reasoning: The paragraph describes the company's internal cybersecurity program: deploying multidisciplinary teams, monitoring prevention/detection/mitigation/remediation, and following an incident response procedure plan. The CISO is mentioned as attribution for who coordinates the program, but the substantive content is about processes and activities. Applying the person-vs-function test, replacing 'The CISO' with 'The Company' leaves the paragraph intact as a process description. CISO is the sole IS-list fact, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: The CISO coordinates with senior leadership to implement a cybersecurity program. Multidisciplinary teams address threats and respond to incidents per their IR plan. CISO and senior leadership monitor and report to Audit Committee.

Category: The paragraph describes what the program does - protecting systems, responding to incidents, deploying teams, monitoring. The CISO is mentioned as attribution but the content is about processes. The person-vs-function test: remove "The CISO" and replace with "The Company" - it still describes processes. → Risk Management Process

Specific facts:
- CISO (cybersecurity-specific title) → IS list ✓

- "Audit Committee" is a generic governance body, not firm-specific
- "multidisciplinary teams" and "cybersecurity incident response procedure plan" are generic descriptions

Only one IS fact identified, which falls short of the two needed for QV eligibility, so this lands in Firm-Specific.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes Ashland's information security program — its ERM integration, incident response plan, NIST CSF 2.0 alignment, and cross-functional coordination purpose. The VP of Cyber Security is mentioned as attribution ('led by') but the paragraph's primary content is about the program/function, not the person. Applying the person-vs-function test: removing the VP reference leaves a complete process description. Specificity is Firm-Specific because the cybersecurity-specific title 'Vice President of Cyber Security' is on the IS list, elevating beyond Sector-Adapted (which NIST alone would provide). Only one QV-eligible fact precludes Quantified-Verifiable.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Describes Ashland's information security program - ERM integration, incident response plan, NIST CSF 2.0 alignment, led by VP of Cyber Security. The paragraph is about the company's internal processes and program structure.

Category: Risk Management Process. The paragraph describes the company's information security program, its alignment with NIST, ERM integration, incident response plan. The VP of Cyber Security is mentioned as attribution ("led by"), but the paragraph is about the function/program, not the person. Per the person-vs-function test, removing "led by the Company's Vice President of Cyber Security" still leaves a complete process description.

Now I'm checking the specificity of each element. NIST CSF 2.0 is a named framework, and the VP of Cyber Security is a firm-specific title. The ERM program is actually a generic program name rather than something uniquely named. Looking at what's verifiable, the VP of Cyber Security is a named role but not eligible as a quantifiable fact since there are no dates, dollar amounts, or headcount metrics attached to it.

fact: Vice President of Cyber Security

fact: NIST Cybersecurity Framework 2.0

type: framework


content_category: Board Governance

category_confidence: medium

reasoning: The paragraph describes how the Audit Committee receives cybersecurity briefings and reviews internal audit results — the overall communicative purpose is the board-level oversight structure. The Senior Director of IT is the grammatical subject of the first sentence, but the framing is about the reporting-to-the-board mechanism, and the second sentence explicitly has the Audit Committee as subject. 'Senior Director of Information Technology' is a generic IT title (per the NOT list: 'Director of IT'), CEO/CFO are generic C-suite, 'Audit Committee' is standard, and 'not less than once per year' is a generic cadence — no IS-list facts survive filtering.

thinking:
Let me analyze this paragraph.

The paragraph describes two things:
1. The Senior Director of IT presents on cyber threats to the CEO, CFO, and Audit Committee (at least annually)
2. The Audit Committee reviews annual internal audit results related to internal controls/financial reporting

The primary actor in the first sentence is the "Senior Director of Information Technology" - a management role making presentations. But the presentations are TO the CEO, CFO, and Audit Committee. The second sentence is about the Audit Committee reviewing audit results.

This is a mixed paragraph. The first sentence: the Senior Director of IT is the grammatical subject, presenting to leadership. This describes reporting lines/briefing structure.

The second sentence shifts focus to the Audit Committee as the subject reviewing audit results. So I'm looking at whether this is primarily about the Senior Director's reporting role or the Audit Committee's oversight function. The first sentence emphasizes the Senior Director as the actor presenting to leadership, which suggests a Management Role classification. But the second sentence centers on the Audit Committee's review activities, which points toward Board Governance. The dominant theme seems to be about oversight and briefing cadence between management and the board. I'm checking whether "Senior Director of Information Technology" qualifies as a cybersecurity-specific role—it seems more like a generic IT title than something like "Director of IT Security" or "CISO," so it probably wouldn't meet the criteria. The paragraph is really about how the company's leadership structure oversees cybersecurity, with the Audit Committee's review of internal audits pointing toward Board Governance as the dominant category.

Looking at what's actually specific here: the CEO, CFO, and Audit Committee composition could count as a specific team arrangement, but these are all generic C-suite and governance titles. The cadence of "not less than once per year" and "annual internal audits" are also generic. Without any concrete, specific facts remaining after filtering, this looks like generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program: monitoring, tools, incident response plan, materiality framework, and insurance. The contract CISO is mentioned as one component of the program (person-vs-function test: remove the CISO mention and the paragraph still describes processes), and third-party providers are a component rather than the central topic, so this is Risk Management Process. CISO is a cybersecurity-specific title on the IS list, making this Firm-Specific; however, no two QV-eligible hard facts are present (FIPS 199 is a framework, CISO is a role, 'decades' is vague).

thinking:
Let me analyze this paragraph.

Content: Describes third-party providers, contract CISO, tools, incident response plan, cybersecurity insurance, materiality framework based on FIPS 199.

Category: This is primarily about the company's internal cybersecurity processes - monitoring, tools, incident response plan, materiality framework. The third-party mention is a component, not the central topic. The contract CISO is mentioned but the paragraph is about what the program does, not about the person. → Risk Management Process

Specific facts:
- "contract Chief Information Security Officer ("CISO")" - named cybersecurity-specific role → IS list ✓

- "Federal Information Processing Standards Publication 199" - named standard → framework
- "decades of cybersecurity experience" - too vague to count as a specific fact
- "vulnerability scans, penetration testing, firewalls, endpoint detection, threat intelligence" - these are standard industry practices, not list-worthy
- "cybersecurity insurance" - just a generic mention
- "tabletop yearly" - generic cadence without specifics

IS facts identified: CISO (named role), FIPS 199 (named standard/framework)

QV check: CISO is a named role (not QV-eligible). FIPS 199 is a framework (not QV-eligible). No specific dates, dollar amounts, or headcount to qualify.

Actually, FIPS 199 as a named standard would make this Sector-Adapted, and CISO is a cybersecurity-specific title on the IS list, so that's Firm-Specific. The specificity level is Firm-Specific (3).

fact: Contract Chief Information Security Officer (CISO)

fact: Federal Information Processing Standards Publication 199 (FIPS 199)


content_category: Strategy Integration

specificity_confidence: medium

reasoning: This is an explicit materiality assessment stating cybersecurity risks have not materially affected business strategy, results of operations, or financial condition — triggering Rule 6 for Strategy Integration. While 'fiscal year ended September 30, 2024' is a specific date, it functions as a standard reporting period reference rather than a cybersecurity-specific fact; the materiality language itself is boilerplate found across thousands of filings.


content_category: Management Role

reasoning: The paragraph is about the person filling the cybersecurity leadership role — their title, experience, and reporting line. This is the person, not the function. VP of IT is a cybersecurity-specific role per the IS list, and 'approximately 20 years' is a specific number. However, 'approximately 20 years' is a soft quantifier and the CFO reporting line is generic, so only one hard QV-eligible fact (the ~20 years). This yields Firm-Specific rather than Quantified-Verifiable.

fact: Vice President, Information Technology (VP, IT)

fact: approximately 20 years of experience

type: quantified

fact: reports to Chief Financial Officer


reasoning: The paragraph describes how SLB leverages external cybersecurity partners to monitor, maintain, and respond to threats within its own environment. Per Rule 3, third parties engaged to serve the company's internal security needs are Risk Management Process, not Third-Party Risk (which requires vendor oversight as the central topic or requirements imposed ON vendors). No named firms, frameworks, dates, or specific facts are present — 'leading cybersecurity companies' is an unnamed entity on the NOT list.

thinking:
Classify this paragraph.

Content: About partnering with external cybersecurity companies for monitoring, maintaining products/services, and incident response assistance.

Category: This is about third-party relationships but in service of the company's own cybersecurity infrastructure. The partners are serving SLB's internal security needs (monitoring, maintaining, responding). Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." These cyber partners are serving SLB. But... the central topic IS about third-party partnerships. Let me re-read Rule 3.

"Third parties mentioned as ONE component of internal program → Risk Management Process"

The key distinction is whether vendor oversight is the central focus or whether these partners are tools supporting the company's own security program. Here the paragraph emphasizes how SLB leverages external cyber partners for its security operations, not the requirements or oversight imposed on those vendors themselves. That points toward Risk Management Process rather than Third-Party Risk.

