurity risks or incidents have 'materially affected'... the company's business strategy, results of operations, or financial condition is Strategy Integration — even when the assessment is boilerplate. The materiality assessment is the substantive content. A cross-reference to Risk Factors appended to a materiality assessment does not change the classification to None/Other."

The materiality language here is standard boilerplate with no specific incidents, dates, or amounts mentioned. The cross-references point to the company's own section headers rather than concrete cybersecurity facts, making this Generic Boilerplate.


reasoning: The paragraph makes an explicit materiality assessment — concluding that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition. Per Rule 6, any materiality disclaimer is Strategy Integration. The language is boilerplate with no named entities, dates, or firm-specific details.

thinking: Materiality assessment paragraph.


reasoning: While the paragraph opens with board reporting (Board Governance), the dominant content identifies the specific management roles comprising the cybersecurity management team, their collective responsibility for the cyber risk program, and their background at similarly sized biotech firms — making Management Role the primary communicative purpose. The explicit enumeration of five specific roles (CFO, General Counsel, VP of Finance, VP of Quality, IT Senior Director) constitutes a firm-specific team composition, but none of these are cybersecurity-specific titles from the IS list individually; the composition as a named team is the firm-specific fact. No QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Committee reports to the board (Board Governance)
2. Board receives briefings from management (Board Governance)
3. Board receives presentations from CFO, internal security staff, external experts (Board Governance)
4. Management team members listed (CFO, General Counsel, VP of Finance, VP of Quality, IT Senior Director) responsible for assessing/managing cyber risks (Management Role)
5. This cybersecurity management team oversees the program and supervises internal/external cybersecurity personnel (Management Role / Risk Management Process)
6. Team includes individuals with experience at similarly sized biotech organizations (Management Role)

7. Now I'm checking which of these roles appear on the IS list to determine if they're considered information security personnel or just general management positions. The specific naming of those roles—Legal, Compliance, and Finance—as the cybersecurity management team composition matches the IS list's criterion for specific team/department compositions, so this is Firm-Specific. There aren't enough hard verifiable facts like dates, amounts, or named entities to qualify for QV, so the classification is Firm-Specific (3).

fact: Management team composition: CFO, General Counsel, Vice President of Finance, Vice President of Quality, and IT Senior Director


reasoning: The audit committee is the grammatical subject receiving reports and accessing cybersecurity information, making this Board Governance. 'Audit committee' is generic governance, 'IT Lead' is a general IT title (not a cybersecurity-specific role like CISO/CIO/CTO), and 'periodic' is a vague cadence — all on the NOT list, leaving no specific facts.

thinking:
Classify this paragraph.

The paragraph is about the audit committee receiving reports and having access to cybersecurity information. The audit committee is the grammatical subject → Board Governance.

Specific facts check:
- "audit committee" — generic, on the NOT list
- "IT Lead" — this is a generic IT title, not a cybersecurity-specific title like CISO/CIO/CTO
- "periodic reports" — generic cadence
- No named frameworks, dates, tools, firms, numbers

All items are on the NOT list. No IS-list facts remain. No named standards either.

→ Board Governance, Generic Boilerplate


content_category: None/Other

reasoning: This is a SPAC with no business operations that explicitly states it has no cybersecurity risk management program or formal processes. Per the codebook's SPAC/no-operations rule, the perfunctory board mention ('generally responsible... if any') and absence-of-incident statement do not constitute substantive cybersecurity disclosure.

thinking: SPAC/no-operations company. Classic None/Other per the codebook.


reasoning: The paragraph describes the Adviser's internal cybersecurity processes: security technologies, penetration testing, vulnerability management, and third-party assessments. Third-party mentions are components of the internal program, not the central topic, so this is Risk Management Process. The 'ISWG' is a named internal group with a distinguishing abbreviation, making it a firm-specific fact, but there are no QV-eligible hard facts (no dates, dollar amounts, named firms/tools, or headcounts).

thinking:
Let me analyze this paragraph.

Content: Describes the Adviser's cybersecurity approach - risk-based, policies/procedures, security technologies (firewalls, anti-virus, passwords, restricted access, surveillance), penetration testing, third-party vulnerability management, third-party consultant for annual assessment, ISWG meets quarterly.

Category: This is about internal cybersecurity processes - Risk Management Process. The third-party mentions are components of the internal program, not central topic.

Specificity: Let me check for specific facts:
- "ISWG" - this is a named internal program/committee with a unique identifier. This qualifies as a specific fact (named committee or named internal program with unique identifier).

- The other elements like firewalls, anti-virus, and penetration testing are standard industry practices, not firm-specific. "Quarterly" is just a generic cadence, and the third-party consultant isn't named, so those don't count as specific facts either.

ISWG stands out as the only firm-specific detail here - it's a named internal committee with its own abbreviation. That gives us one specific fact, making this Firm-Specific. There aren't any QV-eligible facts since there are no specific dates, dollar amounts, headcounts, named third-party firms, named products, or certifications mentioned.

fact: ISWG (named internal group with unique identifier)


reasoning: The board of directors is the grammatical subject overseeing cybersecurity risks, making this Board Governance. The paragraph contains only generic governance language — 'board of directors,' 'its committees,' 'periodic review' — all of which appear on the NOT list, with no named frameworks, specific roles, or firm-specific details.

thinking:
Classify this paragraph.

Content: Board oversight of IT/cybersecurity risks. Board is the grammatical subject. → Board Governance

Specific facts check:
- "board of directors" — generic, on the NOT list
- "its committees" — generic
- "periodic review" — generic cadence
- No named frameworks, no specific roles, no dates, no numbers

→ Generic Boilerplate


reasoning: The paragraph describes what management does to run the cybersecurity program — risk assessment, engaging third parties, evaluating risk profiles, updating controls, integrating into ERM, reviewing assessments. Although CEO, President, and CFO are mentioned, these are generic C-suite titles (NOT list) and the paragraph is about the function (processes and activities) rather than the person (no credentials, background, or cybersecurity-specific roles). No named frameworks, tools, firms, dates, or specific numbers appear, so specificity remains Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes management's role in cybersecurity - CEO, President, CFO discussing cybersecurity, CFO responsible for engaging third parties, management integrating cyber into risk management strategy.

Category: This is about management's responsibilities. But let me apply the person-vs-function test. The paragraph mentions CEO, President, CFO - these are generic C-suite titles (on the NOT list). The paragraph describes what management does - processes, engaging third parties, integrating into risk management, reviewing assessments. This is more about the function than the person. No credentials, no background, no named individuals.

Actually, the paragraph describes management's responsibilities in running the cybersecurity program.

