reasoning: The paragraph identifies a cybersecurity-specific leadership role (EVP of Information Security and Disaster Recovery), describes their qualifications (degree, certifications, 30+ years experience), and reporting line (to COO). While there is some process/ERM content, the dominant focus is on who the person is and what makes them qualified — satisfying the person-vs-function test for Management Role. Specificity is Firm-Specific: the cybersecurity-specific title and 30 years of experience are IS-list facts, but only one QV-eligible hard fact (30 years) exists — 'multiple university certifications' is vague (not named) and the degree lacks a named university, so QV threshold of two is not met.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. Internal cybersecurity team oversees risk management, incident prevention, detection, remediation
2. Leadership includes "Executive Vice President of Information Security and Disaster Recovery" who reports to COO
3. EVP's qualifications: bachelor's in computer information systems, multiple university certifications in advanced cybersecurity, over 30 years' experience
4. Executive leadership team responsible for ERM, considers cybersecurity risks

This is primarily about the person - their title, qualifications, education, experience, reporting line. The person-vs-function test: the paragraph spends significant text on who the EVP is, their credentials, background. There's also process content (risk management, ERM integration), but the dominant focus is on the management role and qualifications.

Now I'm categorizing the specific facts from this role description. The EVP title is cybersecurity-specific and counts as a named role, and the 30+ years of experience is a quantified credential. The education details are too generic without a named institution, and the certifications lack specificity, so neither qualifies. The reporting line to the COO is standard executive structure.

Looking at what actually meets the QV threshold, I've got just the one quantified fact about experience level. That single qualifying element puts this in the Firm-Specific category rather than QV.

fact: over 30 years' experience in cybersecurity and technology roles


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph makes an explicit materiality assessment ('have not experienced any material cybersecurity events' and 'could materially affect our business strategy, results of operations, or financial condition'), which per Rule 6 classifies it as Strategy Integration. The cross-reference to Risk Factors is appended noise. No specific facts remain after filtering — boilerplate materiality language with generic phrasing.

provider: anthropic

generationId: agent-sdk

stage: benchmark


content_category: Management Role

reasoning: The paragraph describes a management-level delegation chain (ERRC → ISC) and the ISC's composition and mandate, with the CISO as chair. While the second half touches on what the ISC does, the dominant purpose is identifying the management committee structure responsible for cybersecurity — who manages it, who sits on the council, and what authority they hold. Multiple firm-specific facts (named councils, CISO role, specific departmental composition) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or tools).

thinking:
Let me analyze this paragraph.

Content: Describes the Enterprise Risk and Return Council delegating to the ISC, CISO chairs ISC, senior management composition, ISC's functions.

Category: This is about management committees and their roles. The primary subject is the ISC (a management-level council), chaired by the CISO. It describes what the ISC does - monitors risks, makes decisions, escalates, oversees policy. The ERRC delegating to ISC is about management structure. This is Management Role - it's about the management committee structure, who chairs it, composition, reporting. Actually, let me reconsider.

The person-vs-function test: Is this about the person or the function? The ISC is described with its composition and what it does.

The CISO chairs the ISC and the paragraph focuses on the committee's structure and delegation chain rather than the specific processes it executes. Even though it mentions what the ISC does—monitoring, deciding, escalating, sponsoring, and overseeing policy—the dominant framing is about the management committee itself and how it fits into the organizational hierarchy. This clearly falls under Management Role.

Looking at the specificity markers, I see multiple firm-specific details: the "Enterprise Risk and Return Council" and "Information Security Council" are named committees with unique identifiers, the CISO is a cybersecurity-specific role, and "Privacy, Legal and Technology" specifies the actual team composition. There are no quantifiable facts like dates, budgets, headcounts, or named external tools, so this is Firm-Specific.

fact: Enterprise Risk and Return Council (named non-generic committee)

fact: Information Security Council (ISC) — named internal program with unique identifier

fact: CISO chairs the ISC

fact: Representatives from Privacy, Legal and Technology (specific departmental composition)


content_category: Risk Management Process

reasoning: The paragraph describes Allstate's general process for hiring and training cybersecurity staff — candidate evaluation, interviews, and continuing education. This is about the company's internal workforce management function, not about any specific person's credentials or background (which would be Management Role). No named frameworks, specific roles from the IS list, dates, tools, or quantified facts are present — the language is entirely generic and could apply to any company.

thinking:
Classify this paragraph.

This is about hiring and training cybersecurity staff - the process of evaluating candidates, interviewing, and providing continuing education. This is about the function/process, not about a specific person's credentials.

Content category: Risk Management Process - describes internal processes for staffing and training cybersecurity team.

Wait - could this be Management Role? No, it's about the general hiring process and staff development, not about a specific person's qualifications or background.

Specificity: No named frameworks, no specific facts from the IS list. Generic descriptions of hiring and training. → Generic Boilerplate.


reasoning: The paragraph describes internal cybersecurity processes — assessments, vulnerability scans, penetration tests, and remediation tracking — making it Risk Management Process. No named frameworks, cybersecurity-specific roles, dates, or other IS-list facts are present; 'periodic,' 'vulnerability scans,' and 'penetration tests' are all on the NOT list as generic cadences and common practices.

thinking:
Classify this paragraph.

Content: Describes internal processes - assessments, vulnerability scans, penetration tests, tracking findings. This is about the company's own cybersecurity processes.

Category: Risk Management Process

Specificity: Let me check for facts.
- "vulnerability scans and penetration tests" - common practices, NOT list
- "periodic assessments" - generic cadence, NOT list
- "Allstate's governance, risk and compliance standards" - company self-reference, NOT list

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


reasoning: The paragraph describes the company's own internal security operations (24/7 staffing) and incident response program — both are internal cybersecurity processes. No named frameworks, cybersecurity-specific roles, tools, dates, or other facts from the IS list are present; '24/7 operations' and 'incident response program' are common generic descriptions.

thinking:
Classify this paragraph.

Content: Describes 24/7 security operations and incident response program. This is about internal processes.

Category: Risk Management Process - describes internal security operations and incident response program.

Specificity: No named frameworks, no firm-specific facts from the IS list. "Dedicated personnel" is generic, "24 hours per day, seven days per week" is a common practice description, "incident response program" is a generic program name. No CISO, no named tools, no dates, no numbers.

Wait - "Allstate's incident response program" - company self-reference doesn't count. No specific facts.

→ Generic Boilerplate


specificity_confidence: medium

reasoning: The paragraph describes the company's internal processes for identifying, assessing, and managing cybersecurity risks through holistic and focused reviews. The specific departmental composition ('finance, legal, tech, and operations teams') is a firm-specific organizational detail, but unnamed external advisors and generic program descriptions don't add further specificity.

thinking:
Let me analyze this paragraph.

Content: Describes the company's processes for identifying, evaluating, and managing cybersecurity threats. Lists threat types, describes holistic and focused review processes, mentions team compositions.

Category: Risk Management Process - describes internal processes for risk assessment and management.

Specificity: Let me check for specific facts.
- "executive leadership team" - generic
- "finance, legal, tech, and operations teams" - this is a specific team/department composition → IS list item
- "external legal, financial, and risk advisors" - unnamed entities → NOT list
- "cybersecurity team" - generic

- "cybersecurity consulting services firm" - unnamed → NOT list

The specific departmental composition "finance, legal, tech, and operations teams" qualifies as a firm-specific fact per the IS list. That's one concrete fact, so this falls under Firm-Specific (3).

fact: Team composition: finance, legal, tech, and operations teams


reasoning: The paragraph is about the persons filling the CISO and CIO roles — their experience, qualifications, degree, and prior background. This passes the person-vs-function test as Management Role. Two QV-eligible hard facts (9 years and 15 years of experience) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph.

Content: Describes CISO and CIO roles, their experience, qualifications, and responsibilities.

Category: This is about the persons - their experience, credentials, background. The person-vs-function test: the paragraph tells us who these people are, their years of experience, degrees, prior roles. Management Role.

Specific facts:
- CISO (cybersecurity-specific title) ✓
- CIO (cybersecurity-specific title) ✓
- "more than 9 years of experience" - specific number ✓ (QV-eligible)
- "over 15 years of information technology experience" - specific number ✓ (QV-eligible)

- Generic computer science degree without a named institution and vague reference to "another large public company" don't qualify as verifiable facts. The two concrete experience figures though—9 years and 15 years—give me quantified-verifiable credentials to work with.

fact: CISO

fact: CIO

fact: more than 9 years of experience in cybersecurity

type: quantified


category_confidence: medium

reasoning: The paragraph's primary communicative purpose is describing the management reporting structure: the VP of Cybersecurity and CIO are the grammatical subjects who inform stakeholders and provide periodic reports to the Subcommittee, CEO, and CFO. While the paragraph touches on program evaluation and vendor engagement (Risk Management Process territory), the dominant frame is who reports to whom and what those reports contain — management reporting lines. No credentials or background are given, keeping confidence moderate. Two cybersecurity-specific titles (VP of Cybersecurity, CIO) qualify as IS-list facts for Firm-Specific, but neither is QV-eligible.

thinking:
Let me analyze this paragraph.

The paragraph describes the VP of Cybersecurity and CIO's reporting activities and the cybersecurity program's evaluation. Let me apply the person-vs-function test.

The paragraph mentions the VP of Cybersecurity and CIO, but the content is about what they report, to whom, and how the program is evaluated. It's about the reporting structure and program oversight process.

