content_category: Management Role

category_confidence: high

specificity_confidence: high

reasoning: The paragraph is about the person filling the CIO role — their membership on the leadership team, when they joined, and their 24-year career background in aerospace/defense. This passes the person-vs-function test as Management Role. Two QV-eligible hard facts: specific joining year (2020) and specific years of experience (24 years).

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

The paragraph is about the CIO - their membership in leadership, responsibility, and career background (24 years in aerospace/defense, joined in 2020, prior roles).

This is about the person - their background, experience, tenure. The person-vs-function test: if you remove the person's identity and background, there's barely anything left. → Management Role.

Specific facts:
- CIO (cybersecurity-specific title per IS list)
- Joined in 2020 (specific date)
- 24 years in aerospace and defense industry (specific number of years)

QV check: specific date (2020) + 24 years of experience = two hard verifiable facts → Quantified-Verifiable

fact: CIO

fact: Joined the company in 2020

fact: 24 years in the aerospace and defense industry

type: quantified


content_category: Board Governance

reasoning: The grammatical subjects are 'The Committee' and 'the full Board of Directors,' describing their oversight activities — receiving reports, presentations, and briefings on cybersecurity. This is board/committee oversight. Vornado is a named third-party firm and CIO is a cybersecurity-specific role on the IS list, yielding Firm-Specific. Only one QV-eligible fact (Vornado as named firm), so not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph describes the Committee (Audit Committee implied from context) receiving reports, presentations from Vornado and its CIO, reporting to the Board, and the Board receiving briefings. The grammatical subjects are the Committee and the Board - this is about board/committee oversight.

Specific facts:
- "Vornado" - named third-party firm
- "Chief Information Officer" - CIO is on the IS list as a cybersecurity-specific title

Wait, let me check: "Vornado and its Chief Information Officer" - Vornado is a named firm, and CIO is a cybersecurity-specific title.

So I'm looking at whether this qualifies as Quantified-Verifiable or Firm-Specific. Vornado is a named third-party firm that manages Alexander's, which gives me one QV-eligible fact, but the CIO is a cybersecurity-specific title on the IS list without being QV-eligible itself. That means I have one IS fact and one QV-eligible fact, which isn't enough for Quantified-Verifiable status, but it does make this Firm-Specific.

fact: Vornado

fact: Chief Information Officer (CIO)


content_category: Risk Management Process

reasoning: The paragraph describes Howmet's internal cybersecurity processes — controls, vulnerability assessments, penetration testing, monitoring, vendor risk assessments, and employee education. Third-party managed security providers and vendor assessments are mentioned as components of the internal program, not as the central topic, so this is Risk Management Process rather than Third-Party Risk. It names CMMC and NIST as standards but is only 'progressing toward' CMMC certification (not holding it), and contains no firm-specific facts like named roles, tools, firms, dates, or headcounts — placing it at Sector-Adapted.

thinking:
Let me analyze this paragraph.

Content: Describes Howmet's cybersecurity risk management framework - CMMC progression, NIST compliance, preventive/detective controls, vulnerability assessments, penetration testing, third-party monitoring, vendor risk assessments, employee education.

Category: This is primarily about the company's internal cybersecurity processes. Third-party mentions (managed security providers, vendor assessments) are components of the internal program, not the central topic. → Risk Management Process

Specificity: Let me check for facts:
- "Cybersecurity Maturity Model Certification" (CMMC) - this is a named standard/framework

- "National Institute of Standards and Technology" (NIST) - named framework
- No specific dates, dollar amounts, headcounts, named firms, named tools, named roles

Decision test:
1. Two+ hard verifiable facts? No named firms, no dates, no amounts, no tools. → No
2. IS list facts? No cybersecurity-specific titles, no named committees, no specific dates, no named tools/firms/products. CMMC and NIST are frameworks/standards.
3. Named recognized standard? Yes - NIST and CMMC are both established standards. → Sector-Adapted

The company is working toward CMMC certification while implementing NIST-aligned controls, so this falls under recognized industry standards rather than proprietary facts.

fact: Cybersecurity Maturity Model Certification (CMMC)

type: framework

fact: National Institute of Standards and Technology (NIST)


reasoning: The paragraph's primary content is organizational structure: two named management committees (ISC and CORC), their specific membership composition, and their mandates. The grammatical subjects are management-level committees, and the content focuses on who comprises these bodies and their responsibilities, fitting Management Role. Multiple firm-specific facts (named committees with unique identifiers, cybersecurity-specific roles like CISO and CTO, specific departmental compositions) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes two management committees: the ISC and the CORC, their compositions, and their responsibilities.

**Content Category:**
This is about management committees and their roles. The ISC oversees the cybersecurity program and the CORC oversees the TPRM program. The grammatical subjects are the committees (ISC and CORC), not the board. These are management-level committees.

The paragraph describes who sits on these committees and what they're responsible for. It's about organizational structure at the management level. This fits Management Role - it's about the people/structure responsible for cybersecurity oversight at the management level.

I'm reconsidering whether this is really about organizational structure or if it's more about the risk management processes these committees execute. The committees oversee programs and identify/manage risks, which could point toward Risk Management Process, but the focus is clearly on who comprises these committees and their roles rather than the processes themselves. I'm checking whether CRO and CCO qualify as specific roles—CRO isn't on the exclusion list, but CCO (Chief Compliance Officer) might be considered generic C-suite. The key verifiable facts are the two named committees with distinct compositions: ISC includes CISO, CRO, and CTO, while CORC pulls from specific departments like third-party risk management and business resiliency. That gives me two hard facts for the QV assessment.

fact: Information Security Committee (ISC)

fact: CISO

fact: Chief Technology Officer (CTO)

fact: Corporate Operational Risk Committee (CORC)

fact: ISC membership: CISO, CRO, CTO, Chief Compliance Officer, and others

fact: CORC membership: leaders from third-party risk management, corporate services, compliance, sourcing, information technology, and business resiliency teams


content_category: None/Other

reasoning: This is a pure cross-reference paragraph pointing to Item 7A and Item 1A with no substantive cybersecurity disclosure content or materiality assessment.


reasoning: The paragraph's primary content is the management committee structure for cybersecurity: its composition (CIO, CISO, senior management), its charter, who chairs it, and the qualifications of key members. While committee activities are listed, they describe the committee's mandate rather than detailed internal processes or tools, making this about the management structure (Management Role) rather than Risk Management Process. Specificity is Firm-Specific due to named cybersecurity-specific roles (CISO, CIO) and a named non-generic committee (Cybersecurity Steering Committee), but no two QV-eligible hard facts are present — certifications and experience are described generically without specific names or numbers.

thinking:
Let me analyze this paragraph.

Content: Describes a cross-functional Cybersecurity Steering Committee comprised of CIO, CISO, and other senior management. Describes what the committee does (overseeing enterprise security program, reviewing risks, monitoring incidents, etc.). Notes CISO chairs it. Last sentence mentions CISO and CIO have extensive experience and certifications.

Category: This is tricky. The paragraph describes a management committee structure. The Cybersecurity Steering Committee is a named non-generic committee. The paragraph describes what this committee does and who leads it. The primary actors are management (CIO, CISO, committee), not the board. The paragraph is about the management structure for cybersecurity oversight.

The bulk of the content focuses on the committee's mandate and composition rather than specific processes or frameworks—it's really about how cybersecurity leadership is organized at the organizational level. The qualifications mentioned at the end support the credibility of those leading this structure, but the core subject is the governance arrangement itself. is the subject. It's a management committee. The paragraph tells us about its composition (CIO, CISO, senior management), its charter (overseeing enterprise security program, reviewing risks, monitoring incidents, etc.), and the qualifications of key members.

This is Management Role - it's about who manages cybersecurity and their structure/qualifications. The activities listed are the committee's mandate, not detailed process descriptions.

Specificity:
- CISO: cybersecurity-specific title ✓ IS fact
- CIO: cybersecurity-specific title ✓ IS fact
- Cybersecurity Steering Committee: named non-generic committee ✓ IS fact

QV-eligible facts: Let me check. Named roles (CISO, CIO) don't count toward QV. Named committee doesn't count toward QV. "Multiple industry-recognized certifications" - not named specifically. "Extensive experience" - no specific number. No dates, no dollar amounts, no named firms, no named tools, no specific headcounts. So I've got multiple IS facts here, which makes this Firm-Specific, but nothing that qualifies for QV reaching the threshold of 2, so it stays Firm-Specific (3).

fact: Cybersecurity Steering Committee (named non-generic committee)

fact: Chief Information Security Officer (CISO)


reasoning: The Board and Audit Committee are the grammatical subjects performing oversight of cybersecurity risk, with delegation, briefing cadence, and continuing education all framed as board-level governance activities. CIO and ISO are cybersecurity-specific titles on the IS list, elevating beyond boilerplate, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Board oversees cyber risk, delegated to Audit Committee, management updates Audit Committee, Board receives presentations from CIO and ISO.

Category: Board Governance — the Board and Audit Committee are the primary subjects performing oversight.

Specific facts:
- "at least twice per year" — generic cadence
- CIO — generic C-suite? No, CIO is on the IS list as cybersecurity-specific title
- Information Security Officer ("ISO") — cybersecurity-specific title, on IS list
- Audit Committee — generic, NOT list

So CIO and ISO are both cybersecurity-specific titles → Firm-Specific.