The generic C-suite roles like CEO, President, and CFO don't add specificity here - they're on the exclusion list anyway. What's really being described are the processes themselves: risk assessment, third-party engagement, control updates, and integration into enterprise risk management. The focus is on the activities and workflows, not the individuals performing them. With no named frameworks, specific dates, or concrete details, this reads as generic boilerplate about how companies typically handle cybersecurity risk management.


reasoning: This paragraph describes a generic risk scenario (IP theft from unauthorized access) that could apply to any company. It contains no substantive cybersecurity disclosure — no process description, no incident narrative, no governance structure, no materiality assessment. It is generic risk language, not a cybersecurity program disclosure.

thinking:
Classifying this paragraph from OSS's 10-K Item 1C.

This describes a generic risk - IP theft from unauthorized access. No specific processes, no frameworks, no dates, no firm-specific details. It's generic risk language that could apply to any company.

This isn't describing a process, incident, board oversight, or materiality assessment. It's just generic risk language about what could happen. None/Other.


reasoning: The paragraph describes the company's internal process for assessing cybersecurity threats using a multidisciplinary team and industry tools, which is core risk management activity. No named frameworks, specific roles (CISO/CIO/CTO), named tools, dates, or other firm-specific facts are present — 'IT function,' 'senior management,' 'third-party service providers,' and 'industry tools and metrics' are all generic and appear on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes collecting/storing data, mentions importance to operations, mentions a multidisciplinary team for assessing cybersecurity threats, mentions industry tools and metrics.

Category: This is about the company's internal risk assessment processes. The multidisciplinary team assesses cybersecurity threats. This is Risk Management Process.

Specificity: Let me check for specific facts:
- "multidisciplinary team (including from our IT function, senior management, and third-party service providers)" - generic team composition, no specific departments beyond generic ones
- "industry tools and metrics" - unnamed
- No named frameworks, no specific roles, no dates, no numbers

- The language is vague and lacks concrete details, so this falls into generic boilerplate territory.


reasoning: The paragraph describes the company's internal cybersecurity processes — risk assessment, incident response planning, and remediation strategies — making it Risk Management Process. The named internal program 'SIRP' with its unique abbreviation qualifies as a firm-specific fact per the IS list, but there are no hard verifiable facts (dates, amounts, named firms/tools) to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the company's security incident response plan (SIRP) and risk management approach. This is about internal processes.

Category: Risk Management Process - describes risk assessment, incident response planning, and remediation strategies. The CISO/management isn't the subject; the company's processes are.

Specificity: Let me check for specific facts.
- "security incident response plan ("SIRP")" - This is a named internal program with a unique identifier/abbreviation. Per the IS list: "Named internal programs with unique identifiers: 'Cyber Incident Response Plan (CIRP)'" - SIRP qualifies.

- There are no named frameworks, dates, dollar amounts, named firms, or named roles, so I'm looking at just one IS fact here. That makes this Firm-Specific.

For the QV check: without hard verifiable facts like dates, amounts, headcounts, named firms, tools, or certifications, this doesn't qualify as QV.

fact: security incident response plan ("SIRP") — named internal program with unique abbreviation


reasoning: The paragraph describes the company's own internal cybersecurity processes—monitoring, audits, vulnerability assessments, penetration testing, and engaging external consultants—which are all standard Risk Management Process content. No named frameworks, tools, firms, roles, dates, or quantified facts are present; all items are common practices or unnamed entities on the NOT list.

thinking:
Classify this paragraph.

Content: Describes internal cybersecurity processes - monitoring, audits, vulnerability assessments, penetration testing, and engaging external auditors/consultants.

Category: Risk Management Process - describes the company's own internal processes and tools.

Specificity: No named frameworks, no named roles, no named tools, no dates, no numbers. "External auditors and consultants" are unnamed. All practices mentioned (monitoring, audits, vulnerability assessments, penetration testing) are common practices on the NOT list. → Generic Boilerplate.


reasoning: The paragraph establishes a management committee and identifies its leadership composition (SVP IT, CFO, CLO), making organizational structure the primary content. While the second sentence describes what the committee monitors, this is subordinate to the committee identification. The SVP of IT is a cybersecurity-adjacent specific role and the 'information technology management committee' is a named non-generic committee, yielding Firm-Specific; however, no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

The paragraph describes an information technology management committee, its composition (SVP IT, CFO, CLO), and what they do (monitor prevention, mitigation, detection, remediation of cybersecurity incidents through management of risk processes).

Category: This is about a management committee responsible for cybersecurity. The grammatical subject is the committee and its members. It describes who is on the committee and what they oversee. This is Management Role - it's about the organizational structure of who manages cybersecurity.

Wait - let me reconsider. The person-vs-function test: is this about the people or about the function? The paragraph names a committee and its composition, then describes what they monitor.

The key here is that the second sentence focuses on their oversight activities—monitoring prevention, mitigation, detection, and remediation through established processes. But the real substance is identifying the committee's membership and their domain of responsibility. This clearly falls under Management Role since it's establishing the organizational hierarchy and who's accountable for cybersecurity governance.

Looking at specificity, the committee itself appears company-specific rather than generic, and the roles listed—SVP of IT, CFO, CLO—are fairly standard C-suite positions that would appear on similar governance structures. The SVP of IT especially aligns with the VP of IT/Security role mentioned in comparable frameworks.

Since there are no dates, dollar amounts, headcounts, or named third-party vendors, this doesn't qualify as QV. The firm-specific nature of the committee composition and named roles puts this in the Firm-Specific category.

fact: SVP, Information Technology


reasoning: The paragraph describes the company's internal cybersecurity processes — threat monitoring, vulnerability assessments, and security controls — making it Risk Management Process. The specific departmental composition ('IT, legal, and finance departments') is a firm-specific fact per the IS list, but no QV-eligible hard facts (dates, amounts, named firms/tools) are present, so it remains Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes IT, legal, and finance departments working with information security function to identify/assess/manage cybersecurity threats. Then describes methods: automated tools, audits, intelligence feeds, threat assessments, vulnerability assessments, scans, law enforcement coordination. Then describes measures: incident detection, encryption, network security, access controls, monitoring, training, DR/BC, risk assessments, security standards, cyber insurance, physical security.

Category: This is clearly Risk Management Process - describes the company's internal cybersecurity processes and methodologies.

The mention of "IT, legal, and finance departments" - this is a specific team composition per the IS list.

The specific team composition is firm-specific, but there are no other quantifiable facts here like dates, amounts, headcounts, named tools, or frameworks that would qualify for QV eligibility.

fact: IT, legal, and finance departments work with the information security function


reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity risks, describing vendor types and review practices imposed on them. No named standards, specific roles, dates, or other IS-list facts are present—generic vendor categories and review activities could apply to any company.

thinking:
Classify this paragraph.

The paragraph discusses third-party service providers and how the company manages cybersecurity risks associated with them. The central topic is oversight of external parties' cybersecurity.

Content category: Third-Party Risk - vendor oversight is the central topic, describing types of vendors and how the company manages their cyber risk.

