reasoning: The CEO is the grammatical subject throughout, but applying the person-vs-function test, the paragraph describes what the cybersecurity program does — monitoring information systems, deploying security measures, identifying vulnerabilities, incident response, and remediation — not who the person is (no credentials, background, qualifications, or name). Replace 'CEO' with 'the Company' and the paragraph still reads as a process description. CEO is generic C-suite (NOT list), 'IT department' and 'external consultants' are unnamed/generic, and no frameworks, dates, tools, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: The paragraph describes the CEO's role in cybersecurity - being informed about threats, implementing processes, overseeing monitoring, responding to incidents, and communicating with the board.

Category: This is about management's role in cybersecurity. The CEO is the grammatical subject throughout. But applying the person-vs-function test: is this about the person or the function? There are no credentials, qualifications, background, name, or experience mentioned. The paragraph describes what the CEO *does* - implements processes, oversees monitoring, initiates actions. Remove the CEO reference and replace with "the Company" and it still reads as a process description.

Actually, I need to reconsider this. The CEO is named as the subject, but the paragraph focuses on functional responsibilities—monitoring, security measures, incident response, communication—rather than who the person is. Rule 2b clarifies that naming a specific executive and then describing what the cybersecurity program does falls under Risk Management Process, not Management Role. Since CEO is on the exclusion list for specific facts anyway, this is really about the processes and functions, not the person.

The person-versus-function test confirms it: strip away the CEO reference and you're left with monitoring, deploying security measures, identifying vulnerabilities, and responding to incidents. That's process description. The board communication touches on reporting lines, but the bulk of the content is operational and procedural.

Everything here is generic boilerplate too—no named frameworks, no dates, no specific tools, just standard language about what a typical executive oversees. This is Risk Management Process.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's own internal cybersecurity processes — protecting against threats and delivering training on cyber awareness — which are core Risk Management Process activities. No named frameworks, roles, tools, dates, or any firm-specific details are present; the language is entirely generic and could apply to any company.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

Content: describes internal cybersecurity activities - policies, processes, practices, technologies to protect against threats, and training/communications on cyber awareness.

Category: Risk Management Process - describes internal processes, training, and technologies.

Specificity: No named frameworks, no specific facts from the IS list. Generic practices (training, policies, processes). → Generic Boilerplate.


content_category: Board Governance

category_confidence: medium

reasoning: The paragraph's primary subject is the Board of Directors and the (future) Audit Committee's role in cybersecurity oversight, including coordination with the CFO and an explicit statement that no directors have cybersecurity expertise — all hallmarks of Board Governance. However, the governance described is largely aspirational ('will be,' 'if needed') and the company appears to lack a functioning cybersecurity oversight structure. No specific facts from the IS list are present: 'Audit Committee,' 'Board of Directors,' and 'Chief Financial Officer' are all on the NOT list as generic governance/C-suite terms, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph from Kun Peng International Ltd.

The paragraph describes a future/aspirational state - the audit committee hasn't been created yet, and when it is, it will handle cybersecurity oversight. It also notes none of the directors have cybersecurity experience. There's a cross-reference at the end.

This is describing board governance structures (or lack thereof). The primary subject is the Board/Audit Committee and their oversight role. But this is quite aspirational/hypothetical - "will be," "if needed," etc.

The company seems to be a small company without even a formed audit committee yet. This is similar to a SPAC/no-operations situation where there's no substantive program. But the paragraph does discuss board governance - it talks about what the Audit Committee will do, who they'll coordinate with (CFO), and board expertise (or lack thereof).

Looking at the specifics, the paragraph mentions the Audit Committee, CFO coordination, and three independent non-executive directors, but these are all generic governance elements without named frameworks or cybersecurity-specific roles - nothing that rises to the level of a concrete fact.

The real question is whether this counts as Board Governance or should be classified differently since the audit committee hasn't actually been formed yet and the directors lack cybersecurity experience. The language is aspirational about future governance structures rather than describing current operations. But unlike a SPAC with no operations, this company is making substantive claims about how cybersecurity oversight will be handled and who bears responsibility, so I'll classify it as Board Governance with Specificity 1.


reasoning: The paragraph describes the company's internal information security programs and their alignment to recognized frameworks (ISO, NIST CSF with its five functions), making it a Risk Management Process disclosure. It names specific frameworks but contains no firm-specific facts—no named roles, tools, dates, or unique program identifiers—placing it at Sector-Adapted.

thinking:
Let me analyze this paragraph.

Content: Describes collecting/processing data, maintaining confidentiality/integrity/availability, and implementing Information Security programs aligned to ISO and NIST frameworks with NIST CSF functions (Identify, Protect, Detect, Respond, Recover).

Category: This is about the company's own internal cybersecurity processes and framework adoption → Risk Management Process.

Specificity: Names ISO and NIST frameworks → Sector-Adapted at minimum. The NIST CSF functions listed are part of the framework name, not firm-specific. No cybersecurity-specific roles, no named committees, no specific dates, no named tools. The mention of "Information Security programs" is generic. → Sector-Adapted (2).

fact: ISO cyber security frameworks

type: framework

fact: NIST cyber security frameworks


content_category: Management Role

reasoning: The paragraph is entirely about the person filling the cybersecurity leadership role — their title, reporting line, education, years of experience, and extensive certifications. Multiple QV-eligible hard facts: 'over 20 years' of experience plus numerous named certifications (CISSP, CISA, CISM, CRISC, CEH, CHFI) well exceed the two-fact threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the Senior Manager of Information Security (SMIS) - their reporting line, responsibilities, background, and certifications. This is clearly about the person - their qualifications, experience, and credentials.

Category: Management Role - the paragraph is about who the person is, their credentials, experience, reporting structure.

Specific facts:
- "Senior Manager of Information Security (SMIS)" - cybersecurity-specific role
- "Chief Operating Officer" - generic C-suite (NOT list)
- "over 20 years of cybersecurity experience" - specific number
- CISSP, CISA, CISM, CRISC, CompTIA Security+, ISO 27001 Lead Auditor, CEH, CHFI - named certifications

- Multiple hard verifiable facts present: quantified experience and named certifications → Quantified-Verifiable classification

type: quantified

fact: CISSP (Certified Information Systems Security Professional)

fact: CISA (Certified Information Systems Auditor)

fact: CISM (Certified Information Security Manager)

fact: CRISC (Certified in Risk and Information Systems Control)

fact: CompTIA Security+

fact: ISO 27001 Lead Auditor

fact: CEH (Certified Ethical Hacker)

fact: CHFI (Computer Hacking Forensic Investigator)


reasoning: The paragraph's framing sentence establishes the board's oversight responsibility (not delegated to any committee), and the remaining text describes how management executes that oversight — making board-level governance the primary communicative purpose. CEO and CFO are generic C-suite titles (NOT list), 'periodically' is a generic cadence, and 'cybersecurity awareness trainings' is a common practice — no IS-list facts remain, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph from Sino Green Land Corp.

Content: The paragraph covers board oversight (first sentence), then management responsibility (CEO/CFO), then their periodic meetings with IT operations, then training.

Category analysis:
- Board oversight is mentioned briefly in the first sentence
- The bulk of the paragraph is about management (CEO/CFO) assessing risks, meeting with IT personnel, reviewing issues
- But CEO and CFO are generic C-suite titles, not cybersecurity-specific roles
- The paragraph describes both board oversight and management processes

The board is mentioned in one sentence. The rest is about CEO/CFO managing cybersecurity. But the CEO/CFO are not cybersecurity-specific roles - they're generic C-suite. The paragraph describes what management does (assesses risks, meets with IT, reviews issues). This feels like it's split between Board Governance and Risk Management Process.

I'm trying to figure out whether this is really about the management structure itself or the processes they follow. The paragraph emphasizes what the CEO and CFO actually do—assess risks, engage with IT operations, review issues—which points toward Risk Management Process rather than just defining their roles. Even though it establishes CEO/CFO as the responsible parties, the focus is on their activities and oversight functions. The bulk of the description focuses on what the CEO and CFO do—assessing risks and meeting with IT operations—which points toward Risk Management Process rather than Management Role. When I strip away the titles and just say "the Company meets periodically with IT operations," it reads as a procedural description, not a characterization of people or their positions. The board gets minimal mention, so even though governance is present, the dominant content is really about the management activities and processes themselves. The codebook clearly states Management Role includes reporting lines and management committees for cybersecurity, which matches this paragraph's focus on the oversight chain from board down through CEO and CFO. Even though those are generic titles, the paragraph is fundamentally describing the organizational structure and reporting relationships for managing cybersecurity risk, so I'll go with Management Role as the final answer. The statement about the board not delegating oversight authority is somewhat firm-specific, but since it's not backed by concrete details or evidence from the IS list, it still reads as generic boilerplate. Everything here—the CEO and CFO assessments, periodic meetings with IT, the awareness trainings—are standard practices without named frameworks or specific facts. This lands squarely in Generic Boilerplate with Specificity 1.


specificity_confidence: medium

reasoning: The paragraph primarily describes internal cybersecurity risk assessment processes — ongoing assessments, ERM integration, and monitoring of processes/procedures to mitigate risks. The CCO reporting and third-party mention are components of the broader risk management description, not central topics. The reference to 'the ISP' (a named internal program with a distinguishing abbreviation, likely defined earlier in the filing) provides one firm-specific fact, but no second QV-eligible hard fact exists (CCO is not a cybersecurity-specific title, 'quarterly' is a generic cadence, 'Adviser and Administrator' are unnamed).

thinking:
Let me analyze this paragraph.

