reasoning: The paragraph mixes generic process descriptions (security policy, response procedures, training) with a substantive materiality assessment ('have not been materially affected... business strategy, results of operations, or financial condition') and a cybersecurity insurance mention. Per Rule 6, the explicit materiality conclusion makes this Strategy Integration despite the process language leading the paragraph. No named frameworks, roles, dates, dollar amounts, or firm-specific facts are present — all details (annual, periodic, last three years) are generic cadences or vague quantifiers.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Security policy reviewed annually
2. Response procedures for incidents, tested periodically
3. Cybersecurity training for employees
4. No material incidents in last three years + materiality assessment
5. Cybersecurity insurance

The dominant content: This paragraph mixes Risk Management Process (security policy, response procedures, training) with Strategy Integration (materiality assessment, insurance). The materiality statement is substantial - "have not experienced material information security incidents in the last three years nor have we incurred any material expenses... nor have we been materially affected or reasonably likely to have had a material adverse effect on us, our business strategy, results of operations, or financial condition." Plus insurance mention.

Looking at the structure more carefully, the first three sentences lay out internal processes while the last two focus on the materiality assessment and insurance coverage. Even though processes take up more space, the materiality conclusion and insurance mention form the substantive core—the paragraph's real message is that we have basic security measures in place, nothing material has gone wrong, and we're covered by insurance. away.

I'll go with Strategy Integration since the materiality assessment is the most substantive claim per Rule 6, and the process descriptions are generic filler leading to that conclusion.

Wait, actually the dominant category rule says assign based on most text or primary communicative purpose. Three sentences are RMP, two are strategy. But the RMP sentences are very generic. The materiality statement is the meatiest sentence. I think Strategy Integration is right given Rule 6's emphasis.

Actually, let me reconsider. The paragraph leads with process descriptions. But per Rule 6, materiality disclaimers → Strategy Integration. And the paragraph explicitly assesses materiality. I'll go Strategy Integration.

Specificity: Let me check for specific facts. I'm seeing vague quantifiers like "last three years" and "annual basis," generic cadences like "periodic basis," and references to things like "cybersecurity insurance policy" with no named insurer, no named frameworks, no named roles, specific dates, dollar amounts, or named firms. Everything points to Generic Boilerplate.


content_category: Management Role

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph's primary purpose is to establish that management is responsible for cybersecurity, listing their areas of responsibility (hiring, budgets, incident prep, reviewing assessments). The grammatical subject is 'certain members of our management team and IT department,' making this a management role attribution. However, no cybersecurity-specific titles (CISO, CIO, etc.), no named individuals, no credentials, and no firm-specific details are provided — 'management team and IT department' are generic references that could apply to any company, yielding Generic Boilerplate.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Describes management team and IT department responsibilities for cybersecurity. Lists functions like hiring, integrating cyber into ERM, budgets, incident prep, approving processes, reviewing assessments.

Category: This is about management's role but uses generic "certain members of our management team and IT department" - no named roles. The paragraph describes functions/responsibilities. It's borderline Management Role vs Risk Management Process. The grammatical subject is "certain members of our management team and IT department" - management is the subject, describing what they're responsible for. But it's very generic - no CISO, no named individuals. This reads more like Management Role since it's about who is responsible, though the responsibilities listed are process-like.

The grammatical subject is clearly management, so that points toward Management Role. But when I test it by substituting "the Company" for the management reference, the paragraph still reads as process descriptions rather than role descriptions. There's no person here—no credentials, background, or specific title—just a list of what management does. That said, these aren't formalized processes either; they're management-level responsibilities for cybersecurity oversight, which ultimately makes this a Management Role category, albeit a very generic one.

Looking at specificity: there are no named roles, no frameworks, no dates, no concrete facts. "Management team and IT department" is entirely generic. That's Generic Boilerplate.


category_confidence: high

reasoning: The paragraph leads with the VP of IT's role, experience (20+ years), and education, making the person's identity and qualifications the primary content — satisfying the person-vs-function test for Management Role. The framework references and team description are subordinate to establishing who leads cybersecurity. Specificity is Firm-Specific: the cybersecurity-specific title (VP of IT) and 20 years of experience are IS-list facts, but only one QV-eligible hard fact (years of experience) exists — the degrees lack named universities and the frameworks are not QV-eligible — so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the VP of IT role, their experience, qualifications, team, and frameworks used.