Primary subject: The VP of cybersecurity and CIO providing reports to the Subcommittee, CEO, CFO. This is about management's role in reporting upward. The grammatical subject is management roles.

But wait - is this about the *person* or the *function*? The paragraph doesn't describe credentials, background, or qualifications. It describes what they do (reporting). This is more about the management reporting structure and process.

Looking at the reporting lines and what gets communicated, this is clearly about the management structure—who reports to whom and what information flows through those channels. There's no personal background or qualifications mentioned, just the functional responsibilities of these roles.

For the specific entities: "vice president of cybersecurity" and "chief information officer" are both cybersecurity-specific titles that belong on the IS list, though "Subcommittee" is too vague without a proper name to be useful.

Since I've identified cybersecurity-specific roles but no quantifiable facts like dates, dollar amounts, or named third-party vendors, this falls into the Firm-Specific category with a specificity level of 3.

fact: vice president of cybersecurity

fact: chief information officer (CIO)


reasoning: The paragraph opens with the CISO's credentials briefly but quickly shifts to describing the company's internal risk management committee structure (ERC, Operational Risk Committee, Global IT and Cyber Risk Management Committee) and how they assess cybersecurity vulnerabilities and review strategies — this is predominantly about the company's internal processes and organizational mechanisms for managing cyber risk, not about the person. Multiple named non-generic committees are firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named third-party firms) reach the two-fact threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. CISO appointment and role - "certified CISO who has significant public and private cybersecurity experience"
2. What the CISO does - "assessing data security risk, monitoring cyber threat intelligence, implementing safeguards"
3. ERC and its sub-committees - oversight structure
4. Committee meetings and their purpose

Let me apply the person-vs-function test. The first sentence is about the CISO's credentials. But then it shifts to what the CISO does (function), and then heavily into committee structure and oversight processes.

The dominant content is about committees and organizational structure for risk management. The ERC, Operational Risk Committee, and Global IT and Cyber Risk Management Committee are the primary subjects for most of the paragraph.

The grammatical subjects shift from the CISO to the Enterprise Risk Committee and its sub-committees, which handle the actual oversight work—reviewing cyber exposure, assessing vulnerabilities, and evaluating strategies and policies. These are management-level committees rather than board committees, so the paragraph is really describing the company's risk management process through its governance structure. The committees themselves—Enterprise Risk Committee, Operational Risk Committee, and Global IT and Cyber Risk Management Committee—are all firm-specific structures, not generic ones. Looking at what qualifies for QV eligibility, none of these named roles or committees count, and there are no specific dates, dollar amounts, headcounts, or third-party vendors mentioned. The cadence is just described as "quarterly," which is too generic. This falls under Firm-Specific facts.

fact: certified CISO with significant public and private cybersecurity experience

fact: ERC (Enterprise Risk Committee)

fact: Operational Risk Committee


reasoning: The paragraph describes the company's internal cybersecurity program elements — risk management strategy, incident response plan, risk prioritization methodology — all hallmarks of Risk Management Process. It names ISO 27001 as the basis for its ISMS, which triggers Sector-Adapted, but contains no firm-specific facts from the IS list (ISMS and 'Incident Response Plan' are generic/standard terms, not unique identifiers).

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity program elements - Risk Management Strategy within ISMS, based on ISO 27001, Incident Response Plan, risk prioritization approach.

Category: Risk Management Process - describes internal processes, framework adoption, incident response planning.

Specificity analysis:
- "ISO 27001 framework" - named standard → Sector-Adapted
- "ISMS" - Information Security Management System, generic term
- "Risk Management Strategy within ISMS" - could be a named internal program? It's somewhat specific but "Risk Management Strategy" is fairly generic. "ISMS" is a standard term.

- "Incident Response Plan" - generic program name per the NOT list

Checking against the IS list: no cybersecurity-specific titles, named committees, specific dates, named products or tools, third-party firms, or specific numbers. ISO 27001 is mentioned as a framework basis rather than a certification claim. The "Risk Management Strategy within ISMS" describes the standard ISO 27001 structure, so beyond naming that framework, there's nothing firm-specific here.

Sector-Adapted classification holds—ISO 27001 is named but no unique internal identifiers are present.

fact: ISO 27001 framework

type: framework


reasoning: The opening sentence contains an explicit materiality assessment ('have not experienced any material cybersecurity incidents, a future incident could materially affect us'), which per Rule 6 classifies this as Strategy Integration. The remainder is generic risk language about IT systems, PII, and potential consequences that could apply to any company — no named frameworks, roles, dates, or firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: States no material incidents have occurred, then describes IT reliance and potential impacts of future incidents. The opening sentence is a materiality assessment ("have not experienced any material cybersecurity incidents" + "could materially affect us"). The rest is generic risk language about IT systems, PII, vendors, and potential consequences.

Category: The opening makes a materiality assessment → Strategy Integration per Rule 6. The rest is generic risk language, but the materiality conclusion is the substantive disclosure.

Specificity: No named frameworks, no firm-specific facts from the IS list. "PII", "residents", "associates" are company-context but not from the IS list.

There are no dates, named tools, or specific roles mentioned—this is pure boilerplate language.


reasoning: The paragraph describes the company's internal cybersecurity risk management framework, assessment methodology, ERM integration, and vendor due diligence process — all core Risk Management Process content. The vendor risk assessment at the end is one component of the broader internal program (Rule 3). Multiple named standards (NIST CSF, CIS IG2, SOC1) are referenced, pushing to Sector-Adapted, but no firm-specific facts from the IS list appear: 'CSP' is just an abbreviation of the generic 'cybersecurity program,' cadences are generic ('annual'), and no named roles, tools, firms, dates, or headcounts are present.

thinking:
Let me analyze this paragraph carefully.

Content: Describes their risk management framework, mentions NIST CSF, CIS IG2, annual assessments, vendor risk assessment process including SOC1 reports.

Category: This is primarily about internal cybersecurity processes - risk assessment methodology, framework adoption, ERM integration. There's a vendor component at the end, but it's described as part of their overall program. Per Rule 3, third parties mentioned as one component of internal program → Risk Management Process.

Specificity: Let me check facts:
- Named frameworks: NIST CSF, CIS IG2, SOC1 - these are named standards

- "CSP" is just an abbreviation for "cybersecurity program," which is generic, not a uniquely identified internal program
- The IG2 specification shows they've chosen a particular implementation level of the CIS framework, which is a firm-specific decision
- Annual assessments follow a standard cadence

The named frameworks qualify as at least Sector-Adapted, and the IG2 selection demonstrates some firm-specific customization of their approach.

For QV purposes, I don't have concrete verifiable facts like specific dates, dollar amounts, headcounts, or named third-party vendors—just the cadence of "annual" assessments. So this lands at Sector-Adapted minimum, with the CIS IG2 specification being the firm-specific element.

Actually, I'm second-guessing myself on IG2. The codebook treats named standards as Sector-Adapted, and choosing a specific implementation group within that standard is still just describing which standard they follow, not revealing a unique company decision. I think this stays Sector-Adapted overall.

But wait—they've named their program "CSP" with quotes and an abbreviation. The codebook distinguishes between unique program identifiers like "Cyber Incident Response Plan (CIRP)" and generic names like "cybersecurity program." Since CSP is just shorthand for a generic term, it doesn't qualify as firm-specific. So I'm settling on Sector-Adapted (Level 2)—they reference NIST CSF, CIS, and SOC1, but nothing beyond standard framework choices that would be unique to this company.

fact: NIST CSF framework

fact: CIS control framework Implementation Group 2 (IG2)

fact: SOC1 report requirement for major vendors


reasoning: The paragraph describes the company's internal cybersecurity processes: 'assume breach' philosophy, cross-functional working group structure, penetration testing, threat hunting, third-party reviews, and simulation exercises. While it names the Director of Global Cybersecurity and CIO, these are attributions — the substantive content is about what the program does, not who the people are (person-vs-function test). Multiple firm-specific facts exist (cybersecurity-specific roles, named department, named JV), but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph from Darling Ingredients Inc.'s 10-K filing.

Content: Describes the company's cybersecurity approach, cross-functional working group, Cybersecurity Department structure, Director of Global Cybersecurity role, CIO, activities (pen testing, threat hunting, third-party reviews, simulation exercises).

Category: This is primarily about the company's internal cybersecurity processes and organizational structure. While it mentions the Director of Global Cybersecurity and CIO, the paragraph is fundamentally about what the program does - the "assume breach" philosophy, cross-functional working group, pen testing, threat hunting, third-party reviews, simulation exercises.

Now I'm applying the person-versus-function test: if I remove the role titles, the paragraph still describes substantive processes, so this falls under Risk Management Process. Looking at the specific facts, I can identify several named roles and entities - the Director of Global Cybersecurity and CIO are both cybersecurity-specific titles that belong on the IS list, while the Cybersecurity Department is a named organizational unit, the DGD Joint Venture is another specific entity, and plant operational technology personnel represent a particular team composition.