Content: Describes risk assessments performed throughout the year, reported to officers and Board by CCO quarterly. Cybersecurity risks assessed as part of ERM, and specifically between ISP and Adviser/Administrator. Third-party apps incorporated into assessments.

Category: This is primarily about risk assessment processes - methodology, frequency, ERM integration. The CCO reporting is incidental attribution. Third-party mention is a component, not central. → Risk Management Process

Specificity: Let me check facts:
- "Chief Compliance Officer ('CCO')" - This is NOT on the IS list for cybersecurity-specific titles. CCO is more like a generic C-suite/compliance role. Not cybersecurity-specific.

- "ISP" appears to be a named internal program referenced elsewhere in the document, likely "Information Security Program" - this could qualify as firm-specific since it's a defined entity with a unique identifier.
- "Adviser and Administrator" are specific entities in the REIT context but lack formal names themselves.
- "quarterly," "Board of Directors," and "enterprise risk management" are all generic terms and cadences.

Looking at the ISP more carefully - if it's a named internal program with an abbreviation, it matches the codebook's criteria for firm-specific facts, similar to how "Cyber Incident Response Plan (CIRP)" would be classified. The CCO title itself isn't cybersecurity-specific, but the ISP reference is firm-specific enough to count.

Since there's only one firm-specific fact here and no two quantified-verifiable facts, this falls under Risk Management Process with a Firm-Specific classification.

fact: ISP (named internal program with unique abbreviation)


reasoning: The paragraph opens with person-focused content about the VP of Enterprise Technology Solutions — their title, 25-year tenure, and areas of expertise — making Management Role the primary communicative purpose. The Audit Committee oversight (sentences 2-3) is substantial but frames the board as the recipient of the VP's reports, and the materiality statement is a single closing sentence. Two QV-eligible hard facts: specific years of experience (25 years) and specific fiscal year (fiscal 2024).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. VP of Enterprise Technology Solutions - their responsibility and experience (25 years tenure)
2. Audit Committee oversight of cyber risk
3. Audit Committee receives reporting from VP
4. No material incidents in fiscal 2024

Let me determine the dominant category. The paragraph has roughly equal parts about the management role and board governance. Let me look more carefully:

- Sentence 1: Management Role (VP title, 25 years tenure, responsibilities)
- Sentence 2: Board Governance (Audit Committee oversees cyber risk)
- Sentence 3: Board Governance (Audit Committee receives reporting from VP)

- Sentence 4: Strategy Integration (materiality assessment - no material incidents)

The board governance content (sentences 2-3) occupies significant space, and the management role (sentence 1) is also substantial. The VP is described with qualifications (25 years), which is person-focused. But the Audit Committee oversight is also a major theme.

Looking at the tiebreaker rules: "Board oversight mentioned briefly + management roles as main focus → Management Role" vs "Management mentioned briefly + board oversight as main focus → Board Governance"

Neither is brief - both are substantial. Let me count: sentence 1 is about the person (Management Role), sentences 2-3 are about the board's oversight responsibilities, and sentence 4 adds context about risk outcomes. The board governance theme appears to be the organizing principle here, with the VP's role serving as the mechanism through which the board receives its oversight information. The Audit Committee receiving reports from the VP makes this Board Governance framing, but the extensive detail about the VP's 25 years of tenure and specific expertise areas is pulling toward Management Role. Looking at similar cases, when oversight and reporting relationships are the main structural point, that's Board Governance—even if the person's qualifications are mentioned. I'm settling on Board Governance as the dominant category here. Looking at the specific facts here: the VP title is cybersecurity-focused, the 25 years of tenure is a concrete number, and fiscal 2024 is a specific date. That gives me two hard verifiable facts—the tenure length and the year—which makes this Quantified-Verifiable. So my classification is Management Role with Quantified-Verifiable specificity.

fact: Vice President of Enterprise Technology Solutions

fact: 25 years of tenure and experience

fact: fiscal 2024


content_category: Strategy Integration

reasoning: The paragraph opens with an explicit materiality assessment ('have not experienced a cybersecurity threat or incident that resulted in a material adverse impact to our business or operations'), which per Rule 6 makes it Strategy Integration. The remainder discusses hypothetical future costs and consequences of potential incidents — generic risk language with no named entities, dates, amounts, or firm-specific details.

thinking: Materiality assessment + hypothetical risk language.


reasoning: While the first sentence describes Audit Committee/Board oversight (Board Governance), the majority of the paragraph (two of three sentences) describes the S&C Team's internal processes — establishing policies, reviewing security practices, monitoring emerging threats. The dominant communicative purpose is the company's internal risk management activities. The named 'Security & Compliance Team (S&C Team)' with its unique abbreviation is a firm-specific fact, but no QV-eligible hard facts are present (Audit Committee and quarterly cadence are on the NOT list).

thinking:
Let me analyze this paragraph.

The paragraph has three sentences:
1. Board/Audit Committee oversight with quarterly reports
2. S&C Team policies and procedures
3. S&C Team reviews and updates

Dominant category: The first sentence is Board Governance, but sentences 2-3 are about the S&C Team's risk management processes. The majority of the paragraph describes what the S&C Team does (Risk Management Process). But the first sentence frames the oversight structure.

Actually, let me reconsider. The first sentence mentions Audit Committee and Board oversight with quarterly reports. Sentences 2 and 3 are about the S&C Team's activities.

Most of the content focuses on the S&C Team's internal processes rather than the Board's oversight role, so this leans toward Risk Management Process as the dominant category. The S&C Team is a named internal program, which counts as a specific fact, while the Board and Audit Committee references are more generic governance structures.

fact: Security & Compliance Team ('S&C Team') — named internal team with unique identifier


reasoning: The paragraph's primary content is the composition and structure of the management committee responsible for cybersecurity oversight — naming a specific non-generic committee (Risk Management Steering Committee) and its members by cybersecurity-specific roles (CIO, ISO, Chief Risk and Operations Officer as Chair). While process activities are mentioned (assess, monitor, internal audit reviews), they are subordinate to the organizational structure description. Multiple IS-list facts (named committee, cybersecurity-specific roles) confirm Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) reach the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a Risk Management Steering Committee with specific composition (Chief Risk and Operations Officer as Chair, CIO, ISO), their function (assesses and monitors cybersecurity risk management program), and internal audit's role.

Category: This is about management-level oversight. The grammatical subjects are the Risk Management Steering Committee and internal audit function. The committee composition and their monitoring role is described. This is about the management structure overseeing cybersecurity - Management Role? Or Risk Management Process?

The person-vs-function test: The paragraph names specific roles (CRO/COO as Chair, CIO, ISO) and describes the committee structure. But it also describes what they do - assess and monitor the program, plus internal audit performs reviews.

The primary content is really about the committee structure itself and who's responsible for oversight. While the paragraph mentions activities like assessing and monitoring, the core focus is on the management committee composition and their authority over the cybersecurity program. That points to Management Role.

Now I'm checking the specificity of the facts mentioned. The Risk Management Steering Committee is a named committee, the CIO and ISO are both cybersecurity-specific titles from the IS list, and the Chief Risk and Operations Officer is a specific organizational role. None of these facts have dates, dollar amounts, headcounts, or other quantifiable elements, so this falls into Firm-Specific with multiple IS-list facts but no QV-eligible information.

fact: Risk Management Steering Committee (named non-generic committee)

fact: Chief Risk and Operations Officer (Chair)

fact: CIO

fact: ISO (Information Security Officer)


reasoning: The paragraph describes the company's internal cybersecurity program designed to assess, identify, and manage risks to IT systems and data, which is squarely Risk Management Process. It names the NIST CSF as an informing standard but contains no firm-specific facts (no named roles, dates, tools, or headcounts), placing it at Sector-Adapted.

thinking:
Let me analyze this paragraph.

Content: Describes data handling, importance of IT systems, cybersecurity program designed to assess/identify/manage risks, mentions NIST CSF.

Category: Risk Management Process - describes the company's internal cybersecurity program and its alignment with NIST.

Specificity: Names NIST CSF framework. No firm-specific facts beyond that. "Informed in part by" NIST is naming a standard, not claiming certification. No cybersecurity-specific roles, no dates, no numbers.

→ Sector-Adapted (2)

fact: NIST Cybersecurity Framework


content_category: Incident Disclosure

reasoning: The paragraph primarily narrates an actual cybersecurity incident: unauthorized access discovered in January 2021 involving a third-party cloud provider, compromised source code and credentials, and an extortion demand. The closing materiality assessment is subordinate to the incident narrative. Only one QV-eligible hard fact (January 2021) is present — the cloud provider is unnamed — so specificity is Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a past cyber incident (January 2021), unauthorized access to IT systems hosted by a third-party cloud provider, source code and credentials compromised, extortion threat, and a materiality assessment.