Specificity: Let me check for specific facts.
- No named frameworks, no named roles, no named firms, no dates, no numbers
- "application providers, hosting companies, contract research organizations, contract manufacturing organizations, and supply chain resources" - these are types of vendors, not specific facts
- "reviewing their security assessments, reviewing their written security program, and applicable reports" - generic practices

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


reasoning: The paragraph's primary subject is the ARCom (a board committee) and its oversight of cybersecurity risks, meeting cadence, and receipt of CISO briefings — classic Board Governance. The named non-generic committee (ARCom, distinct from a standard Audit Committee) and the CISO role are both IS-list facts, yielding Firm-Specific. However, neither qualifies as a QV-eligible hard fact (no dates, dollar amounts, headcounts, named firms, or named tools), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: The paragraph describes the Audit and Risk Committee (ARCom) oversight of cybersecurity risks, its meeting cadence, CISO presentations to the committee, and Board discussions. The primary actor is the ARCom/Board - this is about board-level governance oversight.

Category: Board Governance - the ARCom and Board are the primary subjects performing oversight actions.

Specificity analysis:
- "Audit and Risk Committee ('ARCom')" - this is a named non-generic committee (not just "Audit Committee") → IS fact
- "CISO" / "chief information security officer" → IS fact (cybersecurity-specific title)

- "quarterly" meetings - generic cadence, not a hard verifiable fact

Since neither the committee name nor the CISO role qualifies as a quantifiable fact—no specific dates, dollar amounts, headcounts, third-party firms, products, or certifications are mentioned—this falls into the Firm-Specific category.

fact: Audit and Risk Committee ('ARCom') — named non-generic committee

fact: Chief Information Security Officer (CISO) presents to ARCom


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any cybersecurity threats that have materially affected or are likely to affect us, including our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration. The cross-reference to Risk Factors does not change the classification. No specific facts from the IS list are present — all language is boilerplate.


reasoning: The Board of Directors is the grammatical subject overseeing cybersecurity risk and receiving updates from management. No specific facts from the IS list are present — 'Board of Directors,' 'subcommittee level,' 'management,' and 'regular updates' all appear on the NOT list as generic governance language.

thinking:
Classify this paragraph.

Content: Board of Directors oversees cybersecurity risk, receives regular updates from management on risks, prioritization, and incidents.

Category: Board Governance - the Board is the grammatical subject performing oversight.

Specificity: Let me check for specific facts.
- "Board of Directors" - generic governance, NOT list
- "subcommittee level" - generic, no named committee
- "management" - generic
- "regular updates" - generic cadence

No named frameworks, no specific facts from the IS list. → Generic Boilerplate (1)


reasoning: The paragraph describes the company's intent to maintain and improve its cybersecurity program, making Risk Management Process the dominant category. The hypothetical adverse impact language ('could have a materially adverse impact') is generic risk language, not an explicit materiality assessment. No named frameworks, roles, dates, or firm-specific details are present — entirely boilerplate.

thinking:
Classify this paragraph.

This is generic language about cybersecurity risks and maintaining a program. Let me check for category and specificity.

Category: This mentions potential material adverse impact but it's not really a materiality assessment - it's saying incidents "could have" a materially adverse impact, which is generic risk language. It doesn't make a firm conclusion about whether risks have or haven't materially affected the company. It's more of a general statement about maintaining a cybersecurity program.

Actually, looking more carefully: "the impact of certain cybersecurity incidents could have a materially adverse impact" - this is hypothetical risk language, not a materiality assessment. A materiality assessment would say "have not materially affected" or "are not reasonably likely to materially affect." This is just saying bad things could happen.

The language about maintaining a "robust and continuously improving cybersecurity program" is Risk Management Process framing, but it's extremely vague with no actual process details described. This feels borderline between Risk Management Process at the lowest specificity level and None/Other, since it references the company's program without explaining what that program actually entails.

Rule 5 is the deciding factor here—the paragraph does contain substantive disclosure about maintaining a cybersecurity program, even if it's generic boilerplate. So I'm categorizing this as Risk Management Process, Specificity 1. There are no named frameworks, no specific facts, nothing that distinguishes this from standard corporate language.


reasoning: The entire paragraph describes the Senior Director of IT's qualifications, career history, and expertise — squarely about the person, not the function. Two QV-eligible hard facts: a specific duration of experience ('five years') and a specific date ('since 2004').

thinking:
Let me analyze this paragraph.

Content: Describes the Senior Director of IT's background, expertise, experience, and qualifications. This is about the person - their credentials, career history, and experience.

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

Specific facts:
- "Senior Director of IT" - this is a cybersecurity-adjacent IT leadership role... Let me check the IS list. "Director of IT Security" is listed, but "Senior Director of IT" is more general IT. Actually, looking at the IS NOT list: "Director of IT" is listed as NOT specific. "Senior Director of IT" would fall under generic IT leadership. Hmm, but the context makes clear this person is responsible for cybersecurity. Let me re-read...

- "Senior Director of IT" maps to "Director of IT" on the NOT list, so the title alone doesn't qualify as Firm-Specific.
- But there are other details: "five years" gives me a specific duration, and "ISO 27001" is a named framework they implemented.
- "since 2004" is another specific date, and "SOX IT compliance" rounds out the experience description.

Looking at what counts as Quantified-Verifiable: "five years" is years of experience stated as a number, which the codebook explicitly flags as QV-eligible. "since 2004" is also a specific date, so that's QV-eligible too. Two QV-eligible facts means this qualifies as Quantified-Verifiable.

The overall category is Management Role with high confidence, since the entire passage centers on their professional background and responsibilities.

fact: five years of ISO 27001 implementation experience

fact: since 2004 SOX IT compliance experience


reasoning: The Committee (board-level) is the grammatical subject receiving briefings and presentations on cybersecurity — classic board oversight activity. No IS-list facts are present: 'Chief Financial Officer' is generic C-suite (NOT list), 'external experts' are unnamed (NOT list), 'finance department' alone is not a distinctive team composition, and 'the Committee' is generic governance language.

thinking:
Let me analyze this paragraph.

The paragraph describes the Audit Committee receiving briefings from management and presentations on cybersecurity from the finance department, CFO, and external experts as board continuing education.

Category: The grammatical subject is "The Committee" - receiving briefings, receiving presentations. This is about board/committee oversight. → Board Governance

Specificity: Let me check facts:
- "The Committee" - generic (Audit Committee implied from context)
- "management" - generic
- "finance department" - not cybersecurity-specific
- "Chief Financial Officer" - generic C-suite, on the NOT list

- "external experts" - unnamed, on the NOT list

No named standards or specific facts from the IS list. The finance department alone doesn't constitute the specific team composition mentioned in the codebook, and the CFO is explicitly generic C-suite, so this doesn't meet the threshold for specificity.