Specificity: No named frameworks, no named firms ("leading cybersecurity companies" is unnamed), no specific dates, no numbers. "Cyber partners" is generic. → Generic Boilerplate.


reasoning: The paragraph is entirely about the cybersecurity management team members — their titles, educational backgrounds, years of experience, credentials, and reporting lines. This is the person-vs-function test: the content is about WHO these people are and what qualifies them, making it Management Role. Multiple QV-eligible hard facts exist: headcount (two Engineers), and three distinct specific-number experience durations (30 years, 30 years, 20 years), well exceeding the two-fact QV threshold.

thinking:
Let me analyze this paragraph carefully.

This is about the cybersecurity management team at Unitil Corp. It describes multiple people, their titles, qualifications, educational backgrounds, years of experience, and responsibilities.

**Content Category:** The paragraph is primarily about the *people* — their credentials, education, experience, and roles. It names specific cybersecurity titles (CTO, Director of Information Security and Cyber Operations, Manager of Cyber Security Operations, Cyber Operations Engineers), describes their educational backgrounds, years of experience, and certifications. While there are some process descriptions (threat and vulnerability management, vendor security posture assessment, ICS/SCADA protection), these are subordinate to describing the person's responsibilities. The primary communicative purpose is telling you WHO these people are and what makes them qualified.

The team holds multiple senior cybersecurity positions with substantial experience — I'm seeing titles like CTO, CISO, and Chief Cyber Security Officer, along with specific credentials including an MBA and decades of professional experience ranging from over 20 to over 30 years across different team members.

fact: Chief Technology Officer and Vice President of Information Technology (CTO)

fact: Manager of Cyber Security Operations

fact: two Cyber Operations Engineers

fact: CTO also assumes responsibilities as CISO and Chief Cyber Security Officer

fact: CTO has over 30 years of professional experience in the utility industry

fact: Director has over 30 years of experience in IT

fact: Manager has over 20 years of experience in IT and cyber roles

fact: Masters Certificate in Cyber Security with concentration in Power Systems

fact: Industrial Control System (ICS) and SCADA infrastructure


reasoning: The paragraph primarily describes NNN's internal cybersecurity processes — monitoring, penetration testing, vulnerability assessments, training, ERM integration, and third-party risk evaluation — making Risk Management Process the dominant category. Board and Audit Committee mentions are subordinate (reporting context only). The NIST CSF is the only named standard; all other details (penetration testing, training, monitoring, third-party consultants) are common practices on the NOT list, so specificity stays at Sector-Adapted.

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

Content: This paragraph describes NNN's cybersecurity risk management processes - systems monitoring, tools deployment, third-party consultants, training, penetration testing, ERM integration, etc. It mentions the Board and Audit Committee but only in the context of reporting and training, not as the primary actors. The primary topic is the company's internal cybersecurity processes.

Category: Risk Management Process - the paragraph is primarily about the company's internal cybersecurity processes, tools, and methodologies. Board/management mentions are incidental.

Specificity: Let me check for specific facts:

The only concrete element here is the reference to NIST Cybersecurity Framework with sector adaptation, which qualifies as a named standard at Level 2. Everything else—the Enterprise Risk Management Team, Audit Committee, Board of Directors—is generic language that doesn't meet the specificity threshold. There are no named tools, external firms, dates, headcounts, or specific roles mentioned.

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


reasoning: The Audit Committee is the grammatical subject providing oversight of cybersecurity risk, with briefing cadence described — clearly Board Governance. All elements are generic: 'Audit Committee' is on the NOT list, 'annual updates' is a generic cadence, and 'management' is generic. No IS-list facts remain after filtering.

thinking:
Classify this paragraph.

The paragraph is about the Audit Committee's oversight of cybersecurity risk, briefing cadence, and notification process. The board committee is the grammatical subject.

Category: Board Governance

Specificity: Let me check the facts.
- "Audit Committee" — on the NOT list (generic governance)
- "annual updates" — generic cadence
- "management" — generic

No facts from the IS list. No named frameworks. → Generic Boilerplate.


reasoning: The paragraph describes the company's internal risk assessment scoring methodology (Low/Medium/High thresholds) and risk communication processes, which are core risk management activities. The numeric risk-level ranges (1-2.99, 2-5.99, 6-9) are internal scoring definitions, not externally verifiable facts like headcounts, dollar amounts, or named tools/frameworks from the IS list. No named standards, cybersecurity-specific roles, or firm-specific identifiers are present, so this remains Generic Boilerplate.

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

This describes internal risk assessment scoring/rating methodology and communication processes. It's about the company's own risk management process - risk levels, thresholds, and how results are communicated.

Content category: Risk Management Process - describes risk assessment methodology, scoring, and communication.

Specificity: The numeric scoring ranges (1-2.99, 2-5.99, 6-9) are internal methodology details. These are firm-specific scoring thresholds. But are they on the IS list? They're specific numbers describing the company's own risk scoring system. These are organizational details about how they categorize risk levels - not headcounts, dollar amounts, or externally verifiable facts.

The numeric ranges are internal to this company's risk framework and don't match any QV-eligible categories like dates, dollar amounts, headcounts, or percentages. There are no named frameworks, cybersecurity-specific roles, tools, committees, or programs with unique identifiers mentioned. This falls under Generic Boilerplate since it's internal risk scoring methodology without any named or quantifiable elements that would qualify for the IS list.


reasoning: The paragraph is split between Board Governance (Audit Committee oversight, semi-annual reporting) and Management Role (CIO and Director of Cybersecurity qualifications, degrees, experience, reporting lines). The dominant content by volume and detail is about the management personnel — the CIO's degrees from Loyola Marymount University, 25+ years of experience, reporting line to EVP/CFO, and the Director of Cybersecurity's responsibilities. Two QV-eligible hard facts: named university (Loyola Marymount) and specific years of experience (over 25 years).

thinking:
Let me analyze this paragraph carefully.

This is a long paragraph that covers multiple topics. Let me break it down:

1. Audit Committee oversight of IT/cybersecurity risks - Board Governance
2. Board of Directors oversight - Board Governance
3. CIO and Director of Cybersecurity report semi-annually to Board through Audit Committee - Board Governance
4. Management provides benchmarking to Audit Committee - Board Governance
5. Cybersecurity training for Audit Committee - Board Governance
6. Management involved in assessing/managing risks - transition
7. CIO and Director of Cybersecurity lead efforts - Management Role

8. CIO reports to the EVP/CFO with over 25 years of IT experience and degrees from Loyola Marymount University - Management Role
9. Director of Cybersecurity oversees security capabilities and engages with third-party security partners - Management Role/Third-Party Risk

The paragraph transitions from Board Governance oversight mechanisms into detailed information about the management team's qualifications, reporting structure, and external partnerships. This is a dual-category paragraph that establishes both governance framework and management credentials.

Looking at the distribution, the Board Governance content takes up the opening portion while the Management Role details—credentials, experience, reporting lines, and third-party relationships—comprise the more substantial second half. The tiebreaker here is that Management Role content dominates in volume and specificity, making it the primary category.

Now I'm checking which facts qualify for the list. The CIO and Director of Cybersecurity titles are both cybersecurity-specific roles, Loyola Marymount University is a named institution in a credential context, and "over 25 years" provides a specific tenure metric. The semi-annual reporting frequency doesn't meet the threshold.

fact: CIO

fact: Director of Cybersecurity

fact: Loyola Marymount University

fact: over 25 years of information technology expertise

fact: bachelor's and master's degrees in business administration, specializing in information systems and quantitative methods


reasoning: The paragraph primarily describes the company's own internal cybersecurity safeguards (administrative, technical, physical) and general approach to protecting systems, making Risk Management Process the dominant category. The insurance mention is a secondary element that could suggest Strategy Integration, but it is one clause within a broader process-oriented paragraph. No named frameworks, specific roles, dates, tools, or other facts from the IS list are present — all language is generic and interchangeable across companies.

thinking:
Let me analyze this paragraph.

Content: Describes "administrative, technical and physical safeguards," mentions cybersecurity insurance coverage, and a goal to keep data/systems safe.

Category: Mix of Risk Management Process (safeguards) and Strategy Integration (insurance). The safeguards description is generic, and the insurance mention is brief. The dominant content is about the company's internal safeguards approach, but the insurance mention pulls toward Strategy Integration. Actually, looking more carefully - the paragraph has two sentences about safeguards/security practices and one clause about insurance. The dominant topic is the company's own security approach = Risk Management Process. The insurance is one component.

Wait - let me reconsider.

The paragraph is quite generic. It mentions "administrative, technical and physical safeguards" (generic practices), insurance (Strategy Integration), and a goal statement. The safeguards description is the bulk. Risk Management Process seems right as dominant. No named frameworks, no specific facts from the IS list. "Administrative, technical and physical safeguards" is generic. Insurance is mentioned without specifics. → Generic Boilerplate.


reasoning: The Audit and Finance Committee (a board committee) is the grammatical subject throughout, describing its oversight role, briefing cadence, and reporting structure for cybersecurity — classic Board Governance. The paragraph names a non-generic committee and two cybersecurity-specific roles (CIO, VP Information Security), yielding multiple firm-specific facts, but none are QV-eligible (no dates, dollar amounts, headcounts, named firms, or named tools), so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content category: The grammatical subject is the Audit and Finance Committee (board committee) throughout. It's about board/committee oversight, briefing cadence, reporting structure. → Board Governance

Specific facts:
- "Audit and Finance Committee" - named non-generic committee (not just "Audit Committee") → IS list
- "Chief Information Officer" (CIO) → IS list (cybersecurity-specific title)
- "Vice President, Information Security" → IS list (cybersecurity-specific title)
- "quarterly" - generic cadence, NOT list
- "annually" - generic cadence, NOT list

- CIO and VP Information Security are firm-specific roles but not QV-eligible, with no dates, dollar amounts, headcounts, named firms, tools, or certifications mentioned, so this doesn't qualify as QV.