Category: This is primarily about the person (VP of IT) - their title, experience, education, and team. But it also describes processes and frameworks. Let me apply the person-vs-function test.

The first two sentences are about the person: title, experience (20 years), education. The third sentence describes the team. The fourth sentence describes processes (framework assessments).

The paragraph leads with the person and their qualifications. The dominant content is about who leads cybersecurity and their background. → Management Role

Now I'm checking what qualifies as specific and quantifiable. The VP title and 20+ years of experience are concrete details, while the degrees lack institutional names so they don't meet the bar. The frameworks—NIST CSF, CIS Controls, ISO 27001—are named standards that count as sector-adapted triggers. The companies mentioned are generic references without specifics, so they don't add precision.

With just one quantifiable fact (the 20 years), this doesn't reach the QV threshold, but the IS-list role combined with that experience duration pushes it to Firm-Specific classification.

fact: Vice President, Information Technology and Facilities (VP of IT)

fact: over 20 years in information technology

type: quantified

fact: NIST Cybersecurity Framework

type: framework

fact: CIS Controls


content_category: Board Governance

reasoning: The paragraph's primary subjects are the board of directors and Audit Committee, describing their oversight responsibilities, quarterly meeting cadence with the CISO, reporting flows, and escalation processes. The CISO is mentioned in a subordinate role (reporting to the board), keeping this Board Governance. The CISO title is the sole IS-list fact; 'Audit Committee' and 'quarterly' are on the NOT list, and no QV-eligible hard facts (dates, amounts, named firms/tools) are present, so specificity is Firm-Specific.

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

Content Category: The paragraph is about board/committee oversight of cybersecurity. The board delegates to Audit Committee, the Audit Committee's responsibilities, quarterly meetings with CISO, reporting structure. The grammatical subjects are primarily the board and Audit Committee. Even though the CISO is mentioned, the CISO is subordinate — the paragraph frames everything from the board's oversight perspective. → Board Governance

Specific facts:
- CISO (cybersecurity-specific title) → named_role ✓
- Quarterly meetings with board members and CISO → cadence is generic ("quarterly")

- "risk-based escalation process" → generic

Checking against the IS/NOT lists: Audit Committee, board of directors, and quarterly cadence are all generic. No named frameworks, specific dates, dollar amounts, or named firms appear. The only IS fact is the CISO title itself, which gives me Firm-Specific (3). For Quality Verification, I'd need 2+ hard verifiable facts beyond just the named role, but there are no dates, amounts, or named tools to work with here.

fact: Chief Information Security Officer (CISO)


reasoning: The grammatical subjects performing the primary action are the Director of Information Technology and BDO, who report upward to management (COO, General Counsel) and to the board committee. Per Rule 2, 'Management role reports TO the board → Management Role.' The paragraph describes reporting lines rather than board oversight actions. BDO is a named third-party firm (QV-eligible but only one such fact) and the 'Audit and Cyber Risk Committee' is a named non-generic committee (firm-specific), yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph describes reporting lines: Director of IT and BDO report to COO/General Counsel and to the Audit and Cyber Risk Committee quarterly.

Category: This is about reporting structure. The primary actors are the Director of IT and BDO (a named third-party firm). They report TO the board committee. The paragraph describes management reporting lines and structure, but also involves the board committee receiving reports.

Who is the grammatical subject? "BDO" and "Director of Information Technology" - they report to COO/General Counsel and to the board committee. The primary actors are management-level, reporting upward. But this is really about the reporting structure/lines.

I'm checking whether "Director of Information Technology" qualifies as a cybersecurity-specific role—the IS list has "Director of IT Security" but not this generic IT title. The key entities here are BDO as the named third-party firm and the "Audit and Cyber Risk Committee" as the named board committee they're reporting to. The grammatical subject is BDO and the Director of IT reporting to the committee, which fits the Management Role category per Rule 2 — but BDO isn't actually a management role, and the Director of IT's cybersecurity function is secondary to the reporting structure itself. I'm wrestling with whether the primary purpose is describing the reporting chain (Management Role) or the board's oversight mechanism (Board Governance), since the committee receiving quarterly reports is fundamentally a governance function.