There aren't any cybersecurity-specific roles mentioned either, which pushes this toward generic boilerplate.


reasoning: The paragraph primarily describes the reporting cadence and content delivered to the Audit Committee (incidents, vulnerability testing results, policy developments), making the board/committee the primary recipient and oversight actor. The trailing sentence about the President and CFO managing cybersecurity risk is a brief management attribution but is subordinate to the board reporting structure. No facts from the IS list are present: 'Audit Committee' is generic governance, 'President and Chief Financial Officer' are generic C-suite titles (NOT list), and 'quarterly' is a generic cadence.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two parts:
1. Cybersecurity incidents are reported to the Audit Committee quarterly - covers incidents, vulnerability testing, policy developments
2. Management's role - cybersecurity risk management is managed by the President and CFO

The first part is about reporting to the Audit Committee (Board Governance). The second part names specific roles managing cybersecurity risk (Management Role).

The grammatical subject shifts. First part: "cybersecurity incidents are summarized and reported to the Audit Committee" - the Audit Committee is receiving reports, so this is Board Governance. Second part: "The Company's cybersecurity risk management is managed by the President and Chief Financial Officer" - this is about management's role.

I'm weighing which aspect dominates here. The board oversight section is more detailed, but the paragraph explicitly identifies the President and CFO as the primary managers of cybersecurity risk, which suggests the management role is the main focus despite the board governance content appearing first.

Looking at the specificity: President, CFO, and Audit Committee are all generic titles and structures—nothing cybersecurity-specific or distinctive. The quarterly reporting cadence is also standard boilerplate. This points to Generic Boilerplate rather than a substantive governance statement.


reasoning: The paragraph describes the company's own internal cybersecurity processes — risk assessment, safeguards, vulnerability testing, incident simulations, and policy reviews — making it squarely Risk Management Process. Third parties are mentioned as one component of the internal program, not as the central topic. No named frameworks, no cybersecurity-specific titles, no named firms or tools, no dates or numbers — all entities are generic ('managed security service provider,' 'computer security firms,' 'governance experts'), so it remains Generic Boilerplate.

thinking:
Let me analyze this paragraph from Syros Pharmaceuticals' 10-K Item 1C filing.

The paragraph describes the company's internal cybersecurity processes - risk assessment, safeguards, response plans, vulnerability testing, incident simulations, policy reviews, and engagement of external parties. The primary topic is the company's own internal risk management processes. Third parties are mentioned as one component, not the central topic.

Content category: Risk Management Process

Specificity check:
- No named frameworks (NIST, ISO, etc.)
- No cybersecurity-specific titles (CISO, CIO, etc.)
- No named firms, tools, products

- No specific dates, dollar amounts, or headcounts
- References to "managed security service provider" and "independent privacy assessors, computer security firms" are all generic and unnamed
- The practices mentioned—vulnerability testing, incident simulations, policy reviews—are standard industry approaches described in vague terms

This is generic boilerplate language without any substantive detail or named standards.


reasoning: The paragraph describes an internal working group that implements a cybersecurity program — monitoring, prevention, detection, mitigation, remediation, and incident response. While CISO and other roles are named, they serve as attribution for who participates in the process; the substantive content is about what the program does, not about the persons' qualifications or backgrounds. Removing the role titles, the paragraph still describes a coherent process. CISO is a cybersecurity-specific title on the IS list, yielding Firm-Specific; CCO and COO are generic C-suite titles on the NOT list and do not count.

thinking:
Let me analyze this paragraph.

Content: Describes an internal working group with CCO, COO, CISO that implements a cybersecurity program. Also mentions monitoring, prevention, detection, mitigation, remediation, and reporting to the Board.

Category: The paragraph describes the internal working group and what it does - implementing a program, monitoring threats, responding to incidents. The CISO and senior management are mentioned as part of this group. The primary content is about the process/program, not about the persons' qualifications. The board reporting is a minor element at the end.

This is Risk Management Process - it describes the internal working group and program activities. The CISO is mentioned as attribution, not described in terms of qualifications.

Actually, I need to reconsider whether this is about the management roles themselves or the process they oversee. Looking at it through the person-versus-function lens: the paragraph focuses on what the group does collaboratively—implementing a cybersecurity program with specific activities like monitoring and incident response—rather than detailing the individuals' qualifications or responsibilities. Even without the role titles, the core content remains about the program and its functions. The CISO title is cybersecurity-specific and would appear on the IS list, but the CCO and COO are generic C-suite roles, and the activities described are fairly standard. This still points to Risk Management Process as the primary category.

For specificity, I'm finding only one IS-list fact: the CISO role itself. The program name and Board reference are too generic. Since CISO is a named role rather than a quantifiable metric, and there are no dates, dollar amounts, headcounts, or named tools, this doesn't qualify for QV eligibility. That leaves Firm-Specific as the classification.

fact: CISO is part of the internal working group


reasoning: This paragraph is a cross-reference to Risk Factors (Item 1A) with a quoted risk factor title. It does not make a materiality assessment ('have not materially affected') — it merely points the reader to where risks are described. The quoted risk factor title is generic boilerplate language about security compromises. No substantive cybersecurity disclosure content is present.


reasoning: The paragraph describes the company's internal cybersecurity program—policies, monitoring, phishing exercises, incident response plan, and third-party assessments—making it squarely Risk Management Process. Third parties are mentioned as components of the internal program, not as the central topic. No named frameworks, tools, firms, roles, dates, or specific numbers appear; all language is generic and interchangeable across companies.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity program - systems, processes, policies, monitoring, phishing exercises, incident response plan, third-party assessors. This is about internal processes.

Category: Risk Management Process - describes the company's own internal cybersecurity processes, tools, and methodologies. 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 specific dates
- No named tools or firms

- No specific numbers
- "simulated phishing exercises" - common practice, not specific
- "cyber incident response plan" - generic program name
- "third-party service providers", "cybersecurity assessors, consultants" - unnamed entities

This is Generic Boilerplate - could apply to any company.


reasoning: The paragraph defines the management structure for cybersecurity by identifying the CFO and Chief Information Consultant as responsible parties and enumerating their cybersecurity responsibilities (hiring consultants, approving budgets, reviewing assessments). While it lists functions, the primary communicative purpose is establishing WHO holds cybersecurity management responsibility — this is organizational role definition, not process description. 'Chief Information Consultant' is an unusual, firm-specific information/cybersecurity-adjacent title not found at every company, qualifying as a specific fact. CFO alone would be generic C-suite, but the unique 'Chief Information Consultant' title distinguishes this company's structure.

thinking:
Let me analyze this paragraph.

The paragraph describes who is responsible for cybersecurity management - the CFO and Chief Information Consultant. It describes their responsibilities (hiring consultants, integrating cyber risk, approving budgets, preparing for incidents, etc.).

Category: This is about management roles - who is responsible for cybersecurity. The CFO is the grammatical subject performing actions. However, CFO is on the NOT list as generic C-suite. But "Chief Information Consultant" is a more specific/unique title.