However, these named roles don't actually count toward QV eligibility, and there are no specific dates, dollar amounts, headcounts, named third-party firms, tools, products, or certifications present. This makes it Firm-Specific information rather than QV-eligible.

fact: Director of Global Cybersecurity

fact: Chief Information Officer (CIO)

fact: Cybersecurity Department as a named organizational unit

fact: Cross-functional working group of Cybersecurity Department and plant OT personnel

fact: DGD Joint Venture (named joint venture)


reasoning: The paragraph's primary content describes the people filling cybersecurity leadership roles — the Director of Cybersecurity and IT Compliance and the interim CIO — including their reporting line, experience domains (consumer goods, automotive, manufacturing, outsourcing), and areas of expertise (cybersecurity, information security, architecture, incident response). While the last two sentences touch on what the CIO does functionally, the dominant purpose is identifying who these people are and what qualifies them. Two cybersecurity-specific roles are named (Director of Cybersecurity and IT Compliance, CIO), satisfying Firm-Specific, but no QV-eligible hard facts (no specific dates, headcounts, named certifications, or named firms) are present.

thinking:
Let me analyze this paragraph.

The paragraph mentions board and management briefly, then focuses on describing the Director of Cybersecurity and IT Compliance and the interim CIO - their reporting lines, experience, and qualifications. The primary content is about the people in these roles.

Content category: Management Role - the paragraph is about the persons (interim CIO and Director of Cybersecurity and IT Compliance), their qualifications, experience, reporting lines. The last two sentences touch on what the CIO does (implements controls, provides updates), but the dominant content is about who these people are and their backgrounds.

Specific facts:
- "Director of Cybersecurity and IT Compliance" - cybersecurity-specific named role ✓

- "Chief Information Officer" / "CIO" - cybersecurity-specific role ✓
- Experience areas: "consumer goods, automotive, manufacturing and outsourcing" - this describes the person's background
- "cybersecurity, information security, policy, architecture, engineering and incident response" - experience areas

For specificity:
- Director of Cybersecurity and IT Compliance = cybersecurity-specific title ✓ (IS list)
- CIO = cybersecurity-specific title ✓ (IS list)
- No QV-eligible hard facts (no specific dates, dollar amounts, headcounts, named third-party firms, named tools, named certifications, specific years of experience as a number)

So this falls into Firm-Specific (3) - the candidate has clearly defined cybersecurity roles but lacks the two hard verifiable QV facts needed for a higher qualification level.


reasoning: The paragraph's primary content is the organizational structure of cybersecurity leadership across three lines of defense, identifying specific roles (COO, CIO, CRO, CISO, Chief Audit Executive) and their responsibilities. While the Security function's duties are mentioned, they serve to contextualize the CISO's role rather than describe processes in detail. The grammatical subjects are the management roles and defense lines, making this Management Role. CIO and CISO are cybersecurity-specific titles on the IS list, triggering Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools, certifications) are present.

thinking:
Let me analyze this paragraph.

Content: Describes a three-lines-of-defense model with specific roles - COO, CIO (first line), CRO and CISO (second line), Chief Audit Executive (third line). Describes the Security function's responsibilities.

Category: This is about management roles and organizational structure. The paragraph describes who leads each line of defense and their responsibilities. The primary content is about the organizational structure and the people/roles in it. But it also describes what the Security function does (protect assets, facilitate incident response).

Person-vs-function test: The paragraph names multiple cybersecurity-specific roles (CIO, CISO, CRO) and describes the organizational structure (three lines of defense).

The Security function's responsibilities are mentioned, but they're framed around who's accountable for what - so the focus is really on the management structure and role assignments rather than the function itself. I'm checking whether I have enough cybersecurity-specific titles to classify this as a firm-specific fact: CIO and CISO are clearly cybersecurity roles, CRO is risk-focused, while COO and Chief Audit Executive are more generic. That gives me the two cybersecurity-specific titles I need.

Now I'm looking for hard verifiable facts - dates, amounts, headcounts, named organizations, specific tools or certifications - but there's nothing concrete here, just role names and organizational hierarchy. Without those quantifiable details, this doesn't meet the QV threshold, so it lands in Firm-Specific.

fact: Chief Information Officer (CIO) leads first line of defense

fact: Chief Information Security Officer (CISO) leads Security function

fact: Three lines of defense organizational structure


content_category: Incident Disclosure

reasoning: The paragraph describes an actual ransomware incident — its timing, scope (Dx IT systems, company-wide operations), investigation findings (no data exfiltration), and response. While the final sentence is a materiality conclusion, the dominant content is the incident narrative itself. One QV-eligible hard fact (July 2018) yields Firm-Specific but not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a 2018 ransomware incident - what happened, scope, investigation findings, and materiality conclusion.

Category: This describes an actual incident (ransomware, July 2018, affected systems, investigation findings). The last sentence is a materiality statement, but the dominant content is the incident narrative. → Incident Disclosure

Specificity:
- "July 2018" = specific date (QV-eligible)
- "ransomware" = type of incident but generic
- "Dx information technology systems" = could be a named system (Dx = Diagnostics segment) - this is borderline, not really a named product/tool

- No named third-party firms, no named tools, no dollar amounts, no headcounts

Only the specific date qualifies as a hard verifiable fact → Firm-Specific.

fact: July 2018


reasoning: The paragraph describes an actual cybersecurity incident: a named external collection agency (AMCA) notified the company on a specific date about a security breach involving patient data, with ongoing litigation. Although it includes cross-references, the dominant content is the incident narrative. Two QV-eligible hard facts (specific date + named third-party firm) yield Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a past cybersecurity incident (AMCA breach from 2019) - specific date, named third party, what happened, plus cross-references to other sections.

Category: This describes what happened in an incident - the nature (external collection agency breach), timing (May 14, 2019), the entity involved (AMCA). The dominant content is incident narrative. → Incident Disclosure

Specificity:
- Specific date: May 14, 2019 ✓ (QV-eligible)
- Named third-party firm: AMCA / Retrieval-Masters Credit Bureau ✓ (QV-eligible)

- Since I have two or more QV-eligible facts here, this qualifies as Quantified-Verifiable.

fact: Retrieval-Masters Credit Bureau, Inc. d/b/a American Medical Collections Agency (AMCA)


reasoning: The paragraph discusses cybersecurity insurance coverage as a financial risk mitigation tool, which falls under Strategy Integration (cyber insurance, business/financial impact). However, it provides no specific details — no named insurers, no coverage amounts, no deductibles — making it Generic Boilerplate that could appear in any company's filing.

thinking:
Classify this paragraph.

Content: cybersecurity insurance coverage at industry standard levels, part of comprehensive insurance portfolio, mitigate risk from information security events.

Category: Strategy Integration - discusses cybersecurity insurance as part of risk mitigation strategy.

Specificity: No named insurers, no dollar amounts, no specific facts. "Industry standard levels" is generic. → Generic Boilerplate.


content_category: Board Governance

reasoning: The paragraph describes how management presents cybersecurity risk assessments to the Audit Committee, making the board's oversight mechanism the primary communicative purpose. Although 'Management' is the grammatical subject, the content is about the information flow to the Board/Audit Committee — how the board gets informed about cyber risks. All entities (Management, Board, Audit Committee) and cadences ('annual') are on the NOT list, leaving no firm-specific facts.

thinking:
Classify this paragraph.

The paragraph discusses management's responsibility for risk management and presenting to the Audit Committee. The grammatical subject is "Management" - but this is generic management, not a cybersecurity-specific role.

The paragraph describes management presenting risk assessments to the Audit Committee. This is about the oversight relationship between management and the board committee - it's describing the board's oversight mechanism (receiving presentations from management).

Actually, let me re-read: "Management is responsible for managing risks and informing the Board..." - Management is the subject, but the content is about the flow of information to the Board/Audit Committee. This is about the governance oversight structure.

The core issue here is whether to classify based on the grammatical subject (Management) or the primary purpose (board oversight). Since the paragraph's main point is how the Audit Committee receives and reviews risk information from management, this leans toward Board Governance rather than a generic Management Role classification.

Looking at the specificity markers: "Management," "Board," and "Audit Committee" are all generic terms on the exclusion list, and "annual basis" is a standard cadence with no firm-specific details or named standards. This points squarely to Generic Boilerplate.


reasoning: The paragraph is entirely about the people filling cybersecurity leadership roles — their titles, years of experience, and certifications. This is squarely Management Role per the person-vs-function test. Multiple QV-eligible hard facts: specific years of experience (8+, 25+) and numerous named certifications (CISSP, ISSAP, CISA, CRISC, CDPSE) far exceed the two-fact threshold.

thinking:
This paragraph describes management roles and their qualifications.

Content: VP of Finance and Technology, IT Director, Cyber Security and Architecture Manager - their responsibilities, experience, and certifications.

Category: Management Role - the paragraph is about the people, their credentials, experience, and qualifications.

Specific facts:
- VP of Finance and Technology (cybersecurity-specific-ish role)
- IT Director (generic IT title per NOT list)
- Cyber Security and Architecture Manager (cybersecurity-specific title)
- 8+ years experience (quantified)
- 25+ years experience (quantified)
- CISSP certification (named cert)

- ISSAP, CISA, CRISC, and CDPSE certifications (named certs)
- Bachelor's and master's degrees in IT/Cyber (generic degrees without named university)

These candidates easily meet the QV-eligible threshold with multiple hard verifiable facts including the quantified experience levels and all five named certifications.

fact: Vice President of Finance and Technology (VP FT)

fact: Cyber Security and Architecture Manager (CSA)

fact: More than 8 years of experience (VP FT)

fact: More than 25 years of experience (CSA)

fact: CISSP certification

fact: ISSAP certification

fact: CISA certification

fact: CRISC certification

fact: CDPSE certification


reasoning: The paragraph describes a management-level Cybersecurity Committee — its composition (VP FT, CSA, and members from Legal, Operations, Internal Audit) and meeting cadence. The primary subject is the committee's structure and membership, making this Management Role rather than Risk Management Process. Multiple IS-list facts (named non-generic committee, cybersecurity-specific roles, specific departmental composition) establish Firm-Specific, but no two QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes a management Cybersecurity Committee, its composition, and meeting cadence. The subject is a management committee, not the board. This is about management's role in cybersecurity oversight.