For specificity, BDO qualifies as a named third-party firm, and the Audit and Cyber Risk Committee is a named non-generic committee, but the Director of Information Technology is generic IT leadership that doesn't appear on the cybersecurity-specific roles list.  COO and General Counsel are also generic C-suite positions, and "quarterly" is just a standard reporting cadence. That gives me only one QV-eligible fact—BDO—so this doesn't meet the Quantified-Verifiable threshold. The IS facts are BDO and the committee name, making this Firm-Specific overall.

Now I'm reconsidering the category itself. The passage describes a reporting and oversight structure where BDO, an external consultant, feeds information up through management to the board. This could fit Management Role, Board Governance, or Third-Party Risk depending on what the dominant focus is—and it seems to center on that reporting chain for cybersecurity oversight.

The grammatical subject is management reporting to the board, which per the rules points to Management Role, even though I'm tempted by Board Governance since the real disclosure is about how the board receives its information. But I'll stick with Management Role, Firm-Specific.

fact: BDO (named third-party firm involved in reporting)

fact: Audit and Cyber Risk Committee (non-generic board committee)


reasoning: The paragraph's primary content is organizational structure: committee compositions (ERC, CITF), reporting lines (CISO reports to CDO), and role responsibilities — all describing who is responsible rather than what processes they run. Multiple cybersecurity-specific roles (CISO, CDO) and named team compositions qualify as firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named third-party firms, named tools) are present.

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

The paragraph describes multiple management-level committees and roles responsible for cybersecurity. Let me identify the key elements:

1. ERC (Enterprise Risk Committee) - comprised of CLO, CDO, CISO, VP of Internal Audit, VP of Ethics/Compliance/Risk Management
2. CDO and CISO reporting structure (CISO reports to CDO)
3. CITF (includes CDO, CISO, CLO, CFO) - responsible for evaluating incidents and disclosure

**Content Category:** This is about management roles and committees. The grammatical subjects are the ERC, CDO/CISO, and CITF - all management entities.

The core question is whether this focuses on organizational structure or operational processes. The paragraph emphasizes committee compositions, reporting relationships, and assigned responsibilities—it's fundamentally describing how the organization is structured to handle cybersecurity governance rather than detailing the specific processes or procedures themselves. This is a management structure classification.

Looking at the specific facts that would qualify for QV eligibility: I have named roles like CISO and CDO, committee compositions with specific titles, and reporting lines. But these are firm-specific organizational details without the quantifiable elements—no dates, financial figures, headcounts, or external firm references—that would make them QV-eligible facts.

This lands at Firm-Specific (3) since there are multiple firm-specific facts present but they don't meet the two-fact QV threshold.

fact: CISO

fact: CDO (Chief Digital Officer)

fact: ERC comprised of CLO, CDO, CISO, VP of Internal Audit, VP of Ethics Compliance and Risk Management

fact: CITF comprised of CDO, CISO, CLO, CFO

fact: CISO reports to CDO

fact: Vice President of Internal Audit

fact: Vice President of Ethics, Compliance and Risk Management


content_category: Risk Management Process

reasoning: The paragraph begins by naming CIO and CISO but the bulk of the content describes the information security program, policies, and a series of assessments (enterprise risk, threat/vulnerability, cloud risk). Applying the person-vs-function test: remove the role titles and the paragraph still fully describes processes → Risk Management Process. Firm-Specific due to cybersecurity-specific roles (CIO, CISO) and a named non-generic committee (information security committee); no two QV-eligible hard facts (named roles don't count toward QV).

thinking:
Let me analyze this paragraph.

Content: Describes IT security team led by CIO and CISO, their responsibilities, and lists specific assessments/reviews they conduct. The paragraph starts with management roles but quickly shifts to describing processes and activities.

Person-vs-function test: Remove "led by our CIO and our CISO" — the paragraph still describes the IT security team's processes, the information security program, policies, and various assessments. The bulk is about what the program does, not who the people are. → Risk Management Process.

Specificity:
- CIO: cybersecurity-specific title → IS list ✓

- CISO: cybersecurity-specific title → IS list ✓
- "information security committee": this is a named non-generic committee → IS list ✓
- NIST guidance: named framework → Sector-Adapted
- "annual", "quarterly", "periodic": generic cadences → NOT list

QV check: Named roles (CISO, CIO) don't count toward QV. No dates, dollar amounts, headcounts, named third-party firms, named tools. Only one framework (NIST). So not QV.