Category: This describes what happened in an actual cybersecurity incident - dates, what was accessed, the threat, and response. The materiality assessment at the end is subordinate to the incident narrative. → Incident Disclosure

Specificity:
- "January 2021" - specific date ✓ (QV-eligible)
- "third-party cloud provider" - unnamed, NOT specific

- The rest is incident narrative without named firms or tools

Only one QV-eligible fact (January 2021), so this qualifies as Firm-Specific.

fact: January 2021 — specific date of incident awareness


reasoning: The paragraph is headed 'Role of Management' and primarily describes the organizational structure for cybersecurity management: who is responsible (senior management, cross-functional cybersecurity team), the team's composition (security, IT, R&D, legal), and the escalation/reporting path to CEO and EVP of Operations and Legal Affairs, then to the Board. While it touches on function, the primary communicative purpose is identifying the management structure and reporting lines rather than describing processes, tools, or frameworks. The named departmental composition (security, IT, R&D, legal) is a firm-specific fact per the IS list; however, CEO is generic C-suite and 'Executive Vice President of Operations and Legal Affairs' is not a cybersecurity-specific title, so only one IS-list fact qualifies, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes management's role in cybersecurity, cross-functional team composition, and escalation path to CEO/EVP.

Category: The paragraph starts with "Role of Management" and describes management responsibility. But let me apply the person-vs-function test. The paragraph describes the team composition (security, IT, R&D, legal), their general qualifications, and reporting/escalation lines. It's more about organizational structure than any individual person's credentials.

The primary subject is the cybersecurity team structure and escalation path. The mention of CEO is generic C-suite. "Executive Vice President of Operations and Legal Affairs" - is this a cybersecurity-specific title? No, it's not on the IS list.

This is really about the organizational structure and reporting lines for managing cyber risk. The escalation path from the cybersecurity team up through the CEO/EVP to the Board is a reporting structure, and the cross-functional composition describes how the function is organized rather than individual qualifications. So this fits the Management Role category since it covers the reporting lines and organizational structure responsible for cybersecurity oversight. This doesn't have quantifiable facts like specific dates, amounts, or named entities, so it's not QV. That makes this Management Role with Firm-Specific characteristics, rated as a 3.

fact: Cybersecurity team composed of security, IT, R&D, and legal teams


reasoning: The paragraph makes an explicit materiality assessment — stating that no cybersecurity incidents have materially affected the company's business, financial condition, or results of operations — which triggers Strategy Integration per Rule 6. The second sentence about no assurance is a forward-looking disclaimer but subordinate to the materiality conclusion. No named entities, frameworks, dates, or firm-specific facts are present; the language is boilerplate that could appear in any filing.

thinking:
Classify this paragraph.

This is a materiality assessment - "have not experienced... material impact to our company, including to our business, financial condition, and results of operations." Per Rule 6, materiality disclaimers → Strategy Integration.

Specificity: No named standards, no firm-specific facts, no dates beyond generic "as of the date of this report." All boilerplate language.

Generic Boilerplate.


reasoning: The paragraph describes the company's own internal security processes (static/dynamic scanning, vulnerability scanning), which are core Risk Management Process activities. No named frameworks, no cybersecurity-specific roles, no firm-specific facts from the IS list — 'Application Security program' is a generic program name, scanning practices are common, and 'daily' is a generic cadence.

thinking:
Classify this paragraph.

Content: Describes internal security processes - static/dynamic scanning, vulnerability scans daily.

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

Specificity: "daily" is a generic cadence. "Application Security program" - generic program name. Static/dynamic scanning, vulnerability scans are common practices. No named frameworks, no firm-specific facts from the IS list.

→ Generic Boilerplate


reasoning: The paragraph primarily describes internal risk management processes (designing safeguards, addressing gaps, monitoring effectiveness). The VP of IT and reporting line are mentioned as attribution for who manages the process; applying the person-vs-function test, removing the personnel detail leaves a coherent process description. VP of IT qualifies as a cybersecurity-adjacent specific title per the IS list ('VP of IT/Security'), yielding Firm-Specific, but no second QV-eligible hard fact exists.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment follow-up activities (re-design, implement, maintain safeguards, monitor effectiveness) and mentions personnel including VP of IT reporting to Chief Accounting Officer.

Category: The paragraph describes internal processes (safeguards, monitoring, risk assessment) with a mention of personnel. The bulk is about what the company does (processes). The VP of IT and reporting line is mentioned but as attribution for who manages the process. However, the reporting line (VP of IT reports to Chief Accounting Officer) is notable.

Applying the person-vs-function test: If I remove "including our VP of IT, who reports to our Chief Accounting Officer," the paragraph still describes processes. So the dominant content is Risk Management Process.

The reporting structure is interesting, but the core focus remains on the processes themselves. Now I'm checking whether "VP of IT" meets the specificity threshold — it's not explicitly listed as a match, though "VP of IT/Security" appears on the IS list. The general IT titles like "Head of IT" and "IT Manager" are marked as NOT specific, so "VP of IT" falls into a gray area that needs closer examination. Looking at the NOT list more carefully, "Associate Vice President of IT" is explicitly excluded, which makes me reconsider whether a plain "VP of IT" should count as cybersecurity-specific. The codebook entry "VP of IT/Security" seems to describe a combined role rather than just "VP of IT" alone. Given this inconsistency, I'm leaning toward treating "VP of IT" as borderline and likely falling into the generic IT leadership category. The reporting structure itself—VP of IT under a Chief Accounting Officer—is just organizational context and doesn't change the classification.

Since "VP of IT" appears specific enough relative to the IS list, I'll count it as one firm-specific fact. There are no named frameworks, no quantifiable metrics like dates or dollar amounts, and no named firms mentioned, so this doesn't qualify as Sector-Adapted or Quantified. The classification is Firm-Specific (3).

fact: VP of IT


reasoning: The paragraph mentions both Board and management oversight of cybersecurity risks but is primarily a framing statement about governance mechanisms. The Board is mentioned as having established oversight, making it a governance-oriented paragraph. However, the content is entirely generic — no named roles, committees, frameworks, or specific details — making it Generic Boilerplate.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of external parties' cybersecurity — identifying third-party risk at onboarding, ongoing monitoring, and engaging external firms for high-risk vendors. This is squarely Third-Party Risk per Rule 3 (requirements/oversight imposed on vendors as the central topic). No named firms, tools, dates, frameworks, or cybersecurity-specific roles appear; 'external firms' and 'third-party risk management process' are generic and on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party cybersecurity risks and the company's process for managing them. The central topic is oversight of external parties' cybersecurity - onboarding analysis, ongoing monitoring, and use of external firms for high-risk third parties.

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

Specificity: No named frameworks, no named firms ("external firms" is generic), no dates, no numbers. No cybersecurity-specific titles. No named committees. Nothing from the IS list. → Generic Boilerplate.


reasoning: The paragraph describes an actual cybersecurity incident (fraudulent email leading to an erroneous wire transfer) including timeline, financial impact, and remediation actions. Two hard verifiable facts—specific date (December 31, 2023) and dollar amount ($0.7 million)—qualify it as Quantified-Verifiable. The outside consultant is unnamed and does not count.

thinking:
Let me analyze this paragraph.

Content: Describes a specific cybersecurity incident - fraudulent email leading to erroneous $0.7M payment, then remediation with outside consultant.

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

Specific facts:
- "year ended December 31, 2023" - specific date
- "$0.7 million" - dollar amount
- Outside independent consultant (unnamed - generic)

QV check: specific date (December 31, 2023) + dollar amount ($0.7 million) = 2 hard verifiable facts → Quantified-Verifiable

fact: Year ended December 31, 2023

fact: $0.7 million term loan payment


reasoning: The paragraph describes an actual cybersecurity incident (fraudulent email leading to an erroneous wire transfer) including what happened, the financial loss, and remediation actions taken. While the $0.7M loss is a financial figure, the paragraph's dominant purpose is narrating the incident and response, not assessing materiality or strategic impact. Two QV-eligible hard facts: specific date (December 31, 2023) and dollar amount ($0.7 million).

thinking:
Let me analyze this paragraph.

Content: Describes a specific cybersecurity incident (fraudulent email leading to $0.7M loss), plus remediation actions taken afterward.

Category: This describes what happened (incident narrative) AND financial impact ($0.7M loss) AND remediation. The dominant content is describing the incident - what happened, the loss, and the response. → Incident Disclosure

Specific facts:
- "year ended December 31, 2023" - specific date
- "$0.7 million loss" - dollar amount
- These are two QV-eligible hard facts (date + dollar amount)

Specificity: Two hard verifiable facts → Quantified-Verifiable

fact: $0.7 million loss


reasoning: The paragraph describes the company's own internal cybersecurity processes: associate training, written information security policies and procedures, and PCI DSS compliance self-assessments. These are all internal risk management activities. PCI DSS is a named recognized standard triggering Sector-Adapted, but no firm-specific facts (cybersecurity-specific roles, named tools, specific dates, headcounts) are present to reach Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes training programs, information security policies and procedures, and PCI DSS compliance. This is about the company's internal processes.

Category: Risk Management Process - describes internal security training, policies, procedures, and compliance activities.

Specificity: Let me check for facts.
- "Payment Card Industry Data Security Standard" / "Payment Card Industry Security Standards Council" - this is a named standard (PCI DSS) → Sector-Adapted
- Training topics listed are common practices
- "annual" is generic cadence
- No named roles, no specific dates, no headcounts, no named tools

The paragraph names PCI DSS, which is a recognized standard → Sector-Adapted.

Beyond the PCI DSS reference, there's nothing else that ties this to the specific company.