Wait - is this Management Role or Risk Management Process? The paragraph describes a committee structure, its composition, and what it does. The "person-vs-function" test: this is about organizational structure (who comprises the committee, reporting), not about processes/tools/methodologies. Management Role covers "management committees responsible for cybersecurity."

Category: **Management Role** - The paragraph describes a management committee's composition and structure.

Now I'm checking which elements qualify as specific facts. The Cybersecurity Committee is a named committee, and Legal, Operations, and Internal Audit represent specific departments. The VP FT and CSA roles appear to be cybersecurity-specific positions, though VP FT's exact title is a bit ambiguous. The quarterly meeting frequency is too generic to count as a specific fact.

With multiple firm-specific elements identified, this falls into the Firm-Specific category. However, there aren't enough hard verifiable facts like dates, financial figures, or named external vendors to meet the QV threshold, so this remains Firm-Specific without the QV designation.

fact: VP FT

fact: CSA

fact: Legal, Operations and Internal Audit (committee composition)


reasoning: The paragraph's primary content is the identity and composition of a management-level Cybersecurity Committee — who sits on it (Director of Cybersecurity, Legal, Operations, Internal Audit) and how it is structured. This is organizational structure disclosure about management roles, not a description of internal cybersecurity processes. Three IS-list facts (cybersecurity-specific title, named non-generic committee, specific departmental composition) establish Firm-Specific, but none are QV-eligible (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes a management-level Cybersecurity Committee, its composition, and meeting cadence. The subject is a management committee, not the board.

Category: Management Role - This describes a management committee structure, its composition, and responsibilities. The grammatical subject is "the Company's management Cybersecurity Committee." This is about organizational structure and reporting - who is responsible at the management level.

Wait - let me reconsider. The paragraph describes what the committee does (reviews threats, risks, strategic objectives, progress). Is this about the people/structure or about the process?

The person-vs-function test: The paragraph tells us about the committee's composition (Director of Cybersecurity, Legal, Operations, Internal Audit) and its meeting cadence. If I removed the committee identity, I'd have "reviews cybersecurity threats and risks, strategic objectives, and progress on cybersecurity initiatives" - fairly generic process language. But the primary content is about WHO comprises the committee and HOW it's structured. This is about organizational structure → Management Role.

Now I'm checking the specific facts: the Director of Cybersecurity role, the named Cybersecurity Committee, and the specific departments involved all qualify as list items. However, none of these meet the quantifiable verification threshold - there are no dates, financial figures, headcounts, or named external firms that would make them QV-eligible.

fact: Director of Cybersecurity

fact: Legal, Operations and Internal Audit composition


reasoning: The paragraph primarily describes an actual ransomware incident — its detection date, nature (ransomware), containment, and restoration — making Incident Disclosure the dominant category. The opening sentence about controls is subordinate. Only one hard verifiable fact (the specific date May 4, 2022) is present; 'ransomware' is a descriptor not a QV-eligible fact, and no named firms or tools are mentioned, so it reaches Firm-Specific but not Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a past cybersecurity incident - ransomware on May 4, 2022, affecting internal systems, with containment and restoration actions. It also has a brief intro about controls, but the dominant content is the incident narrative.

Content Category: Incident Disclosure - describes what happened (ransomware), when (May 4, 2022), response actions (containment, business continuity, restoration).

Specificity:
- Specific date: "May 4, 2022" → hard verifiable fact
- "ransomware" → describes the type but not a named tool/firm

- No named third-party firms, no named tools, no dollar amounts, no headcounts

So this is Firm-Specific information - only the date is a concrete verifiable fact, everything else is generic incident description without identifying details.


reasoning: The paragraph describes internal cybersecurity process improvements implemented after an incident — zero trust, security awareness training, MFA, PAM, EDR — which are the company's own risk management activities. While it references a prior incident, the communicative purpose is describing remediation processes, not the incident itself. No named frameworks, no named tools/products, no specific dates, headcounts, or firm-specific facts appear; all terms (zero trust, MFA, PAM, EDR, quarterly training) are common security practices found in any company's disclosure.

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

Content: Describes post-incident remediation actions - hardening identity environments, zero trust, security awareness training, MFA, PAM, EDR. This is about what the company did after an incident to improve processes.

Category: This describes remediation actions taken after an incident. It's describing the company's risk management processes that were implemented post-incident. The paragraph is about process improvements, not the incident itself (no dates, scope, what happened). It's describing internal cybersecurity processes. → Risk Management Process

Specificity: Let me check for specific facts:
- "zero trust environment" - generic concept

- "quarterly basis" - generic cadence
- "multifactor authentication" - common practice
- "Privileged Access Management" - generic concept
- "Endpoint Detection and Response" - generic concept
- No named tools, no dates, no headcounts, no named firms

No named standards (NIST, ISO, etc.). No IS-list facts. Everything here is common security practices described generically. → Generic Boilerplate, Specificity 1


reasoning: The Board and Audit Committee are the grammatical subjects performing oversight—receiving reports, overseeing management's cybersecurity program, and receiving escalations. After filtering, no IS-list facts remain: 'Audit Committee' and 'Board' are generic governance terms, 'Chief Legal Officer' is a generic C-suite role (equivalent to General Counsel), 'IT department' is generic, and 'generally at least once per quarter' is a vague cadence. All content could apply to any public company.

thinking:
Let me analyze this paragraph.

The paragraph is about the Board and Audit Committee's oversight of cybersecurity risk. The Board is the primary actor receiving reports, overseeing management's program. The Audit Committee receives periodic reports. This is clearly Board Governance.

Specific facts:
- "generally at least once per quarter" - generic cadence
- "Audit Committee" - generic (on the NOT list)
- "Board of Directors" - generic
- "Chief Legal Officer" - this is General Counsel equivalent, on the NOT list as generic C-suite
- "IT department" - generic

No named frameworks, no named roles from the IS list (Chief Legal Officer is essentially General Counsel), no specific dates, no named firms.

The Chief Legal Officer is just a generic C-suite title like General Counsel, not a cybersecurity-specific role, so there are no IS-list facts here. This is Generic Boilerplate.


reasoning: The paragraph is entirely about the person filling the cybersecurity leadership role — their title, years of experience, tenure at the company, and career progression through specific prior roles (engineer, infrastructure manager, Director of IT Infrastructure, Global Director of IT). This passes the person-vs-function test as Management Role. Two QV-eligible quantified facts (over 20 years of industry experience + over 15 years at the company) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the VP of IT - their responsibility, team composition, and extensive career background (20+ years experience, 15+ years at company, specific prior roles).

Category: This is about the person - their qualifications, experience, career history. The person-vs-function test: remove the person's identity and credentials, and there's very little left. → Management Role

Specific facts:
- "Vice President, Information Technology" - This is a cybersecurity-specific title? Let me check... The IS list includes "VP of IT/Security". VP of IT fits.
- "over 20 years of industry experience" - specific number (quantified)

- "over 15 years at our Company" - specific number (quantified)
- Named prior roles: engineer, infrastructure manager, Director of IT Infrastructure, Global Director of IT - these are career history details
- "several members" - vague quantifier, NOT list

Both tenure figures qualify as quantified-verifiable facts since they're expressed as specific numbers.

fact: Vice President, Information Technology

fact: over 20 years of industry experience

fact: over 15 years at our Company


reasoning: The paragraph describes engaging external experts to evaluate and test the company's own risk management systems — per Rule 3, external assessors hired to test the company are Risk Management Process, not Third-Party Risk. No named firms, frameworks, roles, dates, or specific numbers are present; all entities are unnamed ('cybersecurity assessors, consultants, and auditors') and all activities are generic ('audits, threat assessments, and consultations'), yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes engaging external experts (assessors, consultants, auditors) to evaluate and test risk management systems. These third parties perform audits, threat assessments, consultations.

Category: The external experts are hired to serve the company's own security program - they're evaluating and testing the company's risk management systems. Per Rule 3: "External assessor hired to test the company → Risk Management Process." The third parties here are serving the company's internal processes, not being overseen as vendors. → Risk Management Process

Specificity: No named frameworks, no named firms, no named roles, no dates, no specific numbers. "External experts," "cybersecurity assessors, consultants, and auditors" are all unnamed entities (on the NOT list). "Audits, threat assessments, and consultations" are common practices. → Generic Boilerplate


reasoning: The paragraph describes an actual cybersecurity incident: unauthorized access on a specific date, data scope (personal information of substantially all customers), and response actions taken. This is squarely Incident Disclosure. Multiple specific dates (October 31, November 2, November 9, December 15, 2023) provide well over two hard verifiable facts, reaching Quantified-Verifiable. Note that 'cybersecurity firms' and 'cybersecurity experts' are unnamed and generic per the NOT list, but the dates alone satisfy the QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes an actual cybersecurity incident - unauthorized access, data obtained, response actions taken. This is clearly Incident Disclosure.