Wait - the person-vs-function test: Is this about the person or the function? It describes responsibilities/functions, not credentials or background.

The core focus here is defining the management structure and responsibility lines for cybersecurity oversight, which is somewhat unusual since a CISO typically handles this rather than a CFO. The paragraph establishes who's accountable and what they're responsible for managing, so this falls under Management Role. The challenge is that CFO is too generic to be useful, but "Chief Information Consultant" is specific enough to warrant inclusion. I'm settling on Firm-Specific classification since "Chief Information Consultant" is a distinctive role that reflects this particular company's organizational structure.

fact: Chief Information Consultant


reasoning: The entire paragraph describes two cybersecurity leadership persons — the Chief Operations & Technology Officer and vCISO — focusing on their experience, backgrounds, and certifications. This is squarely about who these people are (person test), not what the program does. Multiple QV-eligible hard facts: 25 years of experience, 20 years of experience, CMMC certification, and Fortinet NSE level 3 certification.

thinking:
Let me analyze this paragraph.

Content: Describes two people - Chief Operations & Technology Officer and vCISO - their responsibilities, experience, and certifications. This is about the persons, their qualifications, background, and credentials.

Category: Management Role - the paragraph is about who these people are, their experience, and certifications. The person-vs-function test: if you remove the people and their credentials, there's very little left.

Specific facts:
- Chief Operations & Technology Officer (cybersecurity-specific title? It's a tech officer role - close enough to CTO)
- vCISO (virtual CISO - cybersecurity-specific)

- Over 25 years and 20 years of relevant experience respectively, plus CMMC and Fortinet NSE level 3 certifications - all specific, verifiable credentials that qualify this as Quantified-Verifiable content.

fact: Chief Operations & Technology Officer role

fact: vCISO role

fact: Over 25 years of experience in IT and information security

fact: vCISO has 20 years of experience

fact: CMMC (Cybersecurity Maturity Model Certification)

fact: Fortinet NSE (Network Security Expert) level 3


reasoning: The paragraph's communicative purpose is describing how the board receives cybersecurity oversight information ('Board Reporting' framing), with the CIO and ISO reporting TO the board on program status and material findings. While the CIO/ISO are grammatical subjects, the dominant topic is the board's oversight mechanism — what it receives, how often, and what topics are covered. CIO and ISO are cybersecurity-specific titles on the IS list, making this Firm-Specific; the Interagency Guidelines is a named standard but the roles alone already reach Level 3.

thinking:
Let me analyze this paragraph.

Content: The paragraph describes reporting from CIO and ISO to the Board about the Information Security Program. The Board is receiving reports, but the grammatical subject is "CIO and ISO report to the Board." This is about the reporting relationship - who reports to whom and what they report on.

Category: The primary actors are the CIO and ISO reporting TO the board. But the framing is about "Board Reporting" - this is describing the board's oversight mechanism (receiving reports). The board is the recipient of oversight information. Per Rule 2: "Management role reports TO the board" → Management Role. But wait - "CISO reports quarterly to the Board on..." → Management Role per the table.

I'm torn between two interpretations here. The CIO and ISO are clearly the ones performing the reporting action, which points toward Management Role, but the section heading and overall context suggest this is really about how the board maintains oversight of the security program through regular reporting cadences and content requirements. is a named standard, so that counts as a framework reference for specificity. The CIO and ISO are both cybersecurity-specific roles from the IS list, but named roles don't contribute to the QV score. So I'm looking at one framework reference here.

Since CIO and ISO appear as specific named roles, this pushes the classification to Firm-Specific at Level 3.

fact: CIO

fact: ISO (Information Security Officer)

fact: Interagency Guidelines for Safeguarding Customer Information


reasoning: The paragraph contains an explicit materiality assessment ('no known cybersecurity threats have materially affected or are reasonably likely to materially affect us, including our business, financial condition, results of operations and growth prospects'), which per Rule 6 makes it Strategy Integration. The appended cross-reference to Risk Factors does not change the classification. No firm-specific facts, named frameworks, or verifiable details are present — standard boilerplate materiality language.

thinking:
Materiality assessment + cross-reference. Per Rule 6, the materiality assessment makes this Strategy Integration. The cross-reference doesn't change that.

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


reasoning: The paragraph opens by naming the CIO and CISO but the overwhelming bulk of the content describes what the team does — monitoring, scanning, audits, vulnerability assessments, red/blue team testing, tabletop exercises. Applying the person-vs-function test: remove the role titles and the paragraph still functions as a complete process description. The named cybersecurity-specific roles (CIO, CISO) place it at Firm-Specific, but there are no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes the CIO, VP of Information Security/CISO, and their team's activities - monitoring, evaluating threats, using tools, scanning, audits, assessments, etc.

Category: The paragraph opens by naming the CIO and CISO, but then the bulk of the content describes what the team DOES - the processes, methods, and activities. Applying the person-vs-function test: if I remove "Our CIO, our VP of Information Security/CISO," the paragraph still describes substantive cybersecurity processes. The paragraph is about the function, not the person. → Risk Management Process

Now I'm checking whether the named roles qualify as QV-eligible facts. The CIO and CISO are both on the IS list, so they're firm-specific roles but not eligible. I don't see any named frameworks, specific dates, dollar amounts, named firms, or tools mentioned - everything else is generic practices like monitoring, scanning, vulnerability assessments, and threat intelligence exercises.

So this comes down to firm-specificity: since CIO and CISO are on the IS list, the content is firm-specific, not QV.

fact: Chief Information Officer (CIO)

fact: Vice President of Information Security / CISO


reasoning: The paragraph primarily describes the company's internal process for ongoing assessment and testing of cybersecurity practices, making Risk Management Process the dominant category. The Audit Committee/BOD mention is subordinate — it describes an escalation path for findings, not board oversight as the primary topic. No named frameworks, cybersecurity-specific roles, dates, or other specific facts are present; 'Audit Committee' and 'BOD' are on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes ongoing assessment/testing of cybersecurity processes, and reporting material weaknesses to Audit Committee/BOD. The primary content is about the company's internal process for assessing and testing their cybersecurity program, with a secondary mention of reporting to the board.

Category: Risk Management Process - the paragraph describes internal assessment and testing processes. The board mention is subordinate (only about escalation of findings).

Specificity: Let me check for specific facts:
- "Audit Committee" - generic (on the NOT list)
- "BOD" - generic
- No named frameworks, no specific roles, no dates, no numbers, no named tools

- This falls into Generic Boilerplate territory since it lacks concrete details and specificity.


reasoning: The paragraph describes the company's internal cybersecurity risk management strategy, its integration into overall ERM, and framework-guided policy development — all hallmarks of Risk Management Process. It names NIST as a guiding framework but provides no firm-specific facts (no named roles, dates, tools, or headcounts), placing it at Sector-Adapted.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity risk management strategy integrated into overall risk management, based on NIST framework, guides policy development.