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


reasoning: Although the paragraph describes a specific past incident (June 2018, $10M loss from unauthorized email access), the primary communicative purpose is the materiality assessment: 'Risks from cybersecurity incidents... have not materially affected us, including our business strategy, results of operations or financial condition.' The incident detail serves as context for that strategic conclusion, fitting the tiebreaker 'brief mention of a past incident + materiality conclusion as the main point → Strategy Integration.' Two QV-eligible hard facts (specific date June 2018 + $10M dollar amount) yield Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This paragraph covers multiple topics:
1. Third-party service providers (brief mention)
2. Past cybersecurity incidents including a specific June 2018 incident with $10M loss
3. Materiality assessment ("have not materially affected us...")
4. Cross-reference to Risk Factors

The dominant purpose: This paragraph describes past incidents AND makes a materiality assessment. The June 2018 incident is described with specifics, but the paragraph's primary communicative purpose seems to be the materiality assessment - it describes the incident as context for concluding that cyber risks have not materially affected the company.

Actually, let me re-read. The paragraph:

- Opens with third-party risk context
- Mentions past incidents generally
- Gives a specific example (June 2018, $10M)
- Makes a materiality conclusion
- Cross-references Risk Factors

The materiality assessment is the concluding point. The incident is used as an example to support the materiality conclusion. Per the tiebreakers: "Brief mention of a past incident + materiality conclusion as the main point → Strategy Integration"

But this is more than a brief mention - it has specific details. Let me reconsider.

Per Rule 4: "Mixed: 'We detected X... at a cost of $Y' → Assign based on which is dominant"

The incident details are substantial enough that I need to weigh whether the disclosure of the specific incident (with dollar amount) is the primary purpose, or whether the materiality assessment is. The paragraph structure suggests the materiality assessment is the main point - the incident is supporting evidence. So this leans toward Strategy Integration.

But wait - I have two quantified facts here: the specific date and the dollar amount. That triggers Quantified-Verifiable classification regardless of the narrative structure. The presence of verifiable metrics overrides the narrative framing.

fact: June 2018 incident

fact: $10 million in fraudulent payment disbursements


reasoning: The paragraph is primarily about the CISO as a person — their experience (22 years, government and private sector background), their coordination with named executives, and their organizational role chairing the ISSC. While it mentions program activities, the dominant content is the person's qualifications and leadership position. Only one QV-eligible fact (22 years of experience); named roles and committees don't count toward QV, so this remains Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes the CISO's coordination with other executives, the CISO's experience (22 years), and the CISO's leadership of the cybersecurity program including chairing the ISSC committee and reporting to the Audit Committee.

Category: This is about the CISO - their qualifications (22 years experience, government and private sector background) and their role. The person-vs-function test: the paragraph tells us about who the CISO is (experience, background) and their organizational position. While there's some process description (chairs ISSC, provides reporting), the dominant content is about the person - their credentials and leadership structure. → Management Role

Now I'm checking which facts qualify as quantified values. The CISO and CIO titles are named roles, ISSC is a named committee, and the other executives mentioned are generic C-suite positions that don't count. The only quantified value here is the 22 years of experience.

fact: CISO

fact: Chief Information Officer

fact: over 22 years of experience in information security

fact: ISSC (Information Security Steering Committee)


reasoning: The entire paragraph is about the CISO as a person — their years of experience, certifications, and educational background. This is a textbook Management Role paragraph per the person-vs-function test. Multiple QV-eligible hard facts: specific years of experience (20 years IT, 15 years infosec) and named certifications (CISSP, CISA, CISM, Check Point Certified Engineer).

thinking:
Let me analyze this paragraph.

Content: Describes the CISO's qualifications - years of experience, certifications, education. This is clearly about the person, not the function.

Category: Management Role - the entire paragraph is about the CISO's credentials, experience, and qualifications.

Specific facts:
- CISO (cybersecurity-specific role)
- "over 20 years of information technology experience" (specific number)
- "over 15 years of information security experience" (specific number)
- CISSP certification
- CISA certification
- CISM certification
- Check Point Certified Engineer (named certification)

- Bachelor of Arts in statistical science, BS in computer science, MBA

The educational background and certifications are all verifiable facts, so this clearly qualifies as Quantified-Verifiable.

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Information Systems Auditor (CISA)

fact: Certified Information Systems Manager (CISM)

fact: Check Point Certified Engineer


reasoning: The paragraph introduces cybersecurity processes but its substantive content is about the persons who implement them — their titles, years of experience, and domain backgrounds. This passes the person-vs-function test as Management Role: remove the credentials and the paragraph has no remaining content. Three specific years-of-experience figures (20, 30, 17) are QV-eligible hard facts, exceeding the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph describes management roles and their qualifications. Let me apply the person-vs-function test.

The paragraph starts with "Our cybersecurity risk assessment and management processes are implemented and maintained by..." - this introduces the processes but then the entire substance is about WHO implements them and their qualifications.

Key content: Privacy and Security Officer (20+ years experience in healthcare privacy/security), Director of Information Technology (30+ years IT experience, 17 years as privacy/security officer).

This is about the persons - their titles, experience, qualifications. The process mention is just framing. The paragraph tells us WHO these people are and what makes them qualified.

Now I'm categorizing the specific roles and experience metrics. The Privacy and Security Officer is a named role, while Director of Information Technology is generic IT leadership. The experience figures are all quantified - over 20 years, over 30 years, and 17 years in the privacy/security officer position - making them eligible for QV consideration.

fact: Privacy and Security Officer

fact: more than 20 years of experience in healthcare privacy and security

fact: more than 30 years of experience with information technology operations

fact: seventeen years as a corporate privacy and security officer


reasoning: The Audit Committee is the grammatical subject throughout — receiving reports, providing updates to the full Board, reviewing evaluations, and participating in exercises. This is board-level oversight of cybersecurity. The named cybersecurity-specific role 'Head of Global Cybersecurity and Compliance' is an IS-list fact making it Firm-Specific, but there is only one QV-eligible fact so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph is about the Audit Committee receiving reports, reviewing cyber-maturity evaluations, and participating in exercises. The grammatical subject is the Audit Committee throughout - this is Board Governance.

Now for specificity:

Specific facts:
- "Head of Global Cybersecurity and Compliance" - this is a cybersecurity-specific title, so it's on the IS list
- "Audit Committee" - on the NOT list (generic)
- "quarterly" - generic cadence, NOT list
- "periodic" - generic, NOT list
- "tabletop exercises" - common practice, NOT list

-
The only firm-specific fact here is that named cybersecurity role, which puts this at Firm-Specific (3). There are no quantifiable elements like dates, amounts, or headcounts that would elevate it to QV-eligible.

fact: Head of Global Cybersecurity and Compliance (Head of Cybersecurity)


reasoning: The paragraph identifies the VP-IT as leader of the IT team and provides their experience (13 years), establishing who the person is and what qualifies them. While the first two sentences describe functions (monitoring, reporting to Audit Committee), the paragraph's primary purpose is establishing management identity and credentials — the person-vs-function test tips toward Management Role because the VP-IT identification and experience are the paragraph's culminating point. Only one QV-eligible fact (13 years of experience); VP-IT is a named role (Firm-Specific, not QV-eligible), so specificity is Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes senior IT leadership's responsibilities, mentions VP-IT with 13 years experience. The paragraph starts with what senior IT leadership does (day-to-day management, monitoring, working with SC, reporting to Audit Committee), then identifies the VP-IT leader with credentials.

Category: The paragraph describes both what the management does (function) and who the person is (credentials). The last sentence is clearly about the person - VP-IT title, 13 years experience. The first two sentences describe functions but also reporting lines. Let me apply the person-vs-function test.

If I remove the person's identity/credentials, the first two sentences still describe processes. But the last sentence is entirely about the person. The paragraph seems mixed - but the VP-IT identification with experience is a significant portion.

The reporting structure and qualifications point toward Management Role. Looking at the structure more carefully, the first two sentences outline what senior IT leadership handles—program management, incident monitoring, and Audit Committee reporting—while the final sentence identifies the VP-IT and their background. The paragraph's core purpose is establishing who holds responsibility and their qualifications, making this a Management Role classification. The VP-IT title appears on the IS list as "VP of IT/Security," confirming this categorization.

Now examining the specific facts: the VP-IT designation qualifies as a named role, and the "over 13 years of experience" provides a specific number. For the QV check, only the experience duration counts as QV-eligible since the VP-IT title itself isn't QV-eligible. That's one QV-eligible fact, which means this falls under Firm-Specific rather than QV-eligible.

fact: Vice President – IT

fact: over 13 years of experience managing global IT operations


reasoning: The paragraph opens with an explicit materiality assessment ('have not experienced cyber-attacks... that materially disrupted our business') and closes with materiality language about whether threats 'have materially affected or are reasonably likely to materially affect' the company's business strategy, results of operations, or financial condition. Per Rule 6, a materiality conclusion makes this Strategy Integration even though a cross-reference to Item 1A is appended. No specific facts from the IS list are present — all language is boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. "We have not experienced cyber-attacks or other malicious activities that materially disrupted our business." - materiality assessment
2. "Any future failure or disruption..." - generic forward-looking risk language
3. "We describe whether and how risks from identified cybersecurity threats... have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition included as part of our risk factor disclosures at Item 1A" - materiality assessment + cross-reference

Per Rule 6 and the codebook: Any paragraph that explicitly assesses whether cybersecurity risks have "materially affected" the company is Strategy Integration, even with cross-references. The first sentence is a materiality conclusion ("have not... materially disrupted"). The third sentence also contains materiality language with a cross-reference.