Specific facts:
- "November 2, 2023" - specific date
- "November 9, 2023" - specific date
- "December 15, 2023" - specific date
- "October 31, 2023" - specific date
- "substantially all of our current and former customers" - vague quantifier

The dates are multiple hard verifiable facts. That's 4 specific dates = Quantified-Verifiable.

Wait, but the other details like "cybersecurity firms" and "cybersecurity experts" are unnamed/generic.

The four dates alone are enough to cross the threshold for Quantified-Verifiable.

fact: Form 8-K dated November 2, 2023

fact: Form 8-K/A dated November 9, 2023

fact: Form 8-K/A dated December 15, 2023

fact: Incident occurred on October 31, 2023


reasoning: The paragraph describes ongoing post-incident response actions — law enforcement engagement, litigation defense, and offering identity protection/credit monitoring to current and former customers for two years. These are remediation actions following an actual cybersecurity incident. The specific duration of 'two years' for identity protection services is a firm-specific quantified detail, but it is only one hard fact, so specificity remains Firm-Specific rather than Quantified-Verifiable.

thinking: Describing response actions taken after an incident - offering identity protection services to customers, engaging law enforcement, defending litigation. This is about what happened after a cybersecurity incident.

fact: two years of identity protection services offered


reasoning: The paragraph is headed 'Management Personnel' and its primary content describes who comprises the cybersecurity control group — a Virtual CISO, in-house legal counsel, CISSP-certified consultants — along with their qualifications and experience. This is about the people (credentials, composition, background), not about processes, satisfying the person-vs-function test for Management Role. Specificity is Firm-Specific: the Virtual CISO role and CISSP certifications are IS-list facts, but only CISSP is QV-eligible, falling short of the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the "internal cybersecurity control group" - its composition, the Virtual CISO role, qualifications of retained individuals, and their monitoring/reporting activities.

Category: This is about management personnel - who they are, their qualifications, structure. The paragraph is titled "Management Personnel" and describes the composition of the control group, the Virtual CISO role, and the qualifications of retained individuals. This is Management Role.

Specific facts:
- CISSP certifications (named certification)
- Virtual Chief Information Security Officer (cybersecurity-specific role)
- "at least monthly" reporting cadence

- CISSP is QV-eligible as a named certification, while the Virtual CISO role is firm-specific but not QV-eligible, and the monthly reporting cadence is too generic to qualify.
- Since there's only one QV fact, this triggers the Firm-Specific category.
- The paragraph focuses on the people themselves—their credentials and team composition—rather than the processes they follow, so it falls under Management Role.

fact: Virtual Chief Information Security Officer (retained role)

fact: CISSP certifications held by third-party consultants


reasoning: The paragraph describes the company's cybersecurity measures designed to protect infrastructure and maintain compliance — these are internal risk management activities. No named frameworks, specific roles, dates, or firm-specific details are present; the language is generic and could apply to any energy utility.


reasoning: The paragraph's primary communicative purpose is describing the oversight reporting chain flowing up to the Audit Committee and Board of Directors — how they receive updates, review policies, and get informed about incidents. While the CISO is the grammatical subject in several sentences, the CISO serves as the conduit for board-level oversight, and the Audit Committee's review of policies and controls is a substantial component. CISO and 'head of Global Technology & Operations' are cybersecurity-specific titles on the IS list, making this Firm-Specific, but no two QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses the CISO's role, management reporting to the CISO, and the CISO presenting to the Audit Committee and Board. Let me determine the dominant category.

The paragraph starts with the CISO's responsibility, then describes reporting flows: management → CISO, CISO → Audit Committee/Board. The bulk of the paragraph is about oversight structure and reporting cadence between management and the board.

Who is the primary actor? The CISO is the grammatical subject in most sentences. But the content is mixed - it describes both the CISO's role and the Audit Committee's oversight activities.

Looking at the specific rules, the CISO is clearly the central figure connecting management to the board through quarterly reporting. The paragraph focuses on the function and reporting structure rather than the person themselves, so this is fundamentally about the CISO's role in the governance framework. is about oversight structure - how information flows up to the board. The Audit Committee's role is prominent. But the CISO is the grammatical subject more often...

Let me reconsider the tiebreaker rule. Neither board oversight nor management roles is mentioned only briefly here - both are substantial parts of the description. The paragraph lays out the governance and reporting chain, so I'm leaning toward Board Governance since the ultimate purpose is showing how the board gets informed and exercises oversight through the CISO as the conduit.

Looking at the codebook example about the Audit Committee receiving quarterly CISO reports - this paragraph follows that same pattern, with the Audit Committee reviewing updates from the CISO and policies annually. That points to Board Governance as the right classification.

For specificity, the CISO is a cybersecurity-specific title that belongs on the IS list. "Head of Global Technology & Operations" is a firm-specific role title. "Quarterly" is just a generic cadence. There are no dates, dollar amounts, headcounts, named firms, tools, or certifications, so this doesn't meet the QV threshold. The firm-specific roles push this to a Specificity score of 3.

fact: CISO role identified as senior-level executive

fact: Head of Global Technology & Operations presents to Audit Committee


reasoning: The paragraph's primary content is organizational structure and personnel qualifications: the InfoSec Committee's composition (CEO, CFO, GC, VP of IT), the Security Ops Team's reporting lines, the VP of IT's 20 years of experience, and team members' CISSP certifications. While process elements exist (quarterly reviews, annual presentations), the dominant communicative purpose is identifying who is responsible and why they are qualified — the person-vs-function test favors Management Role. Two QV-eligible hard facts (20 years of experience + CISSP named certifications) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes management's responsibilities for cybersecurity. Let me identify the content:

1. Management implements risk management structures
2. Security Ops Team directs cybersecurity operations
3. SecOps Team meets with InfoSec Committee quarterly
4. Annual presentation to Ethics Committee and Risk Committee
5. InfoSec Committee composition: IT leaders, CEO, CFO, General Counsel, VP of IT
6. VP of IT has 20 years of experience
7. Security Ops Team reports to VP of IT and InfoSec Committee
8. Team members hold CISSP certifications from ISC2

9. The organizational structure combines both people and their qualifications - the VP of IT brings 20 years of experience, the Security Ops Team members are CISSP-certified - alongside the formal reporting lines and committee oversight processes like quarterly reviews and annual presentations to the Ethics and Risk Committees. I'm identifying the specific facts that qualify as quantified or verifiable: the VP's 20 years of experience and CISSP certifications are both concrete, named credentials. That gives me two QV-eligible facts, which means this paragraph should be classified as Quantified-Verifiable.

fact: Vice President of Information Technology

fact: InfoSec Committee (subcommittee of IT leaders and senior management)

fact: Risk Committee of the Board of Directors

fact: Ethics Committee

fact: Security Ops Team

fact: VP of IT has 20 years of experience managing IT systems and personnel

fact: CISSP (Certified Information Systems Security Professionals) certifications from ISC2

fact: InfoSec Committee includes CEO, CFO, General Counsel, and VP of IT


reasoning: The paragraph describes the company's internal incident response and recovery plan, crisis management procedures, reporting protocols, and pre-negotiated contracts with external providers — all internal process descriptions. The crisis management team comprises CEO, CFO, and General Counsel, which are all generic C-suite titles on the NOT list. External providers are unnamed, the incident response plan has no unique identifier, and no frameworks, dates, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes incident response plan, crisis management team composition (CEO, CFO, General Counsel), reporting procedures, pre-negotiated contracts with external providers.

Category: This is about the company's internal processes - incident response plan, crisis management procedures. The crisis management team is CEO/CFO/General Counsel (all generic C-suite). Third-party providers are mentioned but as a component. → Risk Management Process

Specificity: Let me check facts:
- "crisis management team (comprised of the Company's Chief Executive Officer, Chief Financial Officer and General Counsel)" - CEO, CFO, General Counsel are all on the ✗ NOT list (generic C-suite)

- The distinction here is tricky: while these are generic titles individually, the specific combination of CEO, CFO, and General Counsel as a crisis management team could be considered a defined team composition. But the NOT list explicitly calls out these titles as generic C-suite that exist everywhere, so the composition itself doesn't elevate it to specific enough.

- Looking at the rest of the content: unnamed third-party providers, a generic incident response plan, no named frameworks, dates, firms, or tools. There's nothing concrete enough to qualify as a specific fact.

This all points to generic boilerplate with no substantive specifics remaining.


reasoning: The paragraph primarily describes the company's own internal security processes — external assessments, vulnerability testing, and lessons-learned integration — with vendor oversight mentioned as a secondary component. Per Rule 3, third parties hired to test the company's own environment are Risk Management Process, and the vendor risk management program is one component of the broader internal process description. No named frameworks, firms, tools, roles, dates, or quantified facts appear; all entities are unnamed ('third-party assessors,' 'external partners') and cadences are generic ('at least twice a year,' 'regularly').

thinking:
Let me analyze this paragraph.

Content: Describes external assessments twice a year, third-party experts for incident response, vulnerability testing, and a third-party risk management program with due diligence, contractual safeguards, and vendor monitoring.

Category: The paragraph covers two things - internal security testing/assessments (Risk Management Process) and vendor oversight (Third-Party Risk). The first half is about the company's own testing using external assessors. The second half discusses their third-party risk management program. The dominant content seems split, but the first ~60% is about internal processes (using third parties to test their own systems), and the last part is about vendor risk management. The external assessors in the first part serve the company's own security - that's Risk Management Process per Rule 3. The vendor oversight portion is subordinate. → Risk Management Process.