Now checking for quantifiable verification: CIO and ISO are named roles rather than hard facts like dates or dollar amounts, so this doesn't qualify as QV. The specificity level is Firm-Specific (3) based on those cybersecurity-specific titles.

fact: Information Security Officer (ISO)


category_confidence: medium

reasoning: The paragraph's primary subject is the CSLT — its composition (eight named functional areas), its responsibilities, and personnel qualifications. While it touches on program oversight, the dominant content is about who the team is and what makes them qualified, satisfying the Management Role person-vs-function test. The named team ('CSLT') and named program ('CSRM') with unique abbreviations are firm-specific facts, but no QV-eligible hard facts (no specific headcounts, dates, named certifications, or named firms) are present.

thinking:
Let me analyze this paragraph.

Content: Describes a cybersecurity leadership team (CSLT) with specific functional areas, their responsibility for the CSRM program, and notes about personnel certifications/experience.

Category: This is about the management team structure and what they do. The CSLT is the grammatical subject. But let me apply the person-vs-function test. The paragraph describes team composition (functional areas), responsibilities (assessing/managing risks, supervising personnel/consultants), and personnel qualifications (certifications, experience).

The paragraph names the team and its functional areas, describes what the program does. It's a mix - but the primary content is about the team structure and their role.

I'm reconsidering the classification here. The functional areas are really about team composition, and the core focus is on who the leadership team is and what they're responsible for. Even when I strip away the CSLT reference, I'm left with descriptions of processes like assessing and managing risks, but also structural elements like team composition, certifications, and experience levels. The paragraph is fundamentally about the CSLT itself—their functional leadership roles, their responsibilities, and their qualifications—so this falls under Management Role.

Looking at specificity, I've got named internal programs like CSLT and CSRM with their own identifiers, plus a detailed list of functional areas that define the team structure. There are no quantifiable facts here—no dates, budgets, headcounts, third-party vendors, tool names, or specific certifications mentioned by name. This points to Firm-Specific classification.

fact: Cybersecurity leadership team ('CSLT') — named team with unique identifier

fact: CSRM program — named internal program with unique abbreviation

fact: Specific functional composition: security operations, incident response, risk and compliance, data security, application security, digital solutions security, vulnerability management, operational technology security


reasoning: The paragraph's primary subject is the Audit Committee and Board of Directors overseeing cybersecurity risks, reviewing policies, and engaging with management — classic Board Governance. No IS-list facts are present: 'Audit Committee' and 'Board of Directors' are generic governance terms, 'regularly' is a vague cadence, and no named frameworks, roles, dates, or numbers appear.

thinking:
Classify this paragraph.

Content: Board/Audit Committee oversight of cybersecurity. The grammatical subject is the Audit Committee and Board. This is Board Governance.

Specificity: Let me check for specific facts.
- "Audit Committee" — on the NOT list (generic governance)
- "Board of Directors" — on the NOT list
- No named frameworks, no specific dates, no named roles (CISO etc.), no numbers
- "regularly engages" — generic cadence

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


specificity_confidence: medium

reasoning: The paragraph describes the company's internal incident response escalation protocols, making Risk Management Process the dominant category. The specific departmental composition ('Legal, Compliance and Internal Audit') is a firm-specific fact per the IS list, but there is only one qualifying fact, so it does not reach Quantified-Verifiable.

thinking:
Classify this paragraph.

Content: Describes incident response escalation protocols, mentioning specific departments (Legal, Compliance and Internal Audit) and IT leaders. This is about internal processes for handling incidents.

Category: Risk Management Process - describes IR planning and escalation protocols as internal processes.

Specificity: The paragraph mentions "Legal, Compliance and Internal Audit" as specific team/department compositions. Per the IS list, "Specific team/department compositions: 'Legal, Compliance, and Finance'" qualifies as firm-specific. "Legal, Compliance and Internal Audit" is a specific departmental composition → Firm-Specific.

Only one IS fact, so Firm-Specific (3).

fact: Legal, Compliance and Internal Audit named as functional leaders in escalation


reasoning: The paragraph primarily describes the company's internal risk assessment methodology — identifying, assessing, and prioritizing risk through audits, tabletop exercises, penetration tests, and simulations. The Audit Committee reporting mention is a subordinate detail. No named frameworks, no named firms (the third-party assessor is unnamed), no cybersecurity-specific roles, no dates or numbers — all items fall on the NOT list (common practices, generic governance, unnamed entities).

thinking:
Let me analyze this paragraph.

Content: Describes internal risk management processes - risk assessment, tools used (third-party assessor, internal audit, tabletop exercises, pen testing, vulnerability tests, simulations), and reporting to Audit Committee.

Category: The primary content is about the company's internal risk management processes. The Audit Committee mention is a brief reporting detail at the end. → Risk Management Process

Specificity: Let me check for specific facts:
- "non-affiliated third-party assessor" — unnamed, so NOT specific
- "internal audit team" — generic
- "tabletop exercises, penetration and vulnerability tests, and simulations" — common practices, NOT specific

- "Audit Committee of the Board of Directors" — generic governance, NOT specific
- No named frameworks, no named tools, no dates, no numbers, no named firms, no cybersecurity-specific titles

This is all generic boilerplate with no concrete details or named standards to anchor it.


content_category: Incident Disclosure

reasoning: The paragraph primarily describes an actual cybersecurity incident — its date, response actions (activating protocols, pausing operations, engaging experts, coordinating with law enforcement), and recovery timeline. The financial impact figures quantify the incident but serve the incident narrative. The closing materiality sentence is secondary. Per Rule 4, when cost is one sentence in a paragraph dominated by incident description, it remains Incident Disclosure. Multiple QV-eligible hard facts (specific date, dollar amounts for revenue and earnings) clearly exceed the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

This paragraph describes an actual cybersecurity incident (June 13, 2023) AND its financial impact AND a materiality assessment.

Content: Describes what happened (IT security incident, systems impacted, response actions, operations paused, resumed in nine days) AND financial impact ($80-85M lost revenue, $35-40M operating earnings) AND materiality statement.

Category decision: This is mixed between Incident Disclosure and Strategy Integration. The paragraph describes the incident (date, what happened, response actions, duration) AND the financial impact (dollar amounts) AND a materiality conclusion.

Per the tiebreaker rules:

- "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure"
- "Paragraph ONLY discusses financial cost, insurance, or materiality of an incident WITHOUT describing the event → Strategy Integration"

This paragraph does both. The incident narrative (disclosed incident, activated protocols, paused operations, engaged experts, coordinated with law enforcement, resumed in nine days) is more prominent than the financial quantification, so the dominant category is Incident Disclosure. The financial impact is just one sentence within a longer incident narrative, so this clearly falls under Incident Disclosure. Now I'm checking the specificity: the disclosure includes a precise date, concrete dollar figures for both revenue loss and operating earnings, and an exact timeline of nine days. Those details make it Quantified-Verifiable, even though "leading security experts" remains vague.

fact: lost revenue of approximately $80 million to $85 million

fact: operating earnings of $35 million to $40 million

fact: nine days to resume normal operations


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of external vendors and suppliers — security assessments before onboarding, contractual security requirements, privacy addenda, and cybersecurity education for suppliers. These are all requirements imposed ON vendors, making this Third-Party Risk rather than Risk Management Process. No named standards, firms, tools, dates, or other specific facts are present, so it remains Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: About third-party vendor/supplier risk management - assessments before onboarding, security requirements, contract addenda, cybersecurity education for suppliers. The central topic is oversight of external parties.

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

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


reasoning: The paragraph's central topic is oversight of external parties — suppliers, subcontractors, and joint venture partners — including third-party risk assessments, remediation processes, and monitoring services. This is squarely Third-Party Risk, not Risk Management Process, because the focus is on requirements and oversight imposed on vendors rather than the company's own internal security processes. No named standards, named firms, specific dates, tools, or other IS-list facts appear; all language is generic ('select suppliers,' 'third-party cybersecurity monitoring and alerting services,' 'risk remediation process').

thinking:
Let me analyze this paragraph.

Content: Describes Caterpillar's third-party cybersecurity program - vendor risk management, supply chain resilience, third-party risk assessments, remediation processes, and monitoring services for select suppliers.

Category: Third-Party Risk - the entire paragraph is about oversight of external parties (suppliers, subcontractors, joint venture partners). Vendor oversight is the central topic.

Specificity: Let me check for facts:
- No named frameworks, no named tools, no named firms, no specific dates, no dollar amounts, no headcounts
- "third-party cybersecurity monitoring and alerting services" - unnamed

- "select suppliers" - vague
- No cybersecurity-specific titles
- No named committees

No IS-list facts. No named standards. This is generic boilerplate with no concrete details to anchor it.


reasoning: The entire paragraph is about obligations and controls imposed ON suppliers, subcontractors, and third-party service providers — classic Third-Party Risk. It names DFARS, FARS, and NIST as regulatory/framework standards but contains no firm-specific facts (no vendor counts, no named vendors, no dates, no unique program identifiers), placing it at Sector-Adapted.

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

Specific facts: DFARS, FARS (named regulations), NIST (named framework). These are named standards/regulations.

The paragraph is about requirements imposed ON vendors/suppliers/subcontractors — classic Third-Party Risk.

Specificity: DFARS, FARS, NIST are named standards → Sector-Adapted. Any firm-specific facts? Not really — no named vendors, no counts, no dates. The practices described (contractual terms, incident notification) are generic. DFARS/FARS are named regulations which function like named standards → Sector-Adapted.