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

Specificity: Names NIST framework → Sector-Adapted. Any firm-specific facts? No cybersecurity-specific titles, no named committees, no dates, no numbers. The content describes using NIST but nothing unique to this company. → Sector-Adapted (2).

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


reasoning: The paragraph opens by identifying the Director of Information Technology, describing their experience (15 years) and education (Master's Degree in CS with cybersecurity concentration), establishing who is responsible for cybersecurity risk management. While a materiality assessment and cross-reference follow, the paragraph's primary communicative purpose is establishing the person responsible and their qualifications. The title 'Director of Information Technology' is generic IT leadership (NOT list), so it does not count as a firm-specific fact, but '15 years of experience' is a specific number qualifying as one hard fact → Firm-Specific. Only one QV-eligible fact (the number), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph has multiple components:
1. Director of IT role description with qualifications (15 years experience, Master's Degree in CS with cybersecurity concentration)
2. ERM integration mention
3. Materiality assessment
4. Cross-reference to Risk Factors

Let me determine the dominant category. The paragraph opens with the Director of IT's credentials and responsibility, then pivots to ERM integration, then a materiality disclaimer, then a cross-reference.

The person-vs-function test: The first sentence is about the person (Director of IT, 15 years experience, Master's Degree). But then the rest is about risk management process and strategy integration.

Looking at the structure more carefully, the opening establishes who manages cyber risk, but the bulk of the content focuses on the materiality assessment and how cybersecurity risks are evaluated within the broader risk framework. The ERM integration and materiality language dominate the paragraph's substance. I need to check whether "Director of Information Technology" qualifies as a cybersecurity-specific role for classification purposes. The NOT list includes generic IT titles like "Director of IT," but this person is explicitly described as managing cybersecurity matters, which pushes toward the IS category. Let me verify against the actual cybersecurity-specific titles on the list to make the right call. The "15 years of experience" is a specific number that counts as a hard verifiable fact, so that gives me Firm-Specific. But I need to reconsider the category—while the opening mentions the management role and qualifications, the bulk of the paragraph actually covers the risk management process and strategy, so this might be better classified as Risk Management Process rather than Management Role. The specific detail about "over 15 years of experience" is what makes this filing distinctive rather than generic boilerplate, so that's a Firm-Specific indicator.

fact: over 15 years of experience managing information technology and cybersecurity matters


reasoning: The paragraph frames cybersecurity risk governance as a partnership, but the concluding and structurally dominant point is that the Audit Committee has primary responsibility for risk oversight of both cyber and ERM programs, with quarterly updates to the Committee and recurring updates to the full Board — making Board Governance the primary communicative purpose. The CIO's credentials (30 years IT experience, 3+ years direct infosec oversight) are subordinate detail within this governance frame. Two QV-eligible hard facts (specific durations: 30 years, 3 years) push specificity to Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content: Describes governance structure involving both management and board. Mentions CIO with experience details, ERM program, Audit Committee oversight, reporting cadence.

Category analysis:
- Board Governance signals: Audit Committee oversight, quarterly updates to board
- Management Role signals: CIO named, 30 years experience, 3 years direct oversight
- Risk Management Process signals: ERM program, cross-functional team

The paragraph covers multiple categories. What's the dominant one? It starts with governance partnership, describes management roles (CIO credentials), and ends with Audit Committee oversight. The primary communicative purpose seems to be describing the overall governance structure. The CIO credentials are substantial (30 years, 3+ years direct oversight). The board/Audit Committee is the entity with "responsibility" for oversight.

Looking at how it's structured, the paragraph frames governance as a partnership between management and the board, with the CIO's qualifications and the ERM program details supporting that framework, but the Audit Committee's primary responsibility for oversight with quarterly reporting appears to be the key governance statement anchoring the whole thing.

For the specificity check: the CIO title is firm-specific, and I've got two quantified facts—30 years of IT experience and 3 years of direct oversight—that qualify for QV eligibility. That gives me three concrete facts to work with.

fact: 30 years of information technology experience

fact: over 3 years of direct oversight of information security


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected... our business strategy, results of operations, or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference. The mention of 'In 2023' is a specific date anchoring the assessment to a particular fiscal year, making it Firm-Specific rather than Generic Boilerplate.


reasoning: The Audit Committee is the grammatical subject performing oversight actions (monitoring reports, developing responses), making this Board Governance. Tuearis is a named third-party firm providing one firm-specific fact; the Audit Committee and 'corporate governance consultant' (unnamed) do not qualify as specific facts, so this reaches Firm-Specific but not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: The Audit Committee provides oversight, works with a corporate governance consultant, monitors reports from Tuearis, develops responses based on Tuearis recommendations. No internal cybersecurity expert - relies on Tuearis.

Category: The Board/Audit Committee is the grammatical subject performing oversight. This is Board Governance.

Specific facts:
- "Tuearis" - named third-party firm
- "corporate governance consultant" - unnamed, generic
- "Audit Committee" - generic per the NOT list

Wait, Tuearis is a named third-party firm. That's a specific fact.

The paragraph centers on the Audit Committee's oversight responsibilities, which falls under Board Governance. I've identified one QV-eligible fact here: Tuearis is a named third-party firm that the company relies on for cybersecurity monitoring and recommendations. Everything else—the Audit Committee itself, the unnamed corporate governance consultant—is generic, so this lands in the Firm-Specific category with just that one verifiable fact.

fact: Tuearis (named third-party cybersecurity firm providing expertise and recommendations)


reasoning: The paragraph makes an explicit materiality assessment ('no previous cybersecurity incidents which have materially affected us... business strategy, results of operations or financial condition'), which per Rule 6 is Strategy Integration. The language is entirely boilerplate with no named entities, dates, amounts, or firm-specific details.

thinking: Materiality assessment paragraph.


reasoning: The paragraph describes the company's internal processes for assessing and managing cybersecurity risks, fitting Risk Management Process. It names a specific internal program ('Cyber Risk Program') with a distinguishing identifier, which qualifies as a firm-specific fact, but contains no second hard verifiable fact to reach Quantified-Verifiable.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity risk management program. Generic language about "assessing, identifying and managing material risks" plus names an internal program "Cyber Risk Program."

Category: Risk Management Process - describes internal processes for managing cyber risk.

Specific facts:
- "Cyber Risk Program" - named internal program with a distinguishing name/abbreviation → IS list item

No named frameworks, no dates, no dollar amounts, no named firms/tools, no named roles.

One IS fact (named internal program) → Firm-Specific.