The language is entirely generic—no named vendors, frameworks, standards, or specific dates. Just vague references to "external third-party assessors," "third-party experts," and a "third-party risk management program" without any concrete details. → Generic Boilerplate.


reasoning: The paragraph describes how the Risk Committee exercises oversight through annual and quarterly reporting from IT Management, covering risk assessments, incidents, testing results, and program recommendations. While the IT Management team is the grammatical subject, the primary communicative purpose is describing the governance oversight mechanism — what the Risk Committee receives and how often. The Risk Committee is a named non-generic committee (IS-list fact), yielding Firm-Specific; cadences like 'annually' and 'quarterly' are generic and do not count toward QV.

thinking:
Let me analyze this paragraph.

The paragraph describes the IT Management team's reporting to the Risk Committee. Let me determine category and specificity.

Category: The primary subject is the IT Management team reporting to the Risk Committee. The Risk Committee is a board-level committee receiving reports. But the grammatical subject is "Our IT Management team" - so this could be Management Role or Board Governance.

Actually, the paragraph describes what gets reported and how often. The IT Management team reports TO the Risk Committee. The primary actor is the IT Management team, but the content is about the reporting relationship and what's covered.

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

The content focuses on the oversight structure and what topics are covered in these reports—risk assessments, service provider arrangements, testing results, incidents—rather than on the IT Management team's qualifications or background. This is fundamentally about the governance reporting relationship itself.

Looking at the codebook definition, "Management Role" includes reporting lines, but the person-versus-function test is key here: the paragraph describes processes and oversight activities, not individual credentials. The Risk Committee's oversight through annual and quarterly reports from IT Management is really about Board Governance—how the board exercises its oversight responsibilities—rather than about identifying or qualifying a specific management role. The Risk Committee is a named governance body on the IS list, so that's a firm-specific fact. The IT Management team isn't a cybersecurity-specific role, and the reporting cadences are generic. With only one IS-list item, this falls under Firm-Specific rather than Qualified Vendor. The core issue is whether this is really about Board Governance or the specific Risk Committee oversight mechanism—but either way, the Risk Committee detail pushes it toward Firm-Specific.

fact: Risk Committee (named non-generic board committee)


reasoning: The paragraph is entirely about the people filling cybersecurity leadership roles — their titles, tenure, experience duration, and career backgrounds. It passes the person-vs-function test: removing the credentials and background would leave no substantive content. Multiple QV-eligible hard facts (26 years, 13 years, 15 years of experience) exceed the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes CIO and CISO - their experience, background, certifications, tenure. This is about the people, not the function.

Category: Management Role - the paragraph is about who these people are, their qualifications, experience, tenure.

Specific facts:
- CIO (cybersecurity-specific title) - named_role
- CISO (cybersecurity-specific title) - named_role
- 26 years of IT experience - quantified
- 13 years with the Company - quantified
- 15 years of IT experience (prior) - quantified

- Fortune 500 company background mentioned as prior employment

I'm noting that the experience metrics here are clearly quantified and verifiable - multiple specific year counts that qualify as QV-eligible facts, and there's also the prior Fortune 500 company experience which adds credibility even though it's not named.

fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

fact: more than 26 years of information technology experience (CIO)

fact: more than 13 years with the Company (CISO)

fact: 15 years of information technology experience prior to joining (CISO)


reasoning: The paragraph describes the company's own internal cybersecurity processes—policies, standards, incident response, access control, vendor management, and regulatory monitoring—making it Risk Management Process. It contains no named frameworks, no cybersecurity-specific roles, no specific dates, tools, or firm-specific facts; all language is generic and could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes internal processes for cybersecurity risk management - policies, standards, incident response, access control, vendor management, monitoring regulations. Ends with a cross-reference.

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

Specificity: No named frameworks, no named roles, no specific dates, no named tools. Generic descriptions of policies covering incident response, access control, vendor management. The cross-reference at the end is just a pointer. Everything here is generic boilerplate language.

Specificity = Generic Boilerplate (1)


reasoning: The Audit Committee is the grammatical subject performing oversight, with CIO, COO, and CISO reporting to it — classic Board Governance structure. CIO and CISO are cybersecurity-specific roles on the IS list triggering Firm-Specific; Audit Committee and quarterly cadence are generic and do not elevate specificity. Two named roles but named roles are not QV-eligible, so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes board oversight (Audit Committee) and how they receive reports from CIO, COO, and CISO. The Audit Committee is the primary subject performing oversight, with management roles mentioned as reporting to the committee.

Category: Board Governance - The Audit Committee oversees cybersecurity risk, and management reports TO the board. The board/committee is the primary actor.

Specific facts:
- CIO (named role) ✓
- COO - generic C-suite, ✗
- CISO (named role) ✓
- "Audit Committee" - generic, ✗

- "quarterly reports" - generic cadence, ✗

CIO and CISO are both on the IS list, so they're Firm-Specific triggers, while COO is just generic C-suite. Since named roles don't count toward QV eligibility, this falls under Firm-Specific (3).


reasoning: The paragraph briefly describes a past incident (February 2022 intrusion, two sentences) but the dominant communicative purpose is the materiality assessment ('did not materially and adversely affect our results of operations') followed by extensive boilerplate language about potential future material adverse effects and a cross-reference to Risk Factors. Per the tiebreaker rule, a brief mention of a past incident plus a materiality conclusion as the main point → Strategy Integration. One QV-eligible hard fact (specific date) yields Firm-Specific; 'third-party experts' is generic and does not count.

thinking:
Let me analyze this paragraph.

Content: Describes a past cybersecurity incident (February 16, 2022) with some details, then transitions into a materiality assessment and extensive risk factor language.

Category analysis:
- First part describes an actual incident (date, what happened, response)
- Then a materiality statement about that incident
- Then extensive boilerplate risk language
- Then a cross-reference to Risk Factors

The paragraph starts with incident description but the bulk is about materiality/strategy/risk language. Let me assess dominant category.

The incident description: "On February 16, 2022, we became aware of a cybersecurity intrusion that caused a network disruption and impacted certain of our systems. Upon detection, we took steps to address the incident, including engaging both internal resources and a team of third-party experts to investigate and respond to this intrusion."

Then the materiality assessment kicks in: "While the February 2022 cybersecurity intrusion did not materially and adversely affect our results of operations" - this is the main point of the paragraph. The rest is boilerplate risk language about potential future impacts.

Looking at the tiebreaker rules: the incident description is only about 2 sentences, while the materiality conclusion and risk language dominate the rest. The paragraph's primary purpose is to say the incident didn't have material impact, not to describe what happened. This leans toward Strategy Integration rather than Incident Disclosure. risk language is the bulk. I'd say the materiality conclusion + risk language dominates. But actually, the incident narrative is fairly substantive (specific date, what happened, response actions).

Hmm, looking more carefully: the first ~2 sentences describe the incident, then 1 sentence gives materiality assessment, then the rest is generic risk language. The paragraph's primary purpose seems to be disclosing the incident AND assessing its materiality.

Given the tiebreaker "Brief mention of a past incident + materiality conclusion as the main point → Strategy Integration" - I think this fits. The incident is briefly mentioned (2 sentences) and the bulk is about materiality and potential impacts.

Actually, let me reconsider. The incident gets a specific date and description of what happened. But the majority of the paragraph is about potential future impacts (boilerplate). I'll go with Strategy Integration since the materiality conclusion seems to be the main point, with the incident as context. The incident is briefly mentioned and then the materiality assessment is the core message.

Now checking the specificity: there's a specific date of "February 16, 2022" which qualifies, but no named third-party firms or tools—just generic references. That's only one QV-eligible fact, so this falls under Firm-Specific rather than QV.

fact: February 16, 2022 — specific date of cybersecurity intrusion


reasoning: The paragraph briefly mentions an actual incident (February 2022 intrusion) but its primary communicative purpose is the materiality assessment ('did not materially and adversely affect our results of operations') followed by extensive discussion of potential business/financial consequences. Per the tiebreaker rule, a brief mention of a past incident plus a materiality conclusion as the main point is Strategy Integration. One QV-eligible hard fact (specific date) yields Firm-Specific, not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

It starts with a specific incident: "On February 16, 2022, we became aware of a cybersecurity intrusion that caused a network disruption and impacted certain of our systems." Then it describes response actions briefly, then pivots to a materiality assessment ("did not materially and adversely affect our results of operations"), then goes into extensive generic risk language about potential future impacts, and ends with a cross-reference to Risk Factors.

Category: The paragraph has incident disclosure (first few sentences) + strategy integration (materiality assessment) + generic risk language. The dominant content by volume is the generic risk language about potential future impacts. But the opening is about an actual incident, and there's a materiality conclusion.

The incident gets mentioned upfront but the real substance is the materiality assessment and discussion of potential business impacts—that's what drives the paragraph. The specific date of February 16, 2022 is the only concrete verifiable detail, making it minimally QV-eligible.


reasoning: The paragraph describes Manhattan's engagement of external auditors, consultants, and cybersecurity service providers as components of its own internal cyber program. Per Rule 3, external parties hired to serve the company's security needs are Risk Management Process, not Third-Party Risk (which requires vendor oversight as the central topic). No named firms, frameworks, dates, or specific facts are present—'industry-leading' and 'outside independent auditors' are unnamed generic references.

thinking:
Classify this paragraph.

Content: Describes engagement of third parties as part of cyber program - outside auditors, consultants, advisors, and cybersecurity service providers.