This is clearly Strategy Integration content, but it's just generic boilerplate about materiality with no specific frameworks or facts from the IS list—just standard disclosure language.


reasoning: The paragraph describes the company's internal continuous monitoring program, SIEM-based detection and response workflow, and SOC operations — all core risk management processes. Despite the technical detail, no named products (SIEM is a generic technology category, not a specific tool like Splunk), no named third-party firms ('managed security service provider' is unnamed), no named frameworks, no dates, and no quantified facts appear, leaving this at Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes continuous monitoring, SIEM system, how it works, alerts monitored by managed security service provider and internal SOC team.

Category: Risk Management Process - describes internal cybersecurity processes, tools, monitoring methodology.

Specificity: Let me check facts:
- "Security Information and Event Management (SIEM)" - this is a generic technology category, not a named product
- "managed security service provider" - unnamed, NOT list
- "Security Operations Center" - generic term
- No named frameworks, no named tools/products, no dates, no numbers, no named firms

No IS-list facts. No named standards.

This is just generic boilerplate—no specific products, frameworks, or concrete details, just standard cybersecurity terminology and processes.


reasoning: The paragraph's primary subject is the Board and its Audit Committee overseeing cybersecurity risk — delegation of oversight, committee qualifications, reporting cadence to the committee, and incident escalation to the committee chair. All key actors (Audit Committee, Chief Compliance Officer, 'crisis response team leader', 'management') are generic per the NOT list; 'quarterly' is a generic cadence; 'Cybersecurity Program' is a generic program name; and Rule 38a-1 is a general investment-company compliance rule, not a recognized cybersecurity standard. No IS-list facts survive filtering.

thinking:
Let me analyze this paragraph.

Content: Board delegated IT/cybersecurity oversight to Audit Committee, committee members have backgrounds for oversight, management reports quarterly to Audit Committee on Cybersecurity Program, Chief Compliance Officer's annual report, crisis response team leader collaborates with Audit Committee chair.

Category: The board/Audit Committee is the primary subject - oversight delegated to Audit Committee, committee composition, reporting TO the committee. This is Board Governance.

Specificity: Let me check facts:
- "Audit Committee" - NOT list (generic)
- "quarterly meetings" - generic cadence
- "Chief Compliance Officer" - NOT list (generic C-suite)

- "Cybersecurity Program" - generic program name
- "crisis response team leader" - generic role, not a cybersecurity-specific title
- Rule 38a-1 under the 1940 Act is a regulatory citation but not cybersecurity-specific

None of these are concrete, identifiable facts from the IS list. They're all generic governance structures and cadences.


reasoning: The paragraph describes the information security team's responsibilities (identifying, assessing, managing cyber risk), control tasks, and ERM integration. The CISO is mentioned as attribution for who directs these activities, but the substantive content is about internal processes — removing the CISO reference leaves a coherent process description. One IS-list fact (CISO) elevates to Firm-Specific.

thinking:
Classify this paragraph.

Content: Describes the information security team's responsibilities, CISO's role in directing control tasks, and integration into overall risk management framework. The primary content is about internal processes - risk assessment, management, ERM integration. The CISO is mentioned as attribution for who directs the work, but the paragraph is about what the program does.

Category: Risk Management Process - the paragraph describes internal processes (identifying, assessing, managing cyber risk, control tasks, ERM integration). The CISO mention is incidental attribution.

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

No named frameworks, no dates, no dollar amounts, no named firms.

Specificity: Firm-Specific (one IS fact: CISO)

fact: CISO designated to oversee evaluation and mitigation of information security risks


reasoning: The paragraph's primary content is about the person who leads cybersecurity — the Director of IT's experience (30 years) and their monitoring responsibilities. While the third sentence describes process activities, the Director of IT remains the grammatical subject throughout sentences 2 and 3, making this about the person rather than the function. For specificity, 'Director of IT' is on the NOT list (generic IT leadership, not cybersecurity-specific), but 'over 30 years of experience' is a specific quantified duration — one QV-eligible fact yields Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes the Director of IT's experience (30 years), their role in managing cybersecurity processes, and monitoring activities.

Category: The paragraph is about the person - their experience and what they monitor. The "Director of IT" title... let me check. The IS list includes "Director of IT Security" but not plain "Director of IT". However, the paragraph is clearly about the person's qualifications and role. The person-vs-function test: the paragraph tells us about the Director of IT's experience (30 years) and what they oversee. It's a mix - but the primary content is about who leads the program and their qualifications.

Looking more closely at the structure, the first sentence establishes that a cybersecurity risk management team leads the processes, while the second highlights the Director's 30 years of experience. The third sentence describes their oversight of prevention, mitigation, detection, and remediation activities. So there's a split between the person's credentials and the actual functions they manage. The dominant thread here is really about who's in charge and what qualifies them for that role, making Management Role the primary category.

Now I'm checking whether these titles and facts qualify for the specificity list. "Director of IT" is generic IT leadership, which is explicitly on the NOT list. But "30 years of experience" is a specific quantifiable fact that would count as QV-eligible. The "incident response plan" is just a generic program name, also on the NOT list. So I have one QV-eligible fact, which puts this in the Firm-Specific category.

For the category itself, even though the title is generic, the paragraph is describing the person's role and qualifications, which fits the Management Role category. The category and specificity are separate dimensions, so this would be Management Role with Firm-Specific specificity.

fact: Director of IT has over 30 years of experience


reasoning: The paragraph is bookended by materiality assessments — it opens with 'no material cybersecurity incidents or threats that have materially affected…' and closes with 'has not had a material impact on our business operations or financial condition.' The February 2025 incident (unauthorized access, misdirected vendor payments) is described in service of the materiality conclusion, not as a standalone incident narrative. Per the tiebreaker, the materiality conclusion is the main point with the incident as supporting context, making this Strategy Integration. Two QV-eligible specific dates (June 30, 2025 fiscal year end and February 14, 2025 incident date) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

Content: The paragraph contains a materiality assessment, references a specific incident (February 14, 2025, unauthorized access, misdirected vendor payments), and concludes with another materiality statement.

Category analysis:
- There's a materiality disclaimer (Strategy Integration)
- There's an incident description with specific date, nature of access, impact (Incident Disclosure)
- The paragraph describes what happened AND assesses materiality

The dominant purpose: The paragraph opens with a materiality assessment, then describes an actual incident, then concludes with another materiality assessment. The incident description is sandwiched between materiality conclusions. The primary communicative purpose seems to be assessing whether cyber risks/incidents materially affected the business, with the incident serving as context for that assessment.

Per the tiebreaker rules, I need to reconsider—the incident details here are substantial, not brief. The paragraph explicitly describes what happened with specific dates, the type of unauthorized access, and concrete consequences like misdirected vendor payments. That level of detail pushes this toward Incident Disclosure rather than Strategy Integration, even though materiality framing bookends the passage. The incident details are substantial enough that this could go either way, but the materiality framing clearly dominates the paragraph—it opens and closes with materiality assessments, making the incident itself supporting evidence rather than the main point. So Strategy Integration is the right call.

Now I'm checking the specificity: February 14, 2025 is a specific date that qualifies, and while "year ended June 30, 2025" is a fiscal period rather than a precise date, I need to consider whether it meets the codebook's threshold for specific dates like "In December 2023" or "On [date]."

Looking at the examples, "fiscal 2025" counts as an IS fact, so a fiscal year end date should qualify too. That gives me two specific dates, which pushes this into Quantified-Verifiable territory.

fact: Year ended June 30, 2025

fact: February 14, 2025 — date company became aware of unauthorized access


reasoning: The paragraph splits between program description (first sentence) and the CISO's personal credentials (second sentence). Applying the person-vs-function test, the CISO is the grammatical subject throughout and the second sentence is entirely about the person's tenure, experience, and prior role — making Management Role the dominant category. Two QV-eligible hard facts: specific start date (February 2021) and specific years of experience (20+ years).

thinking:
Let me analyze this paragraph.

Content: The paragraph starts by saying the CISO is responsible for the Cybersecurity Program, then describes what the program does (NIST Framework, automation, secure development, analytics). The second sentence is about the CISO's tenure and background.

Person vs. function test: The first sentence names the CISO but then describes the program activities. The second sentence is clearly about the person. It's roughly split - half about the program, half about the person's credentials.

The second sentence is squarely Management Role (tenure since February 2021, 20+ years experience, prior role as CISO/Deputy CTO at Fortune 500). The first sentence mixes attribution with program description. But the person's qualifications and background are a major component.

I'm weighing whether this leans more toward the program itself or the person leading it. The CISO is the grammatical subject throughout, and their background and credentials take up significant space in the paragraph. Even though the first sentence touches on program responsibilities, the overall framing is really about introducing this person and their qualifications. I think this falls under Management Role.

Now I'm checking the specificity of the facts mentioned. There's a named cybersecurity role, a reference to NIST Framework as a standard, a specific date in February 2021, and 20+ years of experience. The prior role at a Fortune 500 company is mentioned but the company itself isn't named. Looking at what's actually verifiable, I've got two concrete facts—the date and the years of experience—which makes this Quantified-Verifiable.

fact: CISO title

fact: NIST Framework

fact: Served as CISO since February 2021

fact: More than 20+ years of engineering and/or cybersecurity experience


reasoning: The paragraph describes how cybersecurity risk assessment is integrated into the company's overall risk management processes (ERM integration), which is explicitly covered under Risk Management Process. The mention of 'business strategy, financial planning, and capital allocation' serves as an example of that integration rather than a standalone materiality assessment or strategic impact conclusion, keeping it in RMP territory. No named frameworks, roles, dates, or firm-specific facts are present — entirely generic language.

thinking:
Classify this paragraph.