Only one hard verifiable fact, so not QV.

fact: Named internal program: 'Cyber Risk Program'


reasoning: The paragraph describes the company's internal risk management systems and processes — policies, tools, auditing, training, insurance, legal review — and how cybersecurity is integrated into them. The EVP reporting line is a minor element subordinate to the process description. The Risk Committee is a named non-generic committee (IS list), yielding one firm-specific fact, but no second QV-eligible hard fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the company's risk management systems and processes, listing components like policies, tools, auditing, training, etc. Mentions integration of cybersecurity into overall risk management. The EVP reports to Risk Committee quarterly.

Category: This is primarily about Risk Management Process - it describes the company's internal processes, tools, and methodology for managing risk including cybersecurity. The EVP reporting line is a minor element.

Specificity: Let me check for specific facts:
- "Risk Committee" - this is a named non-generic committee → IS list ✓
- "EVP" - this is a generic title, not cybersecurity-specific

- "Chief Executive Officer" - generic C-suite, NOT list
- "Cyber Risk Program" - named internal program? It doesn't have a unique identifier/abbreviation beyond the generic name
- "quarterly" - generic cadence, NOT list

So I've got at least one firm-specific fact with the Risk Committee being a named non-generic committee. The EVP title itself is generic, but the reporting relationship to the Risk Committee is what makes this firm-specific. No quantifiable facts like dates, dollar amounts, or headcounts appear here, so this falls into the Firm-Specific category based on the Risk Committee reference alone.

fact: Risk Committee


reasoning: The paragraph describes the company's own internal security processes (physical, administrative, technical layers) designed to protect systems and data — squarely Risk Management Process. No named frameworks, roles, tools, dates, or any fact from the IS list; entirely generic language that could apply to any company.

thinking:
Classify this paragraph.

Content: Describes the company's security processes - physical, administrative, technical - to protect facilities and data. This is about internal processes.

Category: Risk Management Process - describes the company's own internal security processes.

Specificity: No named frameworks, no specific facts from the IS list. Generic language throughout - "multiple layers," "physical, administrative, and technical security processes." No CISO, no named tools, no dates, no numbers.

→ Generic Boilerplate


reasoning: The paragraph's primary communicative purpose is assessing the business impact of cybersecurity risks and past incidents. The first sentence provides a brief materiality-like conclusion about past outages ('do not believe impacted the integrity of our data'), and the remainder incorporates by reference the full materiality assessment from Item 1A ('have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition'). While the materiality language is wrapped in a cross-reference, the paragraph does make a substantive claim about past incidents' impact and incorporates the formal assessment by reference — satisfying Rule 6. The specific date 'December 31, 2023' is one IS-list fact, yielding Firm-Specific; no second QV-eligible hard fact is present to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three parts:
1. "As of December 31, 2023, we have experienced a few outages which we do not believe impacted the integrity of our data." - Brief incident mention with a materiality-like assessment.
2. "While we continue to make investments to improve the protection of data and information technology, there can be no assurance..." - Generic forward-looking disclaimer.
3. "We describe whether and how risks from identified cybersecurity threats, including as a result of any previous cybersecurity incidents, have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition, under the heading 'Risks Related to Data Privacy and Cybersecurity' included as part of our risk factor disclosures at Item 1A..." - This is a cross-reference that contains materiality language, but it's saying "we describe [materiality assessment] at Item 1A" - it's pointing elsewhere for the actual assessment.

The tricky part is that while materiality language appears throughout, the third section is really just directing readers to Item 1A for the substantive assessment. The only actual materiality conclusion being made here is in the first sentence about past incidents not impacting data integrity. So I need to figure out whether this counts as a Strategy Integration disclosure under Rule 6 — the codebook says any paragraph explicitly assessing whether cybersecurity risks or incidents have "materially affected" qualifies, but this one is mostly a cross-reference to where that assessment happens elsewhere. the materiality assessment is actually embedded in the cross-reference itself — they're saying the full discussion happens at Item 1A. So this reads as Strategy Integration, where the paragraph's main point is communicating the materiality impact of past incidents. For specificity, the only QV-eligible fact here is the December 31, 2023 date, which makes this Firm-Specific.

fact: As of December 31, 2023


reasoning: The Committee is the grammatical subject receiving reports from management on cybersecurity risks, making this board/committee oversight. All details are generic: 'the Committee,' 'periodic reports,' 'management,' and the bulleted topics are standard presentation items with no named frameworks, roles, dates, or firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: Describes what "the Committee" receives from management - periodic reports, updates on incidents, presentations covering various topics.

Category: The Committee (likely Audit Committee) is receiving reports - this is about board/committee oversight. The grammatical subject is "The Committee" receiving reports. → Board Governance

Specificity: Let me check the facts:
- "The Committee" - generic governance term (NOT list)
- "periodic reports" - generic cadence (NOT list)
- "management" - generic (NOT list)
- Topics listed are all generic (cybersecurity landscape, emerging threats, projects, incident reports, lessons learned, regulatory requirements)

- No named frameworks or specific facts from the IS list, so this is generic boilerplate language.


reasoning: The paragraph describes cybersecurity and IT leaders' work experience and professional certifications — this is about the people and their qualifications, making it Management Role. Three named certifications (CISSP, CISM, GIAC) held by company leaders are QV-eligible hard verifiable facts, meeting the two-or-more threshold for Quantified-Verifiable.

thinking:
Classify this paragraph.

Content: Describes cybersecurity/IT leaders' experience and certifications. This is about the people - their qualifications and credentials. Management Role.

Specific facts:
- CISSP certification (named certification)
- CISM certification (named certification)
- GIAC certification (named certification)

No specific named role like CISO - just "cybersecurity and IT leaders" which is generic. But the certifications are named.

QV check: CISSP, CISM, GIAC are named certifications - these count as QV-eligible facts. Three named certifications = multiple QV facts → Quantified-Verifiable.

The certifications are held by unnamed leaders, but that doesn't change the fact that I'm seeing three specific named certifications mentioned - CISSP, CISM, and GIAC - which gives me enough QV-eligible facts to classify this as Quantified-Verifiable.

fact: CISSP certification held by leaders

fact: CISM certification held by leaders

fact: GIAC certification held by leaders


reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity risks, including assessing their adherence to standards and requiring evaluations — all hallmarks of Third-Party Risk. No named frameworks, specific roles, dates, or firm-specific facts are present; 'TMCC' is a company self-reference and does not qualify.

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

Specificity: No named frameworks, no firm-specific facts beyond "TMCC" (company self-reference). Generic language about third-party oversight.


reasoning: The grammatical subjects are the CSO/CISO and the Global Security Steering Committee — management-level actors who stay informed and communicate upward. The Board/Audit Committee are recipients of reports, not the primary actors. The paragraph describes management's information flow and reporting structure rather than board oversight activities. Contains cybersecurity-specific roles (CSO, CISO) and a named non-generic committee (Global Security Steering Committee), but no QV-eligible hard facts (no dates, dollar amounts, named firms, or tools).

thinking:
Let me analyze this paragraph.

Content: Describes CSO and CISO staying informed, communicating to Global Security Steering Committee, which reports quarterly to Board/Audit Committee.