DFARS and FARS are specific regulatory frameworks that trigger the Sector-Adapted classification, with no additional firm-specific details beyond that.

fact: DFARS

fact: U.S. Federal Acquisition Regulations (FARS)

fact: NIST


reasoning: The paragraph's primary content is about the people who manage the cybersecurity program — the CIO's and CISO's experience, team qualifications, and certifications. While board briefings and ERM are mentioned at the end, the dominant communicative purpose is identifying and credentialing the management personnel. Multiple QV-eligible hard facts: 35 years experience, 30 years at company, 20 years CISO experience, plus named certifications (CISSP, CISM).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. CIO managing cybersecurity program, with team including head of IT Security
2. CIO's experience (35+ years, 30+ at the company)
3. VP of IT Security/CISO's experience (20+ years)
4. Team members' qualifications and certifications (CISSP, CISM mentioned)
5. Board, Audit Committee, Technology Subcommittee, and senior management receive briefings from CIO and CISO
6. Board oversees ERM Program

The primary content is about the people - CIO credentials, CISO credentials, team qualifications. Let me apply the person-vs-function test: if I remove the people's titles, credentials, and experience, what's left? Not much substantive process description. The paragraph is primarily about WHO manages the program and their qualifications.

This is clearly a management role category - the focus is on the CIO and CISO's extensive experience and their team's certifications, with the board oversight structure playing a supporting role. I'm counting the specific facts here: the CIO has over 35 years of relevant experience and over 30 years with the company, the CISO has over 20 years of relevant experience, and there are team members with relevant certifications like CISSP and CISM - all of these are concrete, quantifiable details that support the qualifications claim.

fact: Global Chief Information Officer (CIO)

fact: Vice President of Information Technology Security and CISO

fact: CIO has over 35 years of relevant industry experience

fact: CIO has over 30 years at the Company

fact: CISO has over 20 years of relevant industry experience

fact: CISSP certification mentioned

fact: CISM certification mentioned

fact: Technology Subcommittee of the Audit Committee


reasoning: The paragraph primarily describes what happened in a cybersecurity incident — the March 2021 systems outage, engagement of forensic firms, system restoration, and resulting disruptions to brewery operations, production, and shipments. While it also includes financial impact ($2.4M costs) and a cross-reference to Risk Factors, the dominant content is the incident narrative and its operational consequences. Multiple QV-eligible hard facts are present: a specific incident date (March 2021), a specific dollar amount ($2.4M), and a specific fiscal period (year ended December 31, 2021).

thinking:
Let me analyze this paragraph carefully.

Content: Describes a March 2021 cybersecurity incident - systems outage, forensic firms engaged, systems restored, business disruptions (brewery operations, production, shipments), shift in production timing, $2.4M incremental costs net of insurance, cross-reference to risk factors.

Category: This describes what happened in an incident (March 2021 systems outage, response actions, disruptions) AND discusses financial impact ($2.4M costs, insurance recoveries, production shifts). The paragraph spends significant text on both the incident narrative and the business/financial impact. Let me apply the tiebreaker rules:

The incident narrative—what happened, how it was addressed, and the operational disruptions—dominates the paragraph, with financial details serving as supporting evidence. This points to Incident Disclosure. For specificity, I have "March 2021" as a concrete date and "$2.4 million" as a quantified cost, both of which qualify for QV eligibility. I'm also noting that "December" appears to be cut off, likely referring to when the incident was disclosed or when costs were finalized.

fact: March 2021 (incident date)

fact: $2.4 million incremental one-time costs

fact: year ended December 31, 2021


reasoning: The paragraph describes how the Board, Audit Committee, and SET Committee receive cybersecurity reports and dashboards from senior leaders—classic board/committee oversight content. The SET Committee is a named non-generic committee unique to this company, triggering Firm-Specific. However, 'regular basis' is a generic cadence and 'senior leaders' are unnamed, so there are no QV-eligible hard facts beyond the one committee name.

thinking:
Let me analyze this paragraph.

Content: Board, Audit Committee, and SET Committee receive reports from senior leaders about cybersecurity. Leaders meet regularly with committees and provide dashboards/reports. Committees elevate to Board.

Category: The grammatical subjects are Board, Audit Committee, SET Committee, and "these leaders." The paragraph is about board/committee oversight - receiving reports, briefing cadence. Board Governance.

Specificity:
- "SET Committee" - this is a named non-generic committee (not standard Audit Committee). That's a specific fact → Firm-Specific.
- "Audit Committee" - generic, doesn't count.

- "Board" - generic.
- "regular basis" - generic cadence.
- No named roles, no dates, no numbers.

One IS fact (SET Committee) → Firm-Specific (3).

fact: SET Committee (named non-generic committee)


reasoning: The paragraph describes the company's internal cybersecurity processes—vulnerability scanning, threat modeling, patch management, employee training, and product security integration—all squarely within Risk Management Process. No named frameworks, tools, roles, dates, or quantified facts are present; all elements are common practices described in generic terms.

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

Content: Describes vulnerability scanning, threat modeling, patch management, employee training, and security measures in products. All internal processes.

Category: Risk Management Process - describes internal cybersecurity processes (vulnerability scanning, threat modeling, patch management, training, product security).

Specificity: No named frameworks, no named tools, no named roles, no dates, no numbers. "Vulnerability scanning tools," "threat modeling analysis," "at least annually" - all generic practices. This is Generic Boilerplate.


reasoning: The paragraph describes Emerson's internal cybersecurity awareness and education processes — policies, training, simulated phishing, video content — making it a Risk Management Process paragraph. The named 'Cybersecurity Awareness Team' within the 'global enterprise security team' is a firm-specific organizational detail, but the activities described (phishing simulations, online training, security awareness) are common practices that don't reach Sector-Adapted or QV thresholds on their own.

thinking:
Let me analyze this paragraph.

Content: Describes a "Cybersecurity Awareness Team" within the global enterprise security team, responsible for awareness/education programs, policies, training methods.

Category: This is about internal cybersecurity processes - awareness programs, policies, training. Risk Management Process.

Specificity:
- "Cybersecurity Awareness Team" - this is a named internal team, which could be considered firm-specific
- "global enterprise security team" - organizational structure
- The practices described (online training, custom video, simulated phishing) are common practices per the NOT list

The "Cybersecurity Awareness Team" is a named team/department composition unique to this company. That's a firm-specific fact.

Since there are no quantifiable facts like dates, financial figures, headcount, or named external vendors or tools, this qualifies as firm-specific information.

fact: Cybersecurity Awareness Team (named internal team)


reasoning: The paragraph introduces Equifax's information security program, its investment, and team structure. The CISO is mentioned as attribution ('operating under the leadership of our CISO') rather than as the paragraph's subject — the primary content is about the program's existence and scope, making this Risk Management Process per the person-vs-function test. Contains a cybersecurity-specific role (CISO) and a headcount (~400), but only one QV-eligible fact (the headcount), so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes investment in security program, mentions CISO role, ~400 cybersecurity professionals, and introduces the program description.

Category: This mentions the CISO and team size, but the primary purpose is introducing the company's information security program. The CISO is mentioned as attribution ("operating under the leadership of our CISO"), and the paragraph is about the program existing. However, the team composition (400 professionals) is a notable detail about the management structure.

Actually, let me apply the person-vs-function test. If I remove "operating under the leadership of our CISO," the paragraph still describes the security program and team. But the paragraph does name the CISO role and give a specific headcount of ~400.

The core message here is about the program's existence and structure rather than the person leading it. The CISO mention serves as attribution, while the ~400 professional headcount is a quantifiable fact about the team. Since the CISO is a named role but not a specific person, and the headcount is the only quantifiable detail, this looks like it belongs in the Risk Management Process category with just one QV-eligible fact to extract.

fact: Chief Information Security Officer (CISO)

fact: approximately 400 cybersecurity professionals


content_category: Strategy Integration

reasoning: The paragraph briefly references the 2017 Equifax breach but its dominant content is hypothetical future risk language about potential litigation, fines, and material adverse effects on financial condition — making it a discussion of business/financial consequences of cyber risk rather than an incident narrative. The specific date 'In 2017' is one firm-specific fact, but no second QV-eligible fact is present.

thinking:
Let me analyze this paragraph.

It references the 2017 Equifax breach, then shifts to hypothetical future incidents and generic risk language about litigation, fines, and material adverse effects.

Category: The paragraph starts with a brief mention of a past incident but the bulk is hypothetical/forward-looking risk language about potential future compromises. The dominant purpose is discussing potential business/financial impact. However, the first sentence is incident disclosure, and the rest is generic risk language about what could happen.

Actually, looking more carefully: the first sentence references a real incident (2017 breach). The rest is hypothetical risk language. The dominant content is the hypothetical/strategic risk language. But the materiality language here is conditional ("could have a material adverse effect") rather than an assessment of whether risks "have materially affected" the business. This is more like generic risk factor language.

The conditional phrasing—"could have a material adverse effect"—signals this is boilerplate risk disclosure rather than a concrete materiality assessment. I'm trying to figure out if the brief incident reference at the start pushes this toward Strategy Integration, but the bulk of the content is really just standard forward-looking risk warnings without a substantive materiality conclusion. The 2017 date is a specific fact from the IS list, making this Firm-Specific since there's only one hard data point here—no dollar amounts, named companies, or headcount figures to push it to two facts.


reasoning: The paragraph describes the company's internal process for managing cybersecurity threats and maintaining incident records — squarely Risk Management Process. 'Information Security team' is a generic team reference (not a cybersecurity-specific title like CISO, nor a named non-generic committee), and no frameworks, dates, tools, or other specific facts are present, so it remains Generic Boilerplate.

thinking:
Classify this paragraph.

Content: Describes the Information Security team's responsibility for managing cybersecurity threats and maintaining incident records. This is about internal processes.

Category: Risk Management Process - describes internal processes (managing threats, maintaining records).