The named committee and two cybersecurity-specific titles give me multiple IS facts, though none rise to QV level. This lands at Firm-Specific (3) for specificity.

fact: Audit and Finance Committee (named non-generic committee)

fact: Chief Information Officer

fact: Vice President, Information Security


reasoning: The paragraph describes internal cybersecurity processes — incident response procedures, monthly status reviews, KPI tracking, and risk assessment. The named roles (CIO, VP of Information Security, Manager of Information Security) serve as attribution for who performs these activities; the substantive content is about what the program does, not who the people are (person-vs-function test favors RMP). Three cybersecurity-specific titles qualify as IS-list facts for Firm-Specific, but named roles do not count toward QV, and no other hard verifiable facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes two things:
1. The Information Security team executes incident response procedures and escalates to management
2. Three named roles (CIO, VP of Info Security, Manager of Info Security) conduct monthly status reviews covering KPIs, risk assessment, escalation actions, and project status

Primary topic: This is about internal cybersecurity processes - incident response procedures, monthly reviews, KPI tracking, risk assessments. The roles are mentioned as attribution for who performs these processes.

Person-vs-function test: If I remove the role titles, the paragraph still describes processes (incident response, monthly reviews, KPI tracking, risk assessment). So this is Risk Management Process.

The roles performing these actions are all cybersecurity-specific titles—CIO, VP of Information Security, and Manager of Information Security—and they're conducting standard practices like KPI tracking and risk assessment on a monthly cadence, which confirms this is fundamentally about the risk management program itself rather than the individuals.

For the quality verification check, I don't have concrete dates, dollar amounts, named firms, or specific tools—just role titles, which don't count as hard verifiable facts. But since I've identified at least one IS-specific fact, this qualifies as Firm-Specific at level 3.

fact: Manager, Information Security


reasoning: The CISO is mentioned as attribution, but the paragraph's substantive content describes the cybersecurity program's operations: implementing protections, deploying multidisciplinary teams, monitoring prevention/detection/mitigation/remediation in real time, and incident response. Applying the person-vs-function test, removing 'AGM's CISO' leaves a complete process description. The reporting-to-board clause is subordinate to the overall process narrative. Firm-Specific due to the named CISO role and named internal teams (Technology and ERM teams), but no two QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

Content: Describes the CISO's role in coordinating with teams to implement a cybersecurity program, monitor threats, and report to the audit committee/board. The paragraph is about what the program does - implementing protections, responding to incidents, deploying multidisciplinary teams, monitoring threats. The CISO is mentioned as attribution but the content is about the function/process.

Person-vs-function test: Remove "AGM's CISO" and replace with "the Company" - the paragraph still describes processes (implementing program, deploying teams, monitoring, detection, mitigation). This is Risk Management Process.

Wait - the last clause says "reports such threats and incidents to AGM's audit committee or AGM's Board of Directors, as appropriate" - that's a reporting line element. But the dominant content is about the program's operations.

Now I'm checking the specificity. The CISO title is cybersecurity-specific, so that's an IS-list fact. The paragraph names AGM Technology and ERM teams specifically, which is more detailed than generic references. The audit committee and Board are generic governance bodies, not list items. Since there are no dates, dollar amounts, named firms, or tools mentioned, this falls into Firm-Specific category.

fact: CISO

fact: AGM Technology and ERM teams


reasoning: The paragraph opens with the Board's direct oversight of cybersecurity and delegation to the Audit Committee, framing the entire paragraph around board-level governance. The CIO and VP of Information Security qualifications, the board member's technology expertise, and the incident response team are all presented as components supporting the Board's oversight structure. Two QV-eligible facts (over 20 years, over 25 years as specific experience durations) meet the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Board oversight of cybersecurity risks with quarterly updates from CIO - Board Governance
2. Delegation to Audit Committee - Board Governance
3. CIO's background (20 years engineering/product dev) - Management Role
4. VP of Information Security and Operations background (25 years infrastructure/cybersecurity) - Management Role
5. Independent director with technology expertise - Board Governance
6. Cross-functional incident response team - Risk Management Process

The primary frame is Board Governance - the paragraph opens with the Board's direct oversight, delegation to Audit Committee, and then describes the qualifications of people involved. But there's substantial Management Role content too.

Actually, rereading this more carefully - the structure starts with Board oversight, then pivots to describing the qualifications of key personnel like the CIO and VP of Information Security, circles back to board-level expertise, and mentions the incident response team. The personnel qualifications seem to be presented as supporting evidence for the board's oversight structure rather than being the main focus. The board's governance role frames the entire discussion, with management credentials serving as context for why that oversight is effective.

Looking at the specificity now - I'm identifying which facts qualify as IS-list items. The CIO and VP titles are cybersecurity-specific roles, so those count as named_role entries. The experience durations - "over 20 years" and "over 25 years" - are quantified with specific numbers, which makes them eligible for the QV category.

fact: CIO (Chief Information Officer)

fact: over 20 years in engineering and product development roles

fact: over 25 years in infrastructure and cybersecurity roles


reasoning: The paragraph contains an explicit materiality assessment ('have not experienced any cybersecurity incidents that have materially affected our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration. The cross-reference to Risk Factors is incidental. No specific facts are present — all language is boilerplate materiality disclaimer.


reasoning: The paragraph describes the company's internal cybersecurity processes: threat monitoring, incident reporting workflow, escalation procedures, and the roles of specific teams. The grammatical subjects are internal teams and processes, not the board or a specific management individual. Contains firm-specific named groups (Cybersecurity Oversight Team, IRT) and named programs with unique identifiers (IRP), but lacks two hard verifiable facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools) needed for Quantified-Verifiable.

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

Content Category: This paragraph describes the company's internal cybersecurity processes - how they prevent, detect, mitigate risks, their Incident Response Plan, reporting guidelines, escalation procedures. The primary topic is the company's own internal processes. → Risk Management Process

Specific facts:
- "Cybersecurity Oversight Team" - named non-generic committee ✓
- "Incident Response Plan (IRP)" - named internal program with unique identifier ✓
- "Incident Response Team (IRT)" - named internal program with unique identifier ✓

- "legal and communications teams" - specific team composition ✓
- "audit committee" - generic, ✗

Looking at the verifiable facts here, I see multiple firm-specific references like the named teams and programs with their abbreviations, but no hard quantifiable data like dates, dollar amounts, headcounts, or third-party certifications. That puts this at Firm-Specific (3).

fact: Cybersecurity Oversight Team

fact: Incident Response Plan (IRP)

fact: Incident Response Team (IRT)

fact: legal and communications teams


reasoning: The paragraph describes the company's internal processes for monitoring information systems, incident response, and escalation procedures. Although the Cybersecurity Director is mentioned repeatedly, the content is about what the processes entail (monitoring, audits, incident response plan, escalation notification chain) rather than the person's credentials or background — passing the person-vs-function test in favor of Risk Management Process. The Cybersecurity Director (cybersecurity-specific title) and Risk Committee (non-generic committee) are firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes monitoring processes, incident response plan, and escalation procedures. The Cybersecurity Director is mentioned as implementing/overseeing processes. The paragraph is about what the processes do (monitoring, audits, incident response, escalation), not about the person's credentials/background.

Category: Risk Management Process. The Cybersecurity Director is mentioned as attribution, but the paragraph describes processes - monitoring, audits, incident response plan, escalation notification. The person-vs-function test: remove the role and the paragraph still describes processes.

Wait - there's also the Risk Committee and escalation to Board. But the dominant content is the incident response and monitoring process.

I'm checking for specific identifiable facts here. The Cybersecurity Director and Risk Committee are both named entities that would appear on an IS list, while the generic C-suite roles wouldn't. There are no quantifiable metrics like dates or dollar amounts, so this stays firm-specific based on those named positions.

fact: Cybersecurity Director

fact: Risk Committee


reasoning: The paragraph is entirely about the people on the cybersecurity team — their roles, qualifications, career histories, and experience — making it Management Role under the person-vs-function test. Multiple QV-eligible hard facts are present: specific years of experience (30 combined, 25+, ~5 years), and a named external firm (Kala Pharmaceuticals), easily exceeding the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the team responsible for assessing cybersecurity risks, naming specific roles (COO, CFO, Executive Director/Head of IT Security and Compliance) and their qualifications, experience, and backgrounds.