Firm-Specific facts: CISO, CIO, information security committee — these are at least Firm-Specific details.

fact: CIO leads IT security team

fact: CISO leads IT security team

fact: Information security committee approves policies

fact: NIST guidance


reasoning: The paragraph introduces the VP of IT, establishes their credentials (20+ years industry experience, 25+ years cybersecurity experience), defines the scope of their oversight responsibilities (items i-iv), and describes the supporting IT team. While the activities listed are substantial, the paragraph's communicative purpose is to establish who leads the cybersecurity program, what qualifies them, and what their role encompasses — fitting Management Role. Two QV-eligible facts (specific years of experience counts) yield Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph starts by describing the VP of IT's experience (20+ years industry, 25+ years cybersecurity programs). Then it describes what the oversight includes - reviewing risk register, managing risks, analyzing logs, overseeing prevention/detection/mitigation/remediation, incident response plan. Then mentions an experienced IT team supporting the VP.

Person vs function test: The paragraph opens with the VP's credentials (20+ years, 25+ years), which is about the person. But then the bulk of the paragraph describes what the oversight function includes - processes, log analysis, prevention/detection, etc.

The person's qualifications are mentioned but the dominant content is about what the program does.

Applying the person-vs-function test, if I strip away the VP title and experience, the substantive cybersecurity activities remain intact - the risk register review, risk management, log analysis, and incident response planning all stand on their own. This pulls toward Risk Management Process, though the opening emphasis on the person's credentials and the mix of both personal qualifications and functional responsibilities makes this a borderline case. I'm wrestling with whether the credentials here are substantive enough to push this into Management Role territory. The person's qualifications are genuinely detailed—20+ and 25+ years of experience—but the codebook's example shows that even when a CISO is named with their role, if the paragraph is mostly about what the cybersecurity program does, it's still Risk Management Process. Here, the bulk of the text is the activities list, so despite the prominent credentials, I think this stays as Risk Management Process with management attribution rather than shifting to Management Role. The credentials and organizational structure around the VP are pretty central to how this paragraph is framed—it's really introducing the person and their qualifications as much as describing what they do. Looking back at the category definition, Management Role explicitly includes qualifications, career history, and scope of responsibility, which all fit here. The activities listed aren't just abstract processes; they're defining what this specific role encompasses. I'm leaning toward Management Role because the paragraph's main purpose is establishing who the VP is and what authority they hold, not just documenting a standalone risk management process. define the role's scope rather than being a standalone process description.

Actually, let me be more decisive. The codebook says: "Management Role requires the paragraph's content to be about the person — who they are, what makes them qualified, how long they've served, what their background is."

The qualifications are there (20+ years, 25+ years). But items (i)-(iv) are about processes. It's roughly 30% person, 70% function.

I'll go with Risk Management Process per the dominant category rule and the person-vs-function test. The credentials are present but the bulk is process description.

VP of IT is a named role on the IS list, so that's firm-specific. But the experience metrics—20+ years in the industry and 25+ years in cybersecurity—those are specific numbers that qualify as quantified-verifiable facts. Two separate measurements means two QV-eligible data points, so this falls under Quantified-Verifiable overall. experience).

Hmm, actually, I want to reconsider the category. Given that this has substantial person-description AND substantial process-description, and the paragraph opens with and is framed around the VP's role... Let me just go with my analysis. Risk Management Process, because the person-vs-function test says remove the person details and check if substantive content remains - it does.

Wait, one more consideration. The last sentence about the IT team is about organizational structure supporting the VP, which is more Management Role territory.

I'll split the difference and call it Management Role. The paragraph introduces the VP, gives credentials, defines their scope, and describes their supporting team. The activities listed define the role's responsibilities rather than serving as a standalone process description. The framing is "here's who manages our cybersecurity and what they're responsible for."