Specificity: "Information Security team" - is this a cybersecurity-specific title? Looking at the IS list: "VP of IT/Security, Information Security Officer, Director of IT Security" - "Information Security team" is a team name but not a named non-generic committee or a specific composition. It's somewhat generic. No frameworks, no dates, no named tools. This is Generic Boilerplate.

Wait - "Information Security team" - is this firm-specific? The IS list mentions cybersecurity-specific titles. A team called "Information Security team" is fairly generic.

Since it lacks a specific committee name or defined composition like "Legal, Compliance, and Finance," I'm classifying this as Generic Boilerplate.


reasoning: While the first sentence mentions Board/Risk Committee oversight, the majority of the paragraph (3 of 4 sentences) describes management roles — the CIO and CISO, their responsibilities, reporting lines (CIO→Interim President/CEO, CISO→CIO), and the CISO's experience areas — making Management Role the dominant category. Specificity is Firm-Specific: CISO, CIO, and Risk Committee are all on the IS list, but no QV-eligible hard facts (no specific dates, dollar amounts, headcounts, named firms, named certifications, or specific years of experience — 'extensive experience' is vague).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Board + Risk Committee oversight of risk management including cyber risks
2. CIO and CISO roles, their responsibilities, reporting lines
3. CISO's experience areas

The primary communicative purpose: This paragraph starts with the Board/Risk Committee but quickly shifts to describing management roles (CIO, CISO), their reporting lines, and the CISO's experience. The majority of the text is about management roles.

Let me apply Rule 2: Board vs Management. The first sentence has the Board as subject, but the rest (majority) describes management roles, reporting lines, and qualifications.

The dominant content is about management. Looking at the structure, three out of four sentences focus on management roles and their reporting relationships, while only the opening sentence addresses Board oversight. The specific facts I'm noting are the named Risk Committee, the cybersecurity-specific titles (CIO and CISO), and the reporting lines showing the CIO reports to the Interim President/CEO while the CISO reports to the CIO.

Now I'm checking whether this meets the quantifiable verification threshold. Named roles and committee titles don't count as hard verifiable facts—I'd need dates, dollar amounts, headcounts, named firms, tools, or certifications. Without those, this doesn't qualify as quantifiably verifiable. However, the three firm-specific elements (CISO, CIO, and Risk Committee) do establish this as firm-specific content with a specificity level of 3.

fact: Risk Committee

fact: Chief Information Officer (CIO)


reasoning: The paragraph describes the company's risk governance structure under its ERM program, detailing three components (management oversight, third-party assessment, internal audit) and six named management committees with their chairs. While the opening sentence mentions the Board, the dominant content is the organizational process for managing cybersecurity risk through specific committees — this is about the function/structure, not about any individual person's credentials, making it Risk Management Process rather than Board Governance or Management Role.

thinking:
Let me analyze this paragraph.

Content: Describes board and senior management oversight of cybersecurity risk management processes, including risk governance structure with multiple committees.

Category analysis:
- Opens with "Our Board and senior management oversee our processes" - mixed Board/Management
- The bulk describes the risk governance structure and management oversight committees
- Lists specific committees: Information Security Committee, Operational and Compliance Risk Committee, IT Steering Committee, ERM Committee, Data Governance Committee, Strategic Deployment Committee
- The primary content is about the organizational structure for risk management - the committees and their chairs

This is tricky. The paragraph starts with board oversight but quickly shifts to describing the management committee structure.

The real focus here is the governance framework itself—the committees and their reporting relationships form the backbone of the risk management process. While specific people chair these committees, what matters is the structure and how cybersecurity risk flows through these governance channels. This feels like it's fundamentally about the risk management process and organizational design rather than individual roles. process - which committees exist, what they do (assessment, remediation, escalation). The role titles are used to describe who chairs each committee, but the focus is on the governance structure.

I think this is Risk Management Process - the paragraph describes the company's risk governance structure, ERM integration, and committee framework. The board mention is brief at the start. The committees are described as components of the risk management process.

Wait, but there are named committees and named roles. Let me reconsider - could this be Board Governance? The opening sentence has "Our Board and senior management oversee..." but then the paragraph shifts entirely to the management-level governance structure. The board is mentioned as receiving reports, but the bulk is about management committees.

Actually, I think the dominant category is Risk Management Process - it describes the risk governance structure with three components and details the management oversight committees as part of the ERM program.

Now I'm checking the specificity of the roles and committees mentioned. The CISO and CIO are cybersecurity-specific, and there are several named committees like the Information Security Committee, IT Steering Committee, Data Governance Committee, Strategic Deployment Committee, Enterprise Risk Management Committee, and Operational and Compliance Risk Committee. The CRO isn't explicitly on the IS list, but these firm-specific committees and roles clearly indicate this is tailored to their structure. I don't see any quantifiable facts like dates, dollar amounts, or headcounts, so this falls into Firm-Specific rather than QV-eligible.

fact: Information Security Committee, co-chaired by CISO and CRO

fact: Operational and Compliance Risk Committee, chaired by CFO, vice chaired by CISO and Chief Compliance Officer

fact: IT Steering Committee, chaired by CIO

fact: Enterprise Risk Management Committee, chaired by CRO

fact: Data Governance Committee, chaired by CIO

fact: Strategic Deployment Committee (executive management committee), chaired by CEO

fact: CISO

fact: CIO


reasoning: The paragraph's central topic is oversight of third-party cybersecurity risks — identifying, analyzing, and monitoring risks from third-party relationships, plus a third-party incident response program. While it mentions internal processes, the focus is squarely on managing external-party risk. No named frameworks, specific roles, dates, or other facts from the IS list are present; 'Third Party Risk Management Program' is a generic program name without a unique identifier.

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

Specificity: No named frameworks, no specific facts from the IS list. "Third Party Risk Management Program" is a generic program name. No unique identifier. No cybersecurity-specific roles, no dates, no numbers.

Generic Boilerplate.


reasoning: The paragraph makes an explicit materiality assessment ('has not identified any specific risks from cybersecurity threats that have materially affected... business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration. The cross-reference to Risk Factors and forward-looking disclaimer are secondary. No firm-specific facts from the IS list remain after filtering — 'December 31, 2024' is a standard fiscal year-end date used as boilerplate context, and the rest is generic materiality language.


reasoning: The paragraph describes the company's own cybersecurity program being audited by independent third parties—an external assessor hired to evaluate the company's processes (Risk Management Process per Rule 3, not Third-Party Risk). It names NIST CSF (Sector-Adapted baseline) and includes firm-specific audit timing (2022 audit over 2021 program), which are facts unique to this company's disclosure. However, the year-only dates lack month-level precision for QV counting, and no other QV-eligible facts (dollar amounts, headcounts, named firms/tools) are present, so it remains Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes periodic third-party audits using NIST CSF, mentions most recent audit in 2022 over 2021 program, results showed mature program.

Category: This is about the company's own cybersecurity processes - specifically external audits of their program. The third-party is hired to assess the company (Rule 3: "External assessor hired to test the company → Risk Management Process"). So Risk Management Process.

Specificity:
- NIST Cybersecurity Framework → named standard (Sector-Adapted baseline)
- "2022" and "2021" → specific dates → firm-specific facts

- The 2022 and 2021 dates are years only, which count as firm-specific facts but don't meet the QV threshold that requires month+year or exact dates for quantifiable verification. the year-only dates don't meet the QV threshold of month+year or exact dates, so I'm left with just one potential QV fact, which keeps this at Firm-Specific level. The classification is Risk Management Process with Firm-Specific detail.

fact: NIST Cybersecurity Framework

fact: Most recent audit performed in 2022 over 2021 program


reasoning: The paragraph describes the company's multi-layered cybersecurity risk management program — processes, testing methods, monitoring sources, framework alignment, and incident response plans. The CISO is mentioned as attribution ('supervised by Ford's CISO') but the substantive content is entirely about program activities and processes, making this Risk Management Process. Specificity is Firm-Specific: CISO is a cybersecurity-specific title on the IS list, and NIST CSF is named. However, QV requires two hard verifiable facts (dates, dollar amounts, headcounts, named third-party firms, named tools); CISO is a named role (not QV-eligible), NIST CSF is a framework (not QV-eligible), and CERT/ISACs are public government resources rather than named third-party firms hired by the company.

thinking:
Let me analyze this paragraph.

Content category: The paragraph describes Ford Motor Credit's cybersecurity risk management program - processes, tools, methodologies, framework adoption, monitoring, testing. The CISO is mentioned as attribution ("supervised by Ford's Chief Information Security Officer") but the paragraph is about the program/processes. This is Risk Management Process.

Specificity: Let me check facts:
- CISO mentioned (cybersecurity-specific title) → IS list
- NIST CSF named → framework
- US-CERT mentioned → named entity
- ISACs mentioned → named entity
- Bug bounty program → common practice
- "ransomware response plan" → somewhat specific

- CISO is a firm-specific role, and NIST CSF is a sector-adapted framework, so this triggers the Firm-Specific classification. There are no quantifiable metrics like dates, dollar amounts, or headcounts, and no named third-party vendors or proprietary tools, so this doesn't qualify for QV.

fact: NIST Cybersecurity Framework (CSF)

fact: U.S. Computer Emergency Readiness Team (CERT)

fact: Information Sharing and Analysis Centers (ISACs)


reasoning: The paragraph primarily describes how cybersecurity risk identification, assessment, and management are integrated into the enterprise risk management program — covering risk prioritization, risk owners, mitigation plans, and escalation processes. While the Board is mentioned multiple times, it appears as a component of the ERM process description rather than as the primary actor performing governance oversight. No named frameworks, cybersecurity-specific roles, specific dates, or other IS-list facts are present — all language is generic (senior management, annually, Board, risk owners).

thinking:
Let me analyze this paragraph.