Category: The primary actors are CSO/CISO and the Global Security Steering Committee. The paragraph describes how information flows from management up to the board. The grammatical subjects are "CSO and CISO" and "Updates" and "Global Security Steering Committee." The main content is about reporting structure and information flow. The CISO/CSO are the starting point, and the flow goes up to the board. This is more about management's role and reporting lines than about board oversight. But it's also about governance flow.

I'm seeing two distinct parts here: management staying informed on risks, and then that information flowing up through the committee to the board. The grammatical subjects are the CSO/CISO and the committee itself, not the board, so this is really about how management operates and communicates upward rather than board-level governance. I'll categorize this as Management Role.

Now checking specificity: CISO is a recognized cybersecurity title, and "Global Security Steering Committee" is a named committee specific to this firm. The cadence and KPIs are generic. Since I have CISO plus a named committee, that's two firm-specific elements. There are no hard verifiable facts like dates, amounts, or named external tools, so this doesn't qualify as QV-eligible. The classification is Firm-Specific based on those two identifiers.

fact: CSO (Chief Security Officer)

fact: CISO

fact: Global Security Steering Committee


reasoning: The paragraph describes the company's internal cybersecurity risk management processes — prevention, detection, mitigation, threat intelligence, security tools, and incident planning. Although 'management team' is the grammatical subject, the person-vs-function test shows the content is entirely about what the program does, not who the people are; 'management team' is generic attribution. No named frameworks, roles, tools, firms, dates, or quantified facts appear — all entities are unnamed ('external consultants,' 'security tools,' 'governmental, public or private sources'), making this Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Management team supervises cybersecurity risk management. Describes various means including briefings from external consultants, threat intelligence, security tools. Also mentions tools and activities for prevention, detection, analysis.

Category: The paragraph describes what the management team does regarding cybersecurity risk management processes. The management team is the grammatical subject, but the content is about processes/activities, not about who the people are. Applying the person-vs-function test: remove "Our management team supervises" and the paragraph still describes cybersecurity risk management activities. This is Risk Management Process.

Wait - "management team" is generic (not CISO/CIO/CTO).

So it's describing internal processes without any specific roles or named entities. Looking at the details: "management team" and "external consultants" are both unnamed, "security tools" and "threat intelligence" are generic references with no frameworks or dates mentioned. This reads like generic boilerplate.


reasoning: The paragraph describes the company's cybersecurity program engaging external experts to evaluate its own cybersecurity measures and risk management processes. Per Rule 3, external assessors hired to test/evaluate the company are Risk Management Process, not Third-Party Risk. No named frameworks, no cybersecurity-specific roles, and references to 'the Adviser and the Investcorp Group' are company self-references on the NOT list; 'external experts, consultants, auditors' are unnamed entities — resulting in Generic Boilerplate.

thinking:
Classify this paragraph.

The paragraph describes reliance on the Adviser and Investcorp Group to engage external experts for evaluating cybersecurity measures. This is about third-party engagement as part of risk management. The central topic is the use of external parties to evaluate cybersecurity - but is this Third-Party Risk or Risk Management Process?

Per Rule 3: "External assessor hired to test the company" → Risk Management Process. The external experts here serve the company's evaluation needs. This is about the company's own risk management process that happens to use external parties.

Specificity: No named frameworks, no firm-specific facts from the IS list. "the Adviser and the Investcorp Group" - these are company self-references (the company's own adviser/parent group), which fall under "Company self-references" on the NOT list.

The external experts and assessors mentioned are generic, unnamed entities without specific identities or details - this falls squarely into Generic Boilerplate.


reasoning: The paragraph's primary communicative purpose is identifying who holds cybersecurity oversight responsibility — the Board, Audit Committee, and senior management — making the board/committee the dominant subject. The ERM integration mention is subordinate. No IS-list facts are present: 'Board,' 'Audit Committee,' and 'senior management' are all on the NOT list, and 'the Company's IT subsidiary' is unnamed and generic.

thinking:
Let me analyze this paragraph.

Content: Describes shared oversight between Board, Audit Committee, and senior management, plus mentions ERM integration and IT subsidiary involvement.

Category: This spans Board Governance and Risk Management Process. The paragraph's primary purpose is describing the governance/oversight structure - who is responsible. The Board and Audit Committee are mentioned as having "primary cybersecurity oversight responsibility." But it also mentions ERM integration. The dominant topic is the oversight structure - Board Governance.

Wait, actually the grammatical subjects are mixed. "Primary cybersecurity oversight responsibility is shared by the Board, the audit committee... and senior management." This is about the oversight structure broadly.

The Board is definitely the central actor here, so I'm categorizing this as Board Governance. The oversight structure involving the Board and Audit Committee is the main frame, even though management and the IT subsidiary are mentioned. Looking at the specificity - the Board and Audit Committee are generic references, senior management is generic, and while the IT subsidiary is mentioned, it's not named specifically. There's no reference to particular frameworks or roles like a CISO, so this doesn't hit the IS threshold.

The facts stay generic without any named standards, which confirms this is just standard boilerplate language.


reasoning: The paragraph describes two management-level committees (ISPEC and ECC), their composition, leadership, and responsibilities for cybersecurity oversight. The grammatical subjects are management committees and the CIO, not the board. The content is about who these committees are, how they are structured, and who leads them — fitting Management Role's coverage of management committees responsible for cybersecurity. Multiple IS-list facts (CIO, named committees ISPEC/ECC, specific team compositions) establish Firm-Specific, but no two QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes two internal committees - ISPEC and ECC - their roles, meeting cadence, and leadership. The ISPEC provides oversight of cybersecurity programs, meets quarterly, co-chaired by CIO and other roles. The ECC oversees IT and Cyber risk areas. The CIO is a key risk owner.

Category: This is about management committees and their oversight structure. The grammatical subjects are ISPEC and ECC (management committees), not the board. This describes management-level governance structures, roles, and reporting. The person-vs-function test: this is about organizational structure and who leads what committees - it's about roles and committee composition, not about processes/tools/frameworks.

Now I'm identifying the specific governance elements - ISPEC and ECC are named committees with defined leadership including the CIO, General Counsel, Chief Privacy Officer, and other executive roles overseeing cybersecurity and data privacy programs. I'm realizing this is fundamentally about management structure and governance—the committees themselves and their oversight responsibilities—which falls squarely under Management Role rather than Risk Management Process.

fact: ISPEC (named internal committee with unique identifier)

fact: CIO co-chairs ISPEC

fact: ECC (named internal committee)

fact: Co-chaired by CIO and Assistant General Counsel, Legal, Chief Privacy Officer and Deputy Chief Compliance Officer

fact: ECC chaired by SVP General Counsel & Chief Compliance Officer and Assistant General Counsel, Legal, Chief Privacy Officer and Deputy Chief Compliance Officer