Content: Describes integration of cybersecurity into overall risk management, business strategy, financial planning, capital allocation.

Category: This is about ERM integration and how cyber risk fits into business strategy/financial planning. It touches both Risk Management Process (ERM integration) and Strategy Integration (business strategy, financial planning, capital allocation). The mention of "business strategy, financial planning, and capital allocation" points toward Strategy Integration. But "integrated into our overall risk management processes" is RMP language.

The dominant purpose: The paragraph says cybersecurity risk assessment is integrated into risk management AND is part of business strategy/financial planning/capital allocation. The strategic framing (business strategy, financial planning, capital allocation) is prominent. But "integrated into overall risk management processes" is the opening frame.

Looking at the structure more carefully, the opening frames this as ERM integration while the second part emphasizes how cyber risk connects to business strategy, financial planning, and capital allocation—which is clearly Strategy Integration language. The paragraph's core message is that cybersecurity fits into the company's strategic and financial framework, making Strategy Integration the primary category.

Wait, but the codebook explicitly lists "ERM integration" under Risk Management Process. The paragraph does describe integrating cyber risk into overall risk management, and those strategy/financial planning elements are really just examples of what that integration looks like. I should go with Risk Management Process.

On specificity, there are no named frameworks, specific facts, or named roles—just generic language about integration. That's Generic Boilerplate.


reasoning: The paragraph is entirely about the person filling a cybersecurity leadership role — their skills, experience, and competencies. 'SVP, E&O' is a cybersecurity-specific title (IS-list item) and 'over 30 years of experience' is a specific number (one QV-eligible fact). With only one QV-eligible hard fact, this reaches Firm-Specific but not Quantified-Verifiable.

thinking:
Classify this paragraph.

The paragraph is about a person — their skills, experience, and competencies. The role is "SVP, E&O" which is a specific title. It describes years of experience (30 years) in cybersecurity leadership.

Content category: Management Role — this is about the person's qualifications and experience.

Specific facts:
- "SVP, E&O" — this is a cybersecurity-specific leadership title (named_role)
- "over 30 years of experience" — quantified (specific number)

QV check: "over 30 years" is a specific number (QV-eligible), and "SVP, E&O" is a named role (not QV-eligible).

I've got one QV-eligible fact here — the years of experience — which makes this Firm-Specific.

fact: SVP, E&O (Senior Vice President, Engineering & Operations) — cybersecurity leadership role

fact: over 30 years of experience in IT, OT physical security, and cybersecurity


reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity, making it Third-Party Risk. It describes generic methods (contract management, security control assessments, risk assessment processes) with no named standards, firms, tools, or firm-specific facts.


reasoning: While the CISO is the grammatical subject of the first sentence, the paragraph's primary communicative purpose is describing the board/committee oversight structure — how the Risk and Compliance Committee and Board receive cybersecurity briefings, what topics are covered, and the reporting chain from CISO → Committee → Board. The CISO is described only in terms of reporting duties, not credentials or background, making this governance oversight rather than Management Role. Firm-Specific due to the named non-generic 'Risk and Compliance Committee' and CISO title, but no two QV-eligible hard facts (cadences like 'quarterly' and 'periodically' are generic).

thinking:
Let me analyze this paragraph.

The paragraph describes the CISO reporting to the Risk and Compliance Committee, and the Board receiving reports from the committee chair. The primary actors are the CISO and the Risk and Compliance Committee/Board.

Category: This is a mix of Board Governance and Management Role. The CISO is mentioned as reporting to the committee, but the paragraph is primarily about the oversight structure - how the board and committee receive information. The Board and Risk and Compliance Committee are receiving reports; the CISO is the one reporting. The dominant theme is the governance/oversight flow of information.

Looking at Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). But here, after the first sentence, the paragraph shifts to what the Risk and Compliance Committee receives and what the Board receives.

Tracing through the sentences, the CISO is the subject in the opening and closing statements, but the Committee and Board take center stage in the middle sentences. The overall structure emphasizes the reporting chain and governance flow rather than the CISO's operational responsibilities.

This is clearly Board Governance—the paragraph focuses on how oversight happens through formal reporting structures and briefing cadences, not on the CISO's credentials or background. For specificity, "CISO" and "Risk and Compliance Committee" are both named roles that would qualify for the list, while "Chief Legal Officer" is too generic. The CISO reference here is tied to their reporting function rather than being a standalone named position.

Looking at QV-eligible facts, I don't see any dates, dollar amounts, headcounts, named firms, tools, or certifications—just the firm-specific governance structure itself. That puts this at Firm-Specific (3) with no QV-eligible facts reaching the threshold of 2+.

fact: CISO

fact: Risk and Compliance Committee

fact: Chief Legal Officer


reasoning: Although the paragraph opens with truncated language about third-party oversight and incident response programs, the dominant content describes an actual cybersecurity incident: unauthorized email access in June 2023, customer notification in September 2023, scope (two employees), and cost ($25,000). Multiple QV-eligible hard facts (two specific dates, a headcount, and a dollar amount) yield Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This paragraph contains multiple topics but I need to identify the dominant one. Let me break it down:

1. "establishing and maintaining a comprehensive program to oversee and manage external connections and third-party relationships" - Third-Party Risk / Risk Management Process
2. "maintaining an incident response program" - Risk Management Process
3. "experienced a single cybersecurity event in June of 2023 in which an unauthorized third party gained access to the email accounts of two of our employees" - Incident Disclosure
4. "We notified the affected customers of the incident in early September 2023" - Incident Disclosure

5. "have taken steps to mitigate our and our customers' exposure" - Incident Disclosure
6. "To date, we have incurred expenses of approximately $25,000 related to the cybersecurity incident" - Strategy Integration (financial impact)

The bulk of the paragraph describes an actual incident: what happened, when, scope, response, and cost. The incident narrative dominates. The opening about third-party programs and IR programs appears to be truncated/run-on text leading into the incident description. The dominant content is the incident description - June 2023, unauthorized access to email accounts of two employees, customer notification in September 2023, mitigation steps taken, and $25,000 in expenses incurred.

I'm identifying the quantifiable facts here: the June 2023 timeframe, the two affected employees, the September 2023 notification date, and the $25,000 expense figure. These specific dates, headcount, and dollar amount give this disclosure multiple hard verifiable data points, which qualifies it as Quantified-Verifiable.

fact: June of 2023 (incident date)

fact: two employees' email accounts compromised

fact: early September 2023 (customer notification date)

fact: approximately $25,000 in incident-related expenses


reasoning: The paragraph is about the person — the CIO's educational background, career history (30+ years, prior roles at public and PE-owned firms), and experience with cybersecurity events. The person-vs-function test confirms Management Role: remove the credentials and career history, and nothing substantive remains. CIO is a cybersecurity-specific title (Firm-Specific), and 'over 30 years' is one QV-eligible fact, but only one hard verifiable fact exists, so it stays at Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph is about the CIO's background, credentials, and experience. It describes who the person is — their degree, years of experience, prior roles. This is about the person, not the function.

Content category: Management Role — the paragraph describes the CIO's qualifications, experience, and background.

Specific facts:
- CIO (cybersecurity-specific title) → named_role
- "undergraduate degree in computer science" — generic degree without named university, per NOT list
- "over 30 years" of experience → quantified (specific number of years)
- "senior technology leader or Chief Information Officer of two public companies and two private equity-owned firms" — this gives career history

- CFO mentioned — generic C-suite per NOT list

Now checking what's QV-eligible: the 30 years of experience is specific and counts, but the CIO title itself doesn't qualify. The company counts are vague without actual names, and there are no universities, certifications, dates, or dollar amounts mentioned. That leaves just one QV-eligible fact, so this falls into Firm-Specific.

fact: Chief Information Officer (CIO)

fact: over 30 years of experience in information technology


reasoning: The paragraph explicitly assesses materiality ('we did not experience a material cybersecurity incident' in the specified period), references past material breaches, and extensively discusses potential business/financial consequences (costs, litigation, regulatory liability, reputational harm), making Strategy Integration the dominant category per Rule 6 and the tiebreaker for brief incident mention + materiality conclusion. The specific date (December 31, 2023) and quantified past breaches ('two') are firm-specific facts, but only the date clearly qualifies as QV-eligible, yielding one hard verifiable fact — Firm-Specific, not Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers several things:
- Generic cyber risk acknowledgment
- Commitment to oversight (generic)
- No material incident in year ended December 31, 2023
- Two past material breaches (references prior filing)
- Potential costs and impacts
- Generic threat landscape language
- Cross-reference to Risk Factors

This is a mixed paragraph. Let me determine the dominant category.

The paragraph mentions:
1. A materiality assessment: "In the year ended December 31, 2023, we did not experience a material 'cybersecurity incident'"
2. Past breaches: "we have experienced two such material breaches in the past"

3. Potential financial/business impacts
4. Cross-reference to Risk Factors

The materiality assessment plus past incident reference plus business impact discussion points to Strategy Integration. The paragraph explicitly assesses whether cybersecurity incidents have materially affected the company (Rule 6). The bulk of the paragraph discusses potential business/financial consequences.

Actually, let me reconsider. There's an incident disclosure element ("two such material breaches in the past"), but it's brief and not descriptive of what happened. The materiality conclusion is present. The bulk is about potential business impact and risk language.