Content: Describes how cybersecurity risk is integrated into ERM, how the Ford Credit Board meets with senior management to assess risks, how risks are validated, prioritized, assigned risk owners, mitigation plans developed, and updates provided to the Board.

Category: This is about the enterprise risk management process and how cybersecurity fits into it. The Board is mentioned but in the context of the ERM process description. The primary content is about the risk management methodology - integration into ERM, risk assessment, prioritization, risk owners, mitigation plans. This is Risk Management Process.

Actually, let me reconsider. The Board is mentioned multiple times as receiving updates and meeting with senior management.

The paragraph's core focus is really on the ERM integration process itself—how risks flow through identification, assessment, prioritization, ownership assignment, and mitigation planning. The Board functions as part of the governance structure within that process rather than being the main subject. This is fundamentally about the process methodology, not Board governance specifically.

Looking for specificity: "Ford Credit Board," "senior management," and "annually" are all generic references without concrete details. There are no named frameworks, specific tools, dates, headcounts, or defined roles like CISO mentioned. This reads as generic boilerplate without substantive facts.


reasoning: The paragraph describes the company's incident response process — containment, remediation, recovery, third-party engagement, escalation procedures, and annual plan review. No actual incident is described; this is IR planning. All details are generic: unnamed third-party providers, standard Audit Committee/Board escalation, generic cadences ('at least annually'), and boilerplate incident language. No named frameworks, tools, firms, dates, or cybersecurity-specific roles appear.

thinking:
Let me analyze this paragraph.

Content: Describes incident response procedures - containment, remediation, recovery, third-party assistance, escalation to board, disclosure determinations, annual plan review.

Category: This is about the company's incident response process - not an actual incident. It describes what they do when an incident occurs. This is Risk Management Process (IR planning, process description).

Specificity check:
- "incident response plan" - generic program name (NOT list)
- "third-party providers" - unnamed (NOT list)
- "forensic investigations" - standard language (NOT list)
- "senior management" - generic (NOT list)

- "Franklin Board of Directors" / "Franklin Audit Committee" - generic governance (NOT list, Audit Committee is standard)
- "at least annually" - generic cadence (NOT list)

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


reasoning: The Board and Audit and Finance Committee are the grammatical subjects performing oversight of the cybersecurity program, making this Board Governance. The CISO is mentioned in a subordinate role (reporting to the board). The CISO title is a cybersecurity-specific role on the IS list, pushing specificity to Firm-Specific. The 'Audit and Finance Committee' is essentially the standard audit committee and does not qualify as a non-generic committee. No second QV-eligible hard fact (quarterly is a generic cadence), so it remains Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Board/committee oversight, mentions Audit and Finance Committee, CISO provides quarterly updates alternating between committee and full board.

Category: Board Governance - the Board and its committee are the primary subjects performing oversight.

Specific facts:
- "Audit and Finance Committee" - this is a named non-generic committee (not just "Audit Committee")
- "CISO" - cybersecurity-specific role
- Quarterly updates alternating between committee and full board - this is a specific cadence structure

IS list check:
- CISO → named cybersecurity-specific role ✓

- "Audit and Finance Committee" → the codebook specifically excludes "Audit Committee" as non-specific, and this is essentially the same thing with "Finance" added. It's the company's label for their audit committee, so I shouldn't count it as a named non-generic committee.

So the only concrete fact here is the CISO role, making this Firm-Specific (Level 3). For QV eligibility: CISO is a named role that doesn't qualify, "Quarterly" is just generic cadence, and there are no dates, amounts, headcounts, named firms, tools, or certifications present. Not QV-eligible.

fact: CISO provides quarterly updates


reasoning: This paragraph provides a high-level overview of the company's cybersecurity program across six key areas (governance, collaborative approach, technical safeguards, incident response, third-party risk, education). While it touches governance and third-party risk, these are listed as components of the overall program structure, making the dominant purpose a description of internal cybersecurity processes. The CIO and Global Head of IT Security are cybersecurity-specific titles on the IS list, pushing specificity to Firm-Specific, but no QV-eligible hard facts (dates, dollars, named firms/tools) are present.

thinking:
Let me analyze this paragraph carefully.

This is a high-level overview of GATX's cybersecurity program covering multiple areas: governance, collaborative approach, technical safeguards, incident response, third-party risk, and education.

Content Category: This paragraph describes the company's overall cybersecurity program structure across multiple dimensions. The dominant purpose is describing the company's internal cybersecurity processes and program areas. While it mentions governance and third-party risk, these are components listed as part of the overall program overview. The primary communicative purpose is Risk Management Process.

Specific facts:
- CIO (Senior Vice President and Chief Information Officer) - cybersecurity-specific title? CIO is on the IS list

- Global Head of IT Security - this is a cybersecurity-specific role similar to "Director of IT Security" which is on the IS list
- Audit Committee - on the NOT list
- ERM function - generic

I've identified at least two firm-specific cybersecurity titles: CIO and Global Head of IT Security. Neither of these named roles qualifies as QV-eligible since specific titles aren't counted that way. The Audit Committee and ERM function don't add firm-specific facts here.

fact: Senior Vice President and Chief Information Officer (CIO)

fact: Global Head of IT Security, who reports directly to the CIO


reasoning: The paragraph centers on the Global Head of IT Security as the primary actor — what they lead, what they monitor, their reporting line to the Audit Committee, and their qualifications (15+ years experience, degrees, multiple certifications). While process details are present, they serve to explain the scope of this person's responsibilities. The person-vs-function test is close, but the final sentence dedicating substantial content to the individual's credentials tips toward Management Role. Only one QV-eligible hard fact (15 years); unnamed certifications and degrees without named universities do not reach QV threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. A cybersecurity group within IT, led by the "Global Head of IT Security"
2. What the program does (protect systems, execute incident response)
3. Multidisciplinary teams deployed for threats/incidents
4. The Global Head of IT Security monitors prevention, detection, mitigation, remediation and reports to Audit Committee
5. The Global Head of IT Security's qualifications: 15+ years experience, undergraduate and graduate degrees in information security, multiple certifications

This is a mixed paragraph. Let me apply the person-vs-function test:

The first three sentences describe what the program does and how teams work. The last sentence is about the person's qualifications. The middle content describes the role's monitoring and reporting functions.

The paragraph has significant process content (program administration, multidisciplinary teams, monitoring prevention/detection/mitigation/remediation) BUT also has significant person content (15+ years experience, degrees, certifications). The grammatical subject shifts between the cybersecurity group, multidisciplinary teams, and the Global Head of IT Security. That final sentence is purely about the person's credentials. Applying the person-vs-function test: if I remove the person's credentials, the paragraph still describes processes. But the last sentence takes up substantial space dedicated to who this person is. The "Global Head of IT Security" is the consistent thread throughout—what they lead, what they monitor, who they report to, and their qualifications.

I think the dominant purpose here is Management Role. The paragraph centers on the Global Head of IT Security: what they lead, what they monitor, their reporting line to the Audit Committee, and their qualifications. The process details are subordinate to establishing what this person does and who they are.

Wait, let me reconsider the balance. The first two sentences focus on the program and teams. The third sentence covers the Global Head's monitoring and reporting. The fourth is about their qualifications. It's roughly split between process and person.

Using the person-vs-function test: if I removed the role holder's name, title, qualifications, and background, would the remaining content still describe substantive cybersecurity activities? Yes—"a program designed to protect... multidisciplinary teams are deployed..." But significant content IS about the person.

This is a close call, but I'm going with Management Role because the Global Head of IT Security is the consistent subject threading through the entire paragraph.

Now looking at the specificity: "Global Head of IT Security" is a cybersecurity-specific title that qualifies as an IS fact. The "over 15 years" is a specific duration that's QV-eligible. But the degrees lack named universities, and the certifications are vague—just "multiple certifications" without naming them. So I'm really only finding one solid verifiable fact here: the title itself.

fact: Global Head of IT Security

fact: over 15 years in IT and information security


reasoning: The paragraph describes the company's own internal cybersecurity processes — monitoring, vulnerability management, data protection policies, backup systems, disaster recovery testing — squarely fitting Risk Management Process. No named frameworks, tools, roles, dates, or firm-specific facts are present; phrases like 'industry standard security technology' and 'industry-accepted methods' are generic and could appear in any company's filing.

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

Content: Describes internal cybersecurity processes - monitoring, security technology, data security management program, benchmarking, backup systems, disaster recovery. All about the company's own internal processes.

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

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.) - "industry standard" and "industry-accepted methods" are generic
- No named roles (CISO, etc.)
- No named tools or products
- No dates, dollar amounts, headcounts

- No named firms, no specific standards referenced, just vague mentions of "identity, trust, vulnerability and threat management business processes" and "standard data protection policies"

This is entirely generic boilerplate with no company-specific details or named standards.


reasoning: The paragraph describes engaging an independent third-party audit firm to perform a SOC 2 audit, which centers on an external party's role in assessing the company's controls. However, this is borderline with Risk Management Process since the external assessor serves the company's own compliance needs. The SOC 2 named standard elevates specificity to Sector-Adapted, but 'enterprise claims platforms' is a generic internal reference and 'independent third-party audit firm' is unnamed, so it does not reach Firm-Specific.

thinking: Classify this paragraph about engaging a third-party firm for SOC 2 audit.

fact: SOC 2 audit


reasoning: The paragraph is primarily about the people who manage cybersecurity risk — their identities, qualifications, and credentials. The CIO's certifications (CPA, CITP) and specific experience duration (20 years) are the core content, satisfying the person-vs-function test for Management Role. Two or more QV-eligible hard facts are present: 20 years of experience (specific duration) and named certifications (CPA, Certified Information Technology Professional).

thinking:
Let me analyze this paragraph.