OK, I need to just decide. Let me go with Management Role. The communicative purpose is to introduce and credential the cybersecurity leader, define their responsibilities, and outline their team structure. For specificity, I've got two quantifiable facts here—the years of experience mentioned as specific numbers—plus the VP of IT title which is firm-specific.

fact: Vice President, Information Technology

fact: more than 20 years of industry experience

fact: over 25 years of experience with cybersecurity programs


reasoning: The paragraph is about the person filling the cybersecurity leadership role — their degree, years of experience, and tenure. The SVP of IT is a cybersecurity-adjacent specific role (VP of IT/Security on the IS list), and 'over 26 years' is a specific number. However, the Master's degree lacks a named university (not QV-eligible) and the role title doesn't count toward QV, so only one QV-eligible fact (26 years) → Firm-Specific, not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: About the SVP of IT - their degree, years of experience. Then a generic statement about staying informed.

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

Specific facts:
- "Senior Vice President, Information Technology" - this is a named role, but is it cybersecurity-specific? Let me check the IS list. "VP of IT/Security" is listed. SVP of IT is close enough to VP of IT.
- "Master's degree in business administration and industrial psychology" - generic degree without named university → NOT list
- "over 26 years" - specific number of years of experience → quantified

- The "over 26 years" experience qualifies as a specific duration, which makes it QV-eligible according to the criteria. The named role itself doesn't count toward QV, and the degree without a university name doesn't either. So I'm left with just one QV-eligible fact here, making this Firm-Specific overall.

fact: over 26 years in information technology


reasoning: The audit committee is the grammatical subject overseeing cybersecurity risk via internal controls, making this Board Governance. All elements — 'audit committee,' 'independent directors,' 'internal controls designed to assess, identify, and manage material risks' — are generic governance language found in any filing, with no named frameworks, cybersecurity-specific roles, or firm-specific facts.

thinking:
Classify this paragraph.

The paragraph is about the Audit Committee's oversight of cybersecurity risks and its composition.

Content Category: Board Governance — The audit committee (a board committee) is the grammatical subject, overseeing cybersecurity risk management.

Specificity: Let me check the facts.
- "audit committee" — generic governance, on the NOT list
- "all of our independent directors" — generic governance
- "internal controls designed to assess, identify, and manage material risks from cybersecurity threats" — generic

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


reasoning: The paragraph describes the company's internal incident monitoring and response processes — real-time updates, committee meetings covering metrics, an established incident response plan, and escalation procedures. The CISO is mentioned as attribution for who monitors and escalates, but the substantive content is about the process and workflow, not the person (person-vs-function test). Multiple firm-specific facts (CISO, Information Security Committee, IRT with abbreviation, Risk Committee) but no QV-eligible hard facts (no dates, dollars, headcounts, named third-party firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes monitoring of cybersecurity incidents, CISO's role in monitoring, Information Security Committee meetings, incident response plan, escalation to Risk Committee of the Board.

Category: This is primarily about the company's internal processes - monitoring, incident response plan, escalation procedures. The CISO is mentioned as attribution for who does the monitoring, but the paragraph is about the process. The Risk Committee of the Board is mentioned but only as an escalation path. This is Risk Management Process.

Specific facts:
- CISO (cybersecurity-specific title) → IS list
- Information Security Committee (named non-generic committee) → IS list

- Incident Response Team (IRT) (named internal program with unique identifier) → IS list
- Risk Committee of the Board (named non-generic committee) → IS list

Now checking for hard verifiable facts like dates, dollar amounts, headcounts, or named third-party vendors—there aren't any here. So this lands in Firm-Specific since I've got multiple IS-related facts but nothing that meets the QV threshold.

fact: Information Security Committee

fact: Incident Response Team (IRT)

fact: Risk Committee of the Board of Directors


reasoning: The paragraph's communicative purpose is describing how cybersecurity risk oversight flows up to the Audit Committee of the Board, with the CISO presenting quarterly reports. While the CISO is the agent delivering the report, the Audit Committee receiving it is the culminating point — this is a board oversight mechanism disclosure. The CISO title is a cybersecurity-specific role on the IS list, triggering Firm-Specific; however, 'Audit Committee' and 'quarterly' are on the NOT list and do not add specificity, and there are no QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

Content: Describes monitoring by senior management and CISO reporting to Audit Committee quarterly.

Category: The paragraph has two parts - senior management monitors cyber risks (Management Role / RMP), and CISO presents to Audit Committee quarterly (Board Governance / Management Role). The CISO is presenting TO the Audit Committee - the board committee is receiving reports. The primary frame is about how cyber risks are monitored and reported upward. The CISO is mentioned as performing an action (presenting to the Audit Committee), but the overall structure is about the oversight flow. The Audit Committee is receiving the report - this is about the board's oversight mechanism.