Category: This is about third-party engagement but from the perspective of the company's own program. The central topic is using external parties as part of their internal program. Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." These third parties are serving the company's program. But wait - is vendor oversight the central topic? No, it's about hiring consultants/advisors to help with their own cybersecurity. This is Risk Management Process.

The third parties mentioned—auditors, consultants, advisors, and cybersecurity providers—are all engaged to support the company's own program rather than being vendors the company oversees, confirming this falls under Risk Management Process. The language is entirely generic with no named frameworks, specific firms, dates, or metrics, making this Generic Boilerplate.


content_category: None/Other

reasoning: Despite the section header referencing 'Impact of cybersecurity risks on business strategy, results of operations or financial condition,' the paragraph body contains no materiality assessment and no substantive cybersecurity disclosure. It merely describes the general threat landscape (hackers, nation-state actors, social engineering) in language that could appear in any company's filing unchanged. No processes, frameworks, governance structures, or materiality conclusions are present.

thinking:
Classify this paragraph.

This paragraph describes general cybersecurity threats - hackers, nation-state actors, social engineering, etc. It's generic risk language that could apply to any company. There's a header about "Impact of cybersecurity risks on business strategy" but the content is just describing threat landscape generically.

No materiality assessment is made. No specific processes described. No incident. It's generic threat landscape language.

This could be None/Other (generic risk language) or Strategy Integration (given the header mentions impact on business strategy). But the actual content is just describing the threat landscape generically - no materiality conclusion is made.

The header says "Impact of cybersecurity risks on business strategy, results of operations or financial condition" but the paragraph body doesn't actually assess materiality. It just describes threats generically.

Despite the header suggesting business impact, the actual paragraph content is just boilerplate threat description with no materiality assessment or specific facts - so this is None/Other, Generic Boilerplate.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of third-party entities that provide services or hold customer data — requirements imposed ON vendors (cyber posture assessment, insurance, breach reporting). No named frameworks, firms, tools, dates, or other facts from the IS list are present; the described practices are generic.

thinking:
Classify this paragraph.

Content: About third-party vendor risk management - procurement processes, requirements for third parties including cyber posture assessment, insurance, breach reporting. Central topic is oversight of external parties.

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

Specificity: No named frameworks, no named roles, no specific dates/numbers/firms. The practices described (procurement processes, cyber posture assessment, cyber liability insurance, breach reporting protocols) are general. No IS-list facts.

→ Generic Boilerplate


reasoning: The entire paragraph describes the cybersecurity management team's composition, credentials, educational backgrounds, years of experience, and reporting lines — squarely about the people, not the function. Multiple QV-eligible hard facts: headcount of 2 analysts, over 30 years experience (CTO), over 30 years experience (Director), combined 25 years (Analysts) — well exceeding the two-fact threshold.

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

This is a detailed paragraph about the cybersecurity management team - their roles, qualifications, backgrounds, and credentials.

**Content Category:** Management Role - The entire paragraph is about the people: their titles, educational backgrounds, years of experience, and responsibilities. This is clearly about "who the persons are."

**Specific Facts:**
- CTO and VP of IT (cybersecurity-specific title)
- Director of Information Security (cybersecurity-specific title)
- Two Cybersecurity Analysts (named role + headcount)
- CTO holds MBA and BS in Electrical Engineering

- CTO brings over 30 years of experience and also serves as CISO and Chief Cyber Security Officer
- Director holds BS in Computer Science and Masters Certificate in Cyber Security with concentration in Power Systems, with over 30 years of experience
- The two analysts have combined 25 years of experience with backgrounds in Information Technology, Criminal Justice, and Digital Forensics

**QV-eligible facts:**
- "over 30 years" (CTO) - specific number ✓
- "over 30 years" (Director) - specific number ✓
- "combined 25 years" (Analysts) - specific number ✓
- Two Cybersecurity Analysts - headcount ✓

That's well more than 2 QV-eligible facts, so this qualifies as Quantified-Verifiable.

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

fact: Director of Information Security

fact: Two Cybersecurity Analysts

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

fact: CTO also serves as Chief Information Security Officer and Chief Cyber Security Officer

fact: Director has over 30 years of experience in information technology

fact: Cybersecurity Analysts have combined 25 years of experience

fact: One Analyst holds BS in Information Technology; other holds BS in Criminal Justice / Computer Crime and Digital Forensics


reasoning: The paragraph's primary communicative purpose is establishing who leads the cybersecurity program — the CTO and VP of IT Governance — along with their years of experience, reporting lines, and qualifications, making Management Role dominant. While the IRT description introduces process elements, it is subordinate to the management structure framing. Two QV-eligible hard facts (25 years and 20 years of experience) meet the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Generic risk statement about cybersecurity threats
2. CTO credentials (25 years experience, reporting to CEO)
3. VP of IT Governance credentials (20 years experience, reporting to CTO)
4. Their joint oversight of the information security program
5. Incident Response Team composition and responsibilities
6. IRT activities including tabletop exercises

The primary content is about WHO leads the cybersecurity program - the CTO and VP of IT Governance - their qualifications, experience, and reporting lines. Then it describes the IRT team composition.

Person-vs-function test: The paragraph spends significant text on the CTO's and VP's credentials, experience, and reporting lines.

Now I'm weighing the two halves against each other. The first section establishes management authority through credentials and experience levels, while the second half outlines the IRT's functional composition across different departments. The paragraph seems primarily focused on establishing the leadership structure and their qualifications, with the IRT details serving as supporting information about how that leadership is operationalized.

So Management Role is the dominant category here. Looking at what makes this specific and verifiable: the CTO and VP titles are clearly cybersecurity-related positions, the IRT is a named program with an acronym, the team composition across accounting, legal, communications, and risk management is concrete, and those two experience figures—25 and 20 years—are hard numbers that could be verified.

fact: Chief Technology Officer (CTO) — cybersecurity-specific leadership role

fact: Vice President of Information Technology Governance

fact: CTO reports directly to CEO; VP IT Governance reports to CTO

fact: CTO holds over 25 years of experience in information technology

fact: VP of IT Governance holds 20 years of experience in information security roles

fact: Incident Response Team (IRT) — named internal program with unique identifier

fact: IRT includes senior leadership from accounting, legal, corporate communications, and risk management


reasoning: The paragraph describes how the Board receives cybersecurity information through quarterly written reports and annual in-person presentations from IT leadership, establishing the board's oversight mechanism. While IT leadership is the grammatical subject, the communicative purpose is about the Board's oversight cadence and information flow, not about the person's qualifications or credentials (which would be Management Role). 'Global IT Director' is a general IT title (not cybersecurity-specific per the IS list), 'quarterly' and 'annually' are generic cadences, and 'Innospec' is a company self-reference — no IS-list facts remain after filtering.

thinking:
Let me analyze this paragraph.

The paragraph describes how IT leadership reports to the Board. The Board is receiving reports, but IT leadership is the grammatical subject performing the actions (provides reports, presents). However, the paragraph is really about the oversight mechanism - how the Board receives information about cybersecurity.

Actually, looking more carefully: "IT leadership provides a written report to the Board" - IT leadership is the subject. "Global IT Director presents in person" - management role is the subject. This is about management's reporting activities to the board.

But the frame is about board oversight - the Board receiving quarterly reports and presentations. The board is the recipient of oversight information.

Per Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). Here, IT leadership is the primary actor providing reports to the Board. So this leans Management Role.

I'm torn between two interpretations here. The grammatical subjects are clearly management roles doing the reporting, which points toward Management Role. But the underlying purpose seems to be about board oversight - the Board getting the information it needs to oversee cybersecurity. Let me focus on what's actually being described: the cadence and mechanism of how management communicates cybersecurity status to the Board for oversight purposes. The distinction is really about whether we're describing the person themselves or the oversight mechanism they're part of. Management Role focuses on credentials, background, and qualifications—who the person is. This paragraph is about reporting cadence and what gets presented to the Board, which is the oversight structure itself. So this is Board Governance, not Management Role.

Looking at the specificity markers, "Global IT Director" isn't a cybersecurity-specific title like "Director of IT Security" would be—it's generic IT leadership. The reporting frequencies and key performance indicators mentioned are also generic, not tied to any specific IS list items. There are no concrete facts from the IS list here.


reasoning: The paragraph describes the company's internal risk assessment process — periodic assessments, internal audit evaluation, remediation strategies, and ERM integration. The audit committee mention is incidental (receiving reports), not the primary subject. No named frameworks, cybersecurity-specific roles, dates, tools, or other IS-list facts are present; 'periodic,' 'security team,' 'internal audit team,' and 'audit committee' are all generic.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment process - security team conducts assessments, internal audit evaluates results, reports to audit committee, security team manages remediation.

Category: This is about internal processes - risk assessments, internal audit, remediation strategies. The audit committee mention is incidental (results are reported to it). Primary topic is the company's own internal risk assessment process. → Risk Management Process

Specificity: Let me check for specific facts:
- "security team" - generic
- "enterprise risk management team" - generic
- "internal audit team" - generic
- "audit committee" - generic (on the NOT list)

- "periodic" - generic cadence
- 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 a management committee's composition and collective experience areas (information security, IT, data protection, risk management, compliance). The grammatical subject is the committee's members—senior management—making this about who fills cybersecurity leadership roles and their qualifications. The ERM integration sentence is subordinate. No specific facts from the IS list are present: 'The Committee' is generic, no cybersecurity-specific titles are named, and the experience areas are generic descriptions.

thinking:
Classify this paragraph.