Content: Describes a Cyber Risk Committee with specific members (CFO, CIO, management from IT/finance/accounting/legal/internal audit). Then describes the CIO's credentials and experience. Then mentions collective expertise of other members.

Category: This is about management roles and their qualifications. The paragraph names specific roles (CIO, CFO), describes the CIO's credentials (CPA, CITP, 20 years experience), and describes the committee composition. The primary focus is on WHO manages cybersecurity risk - the people and their qualifications. This is Management Role.

Person-vs-function test: The paragraph names the Cyber Risk Committee, identifies its members, and then spends most of its text on the CIO's qualifications. Remove the people and credentials, and there's very little left.

Now I'm breaking down the specific elements to categorize them. The Cyber Risk Committee is a named committee, the CIO is a cybersecurity-specific role, and the CPA and CITP certifications are relevant credentials. The 20 years of experience is a quantified metric, and the team spans IT, finance, accounting, legal, and internal audit functions. The key quantifiable facts here are the specific tenure and the named certification.

fact: Cyber Risk Committee

fact: information technology, finance and accounting, legal and internal audit functions

fact: Certified Public Accountant (CPA)

fact: Certified Information Technology Professional (CITP)

fact: 20 years of experience in cybersecurity and information technology


reasoning: The paragraph opens with Board oversight (2 sentences) but the majority of the text (3 sentences) describes the company's incident response organizational structure — cross-functional management teams, division-level and central Cyber Incident Response Teams, and protocols for communicating incidents. The CISO is mentioned as attribution for who leads the team, not as personal background, so the person-vs-function test points to Risk Management Process. The CISO title (cybersecurity-specific role on the IS list) and the named divisional incident response team structure make this Firm-Specific, but there are not two QV-eligible hard facts (no dates, dollar amounts, named firms, or tools).

thinking:
Let me analyze this paragraph.

Content: The paragraph starts with the Board's oversight role, then shifts to cross-functional management teams, division-level incident response teams, and a central Cyber Incident Response Team led by the CISO.

Category: This spans Board Governance and Risk Management Process. The first two sentences are about the Board. The remaining sentences describe management teams and incident response structure. The dominant content is actually split - but the majority of the text (3 out of 5 sentences) describes the management/process structure. However, the opening frame is Board oversight, and the rest describes what's underneath it.

Actually, let me re-read. The paragraph's primary communicative purpose: it starts with Board oversight, then describes the organizational structure for cyber incident response. The board is the frame, but the bulk describes the process/structure - cross-functional teams, division teams, central CIRT, CISO leading it.

---

Looking at the text volume, the incident response structure dominates with three sentences versus two on Board oversight. The paragraph describes organizational functions and protocols rather than individual roles—the CISO is just mentioned as the leader. So this falls under Risk Management Process, not Management Role.

For specificity, the CISO is a named cybersecurity title that qualifies as Firm-Specific. The "Division Cyber Incident Response Team" has a distinctive organizational name that sets it apart from generic incident response plans, making it Firm-Specific as well. "Cross-functional management teams" is too generic to code. On the QV side, there are no dates, dollar amounts, headcounts, or named external firms—just the CISO role, which isn't QV-eligible anyway.

fact: Chief Information Security Officer leads the Cyber Incident Response Team

fact: Division Cyber Incident Response Team structure at each division reporting to a central Cyber Incident Response Team


reasoning: The paragraph is about the person filling the CISO role — their experience (20+ years), certification (CISM), and reporting line (to CIO). This passes the person-vs-function test: the primary content is who the person is and what qualifies them. Two QV-eligible hard facts: specific years of experience ('over 20 years') and a named certification (CISM).

thinking:
Let me analyze this paragraph.

Content: Describes the CISO's experience (20 years), certification (CISM), reporting line (to CIO), and responsibility. Also mentions a "dedicated global team of cybersecurity professionals."

Category: This is about the person - their experience, credentials, reporting line. The person-vs-function test: if you remove the CISO's qualifications and reporting structure, there's very little left besides "cybersecurity program is overseen by a team." The primary content is about who the person is. → Management Role

Specificity:
- CISO: named cybersecurity-specific role ✓ IS

- CIO: named cybersecurity-specific role ✓ IS
- "over 20 years" of experience: specific number → QV-eligible
- CISM certification: named certification → QV-eligible

I've identified two hard verifiable facts here: the specific duration of experience and the named certification, which makes this Quantified-Verifiable.

fact: CISO role

fact: CIO role

fact: over 20 years of experience

fact: Certified Information Security Manager (CISM) designation


reasoning: The paragraph describes the company's internal incident response plan, escalation procedures, testing practices, and cybersecurity insurance — all internal cybersecurity processes. The specific departmental composition (IT, Legal/Employee Relations, Corporate Communications, Human Resources) is a firm-specific organizational detail per the IS list, but there are no hard verifiable facts (dates, dollar amounts, named third-party firms, named tools) to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the company's InfoSec Incident Response Plan, its components, escalation procedures, cybersecurity insurance, and testing practices. This is about internal processes.

Category: Risk Management Process - describes internal cybersecurity processes, IR planning, testing, escalation procedures.

Specific facts check:
- "InfoSec Incident Response Plan" - named internal program? It's a somewhat generic name. The codebook says "incident response plan" is generic, but "InfoSec Incident Response Plan" could be considered a named program. However, it's not really uniquely identifiable like "Cyber Incident Response Plan (CIRP)".

The specific departmental composition "IT, Legal/Employee Relations, Corporate Communications, Human Resources" is what stands out as firm-specific, since it shows their actual team structure involved in incident response. The other elements like the Audit Committee, Board involvement, and tabletop exercises are fairly standard practices across companies.

Looking at the verifiability angle, there aren't any concrete dates, numbers, or named external vendors that would push this into the QV category. So this lands as Firm-Specific based on that departmental breakdown alone.

fact: Key partners include IT, Legal/Employee Relations, Corporate Communications, Human Resources


reasoning: The paragraph describes the company's post-incident review process — documenting causes, evaluating remediation, considering improvements — which is an internal IR process. The CTO is mentioned as the person who reports findings upward, but the primary content is the process itself, not the person's qualifications or background. CTO is a cybersecurity-specific title on the IS list, yielding Firm-Specific; no second QV-eligible fact is present.

thinking:
Let me analyze this paragraph.

Content: Describes post-incident review process and reporting. The paragraph describes what happens after an incident - review, document, evaluate remediation, consider improvements. Then the CTO reports to Audit Committee/Board.

Category: This is about incident response processes (post-incident review). The CTO is mentioned as attribution for reporting. The primary content is about the process of reviewing incidents and reporting findings. This is Risk Management Process - it describes internal IR processes.

Wait - could this be Board Governance? The CTO reports to the Audit Committee and Board. But the paragraph's primary focus is the post-incident process, with reporting being one component.

The grammatical subject throughout is "we" describing our processes. Risk Management Process is definitely the right fit here. Looking at the specificity markers: CTO appears on the Information Security list, so that's one firm-specific fact. The Audit Committee and Board are generic governance terms, not on any specialized list. That gives me one IS fact total, making this Firm-Specific. And with just that single fact, it doesn't meet the QV threshold.

fact: CTO


reasoning: The paragraph contains an explicit materiality assessment ('has not been materially affected by a cybersecurity breach') and discusses potential material effects on business strategy, results of operations, and financial condition — triggering Strategy Integration per Rule 6. The appended cross-references to Item 1A Risk Factors do not change the classification. No firm-specific facts from the IS list are present; the language is standard boilerplate materiality disclaimer.

thinking:
Let me analyze this paragraph.

It contains a materiality assessment ("has not been materially affected by a cybersecurity breach") plus cross-references to Risk Factors. Per Rule 6, materiality disclaimers → Strategy Integration.

Specificity: The materiality assessment is boilerplate language. No named frameworks, no firm-specific facts from the IS list. The cross-references are just pointers. → Generic Boilerplate.


reasoning: The Board of Directors is the grammatical subject with overall oversight responsibility for cybersecurity. The paragraph describes generic board oversight duties (ensuring management has processes) with no named committees, roles, frameworks, or firm-specific details — standard boilerplate that could apply to any company.


reasoning: The paragraph describes the company's security program structure, regulatory compliance model (NERC, NRC, PCI DSS, HIPAA), and enterprise risk coordination with government partners. While CISO and other roles are mentioned, they serve as attribution for process descriptions — the person-vs-function test points to Risk Management Process since the substantive content is about what the program does, not who the people are. The CISO title (a cybersecurity-specific role on the IS list) elevates specificity beyond Sector-Adapted to Firm-Specific, but no two QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes multiple management roles (CISO, Chief Ethics & Compliance Officer, CSO) and their responsibilities, then describes the risk management model including regulatory compliance (NERC, NRC, PCI DSS, HIPAA), and enterprise risk coordination.

Category: This is primarily about risk management processes - the paragraph describes the security program structure, regulatory compliance, risk management model, and coordination activities. While CISO and other roles are mentioned, they're attributed as part of describing what the program does (person-vs-function test). The bulk of the paragraph is about processes.