Category: This is about the people - their qualifications, experience, backgrounds. The person-vs-function test: the paragraph is entirely about WHO these people are and what makes them qualified. → Management Role

Specificity: Let me identify facts:
- "Executive Director, Head of IT Security and Compliance" - cybersecurity-specific title → IS fact
- "25+ years" track record → specific number (QV-eligible)

- "combined 30 years" → specific number (QV-eligible)
- COO, CFO - generic C-suite per NOT list
- "approximately five years" managing IT → specific number (QV-eligible)
- "Kala Pharmaceuticals" - named firm (QV-eligible)
- "Audit Committee chairperson at Kala Pharmaceuticals" - named firm

I'm finding multiple quantified facts here: the 25+ years, the combined 30 years, the five years of IT management experience, plus the named company Kala Pharmaceuticals appearing multiple times. That's well over the threshold of two QV-eligible facts. → Quantified-Verifiable

fact: combined 30 years of risk management experience

fact: 25+ years track record on cyber- and IT risks management

fact: Kala Pharmaceuticals (CFO served as Audit Committee chairperson)

fact: approximately five years managing IT organization at Merus


reasoning: The CICSO is mentioned as attribution for who leads the team, but the paragraph's substantive content describes internal processes: publishing policies, compliance promotion, risk mitigation measures (network segmentation, detection/response, recovery), and periodic assessments. Removing the CICSO reference, the paragraph still functions as a process description. The CICSO title is a cybersecurity-specific role on the IS list, yielding Firm-Specific, but no second QV-eligible hard fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content category: The paragraph describes a dedicated cybersecurity team led by the CICSO, and then describes what the team does - publishing policies, compliance, risk mitigation, assessments, network segmentation, detection/response, recovery. The CICSO is mentioned as attribution, but the bulk is about what the team/program does. Using the person-vs-function test: remove "which is led by our Chief Information & Cybersecurity Officer ("CICSO")" and the paragraph still describes processes. → Risk Management Process.

Specific facts:
- "Chief Information & Cybersecurity Officer ("CICSO")" — this is a cybersecurity-specific title → IS list item

- No named frameworks, specific dates, dollar amounts, or named firms/tools present, so only the one IS-list fact qualifies. Since I need two QV-eligible facts to reach the threshold, this falls short. → Firm-Specific.

fact: Chief Information & Cybersecurity Officer (CICSO)


reasoning: The paragraph describes the company's internal cybersecurity program: deploying multidisciplinary teams, monitoring prevention/detection/mitigation/remediation, and incident response processes. The COO is mentioned as attribution for who implements the program, but the person-vs-function test shows the substantive content is about the program's activities — remove the COO reference and it still reads as a process description. COO is generic C-suite (not on the IS list), Audit Committee is generic governance, and no named frameworks, tools, dates, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: The COO works to implement a cybersecurity program, multidisciplinary teams address threats, COO and IT Security Operations Team monitor incidents and report to Audit Committee.

Category: This is about management's role in cybersecurity. The COO is the grammatical subject initially, but the paragraph describes what the program does (protect systems, respond to incidents, deploy teams, monitor). Let me apply the person-vs-function test: if I remove the COO reference, the paragraph still describes processes - teams deployed, monitoring, incident response. But the COO is a primary actor throughout, and the paragraph describes the COO's collaborative role and monitoring function.

Actually, looking closer, the COO isn't a cybersecurity-specific title like CISO or CIO — it's a general executive role. When I strip away the COO attribution and just read "the Company implements a cybersecurity program, deploys teams, monitors incidents, and reports to the Audit Committee," the core meaning remains intact. The paragraph is really describing the process itself, not the person executing it. This belongs in Risk Management Process.

As for the other elements — the IT Security Operations Team is pretty generic, the Audit Committee is a standard governance body, and there are no named frameworks, dates, tools, or specific metrics. This reads like standard boilerplate language without firm-specific details.

Specificity: Generic Boilerplate (1)


reasoning: The paragraph is overwhelmingly about the people — the CISO's and CCO's qualifications, credentials, experience, and education. This is the person-vs-function test: the content describes who these individuals are and what makes them qualified, not what the cybersecurity program does. Multiple QV-eligible hard facts: 10 years tenure, 14 years experience, CISSP certification, Brown University, Carnegie Mellon.

thinking:
Let me analyze this paragraph.

Content: Describes CISO, CCO, their qualifications, credentials, experience, certifications, education. This is about the people - their backgrounds, expertise, credentials.

Category: Management Role - the paragraph is about the persons (CISO, CCO) and their qualifications, experience, certifications, education.

Specific facts:
- CISO (cybersecurity-specific title) - named_role
- CCO with 10 years in oversight role - quantified
- 14 years' experience in information security - quantified
- CISSP certification - quantified (QV-eligible)

- Executive Master's in Cyber Security from Brown University and Chief Risk Officer Certificate from Carnegie Mellon - both named universities with specific credentials, making these QV-eligible facts that easily exceed the threshold of 2 quantified-verifiable items.

fact: CISO (Bain Capital's CISO)

fact: CCO has been responsible for oversight for 10 years

fact: CCO has more than 14 years' experience in information security

fact: CISSP certification held by CISO


reasoning: The paragraph describes the company's own internal cybersecurity program elements — risk assessments, testing, technical safeguards, BC/DR, incident response, employee training, and third-party risk management. All elements are common security practices described in generic terms with no named frameworks, tools, firms, dates, or cybersecurity-specific roles. Third-party risk management is one bullet among seven, so the dominant topic is internal processes (Risk Management Process, not Third-Party Risk).

thinking:
Let me analyze this paragraph.

Content: Describes the company's information security program elements - risk assessments, testing, technical safeguards, BC/DR, incident response plan, employee training, third-party risk management. This is clearly about internal processes.

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

Specificity: Let me check for specific facts:
- No named frameworks/standards
- No cybersecurity-specific titles (CISO, CIO, etc.) - "Incident Response Team" is generic
- No named tools, firms, dates, dollar amounts
- Practices mentioned: risk assessments, testing, technical safeguards, BC/DR, incident response plan, employee training, phishing exercises, third-party risk management - all generic/common practices

- "Annual training" and no unique identifiers either

This reads as generic boilerplate that could describe almost any company's security posture.


reasoning: Although titled 'Management's Role,' the paragraph's primary communicative purpose is describing the Audit Committee's oversight activities — receiving briefings, maintaining dialogue, participating in strategic decisions, and conducting annual reviews. Management (CISO, CEO, CFO) are described in terms of what they provide TO the Audit Committee, making the board committee the dominant actor. The CISO is a cybersecurity-specific title (IS list), yielding Firm-Specific; CEO/CFO and Audit Committee are generic and do not count. No second QV-eligible hard fact exists.

thinking:
Let me analyze this paragraph carefully.

The paragraph is titled "Management's Role Managing Risk" but the content is mixed between management roles and board governance.

Let me look at the primary actors:
- CISO, CEO, CFO inform the Audit Committee
- They provide briefings to the Audit Committee
- The Audit Committee maintains dialogue with these officers
- The Audit Committee participates in strategic decisions
- The Audit Committee conducts annual review

The grammatical subjects shift between management (CISO, CEO, CFO) and the Audit Committee. But the dominant theme is about how the Audit Committee is informed and exercises oversight, with management being the ones who brief them. The Audit Committee is the entity being briefed, participating in decisions, and conducting reviews.

Now I'm weighing whether this fits better under management roles or board governance. The paragraph does describe management informing the Audit Committee, but the Audit Committee emerges as the primary actor—they're the ones being briefed, participating in decisions, and conducting reviews. This creates tension between the title and the actual content focus. The oversight relationship between management and the board committee is central, with the board committee clearly in the oversight position.

Looking at specificity, I can identify CISO as a cybersecurity-specific role that would qualify for the IS list, while CEO and CFO are generic C-suite positions. The Audit Committee is also generic, and the cadence mentioned is just a standard annual frequency with no named frameworks, specific dates, or dollar amounts. That leaves me with one IS fact—the CISO—which puts this at Firm-Specific level 3.

fact: Chief Information Security Officer


reasoning: The paragraph describes the company's internal risk management and information security programs — their design goals (identify, assess, mitigate risks; protect security, availability, integrity, confidentiality). No board, management roles, third parties, incidents, or materiality assessments are discussed. All language is entirely generic with no named frameworks, specific roles, dates, or firm-specific facts.

thinking:
Classify this paragraph.

Content: Describes the company's risk management program and information security program in general terms. No board, no management roles, no incidents, no third parties, no strategy/materiality. This is about internal processes.

Category: Risk Management Process

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


reasoning: The paragraph is about the people filling the CIO and CISO roles — their years of experience and skill sets — making it Management Role under the person-vs-function test. Two QV-eligible hard facts (over 20 years and over 25 years of experience) push specificity to Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph names CIO and CISO roles and then describes their experience and qualifications in detail. The primary content is about the people - their years of experience, skill sets, and backgrounds. This is the person-vs-function test: the paragraph is about WHO these people are and what makes them qualified.

Content category: Management Role

Specific facts:
- CIO (cybersecurity-specific title) → named_role
- CISO (cybersecurity-specific title) → named_role
- "over 20 years" of IT experience → quantified
- "over 25 years" of cybersecurity experience → quantified

- Both experience figures are verifiable metrics, giving us two hard facts that qualify as Quantified-Verifiable.

fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

fact: CIO has over 20 years of information technology experience

fact: CISO has over 25 years of cybersecurity experience


reasoning: The paragraph contains an explicit materiality assessment ('we have not experienced a cybersecurity threat or incident... that has materially adversely affected our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the accompanying forward-looking risk language and cross-reference to Risk Factors. No named frameworks, firm-specific facts, or verifiable details are present — the language is standard boilerplate.

thinking:
Materiality assessment present → Strategy Integration per Rule 6. The paragraph explicitly states cybersecurity has not "materially adversely affected our business strategy, results of operations or financial condition." The rest is forward-looking risk language and a cross-reference.