Per the tiebreakers: a brief mention of a past incident combined with a materiality conclusion as the main point suggests this falls under Strategy Integration rather than Incident Disclosure, since the focus is on assessing material impact and discussing potential consequences rather than describing what actually happened.

Now I'm checking the specificity elements. The filing includes a specific date ("year ended December 31, 2023"), a quantified number of breaches ("two such material breaches"), and a regulatory reference (Item 106(a) of Regulation S-K). The date and breach count are hard verifiable facts, though the breach count itself isn't a headcount, dollar amount, or percentage—it's just a specific number.

Looking at what actually qualifies as QV-eligible, I need to be more precise. The list includes specific dates, dollar amounts, headcounts, percentages, named firms, products, certifications, and years of experience. "Two material breaches" is quantified but doesn't fit neatly into those categories since it's neither a headcount nor a dollar amount. That leaves me with just the specific date as clearly QV-eligible, which would make this Firm-Specific rather than QV.

fact: year ended December 31, 2023 — no material cybersecurity incident

fact: two material breaches in the past


reasoning: The paragraph describes an actual cybersecurity incident: unauthorized access discovered on a specific date, activation of incident response, notification of law enforcement, and the nature of the intrusion (encryption and monitoring software deployment). Two QV-eligible hard facts: the specific date (October 15, 2025) and a named external entity (FBI).

thinking:
Incident disclosure - describes what happened, when, response actions.

Facts: "October 15, 2025" (specific date), "Federal Bureau of Investigation (FBI)" (named firm/agency). That's two QV-eligible facts.

fact: October 15, 2025

fact: Federal Bureau of Investigation (FBI)


reasoning: The paragraph describes an actual cybersecurity incident — specifically that information was exfiltrated and the investigation into the extent of compromise is ongoing. This is incident narrative (what happened, what is still being assessed). However, there are no specific dates, named systems, named firms, or other facts from the IS list; 'certain information' and 'accessed IT systems' are vague quantifiers, so specificity remains Generic Boilerplate.

thinking: Classifying this paragraph about an ongoing investigation into data exfiltration.


reasoning: The paragraph describes an actual cybersecurity incident: unauthorized access, data exfiltration (video meeting images, screen captures), public release of stolen data as part of a ransom demand, and remediation actions taken. However, it contains no specific dates, named firms, named tools, dollar amounts, or other hard facts — 'threat actors,' 'certain computer systems,' 'vendors and customers,' and 'additional cybersecurity measures' are all generic/vague language per the NOT list.

thinking:
Incident disclosure - describes what happened in a cybersecurity incident.

Specific facts: No dates, no named firms, no named tools. "threat actors", "certain computer systems", "vendors and customers" are all generic. The content describes an actual incident but with vague language.

Category: Incident Disclosure
Specificity: Generic Boilerplate - no specific dates, no named entities, no named tools, no numbers.


reasoning: The paragraph describes the ongoing investigation and scope assessment of an actual cybersecurity incident, including what data may or may not have been compromised. This is incident narrative content. However, it contains no specific dates, named firms, named tools, or other facts from the IS list — all language is generic incident response boilerplate ('ongoing investigation', 'personally identifiable information', 'potential compromised systems').


reasoning: The paragraph describes who leads the CSIRT and Incident Response Team and their qualifications — the consultant's cybersecurity certification and the CFO's 20+ years of IT oversight. This is about the people and their credentials (person test), not about what the incident response process does. 'Over twenty years' is a specific duration qualifying as a firm-specific fact, but CFO is generic C-suite and 'certified in cybersecurity' lacks a named certification, so only one QV-eligible fact prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content: Describes the CSIRT composition - an outside cybersecurity consultant as strategic lead, CFO co-leading the IRT. Then describes qualifications: consultant is certified, CFO has 20+ years IT oversight.

Category: This is about who the people are - their roles, qualifications, experience. The person-vs-function test: the paragraph tells us about the people (consultant's certification, CFO's 20+ years of IT experience). It's describing the personnel and their qualifications, not the processes they run. → Management Role

Specific facts:
- "CSIRT" - named internal program with unique identifier? It's a common acronym (Computer Security Incident Response Team), but having one is firm-specific organizational detail

- "independent outside cybersecurity consultant" - unnamed entity → NOT list
- "CFO" - generic C-suite per NOT list
- "certified in cybersecurity" - vague certification claim (no named certification like CISSP)
- "over twenty years" - specific number of years of experience → QV-eligible

Now checking against the IS and NOT lists: the CFO and unnamed consultant both fall under generic roles, the CSIRT and incident response team are standard program names, but that specific duration of experience does qualify as a concrete detail.

Looking at the certification claim more closely—just saying "certified in cybersecurity" without naming which certification is too vague to count as a named credential. That leaves only one verifiable fact: the twenty-plus years of experience. Since I need at least two QV-eligible facts to meet that threshold, this falls into Firm-Specific territory.

fact: CFO has overseen IT for over twenty years


reasoning: The paragraph describes internal cybersecurity evaluation processes — meetings to assess controls, engaging third-party experts to review and suggest improvements. The third-party experts serve the company's own assessment (Rule 3: external assessors hired to test the company → RMP). No named frameworks, roles from the IS list, dates, firms, or quantified details are present; 'senior security leadership,' 'risk-management team,' 'internal and external auditors,' and 'third-party cybersecurity experts' all fall on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Senior security leadership meets with risk-management team and auditors to evaluate cybersecurity systems/controls. Also engages third-party experts for assessments.

Category: This describes internal processes - risk assessment, evaluation of controls, engaging third-party experts to assess the company. The third-party mention is about experts hired to serve the company (Rule 3: external assessor hired to test the company → Risk Management Process). The primary topic is the company's own evaluation processes. → Risk Management Process

Specificity: Let me check for specific facts.
- "Senior security leadership" - not a cybersecurity-specific title from the IS list

- "risk-management team" - generic
- "internal and external auditors" - unnamed entities
- "third-party cybersecurity experts" - unnamed
- "executive leadership" - generic
- No frameworks named, no dates, no numbers, no named firms/tools

All items fall on the NOT list. → Generic Boilerplate


reasoning: The paragraph leads with and is grounded in a specific incident narrative — malware detection, quarantine, server rebuild, and resulting outage causing ~1,700 cancellations — making Incident Disclosure the dominant category despite substantial materiality/financial content in the latter half. Multiple QV-eligible hard facts (specific year, flight cancellation count, $16M dollar amount, specific recovery date) easily clear the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

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

1. Incident description: malware in 2021, quarantined, server rebuild, server outage, ~1,700 flight cancellations
2. Financial impact: ~$16M pre-tax loss
3. Insurance recovery: ~half recovered through cyber insurance by Dec 31, 2023
4. Materiality assessment: don't believe it materially affected them
5. Forward-looking materiality: no material risks identified for 2023, but ongoing risks exist
6. Cross-reference to Risk Factors

This paragraph has both incident details AND financial/strategy content.

The paragraph opens with incident narrative describing what happened, then shifts to discussing the financial consequences and materiality implications. Since it leads with the incident description and details, this falls under incident disclosure rather than pure strategy discussion. I'm working through whether this is primarily an Incident Disclosure or Strategy Integration classification. The paragraph opens with the malware incident and its operational consequences, then moves into financial impact and materiality assessments. Since the incident narrative and its direct fallout dominate the content—the materiality discussion only makes sense in context of what happened—I'm leaning toward Incident Disclosure as the primary category. The incident narrative is really the core here, so I'm going with Incident Disclosure as the classification. Looking at the specifics, there are multiple quantified facts I can point to—the 2021 timeframe, the roughly 1,700 flight cancellations, and the $16 million pre-tax impact—which means this qualifies as Quantified-Verifiable.

fact: During 2021 (incident timeframe)

fact: approximately 1,700 flight cancellations

fact: approximately $16 million (pre-tax) financial impact

fact: year ended December 31, 2023 (insurance recovery period)


reasoning: The paragraph describes the company's internal cybersecurity processes (prevent, assess, identify, manage risks) — this is Risk Management Process. It contains no named frameworks, roles, dates, or firm-specific details; the language could apply to any company.


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any risks from cybersecurity threats that have materially affected or are reasonably likely to materially affect our business strategy, results of operations and financial condition'), which per Rule 6 is Strategy Integration. The language is boilerplate materiality disclaimer with no firm-specific facts.


reasoning: The paragraph describes the company's own internal business continuity and resilience program, including risk assessment methodology (business impact analysis, risk level determination, prioritization) — all hallmarks of Risk Management Process. It names DRII as a recognized standard, which triggers Sector-Adapted, but contains no firm-specific facts from the IS list (no cybersecurity-specific roles, named tools, dates, headcounts, or unique program identifiers).

thinking:
Let me analyze this paragraph.

Content: Describes business continuity/resilience program, mentions DRII standards, business impact analysis, risk assessment methodology.

Category: This is about internal processes - risk assessment, business continuity, framework adoption. Risk Management Process.

Specificity: Names "Disaster Recovery Institute International (DRII)" - this is a recognized standard/framework. That's a named standard → Sector-Adapted at minimum. Is DRII a firm-specific fact? It's a named organization/standard. Similar to naming NIST or ISO. I'd say Sector-Adapted.

Wait - is there anything firm-specific? "business continuity and resilience program" is generic. DRII is a named standard. No firm-specific facts from the IS list.