→ Risk Management Process

Specificity:

Now I'm checking which elements qualify as IS facts. CISO is a cybersecurity-specific role that counts, while the Chief Ethics & Compliance Officer is too generic. The CSO title isn't explicitly listed as cybersecurity-specific. The regulatory standards—NERC, NRC, PCI DSS, and HIPAA—are all named frameworks. Since named roles and frameworks don't contribute to QV, this paragraph doesn't meet the quantitative threshold.

With at least one IS fact present (the CISO role combined with multiple frameworks), this moves into Firm-Specific territory rather than staying at Sector-Adapted, even though frameworks alone wouldn't be enough to make that jump.

fact: Chief Information Security Officer (CISO) responsible for cybersecurity strategy

fact: NERC Reliability Standards

fact: NRC Code of Federal Regulations

fact: Payment Card Industry Data Security Standard (PCI DSS)

fact: Health Insurance Portability and Accountability Act (HIPAA)


reasoning: The paragraph's primary content is the company's three-lines-of-defense risk management model, describing how operational functions, oversight, and assurance are structured. The board/Audit Committee mention is brief attribution; the CISO, CIO, and CSO are named as components of the defense lines (describing the function/structure, not the persons). Multiple cybersecurity-specific roles (CISO, CIO, CSO) and named regulatory frameworks (NERC, NRC Cyber Rule) qualify as firm-specific facts, but no two QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes a three lines of defense model for cybersecurity risk management. Opens with board/audit committee oversight mention but quickly shifts to management's responsibility and the organizational structure of the security program.

Category: This is primarily about the company's internal risk management structure - the three lines of defense model. The board mention is brief attribution. The paragraph describes organizational roles and processes. While it names CISO, CIO, CSO, these are mentioned as parts of the defense lines, describing the function/structure rather than the persons. This is Risk Management Process.

Specificity: Let me check for specific facts:
- CISO (cybersecurity-specific title) ✓ IS

- CIO (cybersecurity-specific title) ✓ IS
- CSO / Chief Security Office - this is a cybersecurity-specific role ✓ IS
- NERC Reliability Standards - named regulatory standard ✓ IS (framework)
- NRC Cyber Rule - named regulatory standard ✓ IS (framework)
- "three lines of defense model" - this is a recognized risk management framework
- Internal Audit - generic

Now I'm checking what counts toward QV eligibility. Named frameworks like NERC and NRC don't qualify, and neither do named roles or titles. There are no dates, dollar amounts, headcounts, or third-party firm names that would add specificity.

Since the document contains IS-list facts like CISO, CIO, CSO, NERC, and NRC, this falls into the Firm-Specific category.

fact: CISO identified as first line of defense

fact: CIO identified as first line of defense

fact: CSO and Chief Security Office as second line of defense

fact: NERC Reliability Standards referenced as regulatory construct

fact: NRC Cyber Rule referenced as regulatory construct


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected us, including our business strategy, results of operations, and financial conditions'), 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—past threats/breaches are described generically, and the cross-reference is noise.

thinking:
Let me analyze this paragraph.

Content: Materiality assessment ("have not materially affected us, including our business strategy, results of operations, and financial conditions") + brief mention of past threats/breaches + cross-reference to Risk Factors.

Category: The paragraph contains an explicit materiality assessment - "such risks have not materially affected us, including our business strategy, results of operations, and financial conditions." Per Rule 6 and the codebook, this is Strategy Integration. The cross-reference doesn't change it.

Specificity: No named frameworks, no specific dates, no named roles, no specific facts from the IS list. Generic boilerplate materiality language.


reasoning: The paragraph describes the company's own internal cybersecurity processes — incident response plan steps, insider threat detection, regulatory compliance, and threat intelligence sharing — making it Risk Management Process. It names specific regulatory frameworks (DFARS, CMMC) which elevate it to Sector-Adapted, but contains no firm-specific facts from the IS list: no cybersecurity-specific titles, no named tools/firms, no specific dates or numbers. The IR plan is generic ('Incident Response Plan' without a unique identifier), and the threat-sharing partners are unnamed categories.

thinking:
Let me analyze this paragraph.

Content: Describes incident response plan, insider threat detection program, regulatory compliance (DFARS, CMMC), and threat intelligence sharing.

Category: This is about the company's own internal cybersecurity processes - IR plan, insider threat program, regulatory compliance, threat intelligence sharing. → Risk Management Process

Specific facts:
- "Incident Response Plan" - generic program name, NOT specific
- "insider threat detection program" - generic
- "Defense Federal Acquisition Regulation Supplement" (DFARS) - this is a named regulation
- "Department of Defense's Cybersecurity Maturity Model Certification program" (CMMC) - named standard/program

- "controlled unclassified information" and "Department of Defense's Cybersecurity" - these are references to government frameworks

The entities mentioned for information sharing—defense industrial base peers, government agencies, information sharing and analysis centers, and cybersecurity associations—are all generic categories without specific names. DFARS and CMMC are recognized regulatory frameworks that apply across the defense contractor sector, so compliance with them doesn't constitute firm-specific detail. The incident response procedures described are standard practices, and there are no named roles, specific dates, headcounts, or proprietary tools mentioned, so this appears to be Sector-Adapted at minimum rather than firm-specific.

fact: Defense Federal Acquisition Regulation Supplement (DFARS)

fact: Department of Defense's Cybersecurity Maturity Model Certification (CMMC) program


reasoning: The paragraph describes the company's internal cybersecurity program including its security management program, defense-in-depth model, SOC, insider threat program, and regulatory monitoring — all squarely Risk Management Process. It names specific departmental composition (IT, Privacy, Product, Operations) which qualifies as a firm-specific fact, and references GDPR as a named standard. One IS-list fact (specific team composition) elevates this to Firm-Specific, but there are not two QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal cybersecurity program - security management program, defense-in-depth model, SOC, insider threat program, policies, risk management team working with departments, regulatory monitoring including GDPR.

Category: Risk Management Process - this is about the company's own internal processes, tools, and methodologies.

Specific facts:
- "Information Technology, Privacy, Product, and Operations departments" - specific team/department composition → IS list
- "GDPR" - named standard → framework
- "Lumen" - company self-reference → NOT list
- "insider threat program" - generic program name → NOT list

- "security operations center" - generic → NOT list
- "defense-in-depth model" - generic practice

So I'm identifying one IS fact here: the specific departmental composition. GDPR is a named standard but that's framework-level. No quantifiable metrics like dates, amounts, or headcounts, and no named third-party vendors or tools mentioned. This lands as Firm-Specific (3).

fact: Risk management team works with Information Technology, Privacy, Product, and Operations departments

fact: GDPR


reasoning: The paragraph is anchored by the April 2022 cybersecurity incident and describes what happened (disruption of hospital operations, exfiltration of data), the response (remediation changes, SOC enhancements, new tools), and ongoing risk. While it touches on financial impact and a materiality-adjacent risk statement, the incident narrative and post-incident remediation actions are the dominant content. Only one QV-eligible hard fact (specific month+year date), so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a past cybersecurity incident (April 2022), its impact, remediation actions taken, and a forward-looking risk/materiality statement.

Content category: This is tricky. It describes an actual incident (April 2022), costs/impact (Strategy Integration), remediation changes (Risk Management Process), and a materiality/risk statement (Strategy Integration).

The dominant content: The paragraph starts with the incident, describes costs, then describes remediation changes, then a materiality-adjacent risk statement. Let me assess what's dominant.

- Sentence 1: Incident description (April 2022, disrupted hospital operations, exfiltration)

- Sentence 2: Financial impact (costs, lost revenues, expenses) → Strategy Integration
- Sentence 3: Remediation changes (SOC enhancements, backups, training, detection tools) → Risk Management Process
- Sentence 4: Forward-looking risk statement + materiality language → Strategy Integration
- Sentence 5: Cross-reference to Risk Factors → None/Other

This is a mixed paragraph. The incident itself is referenced briefly, but the bulk focuses on financial consequences, the remediation steps we've implemented, and how we're positioning the ongoing risk. The tiebreaker here is that the paragraph spends more space on aftermath and forward-looking posture than on the incident itself.

Looking at the actual content, the paragraph does describe what happened and includes our response actions, which points toward Incident Disclosure. But the financial impact and materiality language are substantial enough that it could lean toward Strategy Integration. The incident is really the anchor point—what happened is less important than what it cost us and how we're managing the risk going forward. Given that the remediation actions are part of our incident response and the incident frames the entire discussion, I'm leaning toward Incident Disclosure as the primary category, though the financial and strategic elements are definitely present.

For specificity, I've got "April 2022" as a concrete date, which qualifies for QV. "Security Operations Center" is too generic, "hospital operations" isn't specific enough, and there are no named firms, dollar amounts, headcounts, or tools. That's just one QV-eligible fact, which isn't enough to meet the threshold. The date itself is Firm-Specific since it references when this incident happened to us.

fact: April 2022


reasoning: The paragraph describes a management-level Cybersecurity Committee — its composition, function, and reporting line to the board. The primary subjects are the committee and the management roles that comprise it, fitting Management Role (management committees responsible for cybersecurity). The Cybersecurity Committee is a named non-generic committee and the specific departmental composition (COO, Chief Risk Officer, General Counsel, VP Internal Audit) is a firm-specific organizational fact, yielding Firm-Specific. No 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 a "Cybersecurity Committee" composed of specific management roles, reporting to the board. This is about management structure and organizational oversight.

Category analysis:
- The paragraph describes the Cybersecurity Committee (a management-level committee) and its composition, role, and reporting. The grammatical subjects are "Our second line of defense," "Our Cybersecurity Committee," and "The Cybersecurity Committee." This is about management's organizational structure for cybersecurity oversight. The committee reports TO the board, making management the primary actor. → Management Role

Wait - let me reconsider. The Cybersecurity Committee is a management committee, not a board committee.