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


reasoning: The paragraph's primary communicative purpose is identifying the Enterprise Cybersecurity Council — its composition (CIO, CISO, Director of Information Security, Director of Infrastructure, senior architects/engineers), and members' credentials (CISM, CISSP, CEH, CCNA). While it also describes council activities (reviewing risks, tracking metrics), the framing centers on who these people are and what qualifies them, making Management Role dominant over Risk Management Process. Multiple named certifications (CISSP, CISM, CEH, CCNA) provide four QV-eligible hard facts, well exceeding the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

Content: Describes the Enterprise Cybersecurity Council at management level - its composition (CIO, CISO, Director of Information Security, Director of Infrastructure, senior security architects), meeting cadence (monthly), activities (review/assess cyber risks, evaluate performance metrics, review project implementation, track training completion and phishing response rates), and member certifications (CISM, CISSP, CEH, CCNA).

Category: This is about management-level people and their qualifications. The paragraph describes WHO is on the council, their roles, and their certifications. But it also describes what the council DOES (reviews risks, evaluates metrics, tracks training).

The council composition and credentials form the primary focus, though the paragraph does detail their operational activities. The grammatical subject centers on the council itself and its members' qualifications, with their functions serving as supporting detail about how they apply their expertise.

Now I'm identifying the specific facts that qualify as quantified-verifiable: the four named certifications—CISM, CISSP, CEH, and CCNA—are concrete, verifiable credentials held by individuals on the council. That's clearly four QV-eligible facts right there.

Actually, wait—I need to reconsider whether these certifications count as QV-eligible even though they're attributed to the council collectively rather than to specific named individuals. The codebook explicitly lists named certifications like CISSP and CISM as QV-eligible, and these are specific, named credentials regardless of how they're attributed. Multiple named certifications means this qualifies as Quantified-Verifiable.

fact: Enterprise Cybersecurity Council

fact: CIO

fact: CISO

fact: Director of Information Security

fact: Director of Infrastructure

fact: CISM certification

fact: CISSP certification

fact: CEH certification

fact: CCNA certification


reasoning: The paragraph lists key elements of the company's cybersecurity risk management program—risk assessments, a security team, external service providers, training, incident response plan, and third-party risk management—all describing internal processes. No named frameworks, specific roles (just 'a security team'), named tools, dates, or quantified details appear; every element is a generic practice that could apply to any company.

thinking:
Let me classify this paragraph.

Content: Lists key elements of cybersecurity risk management program - risk assessments, security team, external service providers, training, incident response plan, third-party risk management.

Category: Risk Management Process - describes internal cybersecurity processes and program elements.

Specificity: Let me check for specific facts:
- No named frameworks
- No cybersecurity-specific titles (just "a security team")
- No named tools, firms, dates, numbers
- Generic practices: risk assessments, security controls, awareness training, incident response plan, third-party risk management
- All generic/boilerplate language

This is Generic Boilerplate (1).


reasoning: The paragraph is an introductory overview of the company's cybersecurity programs — their importance, regulatory guidance, sustainability alignment, and independent operation. The CISO→CTO reporting line is one sentence of attribution rather than the primary content; applying the person-vs-function test, removing the CISO/CTO sentence leaves a coherent description of the program's purpose and operational posture. CISO and CTO are cybersecurity-specific titles on the IS list, elevating specificity to Firm-Specific, but neither qualifies as QV-eligible.

thinking:
Let me analyze this paragraph.

Content: Describes the importance of cybersecurity programs, mentions regulatory requirements, sustainability efforts, CISO reporting to CTO, and general operation of programs.

Category: The paragraph mentions CISO reporting to CTO (Management Role signal), but also describes the program broadly (Risk Management Process). The CISO/CTO mention is about reporting structure - who reports to whom. But the paragraph's primary content is about the cybersecurity program overall. Let me apply the person-vs-function test: if I remove "Our CISO, who reports directly to our CTO, has day-to-day responsibility for our cybersecurity programs" - the rest is about the importance of programs, regulatory requirements, sustainability. The CISO/CTO reporting line is one sentence but it's substantive - it tells you about the person's reporting structure.

Looking at this more carefully, the core of the paragraph is really about the program itself—its regulatory foundation, operational independence, and sustainability—rather than the management structure. The CISO-to-CTO reporting relationship is mentioned but feels secondary to the broader program description. I'm leaning toward Risk Management Process as the primary category since the paragraph establishes what the program is and how it operates, with the management reporting line being supporting detail rather than the main point.

For classification purposes, CISO and CTO are both named cybersecurity-specific roles that appear on the IS list, making this Firm-Specific. There's no quantifiable data here—no dates, financial figures, headcount, or named organizations—so this doesn't qualify as QV.

fact: CISO role identified

fact: CISO reports directly to CTO


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected us, including our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No named frameworks, roles, dates, firms, or other specific facts are present — 'malware and computer virus attacks' and 'threats to and breaches' are generic incident language on the NOT list.

thinking:
Let me analyze this paragraph.

Content: It contains a materiality assessment ("have not materially affected us, including our business strategy, results of operations or financial condition"), mentions past threats/breaches vaguely, and cross-references to Risk Factors.

Category: The paragraph makes an explicit materiality assessment → Strategy Integration per Rule 6. The cross-reference doesn't change this.

Specificity: Let me check for specific facts. No dates, no dollar amounts, no named firms, no named tools, no named roles, no named committees, no named frameworks. "Malware and computer virus attacks" is generic incident language. The cross-reference titles are just risk factor names. → Generic Boilerplate.


reasoning: The paragraph describes the qualifications (25 years of experience) and responsibility of the SVP of IT for the cybersecurity program, making it about the person rather than the function. SVP of IT is a cybersecurity-specific leadership role (per IS list), and '25 years' is a specific number, but only one QV-eligible fact (years of experience; named roles don't count toward QV), so Firm-Specific rather than Quantified-Verifiable.

thinking:
Classify this paragraph.

Content: About the SVP of IT and their experience/responsibility for cybersecurity program management.

Category: Management Role - describes who the person is (SVP of IT), their experience (25 years), and their responsibility.

Specific facts:
- "over 25 years of experience" - quantified (years of experience)
- "SVP of IT" - this is a named role... but is it cybersecurity-specific? The IS list includes "VP of IT/Security". SVP of IT is similar. I'll count it.

Wait - "SVP of IT" - the IS list says "VP of IT/Security". SVP of IT is close enough to be cybersecurity-specific given the context of overseeing cyber security functions.

Now I'm checking the QV eligibility: the specific number of years qualifies, but the named role doesn't. That gives me just one QV-eligible fact, so this falls into Firm-Specific rather than QV.

fact: over 25 years of experience in IT leadership roles

fact: SVP of IT


reasoning: Management is the grammatical subject throughout ('Our management is generally responsible...', 'our management shall promptly report...', 'our management reports to...'). The paragraph describes management's responsibilities and reporting structure to the Audit Committee, fitting Management Role. However, it contains no person-specific details (no named roles, credentials, or qualifications) — it describes a generic governance structure. All entities are on the NOT list: 'management', 'Audit Committee', 'Board of Directors', 'third-party information technology consultant' (unnamed), 'regular basis' (generic cadence).

thinking:
Let me analyze this paragraph.

This is from GigCapital7 Corp., a SPAC (GigCapital7 - the name suggests it's a serial SPAC sponsor). Let me check if this is a SPAC/shell company situation.

The paragraph describes management's role in assessing cybersecurity risks, mentions a third-party IT consultant, reporting to Audit Committee, and board delegation.

Content category: This is a mixed paragraph. It talks about management responsibility, a third-party consultant, and board oversight. The primary subject is "our management" - management is the grammatical subject performing actions. But it also describes the Audit Committee's role.

Management is the primary actor throughout—assessing risks, engaging consultants, and reporting to the Audit Committee. The paragraph focuses on what management does functionally rather than who they are, so it's really describing processes and governance structure rather than management credentials or background. I'm checking whether this fits Management Role based on the grammatical subject and reporting structure—management is clearly the focus here, describing their responsibilities and how they report to the Audit Committee. Looking at the specificity now: all the references are generic (unnamed management, unspecified consultant, generic committees and cadences), so this lands as Generic Boilerplate.

I notice the company name "GigCapital7" suggests it might be a SPAC, but the paragraph describes an actual operational structure rather than explicitly stating they have no operations, so I won't apply that exception.


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected us, including our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. The threat types listed (social engineering, denial of service, malware) are generic examples, and no named frameworks, firm-specific facts, dates, or quantified details are present.

thinking:
Let me analyze this paragraph.

The paragraph contains a materiality assessment ("such risks have not materially affected us, including our business strategy, results of operations or financial condition") plus some generic threat examples and a cross-reference.

Per Rule 6 and the codebook: any paragraph with an explicit materiality assessment is Strategy Integration, even with a cross-reference appended.