The paragraph describes a committee's membership composition and their collective experience areas, and how this helps incorporate cyber risk management across programs.

Content category: This is about a management committee's composition and experience. The grammatical subject is "The Committee's members" - these are senior management members. This describes management's role in cybersecurity. But it's also about risk management process integration ("incorporate cyber risk management across all of our significant risk management programs").

The first sentence is about who's on the committee and their experience areas. The second sentence is about ERM integration. The dominant focus seems split - but the committee composition and their experience is Management Role territory, while ERM integration is Risk Management Process.

Actually, I'm realizing the committee here is a management committee made up of senior leaders, not a board committee. The paragraph focuses on who comprises this committee and what expertise they bring, then mentions how that composition supports ERM integration. The ERM piece feels secondary to the main point about the committee's structure and makeup, so this leans toward Management Role.

Looking at specificity though—there are no named frameworks, no specific facts, no actual committee name, just generic references to "senior members of management" and broad experience areas like information security and compliance. This is clearly Generic Boilerplate.


reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity risks, including questionnaire assessments and contractual addendums — requirements imposed ON vendors. No named frameworks, specific roles, dates, or other IS-list facts are present; 'cybersecurity questionnaire' and 'security and privacy addendums' are generic practices.

thinking:
Classify this paragraph.

Content: About third-party service provider risks and how the company manages them - cybersecurity questionnaire, security/privacy addendums in contracts. Central topic is vendor oversight.

Category: Third-Party Risk - the central topic is oversight of external parties.

Specificity: No named frameworks, no named roles, no specific dates, no named tools. "Cybersecurity questionnaire" and "security and privacy addendums" are generic practices. No IS-list facts. → Generic Boilerplate.


reasoning: The paragraph describes internal cybersecurity processes — periodic risk assessments, annual framework reviews, and scope reviews triggered by business changes. Third-party vendor assessments are mentioned as one component of the internal program, not the central topic. The Head of Technology Risk is named as attribution for who performs these reviews, but the substantive content is about the processes themselves (person-vs-function test favors RMP). 'Head of Technology Risk' is a cybersecurity-specific title analogous to those on the IS list, making this Firm-Specific, but there is only one such fact so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes periodic risk assessments, third-party vendor audits, and the Head of Technology Risk's review activities. The primary content is about internal cybersecurity processes (risk assessments, framework review, scope review). Third-party vendors are mentioned as one component. The "Head of Technology Risk" is mentioned but the paragraph describes what the program does, not who the person is.

Category: Risk Management Process - the paragraph describes internal processes (risk assessments, framework review, scope review). Third-party vendors are one component, not the central topic. The Head of Technology Risk is attribution, not the focus.

Specificity: "Head of Technology Risk" - is this a cybersecurity-specific title? It's not exactly CISO/CTO/CIO but it's a specific cybersecurity-adjacent role.

Comparing against the IS list, "Head of Technology Risk" aligns with roles like "Director of IT Security" or "HSE Director overseeing cybersecurity" — it's a cybersecurity-specific title. There are no quantifiable facts here (no dates, amounts, headcounts, or named entities), just the one specific role mentioned. This makes it Firm-Specific.

fact: Head of Technology Risk


reasoning: The paragraph's primary subject is the board and Audit Committee overseeing cybersecurity risk, with the management roles (Director of Cybersecurity, CIO) mentioned subordinately. Two cybersecurity-specific titles from the IS list establish Firm-Specific, but named roles don't count toward QV.

thinking:
Let me analyze this paragraph.

Content: Board oversees risk management, Audit Committee handles cybersecurity oversight, Director of Cybersecurity and CIO mentioned at management level.

The board/Audit Committee is the primary subject for most of the paragraph. The management mention is secondary. → Board Governance

Specific facts:
- "Director of Cybersecurity" — cybersecurity-specific title → IS list ✓
- "Chief Information Officer" (CIO) — cybersecurity-specific title → IS list ✓
- "Audit Committee" — NOT list (generic)

Two cybersecurity-specific roles. But for QV, named roles don't count.

This qualifies as Firm-Specific since there are at least two IS facts present, and there aren't any QV-eligible facts like dates, dollar amounts, headcounts, or named certifications.

fact: Director of Cybersecurity

fact: Chief Information Officer (CIO)


reasoning: The paragraph's primary content is about the Information Security Officer — their responsibilities, experience (20+ years), and qualifications — making the person the central subject. The second half describes escalation to the Audit Committee and Board, but the ISO's identity and credentials are the dominant focus. Specificity is Firm-Specific: the ISO title is on the IS list and '20 years of experience' is one QV-eligible fact, but 'industry certifications' are not named, so only one hard verifiable fact prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph covers multiple topics: Information Security Officer's role and qualifications, reporting to executive leadership, CFO/CLO reporting to Audit Committee about incidents, and Board review.

Primary content: The paragraph describes the Information Security Officer's responsibilities and qualifications (person-focused), plus the reporting/escalation chain. The ISO's experience and qualifications are described, making this about the person. But there's also significant board governance content.

Let me apply the dominant category test. The paragraph has:
1. ISO provides updates on IT risks → Management Role
2. ISO has 20+ years experience, certifications → Management Role (person-focused)

3. CFO/CLO report to Audit Committee → Board Governance
4. Board reviews incidents → Board Governance

The first half focuses on the ISO's qualifications and experience, while the second half shifts to the reporting structure up through the CFO/CLO to the Audit Committee and Board. Given that the ISO's role, background, and responsibilities form the core of the paragraph, with board escalation as a secondary element, I'd classify this as Management Role.

Specific facts:
- "Information Security Officer" - cybersecurity-specific title → IS list ✓
- "over 20 years of experience" - specific number → QV-

eligible

For the QV check: "over 20 years of experience" is the only quantified fact. "Industry certifications" lacks specificity since they're not named. There are no named firms, specific dates, dollar amounts, or tools mentioned. With just one QV-eligible fact, this falls into Firm-Specific rather than QV.

fact: Information Security Officer

fact: over 20 years of experience in information security


reasoning: The Audit Committee is the grammatical subject performing oversight actions (reviewing risks, reporting to the full Board), making this Board Governance. Despite detailed enumeration of committee responsibilities, all elements are generic: 'Audit Committee' is on the NOT list, 'management' is generic, cadences are 'regularly' (vague), and the Chair's expertise description ('expertise in risk management which includes IT and cybersecurity') names no specific credentials, certifications, or cybersecurity-specific role from the IS list.

thinking:
Let me analyze this paragraph.

Content: Board delegated to Audit Committee, describes committee responsibilities (reviewing risks, reviewing management steps, reporting to board), Chair has risk management expertise including IT/cyber.

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

Specificity: Let me check facts:
- "Audit Committee" - NOT list (generic)
- "Board of Directors" - NOT list
- "Chair of the Audit Committee has expertise in risk management which includes IT and cybersecurity" - this is about the board chair's expertise, but it's generic ("expertise in risk management") - no named person, no specific credentials

- No named frameworks, no dates, no specific roles from the IS list, no named standards. This is generic boilerplate language.


reasoning: The paragraph opens with an explicit materiality assessment ('we do not believe that our business strategy, results of operations, or financial condition have been materially adversely affected by any cybersecurity incidents'), which is the primary communicative purpose per Rule 6. The remaining content—generic threat landscape language, vague investment mentions, and a cross-reference to Risk Factors—is boilerplate with no named frameworks, firm-specific facts, or verifiable details.

thinking:
Materiality assessment present → Strategy Integration per Rule 6. Mixed content but the materiality disclaimer is the lead and dominant purpose.

Specificity: No named standards, no firm-specific facts from the IS list. "global financial services firms" is generic. Cross-reference is boilerplate. → Generic Boilerplate.


reasoning: The paragraph's primary content describes risk management processes — identifying, measuring, managing, monitoring, and reporting information security risks, plus escalation criteria and reporting channels. The ORC and CISO are mentioned as attribution for who governs these processes; removing them, the paragraph still describes substantive risk management activities (person-vs-function test → function). Multiple firm-specific facts (named ORC committee, CISO as chair, Risk Management Committee) but no QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

The paragraph describes the Operational Risk Committee (ORC), chaired by the CISO, and its role in overseeing information security risk management. It describes processes like identifying, measuring, managing risks, escalation criteria, and reporting channels.

Category: This is a mix. The ORC is a named committee, chaired by CISO, providing oversight and governance. But the content is primarily about risk management processes - identifying, measuring, managing, monitoring risks, escalation procedures, reporting channels. The primary actor is the ORC (a management-level committee), and the content describes what processes it oversees.

This is Risk Management Process - the paragraph describes internal processes for risk management, escalation, and reporting.

Now I'm reconsidering whether the governance structure and reporting flows matter more than the underlying processes. Even if I strip away the committee and role names, the core content remains about identifying, measuring, managing, and monitoring risks with specific escalation and reporting procedures. That's fundamentally a process description, so I'll categorize this as Risk Management Process. The specific entities involved—the CISO as a named role and the Operational Risk Committee as a named committee—are just the actors executing these processes.

Looking at what qualifies as firm-specific facts: the CISO and the two committees are all organization-specific identifiers with no quantifiable metrics like dates, amounts, or headcounts, and no references to external tools or certifications. This makes the entire passage Firm-Specific.

fact: Operational Risk Committee ("ORC")

fact: CISO chairs the ORC

fact: Risk Management Committee