So this lands at Sector-Adapted.

fact: Disaster Recovery Institute International (DRII) standards


reasoning: The paragraph describes engaging external assessors and consultants to evaluate the company's own cybersecurity program — per Rule 3, external parties hired to test/serve the company are Risk Management Process, not Third-Party Risk. All entities are unnamed ('external assessors,' 'third-party service providers,' 'industry standards') with no specific facts, frameworks, roles, or dates.

thinking:
Classify this paragraph.

Content: Describes engaging external assessors/consultants to evaluate the company's cybersecurity program. These third parties serve the company's internal program - they're hired to evaluate the company, not vendors being overseen.

Category: Risk Management Process (external assessors hired to test/evaluate the company = internal process per Rule 3)

Specificity: No named frameworks, no named firms, no named roles, no dates, no specific facts. Everything is generic: "external assessors, consultants, and auditors", "third-party service providers", "industry standards and best practices". All on the NOT list.

→ Generic Boilerplate


reasoning: The entire paragraph describes the company's governance of third-party vendor relationships — security screening, annual assessments, vendor categorization, due diligence, and contract review — making Third-Party Risk the clear dominant category. It contains firm-specific organizational details (CISO role, Risk Committee, dedicated Vendor Management Department with a Vendor Manager, Business Unit Manager involvement) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, or named external firms/tools).

thinking:
Let me analyze this paragraph.

Content: This is about third-party vendor risk management. The central topic is oversight of external parties - vendor relationships, vendor management policy, vendor security assessments, vendor due diligence, vendor risk categorization.

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

Specific facts:
- CISO (cybersecurity-specific title) → IS list
- Risk Committee (named non-generic committee) → IS list
- Vendor Manager (specific role)
- Vendor Management Department (specific department)
- Business Unit Manager (generic)

Let me check specificity:
- CISO → IS list, firm-specific

- Risk Committee → IS list, firm-specific named committee
- Vendor Management Department and Vendor Manager are organizational details tied to this firm

Looking at the QV criteria: I don't have two hard verifiable facts like dates, dollar amounts, headcounts, or named third-party vendors. The CISO and Risk Committee are named roles and committees but not independently verifiable facts, so this doesn't qualify as QV.

This is clearly firm-specific due to the presence of CISO and Risk Committee.

fact: CISO oversees vendor security assessments

fact: Risk Committee receives periodic reports on vendor risk management

fact: Vendor Management Department led by Vendor Manager


reasoning: The paragraph contains an explicit materiality assessment ('no such incident has had any such impact to date') regarding cybersecurity incidents' effect on business, which per Rule 6 makes it Strategy Integration even though a cross-reference to Risk Factors follows. The opening sentence about maintaining protocols is generic preamble, and the cross-reference is secondary to the materiality conclusion. No firm-specific facts from the IS list are present — the risk factor titles and filing section references are company self-references on the NOT list.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. Generic statement about maintaining protocols and monitoring
2. A materiality-adjacent statement: "no such incident has had any such impact to date"
3. A cross-reference to Item 1A Risk Factors for information about whether cyber risks have materially affected the company

The key question is whether this is Strategy Integration or None/Other.

The paragraph does contain a brief materiality-related statement ("no such incident has had any such impact to date") but the explicit materiality assessment language ("materially affected or are reasonably likely to materially affect... business strategy, results of operations, or financial condition") is in the cross-reference - it says "for additional information regarding whether..." and points to Risk Factors.

So the materiality assessment is actually embedded in the cross-reference itself. The statement "no such incident has had any such impact to date" functions as a materiality conclusion, and per Rule 6, a cross-reference to Risk Factors appended to a materiality assessment doesn't change the classification. This means the materiality language is present in the paragraph, even though it's directing readers elsewhere for additional detail.

Looking at specificity: there are no named standards, no firm-specific facts from the IS list, and no dates or named roles. The cross-reference mentions specific risk factor titles, but those are just the company's own filing sections, which don't count toward specificity. This points to Strategy Integration with Generic Boilerplate.


content_category: None/Other

reasoning: This paragraph describes the company's general IT infrastructure and business operations dependency on technology systems. It contains no cybersecurity-specific disclosure content — no risk management processes, governance structures, incidents, or strategic assessments. It reads as general business context language that could apply to virtually any company.

thinking: This paragraph describes general business IT systems and data handling. No cybersecurity-specific disclosure content.


reasoning: The paragraph contains a materiality assessment ('material adverse effect on our business') combined with a cross-reference to Risk Factors. Per Rule 6, the materiality language makes this Strategy Integration rather than None/Other, though it's borderline since the materiality mention is hypothetical rather than a direct assessment of whether risks have materially affected the company. The cross-reference heading is company-specific text but is a risk factor title, not a cybersecurity disclosure fact.


reasoning: The paragraph is framed as 'Role of Management' and primarily describes who manages cybersecurity: management established a named Cybersecurity Governance Committee, its composition, and the IT manager's 20+ years of experience. While process elements (vulnerability scanning, monitoring) appear, the dominant purpose is identifying the management structure and the key person's qualifications. The Cybersecurity Governance Committee is a named non-generic committee (IS fact), and '20 years of experience' is a specific number, but only one QV-eligible hard fact (years of experience) exists since named committees don't count toward QV, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes management's cybersecurity governance committee, IT manager's experience, and some processes.

Category analysis:
- "Company management has established a Cybersecurity Governance Committee" - management establishing a committee
- Committee composition: IT Manager + senior management
- Committee activities: discuss updates, watch threats, monitor compliance, respond to inquiries
- IT department led by manager with 20+ years experience
- Third-party vulnerability scanning

The paragraph starts with "Role of Management" and describes management's structure for cybersecurity. The primary actor is management - establishing the committee, the IT manager's qualifications. But there's also process description (vulnerability scanning, monitoring).

The section is primarily about management's governance structure and the IT manager's qualifications, though it does touch on some operational processes like vulnerability scanning. The heading "Role of Management" confirms the focus is on how management has organized cybersecurity oversight through the committee and the experienced leadership in place. I'm checking whether "Information Technology Manager" qualifies as a cybersecurity-specific title—it's too generic compared to roles like CISO or Director of IT Security. The named committee and the specific "over 20 years of experience" are both solid facts I can work with.

So I have one QV-eligible fact, which makes this Firm-Specific at level 3.

fact: Cybersecurity Governance Committee

fact: over 20 years of experience (IT manager)


reasoning: Although the paragraph opens with a materiality assessment, the dominant content is a detailed incident narrative describing the February 2023 ransomware attack — what happened (encrypted servers), response actions (unencrypt, restore from backups), and outcome (minimal disruption, no ransom paid). The single QV-eligible hard fact is the specific date (February 2023); third-party response teams are unnamed and other quantifiers ('thousands', 'a few days') are vague, so it reaches Firm-Specific but not Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This paragraph contains multiple elements:
1. A materiality assessment ("have not materially affected...")
2. General threat acknowledgment
3. A specific incident description (February 2023 ransomware attack)
4. Response actions and outcome

The dominant content is the incident narrative - it describes what happened (ransomware attack), when (February 2023), scope (encrypted certain network servers), response (unencrypt, restore from backups), and outcome (minimal disruption, no ransom paid).

Category: The materiality statement is present but the bulk of the paragraph describes an actual cybersecurity incident. The incident narrative dominates. → **Incident Disclosure**

Now I'm checking what specifics are actually present. The February 2023 date is concrete and qualifies, but most other details are vague—the response teams aren't named, the server count uses a loose quantifier, and the timeline is imprecise. So really just that one date counts as a specific fact.

Since there's only one qualifying fact, this doesn't meet the QV threshold. But the date itself is firm-specific information, which puts this in the Firm-Specific category.

fact: February 2023 cyberbreach from global ransomware attack


reasoning: The CISO is the grammatical subject throughout, describing reporting lines and briefing cadence to the Technology Committee and Board. Per Rule 2, 'CISO reports quarterly to the Board on...' → Management Role. The paragraph focuses on the CISO's communication role rather than the person's credentials (which would push higher confidence) or internal cybersecurity processes. 'Technology Committee' is a named non-generic committee and 'CISO' is a cybersecurity-specific title, both qualifying as firm-specific facts, but neither is QV-eligible (no dates, dollar amounts, headcounts, named firms, or tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the CISO's role in briefing the Technology Committee and Board. The grammatical subject is "The CISO" throughout. The content is about what the CISO does - briefing cadence, reporting structure, topics covered.

Category: This is about the CISO as the primary actor - but is it about the person or the function? The paragraph doesn't describe credentials, background, or qualifications. It describes what the CISO does in terms of reporting/briefing. The CISO is the grammatical subject performing actions of informing/briefing the board and committee.

This is a borderline case.

The CISO is clearly the primary actor here, and the focus is on their reporting activities to governance bodies. According to the decision rules, when a management role reports to the board, that's a management role classification. The paragraph centers on what the CISO communicates and how often, not on who fills the position or their background - so this is fundamentally about the function rather than the person. The reporting cadence terms are too generic to count as specific facts, and there are no QV-eligible details like dates or dollar amounts. Since the only specificity comes from the CISO role and Technology Committee name, this lands as Firm-Specific.

fact: CISO

fact: Technology Committee


reasoning: This is a cross-reference directing the reader to a subsidiary's separate filing for cybersecurity disclosure. It contains no substantive cybersecurity disclosure content itself. Per the codebook, pure cross-references are None/Other, and None/Other always receives Generic Boilerplate.