Specificity: The threat types mentioned (social engineering, denial of service, malware, computer virus) are common/generic. No named frameworks, no firm-specific facts, no dates, no dollar amounts. → Generic Boilerplate.


reasoning: The paragraph's primary communicative purpose is identifying who leads cybersecurity processes (PEO and PFO) and their reporting line to the audit committee, making Management Role the dominant category per Rule 2 ('Management role reports TO the board → Management Role'). However, PEO and PFO are generic C-suite titles (NOT list), the managed services provider is unnamed, 'audit committee' is standard, and 'annual' is a generic cadence — no facts from the IS list remain after filtering, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes who leads cybersecurity processes (PEO and PFO), mentions managed services provider, and reporting to audit committee annually.

Category: This is about management's role in cybersecurity. The grammatical subjects are the PEO and PFO. But let me apply the person-vs-function test. The paragraph describes what these roles do (lead processes, report to audit committee) but doesn't describe their qualifications, background, or credentials. It's more about the function than the person. However, the primary actors are management roles reporting to the board.

Actually, looking more carefully: the paragraph has two main parts:

1. PEO and PFO lead cybersecurity processes along with managed services provider
2. PEO and PFO report to audit committee annually

The dominant topic is Management Role—it's about who leads the processes and their reporting lines. Even though PEO and PFO are generic C-suite titles, the paragraph focuses on their responsibilities and governance structure rather than their individual qualifications. The PEO and PFO aren't cybersecurity-specific roles—they're generic C-suite positions that exist everywhere—but the paragraph is fundamentally about their management role in cybersecurity oversight and their reporting structure to the board. Looking at the specificity markers: the managed services provider is unnamed, the audit committee is generic, the cadence and program names are all non-specific. This clearly falls under Management Role.

No named frameworks or concrete facts here—this is just generic boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity processes — periodic risk assessments, security control evaluation, and employee training. No named frameworks, no cybersecurity-specific roles, no dates or numbers are present. The 'third-party managed security service provider' is unnamed and falls on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes periodic risk assessments, security controls evaluation, employee training (both from third-party MSSP and internal). This is about the company's own internal processes.

Category: Risk Management Process - describes internal cybersecurity processes (risk assessments, security controls, employee training).

Specificity check:
- "periodic risk assessments" - generic practice
- "third-party managed security service provider" - unnamed entity (NOT list)
- "training employees" - common practice
- No named frameworks, no specific roles, no dates, no numbers

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


reasoning: The paragraph describes the company's internal process for identifying and assessing cybersecurity risks, including ERM integration and cross-functional collaboration — squarely Risk Management Process. The named 'Cybersecurity Governance, Risk and Compliance (GRC)' team is a named internal program with a distinguishing abbreviation, qualifying as a firm-specific fact, but there is only one such fact so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal risk assessment process - GRC team, enterprise risk professionals, collaboration with SMEs for identifying/assessing cyber risks.

Category: Risk Management Process - describes internal processes for identifying and assessing cybersecurity risks, ERM integration.

Specific facts:
- "Cybersecurity Governance, Risk and Compliance ("GRC") team" - this is a named internal program/team with a unique identifier (GRC acronym). This qualifies as a specific fact.

No named frameworks, no dates, no dollar amounts, no named third-party firms, no named tools. Just one specific fact (the named GRC team).

This paragraph is firm-specific because it references their internal GRC team by name, which is the only concrete identifier present.


reasoning: The paragraph describes the company's internal cybersecurity training and awareness programs—employee data handling responsibilities, annual privacy/security training, and specialized developer training—all of which are internal risk management processes. No named frameworks, cybersecurity-specific roles, dates, tools, or other IS-list facts are present; 'annual' is a generic cadence and 'security awareness training' is a common practice.

thinking:
Classify this paragraph.

Content: describes employee training programs - security awareness training, annual privacy/security training, specialized developer training. This is about internal processes.

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

Specificity: Let me check for specific facts.
- "annual privacy and security training" - generic cadence + common practice
- "specialized training of our development staff" - mentions a specific team but "development staff" is generic
- No named frameworks, no named roles from IS list, no dates, no numbers, no named tools

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


reasoning: The paragraph describes how the company monitors and manages cybersecurity risks through briefings, threat intelligence, and security tools. Although 'management team' is the grammatical subject, applying the person-vs-function test shows the content is about monitoring processes and information sources, not about who the managers are, their credentials, or reporting lines. No named roles (CISO/CIO), no named frameworks, tools, firms, dates, or other specific facts — everything is generic and interchangeable across companies.

thinking:
Classify this paragraph.

Content: Management team monitors cybersecurity through briefings, threat intelligence, and security tools. This is about management's role in monitoring cyber risks.

Category: The grammatical subject is "Our management team" - but this describes what they do (monitor, prevent, detect, mitigate) through various means. This is about the function/process, not about who the person is. "Management team" is generic - no named roles like CISO. This is describing internal processes for monitoring cybersecurity.

Actually, let me reconsider. The subject is "management team" which is generic. The paragraph describes how management stays informed - through briefings, threat intelligence, alerts. This could be Management Role or Risk Management Process.

Applying the person-vs-function test: if I swap "management team" for "the Company," the sentence still works as a process description. There are no specific roles or credentials mentioned, just the monitoring function itself. The paragraph is really about the processes and mechanisms for staying informed about cybersecurity risks, not about the people doing it. This looks like Risk Management Process.

Now I'm checking the specificity level. There are no named frameworks, no specific roles beyond the generic "management team," no named tools, and no dates or numbers. Everything is described in broad terms like "internal security personnel," "security tools," and "various means." That makes this Generic.


content_category: None/Other

reasoning: The paragraph consists of a generic statement about investing in system security (no process, framework, or methodology described) followed by a cross-reference directing readers to the Risk Factors section. The phrase 'risks that may materially affect us' is not a materiality assessment/conclusion — it merely points the reader elsewhere for that discussion, making it a cross-reference rather than Strategy Integration. No substantive cybersecurity disclosure content is present.

thinking:
Let me analyze this paragraph.

Content: Two parts - (1) generic statement about investing in security/resiliency, (2) cross-reference to Risk Factors with a materiality framing.

Category: The first sentence describes generic investment in systems security. The second sentence is a cross-reference to Risk Factors that includes "materially affect" language. But this is not a materiality *assessment/conclusion* — it's directing the reader elsewhere for discussion of risks that "may materially affect." It's saying "for discussion of how cyber risks may materially affect us, see Risk Factors." That's a cross-reference, not a materiality conclusion.

So I'm checking this against the codebook criteria: a pure cross-reference with no materiality assessment is None/Other, and the key question is whether the paragraph makes a substantive claim about cybersecurity's impact or just points elsewhere. The first sentence is generic investment language, and the second sentence is purely directional—it doesn't conclude anything about materiality, just redirects to Risk Factors. There's no statement like "have not materially affected" or "are not reasonably likely to materially affect." The tension here is whether that opening sentence about investing in security counts as substantive enough, but it's really just describing what they do, not claiming any business impact. investing in security and resiliency is too vague to constitute substantive disclosure—it's really just a generic statement without any actual process, framework, or methodology described. The paragraph also leans heavily on cross-references, so I'm leaning toward None/Other despite the borderline nature.


reasoning: The paragraph describes the company's investment in cybersecurity people, processes, and technology to execute its Information Security Program — all internal process topics. However, it names no specific tools, vendors, frameworks, roles, dates, or quantified investments; 'market-leading technology,' 'award-winning security partners,' and 'best-in-class providers' are all unnamed and generic marketing language that could appear in any company's filing.

thinking:
Let me analyze this paragraph.

Content: Describes investment in people, processes, technology for their Information Security Program (ISP). Mentions "market-leading technology" and "award-winning security partners" but names nothing specific.

Category: Risk Management Process - discusses internal processes, technology investments for cybersecurity program execution.

Specificity: No named frameworks, no named tools, no named firms, no specific dates, no numbers. "ISP" could be a named internal program - "Information Security Program" abbreviated as "ISP" - but ISP is pretty generic. Actually, looking at the IS list: "Named internal programs with unique identifiers" - "ISP" is just a generic abbreviation for Information Security Program, similar to "cybersecurity program." Not unique enough.

The rest of the language is just vague marketing speak—"market-leading," "award-winning," "best-in-class"—without any actual names or specifics attached. This is clearly generic boilerplate.


reasoning: The paragraph opens with an explicit materiality assessment ('has not experienced any cybersecurity incidents that materially affected our business strategy, operational results, or financial condition'), which is the substantive content per Rule 6. The remainder is generic vigilance language and a lengthy cross-reference to Item 1A Risk Factors, which does not change the classification. No firm-specific facts appear — the cross-reference title is boilerplate risk language, not a cybersecurity-specific fact.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. A materiality assessment: "has not experienced any cybersecurity incidents that materially affected our business strategy, operational results, or financial condition"
2. Generic vigilance language
3. A lengthy cross-reference to Risk Factors

The first sentence is an explicit materiality assessment → Strategy Integration per Rule 6.