Actually, I'm seeing the structure more clearly now. The first sentence establishes senior management's monitoring role within risk management, while the second focuses on the CISO's quarterly reporting to the Audit Committee. The CISO is the actor here, but the real point is describing the board's oversight mechanism—how governance flows upward through reporting. This could fit either Management Role or Board Governance depending on emphasis, but the reporting structure itself is the key element. The oversight structure flows up to the board, with the CISO as the active agent driving those reports. I'm settling on Board Governance since the paragraph's core purpose is showing how cyber risk reaches board-level oversight through the Audit Committee's quarterly reporting cadence. For specificity, I've identified one firm-specific fact—the CISO role—which puts this at level 3, and there are no hard verifiable metrics like dates or dollar amounts, so it doesn't meet the QV threshold.

fact: chief information security officer


reasoning: The paragraph is framed around the risk oversight committee's responsibility for cybersecurity oversight, its briefing cadence, and the supporting steering committee structure — the board committee is the primary grammatical subject and actor. CISO background details are subordinate to the governance narrative. Two QV-eligible hard facts: specific years 2019 (CISO role start) and 2015 (company tenure), plus multiple firm-specific facts (named non-generic committees, CISO role).

thinking:
Let me analyze this paragraph carefully.

This paragraph covers multiple topics: board committee oversight, briefing cadence, management roles, and CISO background. Let me determine the dominant category.

The paragraph starts with the risk oversight committee (board governance), describes briefing cadence (board governance), then mentions a security and privacy steering committee, and ends with CISO background.

The grammatical subject shifts: first the "risk oversight committee of our board" is the subject, then "we" establish a steering committee, then "Our CISO" has experience.

The dominant frame is board governance - the risk oversight committee's oversight role, briefing cadence, and supporting structures. The CISO details at the end are subordinate to the board oversight framing.

Now I'm checking the specificity of the facts mentioned. The risk oversight committee is a named non-generic committee, the CISO is a cybersecurity-specific title, and there's a security and privacy steering committee also named specifically. I see dates like 2019 and 2015 that provide concrete timelines, though the semi-annual briefing cadence is more generic. The specific committee names and dates give this good factual grounding.

fact: risk oversight committee (named non-generic board committee)

fact: CISO (cybersecurity-specific title)

fact: security and privacy steering committee

fact: CISO has served in the role since 2019

fact: CISO has supported the company since 2015


reasoning: The Risk Committee (a board-level committee) is the grammatical subject performing oversight of cybersecurity risk, and the reporting chain flows upward to the committee, making this Board Governance. The Risk Committee is a named non-generic committee on the IS list, yielding Firm-Specific; other elements (quarterly cadence, President/CFO/CEO titles) are on the NOT list and do not count.

thinking:
Let me analyze this paragraph.

Content: Describes the Risk Committee's oversight of cybersecurity risk, and a reporting chain from EVP of Technology → President/CFO → CEO and Risk Committee.

Category: The Risk Committee (a board-level committee) is the grammatical subject in the first sentence. The second sentence describes reporting lines TO the committee. This is about board/committee oversight. → Board Governance

Specific facts:
- "Risk Committee" — named non-generic committee (IS list) → Firm-Specific
- "Executive Vice President of Technology" — this is more of a generic IT leadership title, not cybersecurity-specific per the IS list

- "quarterly basis" — generic cadence, not on the list
- "President and Chief Financial Officer" — generic C-suite titles, not on the list
- "Chief Executive Officer" — generic C-suite title, not on the list

So the only IS fact here is the Risk Committee as a named non-generic committee, making this Firm-Specific. There are no QV-eligible facts—no specific dates, dollar amounts, headcounts, named third-party firms, tools, or certifications.

fact: Risk Committee oversees cybersecurity risk


reasoning: The CCO and Cybersecurity Management Board are the grammatical subjects throughout, and the paragraph describes their monitoring activities, participation in processes, and reporting lines to the Risk and Cybersecurity Committee. While process elements are present (incident response plans, escalation procedures), the primary communicative purpose is establishing how these management roles participate in and report on cybersecurity oversight — management structure, not process mechanics. Named non-generic committees (Cybersecurity Management Board, Risk and Cybersecurity Committee) and a cybersecurity-specific role (CCO) place this at Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

Content: The CCO and Cybersecurity Management Board monitor cybersecurity incidents through risk management processes, incident response plans, and the CCO reports to the Risk and Cybersecurity Committee quarterly.