The paragraph describes who's on it and what it does, which fits the Management Role category since it covers management committees responsible for cybersecurity and their reporting lines. The Cybersecurity Committee is clearly a management-level committee, and the paragraph focuses on its composition and organizational structure.

Now I'm checking the specificity of the roles mentioned. "Cybersecurity Committee" is a named, non-generic committee that appears on the IS list. However, "Chief Risk Officer" isn't listed as a cybersecurity-specific title—it's a general risk management role, not cybersecurity-specific.

The other roles like "General Counsel," "Vice President, Internal Audit," and "board of directors" are all generic C-suite or organizational positions, not on the IS list. So the only firm-specific fact here is the named Cybersecurity Committee itself. There are no quantitative facts—no dates, dollar amounts, headcounts, or named tools. This puts it at Firm-Specific (Level 3).

fact: Cybersecurity Committee

fact: Composed of COO, Chief Risk Officer, General Counsel and Vice President, Internal Audit


reasoning: The CISO is mentioned as attribution, but the paragraph's substance is about the company's cybersecurity assessment processes, monitoring techniques, and use of industry frameworks — a classic process description. Removing 'The CISO' and substituting 'The Company' leaves the paragraph intact. The CISO title is the only IS-list fact; no named frameworks, dates, tools, or other QV-eligible facts appear, so specificity stops at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: The CISO assesses cybersecurity readiness using tools, third-party tests, vulnerability assessments, audits. The security organization elevates issues to CEO and Board. They employ defensive and monitoring techniques using industry frameworks.

Category: The CISO is mentioned as attribution, then the paragraph describes what the program does - assessments, vulnerability assessments, audits, monitoring, frameworks. This is the person-vs-function test: remove "The CISO" and replace with "The Company" - it still makes sense as a process description. → Risk Management Process

Specificity:
- "CISO" - cybersecurity-specific title → IS list → Firm-Specific

- The remaining references are all generic titles and unnamed frameworks, so they don't qualify as IS facts. Only the CISO designation is specific enough to the company's structure, while everything else—the CEO, Board, and unnamed industry frameworks—are too general to be firm-specific identifiers.

fact: CISO


reasoning: The paragraph describes the composition of a management-level Cyber Governance Committee, detailing which roles and functions participate. This is organizational structure for cybersecurity leadership, fitting Management Role. Multiple firm-specific facts (named non-generic committee, CISO, CIO, specific departmental composition) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named external firms, or named tools).

thinking:
Let me classify this paragraph.

Content: Describes a Cyber Governance Committee and its composition including CISO, CTO, CAO, executive management, and assurance functions.

Category: This is about a management-level committee structure. The committee includes management roles. It's not about the board - it's a management committee. The paragraph describes the composition of a management committee responsible for cybersecurity. This fits Management Role (management committees responsible for cybersecurity, reporting lines, organizational structure).

Specificity: Let me check facts:
- "Cyber Governance Committee" - named non-generic committee ✓ IS

- "Chief Information Security Officer" - CISO ✓ IS
- "Chief Information Technology Officer" - CIO equivalent ✓ IS
- "Chief Accounting Officer" - generic C-suite role, not cybersecurity-specific, but part of the team composition
- Team composition: "Corporate Compliance, Enterprise Risk Management, and Internal Audit" - specific departmental composition ✓ IS

QV check: Are there 2+ hard verifiable facts (dates, dollars, headcounts, named firms, named tools, named certs)? No. So not QV.

IS facts: Cyber Governance Committee (named non-generic committee), CISO, CIO equivalent, and specific departmental functions like Corporate Compliance, Enterprise Risk Management, and Internal Audit all qualify as IS.

fact: Cyber Governance Committee

fact: Chief Information Security Officer

fact: Chief Information Technology Officer

fact: Corporate Compliance, Enterprise Risk Management, and Internal Audit as assurance functions


reasoning: The paragraph frames cybersecurity as critical to the company's vision and operations, discusses potential material adverse effects on business performance, and notes considerable resource expenditure — all tying cyber risk to business strategy and financials. However, it contains no named frameworks, roles, dates, dollar amounts, or any firm-specific details, making it generic boilerplate that could appear in virtually any company's filing.

thinking:
Let me analyze this paragraph.

Content: General statement about cybersecurity importance, threat landscape (ransomware, DoS), supply chain risk, and resource expenditure. No specific processes, no board/management details, no incident description.

The paragraph mentions threats, says they "expend considerable resources" - this is about business/strategic importance of cybersecurity. But let me check: does it make a materiality assessment? It says "could materially adversely affect" - that's hypothetical risk language, not a materiality conclusion about whether risks HAVE materially affected the company.

This is general risk language. It doesn't describe processes, governance, incidents, or make a firm materiality assessment. It's introductory/contextual language.

The language about threats and resource spending is substantive, but it's really just generic threat landscape framing without specific disclosures. The "could materially adversely affect" phrasing is hypothetical rather than a concrete materiality assessment. I'm noticing the resource allocation mention could potentially fit Strategy Integration, but the paragraph is fundamentally introductory—it's establishing why cybersecurity matters without revealing anything specific about how the company actually manages it.


reasoning: The paragraph describes the company's own internal cybersecurity processes—employee training, phishing simulations, tabletop exercises, security tools, and third-party assessments—making it Risk Management Process. Third-party consultants are mentioned as one component of the internal program, not as the central topic. No named frameworks, tools, firms, roles, dates, or quantified facts appear; all items (phishing simulations, tabletop exercises, unnamed 'security tools', unnamed 'third-party consultants') are common practices and unnamed entities on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity processes - training, phishing simulations, tabletop exercises, security tools, and third-party consultants for assessments. The central topic is the company's own internal processes. Third parties are mentioned as one component.

Category: Risk Management Process (internal processes are the central topic; third parties mentioned as a component per Rule 3)

Specificity: Let me check for specific facts:
- "information security employee training" - common practice
- "phishing simulation campaigns" - common practice
- "tabletop exercises" - common practice
- "security tools" - unnamed

- "third-party consultants" - unnamed
- No named frameworks, no named tools, no named firms, no dates, no numbers, no specific roles

This is Generic Boilerplate.


reasoning: The paragraph describes the company's own information security program engaging external experts (assessors, consultants, auditors) to support its cybersecurity risk management — per Rule 3, external assessors hired to test/serve the company are Risk Management Process, not Third-Party Risk. No named firms, frameworks, roles, dates, or specific numbers are present; 'third-party external experts' and 'regular audits' are generic/NOT-list items.

thinking:
Let me analyze this paragraph.

Content: Describes engaging external experts for cybersecurity risk management - assessors, consultants, auditors. Mentions audits, assessments, simulated testing.

Category: This is about using third-party experts to serve the company's own risk management. Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." The central topic is the company's own program using external help, not oversight OF vendors. → Risk Management Process

Specificity: No named frameworks, no named firms, no specific dates, no named roles (cybersecurity-specific), no specific numbers. "third-party external experts" is on the NOT list. "regular audits, assessments, and simulated testing" are common practices. → Generic Boilerplate


reasoning: The paragraph opens with an explicit materiality assessment ('has not had a material adverse affect on our business, results of operations and financial condition'), which per Rule 6 makes it Strategy Integration. The acknowledgment of past incidents is vague and generic, and the cross-reference to Risk Factors is noise. No named entities, dates, frameworks, or firm-specific facts are present.


reasoning: The paragraph describes the company's incident response and escalation process — SOC monitoring, assessment workflow, materiality evaluation, and notification escalation. The CISO is mentioned as a recipient of reports (incidental attribution), and the board/CEO references describe the escalation endpoint, not board oversight as the primary topic. Applying the person-vs-function test, the content is entirely about the process. CISO is the sole IS-list fact, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes incident response process - SOC monitoring, escalation procedures, materiality evaluation. The CISO is mentioned as receiving reports, but the paragraph is about the process/workflow, not about the person.

Category: Risk Management Process. The paragraph describes the company's incident response and escalation process. The CISO mention is incidental attribution. The board/CEO mentions are about the escalation process, not about board oversight as the primary topic.

Specificity: Let me check facts.
- CISO: cybersecurity-specific title → IS list ✓
- "security operations center": generic term, not a named product

- CEO and Board of Directors are generic C-suite/governance terms, not specific facts
- No QV-eligible facts present (no dates, dollars, headcounts, named firms, named tools, named certs)

So this is Firm-Specific with just one IS fact.


reasoning: This paragraph is generic risk factor language describing hypothetical cybersecurity threats and their potential adverse effects. It makes no materiality assessment (no 'have not materially affected' conclusion), describes no actual incident, names no framework, process, role, or governance structure. It is boilerplate risk disclaimer language that could appear in any public company's filing unchanged.

thinking:
This is generic risk factor language about cybersecurity threats. No specific facts, no frameworks, no named roles, no dates. It's hypothetical risk language ("may be affected", "may be vulnerable") discussing potential adverse effects. This is essentially boilerplate risk language that could apply to any company.

This reads like general risk factor language, not substantive cybersecurity disclosure. It doesn't describe any program, process, governance, or incident. It's essentially a risk disclaimer. → None/Other or Strategy Integration?

Looking more carefully: it discusses potential material adverse effects but doesn't make a materiality *assessment* (it doesn't say "have not materially affected" or "are reasonably likely to materially affect").

Since it's just laying out hypothetical risks without any actual materiality determination, this falls under None/Other.