Specificity: No named standards, no firm-specific facts from the IS list. The cross-reference names a specific risk factor title, but that's just a company self-reference/cross-reference. → Generic Boilerplate.


reasoning: The paragraph describes internal cybersecurity controls (encryption, MFA, role-based access controls), which are the company's own risk management processes. However, it contains no named frameworks, no firm-specific facts, and no quantified details — these are common practices described in generic terms that could apply to any company.


reasoning: The paragraph's primary communicative purpose is describing the organizational assignment of cybersecurity responsibility to a management-level committee (the ISC). Senior leadership is the grammatical subject performing the key action of assigning responsibilities, making this about management structure rather than board governance (the board is mentioned only subordinately, 'in consultation with'). The named committee 'Marchex Information Security Committee (ISC)' is a non-generic committee with a unique identifier, qualifying as a firm-specific fact, but there is only one QV-eligible fact so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes commitment to cybersecurity, references risk factors, then describes that senior leadership assigned responsibilities to the "Marchex Information Security Committee" (ISC) comprised of senior representatives.

Category: The paragraph's primary content is about who is responsible for the cybersecurity program. The grammatical subject performing the key action is "senior leadership, in consultation with our board of directors" - they assigned responsibilities to the ISC. This is about management structure/organizational responsibility. The ISC is a management-level committee (not a board committee). This feels like Management Role - it's about organizational structure and who is responsible.

Actually, let me reconsider.

The board is mentioned but subordinately ("in consultation with"). The main action is assigning responsibility to the ISC, which is a management committee, so this is clearly about management organizational structure. The person-versus-function test confirms it: this is about who's responsible, not the function itself, which points to Management Role. The ISC is a named internal committee with a specific identifier, making it firm-specific.

Looking at the specificity more carefully, I have the named committee with its unique identifier, but the other elements—senior representatives and board of directors—are generic descriptions. That's only one concrete, hard fact that qualifies, so this doesn't meet the threshold for two QV-eligible facts. It's Firm-Specific, not Firm-Specific (✓ IS).

fact: Marchex Information Security Committee ("ISC") — named non-generic committee with unique identifier


reasoning: The paragraph describes the IT Security Team's functions — risk management, compliance oversight, policy review, benchmarking, and security awareness — all internal cybersecurity processes. Applying the person-vs-function test, the content is about what the team does (the function), not who the team members are (the people). No named frameworks, specific dates, named tools, or other facts from the IS list are present; 'IT Security Team' is a generic team name and 'cybersecurity framework' is unnamed.

thinking:
Classify this paragraph.

Content: Describes what the IT Security Team does - addresses cyber risk, oversees compliance with framework, facilitates risk management, reviews policies, benchmarking, security awareness program.

Category: This is about internal processes and what the team does. The "IT Security Team" is mentioned as the subject, but this is describing the function/activities, not the people's credentials. Applying the person-vs-function test: remove "The IT Security Team" and replace with "The Company" - it still makes sense as a process description. → Risk Management Process

Specificity: Let me check for specific facts.
- "IT Security Team" - this is a generic team name, not a cybersecurity-specific title from the IS list

- "security architecture and engineering, identity and access management and security operations" - these are common practice areas
- "cybersecurity framework" - unnamed, generic
- "security awareness program" - generic program name

No named frameworks, no specific facts from IS list. → Generic Boilerplate


reasoning: The paragraph is entirely about the CSO as a person — their tenure, years of experience, career background, and education. This is the person-vs-function test clearly pointing to Management Role. Two or more QV-eligible hard facts are present: 'four years' tenure and 'more than 14 years of experience' are specific numeric durations, reaching the QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the CSO's responsibilities and qualifications - experience, credentials, background. The paragraph is about the person (CSO) - their tenure, experience, education. This is Management Role.

Specific facts:
- CSO (cybersecurity-specific title) → named_role
- "four years" in role → quantified
- "more than 14 years of experience" → quantified
- "Ph.D. in privacy and security" → other_specific (but no named university, so not QV-eligible)
- HIPAA → framework

QV check: specific durations ("four years", "14 years") are QV-eligible as specific numbers. That's two hard verifiable facts → Quantified-Verifiable.

fact: CSO (Chief Security Officer)

fact: four years in current role

fact: more than 14 years of experience managing cybersecurity risk

fact: HIPAA-regulated entities

fact: Doctorate of Philosophy (Ph.D.) in privacy and security


content_category: Incident Disclosure

reasoning: The paragraph describes an actual cybersecurity incident — the CrowdStrike-caused outage on a specific date, the company's response actions, and restoration timelines. Multiple QV-eligible hard facts: specific date (July 19, 2024), named third-party firm (CrowdStrike), and specific restoration durations (24 hours, three calendar days).

thinking:
Let me analyze this paragraph.

Content: Describes a specific incident (CrowdStrike outage on July 19, 2024), response actions, and restoration timeline.

Category: Incident Disclosure - describes what happened, when, response actions, and restoration scope.

Specific facts:
- July 19, 2024 (specific date)
- CrowdStrike (named third-party firm)
- "within 24 hours" and "fewer than three calendar days" (specific durations)

Specificity: Date + named firm = 2 QV-eligible facts → Quantified-Verifiable

fact: CrowdStrike

fact: restored within 24 hours

fact: fewer than three calendar days


reasoning: The paragraph narrates an actual cybersecurity incident — the Change Healthcare breach — describing its operational impact on Veradigm's customers (disrupted network connections, claims submissions, billing), clarifies the company's own systems were unaffected, and describes response actions (mitigation steps). This is incident narrative and response, not a pure financial/materiality assessment, making it Incident Disclosure. Two QV-eligible hard facts: named firm (Change Healthcare) and specific timeframe (first quarter of 2024).

thinking:
Let me analyze this paragraph.

The paragraph describes the impact of the Change Healthcare cybersecurity incident on Veradigm's customers. It's about an incident that affected a third party (Change Healthcare) and its downstream impact.

Content category: This describes what happened in a cybersecurity incident - the Change Healthcare incident disrupted customers' abilities. It describes the nature, scope, timing, and response. But it's actually about a third-party incident's impact on the company. Let me think...

The paragraph describes: a specific incident (Change Healthcare), timing (first quarter 2024), what happened (disrupted customers' claims/billing), clarifies the company's own systems weren't affected, and mentions mitigation steps. This is describing an actual cybersecurity event and its impact. It's an incident disclosure - describing what happened, when, scope, and response actions.

So the key distinction here is whether this is Incident Disclosure or Strategy Integration. The paragraph narrates the operational disruption to customers and the mitigation steps taken in response, which points toward Incident Disclosure rather than just discussing financial impact. it. I'd lean Incident Disclosure - it's describing the incident's effects and the company's response, even though it was a third-party incident.

Actually, re-reading: the paragraph is about the business/operational impact on customers, not really describing the incident itself (that was Change Healthcare's incident). The company is disclosing how a third-party cyber incident affected their business operations. This feels more like Strategy Integration - business impact of a cyber event.

Hmm, but the tiebreaker: "Paragraph DESCRIBES what happened in an incident" - it does describe what happened (disrupted network connections, affected claims submissions and billing, caused delay and downtime) and response actions (took steps to mitigate).

I think Incident Disclosure is appropriate here. The paragraph narrates the event timeline, scope of impact, and response actions. It's not purely about financial/materiality impact.

Now I'm checking the specificity - there's a named third-party firm and a specific timeframe, which gives me two concrete, verifiable facts that qualify for Quantified-Verifiable.

fact: Change Healthcare (named third-party firm whose incident is described)

fact: first quarter of 2024


reasoning: The paragraph describes the Inland CSIRT program — its purpose, membership, and notification decision framework — making it about the function (incident response process) rather than any individual person. Applying the person-vs-function test, removing the VP Director's credentials leaves a complete process description. Specificity is Firm-Specific: multiple IS-list facts (named program with unique identifier, cybersecurity-specific role, team composition), but only one QV-eligible hard fact (20 years of experience), which falls short of the two needed for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes an incident response team ("Inland CSIRT"), its composition, members' qualifications, and a notification framework.

Category: This is primarily about Risk Management Process. It describes the CSIRT team structure, notification framework, and incident management processes. While it mentions specific roles, the paragraph is about the function/program (CSIRT), not about the person. The VP Director's experience is mentioned but subordinate to the overall process description.

Wait - let me reconsider. There's a named internal program (Inland CSIRT), specific roles (VP Director of IT Infrastructure & Information Security), specific experience (20 years), team composition (legal, risk, communications), and a notification decision framework.

Now I'm applying the person-versus-function test: if I remove the VP Director, the CSIRT program and its incident management capabilities still stand. So this is fundamentally about the Risk Management Process. Looking at the specific details—the named program "Inland CSIRT" with its unique identifier, the cybersecurity-specific title, the 20-year experience metric, and the notification framework with severity thresholds—these are all IS facts that support the process description.

For QV eligibility, I've got the "more than 20 years" as a specific number, but that's the only QV-eligible fact here. The role title and team composition are IS-specific but don't meet QV criteria. With just one QV fact, this classifies as Firm-Specific rather than QV.

fact: Computer Security Incident Response Team ("Inland CSIRT")

fact: more than 20 years of experience in information technology security

fact: Head of Technology Strategy

fact: legal, risk, and communications groups


reasoning: The paragraph is primarily about who manages the cybersecurity program — the CCO's qualifications and experience, the named committee's composition and chair, and the reporting/reliance structure between CCO and Committee. The person-vs-function test confirms this: the content centers on the people (CCO tenure, expertise, committee membership) rather than on processes or tools. Contains a named non-generic committee and specific team composition (Firm-Specific), but only one QV-eligible hard fact (25+ years), so does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes management's role in cybersecurity risk management. Let me identify the key elements:

1. The Fund's CCO and the Investment Adviser's Technology Risk and Information Security Committee manage the cybersecurity program
2. The CCO oversees the oversight function and relies on the Committee
3. The Committee is chaired by an outside cybersecurity/IT expert
4. Committee members: CFO, General Counsel, Director of Information Technology
5. CCO has been responsible since inception, 25+ years in financial services

**Content Category:**
This is about management roles - who the people are, their qualifications, the committee structure. The paragraph tells us about the CCO's experience, the committee composition, and reporting structure. This is about the *people* managing cybersecurity, not about the processes themselves.