Category: This mentions both management roles (CCO, Cybersecurity Management Board) and their activities. The paragraph describes what these management figures DO in terms of monitoring and reporting. The grammatical subjects are the CCO and Cybersecurity Management Board. It's about management's role in overseeing cybersecurity processes and reporting to a committee.

The primary actors are management (CCO, Cybersecurity Management Board), and the content describes their monitoring activities and reporting lines. This is Management Role - the management figures are the grammatical subjects performing actions.

I'm second-guessing myself here. The paragraph does focus on processes like monitoring, prevention, mitigation, detection, and remediation, but the CCO and Cybersecurity Management Board are clearly the ones driving these activities and reporting on them. Even though the underlying processes would exist without naming these roles, the paragraph itself centers on what management is doing and their accountability structure, so this still reads as Management Role rather than just describing the processes themselves. The key distinction is whether the paragraph emphasizes the management roles themselves or the processes they oversee. Looking at the structure, the CCO and Cybersecurity Management Board are the grammatical subjects performing actions—monitoring, managing, reporting—which suggests Management Role. However, the content heavily focuses on incident response plans, escalation procedures, and risk management processes, which points toward Risk Management Process. The tiebreaker seems to be that the role titles are used as attribution for describing these processes rather than being the primary focus, so this leans toward Risk Management Process.

For specificity, the Cybersecurity Management Board and Risk and Cybersecurity Committee are both named, non-generic committees that appear on the firm-specific list, putting this at Firm-Specific level. There are no quantifiable details like dates, dollar amounts, or headcounts, so this doesn't reach Quantified Values.

fact: CCO (Chief Cybersecurity Officer) as named cybersecurity-specific role

fact: Cybersecurity Management Board

fact: Risk and Cybersecurity Committee


reasoning: The Audit Committee and full Board are the grammatical subjects throughout, receiving updates, reviewing materials, and engaging on cybersecurity matters — classic Board Governance. The CISO is mentioned as someone the board interacts with, not as the primary actor. The CISO reference is the sole IS-list fact (Audit Committee, 'quarterly', 'annually' are all on the NOT list), yielding Firm-Specific. No second QV-eligible hard fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph describes board/committee oversight of cybersecurity. The Audit Committee and Board are the primary subjects - they receive updates, oversee risks, receive materials, discuss matters. The CISO is mentioned but as someone the board discusses matters with, not as the primary subject.

Content Category: Board Governance - The Audit Committee and Board are the grammatical subjects performing oversight actions.

Specific facts:
- CISO mentioned (cybersecurity-specific title) → IS list
- Audit Committee → NOT list (generic)
- "quarterly" → NOT list (generic cadence)
- "annually" → NOT list (generic cadence)

- "cybersecurity scorecard" is somewhat generic, not a clearly named internal program → NOT list
- Board, management → NOT list

The only IS-list fact here is the CISO mention. There are no QV-eligible hard facts like dates, dollar amounts, headcounts, named firms, tools, or certifications, so this falls into Firm-Specific (3).

fact: Chief Information Security Officer (CISO) discussed with by the Board


reasoning: The paragraph's primary communicative purpose is describing the management-level committee structure for cybersecurity oversight — which committees exist, who chairs them (CIO, Chief Operational Risk Management Officer), who participates (CISO, departmental managers), and how they report up to the board's Innovation and Technology Committee. While the board is mentioned as having established these committees and as the recipient of reports, the grammatical subjects and dominant content are the management committees and officers themselves. Multiple named non-generic committees and cybersecurity-specific roles make this Firm-Specific, but no QV-eligible hard facts (specific dates, dollar amounts, headcounts, named third-party firms, or named tools) reach the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes management committees and their roles in cybersecurity oversight. The board established these committees, but the bulk of the paragraph is about the committees themselves - their composition, meeting cadence, and reporting structure. The grammatical subjects are the committees and officers, not the board itself. The board is mentioned at the start ("Our board of directors has established") and at the end (reporting to the Innovation and Technology Committee of the board).