→ **Management Role**

Now I'm checking the specificity of the details mentioned. The Technology Risk and Information Security Committee is a named, non-generic committee, which qualifies. The CCO's 25+ years of experience in financial services is a specific credential. The Director of Information Technology is listed as a committee member, though it's a more generic IT title compared to specialized security roles, but it's still part of the named committee structure.

Looking at what counts as QV-eligible facts: the 25+ years of experience is one concrete data point. The committee composition itself—listing the CFO, General Counsel, and Director of IT—doesn't qualify as QV-eligible since team rosters aren't on that list. So I'm counting just one QV fact here, which means this falls into the Firm-Specific category with limited quantifiable support.

fact: More than 25 years in financial services industry


reasoning: The audit committee is the grammatical subject receiving cybersecurity reports, making this Board Governance. The 'Director of IT Operations and Security' is a cybersecurity-specific title on the IS list, triggering Firm-Specific. Other elements (audit committee, periodic cadence, Principal Accounting Officer) are generic and do not count.

thinking:
Let me analyze this paragraph.

Content: The audit committee receives reports from Principal Accounting Officer and IT department about cybersecurity threats/risks, and from the Director of IT Operations and Security.

Category: The audit committee is the grammatical subject performing the primary action (receiving reports). This is about board-level oversight. → Board Governance

Specificity analysis:
- "audit committee" — generic, on the NOT list
- "Principal Accounting Officer" — generic C-suite title
- "Director of IT Operations and Security" — this is a cybersecurity-specific title (Director of IT Security variant)
- "periodic" — generic cadence, NOT list

- "information technology department" — generic

The "Director of IT Operations and Security" is the only firm-specific fact here, making this a Firm-Specific (3) classification with no quantifiable values present.

fact: Director of IT Operations and Security


reasoning: The paragraph describes the company's internal incident escalation process — who gets notified and how incidents are reported up to the audit committee. This is incident response planning, a core Risk Management Process activity. The roles listed (VP Legal and Compliance, VP Finance, CFO, Director of Information Technology) are all generic corporate/IT titles not on the IS list for cybersecurity-specific roles, and 'audit committee' is explicitly generic per the NOT list, so no firm-specific facts remain.

thinking:
Let me analyze this paragraph.

Content: Describes escalation processes for cybersecurity incidents, naming specific management roles and mentioning reporting to the audit committee.

Category: This is about incident escalation processes and reporting structure. The primary content is about the company's internal processes for handling incidents - who gets notified and how. This is Risk Management Process (incident response planning/escalation procedures).

Could it be Management Role? The paragraph lists roles but doesn't describe any person's qualifications or background. It's about the process of escalation, not about the people.

Could it be Board Governance? The audit committee mention is secondary - the main topic is the escalation process.

Now I'm checking whether the roles mentioned are actually cybersecurity-specific. The list includes general VP and CFO titles, but none of these are specialized cybersecurity positions like a CISO, and the Director of Information Technology is a generic IT role rather than a dedicated security role.

I also notice the Audit Committee is explicitly excluded, and there's no mention of specific frameworks, dates, firms, or quantified metrics—just generic boilerplate language.


reasoning: The paragraph's primary content describes management personnel — their titles and years of experience in cybersecurity-related domains — making it about the persons rather than the function. The second sentence about the Audit Committee reporting to the board is subordinate. VP of Operations and IT qualifies as a cybersecurity-specific title (per VP of IT/Security on the IS list), and '19+ years' is a specific number, but only one QV-eligible hard fact (years of experience); the named role does not count toward QV, so this is Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph has two sentences:
1. Describes management team members (VP of Operations and IT, Head of IT) with 19+ years of experience and their areas of expertise.
2. The Audit Committee reports to the full board regarding cybersecurity activities.

Primary focus: The first sentence is about management personnel - their titles and experience. The second sentence is about board governance (Audit Committee reporting to board). The dominant content is about the management team's qualifications.

Category: Management Role - the paragraph is primarily about who the people are and their experience/qualifications.

Specific facts:
- "Vice President of Operations and Information Technology" - this is a cybersecurity-adjacent title (VP of IT/Security is on the IS list)

- "Head of Information Technology" - generic IT leadership, not cybersecurity-specific
- "19+ years of experience" - this is a concrete number that qualifies
- "Audit Committee" - generic governance structure, not cybersecurity-specific

So I'm counting the VP of Operations and IT role plus the 19+ years as QV-eligible facts, while the Head of IT and Audit Committee references don't meet the criteria.

Looking at what qualifies: the VP title is a named position but doesn't count toward QV on its own. The 19+ years is the one hard verifiable fact. That puts this at Firm-Specific level.

The paragraph focuses on management team qualifications and experience, so the category is Management Role.

fact: 19+ years of experience in cybersecurity and data risk administration


reasoning: The paragraph identifies the Chief Financial and Business Officer as the person overseeing IT/cybersecurity, describes their reporting relationship to the IRT, and provides their experience (7 years). While process elements (IRT implementing programs, monitoring) are present, the primary communicative purpose is establishing who is responsible and their qualifications — a management role disclosure. The CFBO title is a generic C-suite variant (CFO), not a cybersecurity-specific title per the IS NOT list, but '7 years of experience' is one QV-eligible quantified fact, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes management's responsibility for cybersecurity risk, mentions IRT (incident response team), Chief Financial and Business Officer oversees IT department, reports to IRT, 7 years of experience.

Category: This is about management roles - the Chief Financial and Business Officer's oversight and qualifications. But let me apply the person-vs-function test. The paragraph describes both what the IRT does (processes, monitoring, mitigation) and the CFBO's role and experience. The last two sentences focus on the CFBO - their oversight role and experience. The first part about "management" and IRT is more process-oriented.

The CFBO's qualifications and reporting structure are the main focus here, with the process elements serving as context for their responsibilities. This leans toward Management Role since the paragraph is primarily establishing who oversees IT and their background, even though it mentions some operational processes. the paragraph is about management oversight of cybersecurity. The CFBO title is a generic C-suite variant like CFO, so it's not a specific fact, but "over 7 years of experience" gives me one quantified fact—that makes this Firm-Specific.

For the category, I'm weighing whether this is Management Role or Risk Management Process. The paragraph covers both the IRT's processes and the CFBO's oversight role, but it's really establishing the management structure responsible for cybersecurity. The focus is on who oversees it rather than how the processes work, so I'm categorizing this as Management Role.

Now looking at the specificity—the CFBO's seven years of experience is a single qualifying fact, which makes this Firm-Specific.

fact: over 7 years of experience with overseeing risk, compliance, and information technology functions


reasoning: The entire paragraph describes the background, qualifications, and prior experience of the Director, IT Infrastructure & Cybersecurity — it is about the person, not the function. Two specific durations ('two years', 'five years') count as hard verifiable facts, reaching the QV threshold.

thinking:
Management Role - about the person's background and qualifications.

Specific facts:
- "Director, IT Infrastructure & Cybersecurity" - cybersecurity-specific title
- "two years" building SOX compliant IT controls
- "five years" at a pharma company
- NIST, HIPAA, CLIA, GxP frameworks mentioned

QV check: "two years" and "five years" are specific durations (years of experience as specific numbers). That's two hard verifiable facts. Plus named frameworks. → Quantified-Verifiable.

fact: two years building SOX compliant IT controls framework for a biotech company

fact: five years at a publicly traded pharmaceuticals company

fact: NIST

fact: HIPAA

fact: CLIA

fact: GxP security models


reasoning: The board and Audit Committee are the grammatical subjects performing oversight actions (delegating, overseeing), making this Board Governance. The 'General Administrative Leadership team' is a named, non-generic team unique to this company, triggering Firm-Specific. No second hard verifiable fact prevents QV.

thinking:
Let me analyze this paragraph.

Content: Board delegated cybersecurity risk management to Audit Committee, which oversees through "General Administrative Leadership team."

Category: Board Governance - the board/Audit Committee is the grammatical subject performing oversight actions.

Specific facts:
- "Audit Committee" - generic, on the NOT list
- "General Administrative Leadership team" - this is a named team/committee specific to this company, not a standard governance body
- "board of directors" - generic

The "General Administrative Leadership team" seems like a firm-specific team name. It's not a standard committee name.

Specificity: The General Administrative Leadership team is a specific team composition/name unique to this company → Firm-Specific (3).

Since there's only one specific fact here, this doesn't qualify as QV.

fact: General Administrative Leadership team


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected... business strategy, results of operations or financial condition'), making it Strategy Integration per Rule 6. The cross-reference to Risk Factors and generic threat acknowledgment are noise. No specific facts are present — all language is boilerplate.