This is a borderline case. The paragraph describes management-level committees and their structure, composition, and activities. The primary actors are management committees and officers (CIO, CISO, Chief Operational Risk Management Officer).

The key tension here is that while the board created these committees, the paragraph's focus is really on the management committee structure itself - who leads them, who participates, how frequently they meet, and what governance areas they cover. The reporting line to the board's Innovation and Technology Committee anchors this to board oversight, but the substance is about management's organizational design and the risk management processes these committees oversee. level organizational structure for cybersecurity oversight.

Now I'm checking the specificity of the named entities and roles mentioned. The committee names like Information Technology Steering Committee and Operational Risk Management Committee are concrete, and the roles—CIO, CISO, Chief Operational Risk Management Officer—are all specific cybersecurity titles. The meeting cadences like monthly and quarterly are generic though. Looking for hard verifiable facts like dates, dollar amounts, or named third-party vendors, but I'm not finding any of those here.

This lands at Firm-Specific Level 3—it has multiple industry-standard facts and named roles, but without concrete quantifiable details like headcounts or certifications, it doesn't reach the threshold for QV-eligible classification.

fact: Operational Risk Management Committee

fact: Chief Information Officer (chairs IT Steering Committee)

fact: Chief Operational Risk Management Officer (chairs ORM Committee)

fact: Chief Information Security Officer

fact: Innovation and Technology Committee (board committee)


content_category: Strategy Integration

reasoning: The paragraph contains a materiality-adjacent assessment ('not aware of any material breach to date') combined with generic risk language and a cross-reference to Risk Factors. Per Rule 6, the substantive claim about cybersecurity's impact on the business (no material breach) makes this Strategy Integration rather than None/Other, even though a cross-reference is present. No specific facts from the IS list are present — all language is boilerplate.

thinking:
Let me analyze this paragraph.

Content: "We face risks from cybersecurity threats that could have a material adverse effect on our business strategy. See [cross-reference]. With respect to our cybersecurity process, we are not aware of any material breach to date."

This contains a materiality assessment ("not aware of any material breach to date") and a cross-reference. Per Rule 6, the materiality assessment makes this Strategy Integration. The cross-reference doesn't change that.

Specificity: No named standards, no specific facts from the IS list. Generic boilerplate language throughout.


reasoning: The paragraph describes IHM's internal cybersecurity program including safeguards, monitoring, vulnerability assessment, threat mitigation, and ERM integration — all core risk management process activities. Third-party consultants are mentioned as one component of the internal program, not as the central topic. No named frameworks, tools, firms, dates, specific roles, or quantified facts are present — all language is generic and could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes IHM's cybersecurity program - safeguards, plans, procedures, risk management process, monitoring, vulnerability assessment, ERM integration, and third-party consultant engagement. This is about internal cybersecurity processes.

Category: Risk Management Process - describes the company's (via IHM) internal processes for managing cybersecurity risk.

Third-party consultants are mentioned as one component, not the central topic → Rule 3 confirms RMP.

Specificity: Let me check for specific facts.
- No named frameworks
- No cybersecurity-specific titles
- No named committees, tools, firms, dates, numbers

- "IHM" is just the company/manager reference
- "third-party consultants and key vendors" - generic/unnamed
- General practices described: monitoring, vulnerability assessment, etc.

This is Generic Boilerplate - no named standards, no firm-specific facts.


specificity_confidence: medium

reasoning: Two of three sentences describe the Board receiving periodic updates on cybersecurity effectiveness and material incidents, making Board Governance the dominant topic. The first sentence assigns oversight responsibility to the CEO, but CEO/President are generic C-suite titles (NOT list), so this functions more as a governance attribution than a Management Role paragraph — no cybersecurity credentials, background, or reporting lines are described. Specificity is Firm-Specific because the named individual 'Dana Green' is company-specific information that couldn't appear unchanged in another filing, though the rest of the paragraph (generic Board, 'periodically,' no frameworks or dates) is boilerplate.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three sentences:

1. "Our Chief Executive Officer and President, Dana Green, is responsible for the oversight of risks from cybersecurity threats." - Names a person (Dana Green) with titles CEO and President. CEO/President are generic C-suite titles per the NOT list.

2. "The Board will receive information and updates periodically with respect to the effectiveness of our cybersecurity and information security framework, data privacy and risk management..." - Board oversight, generic cadence ("periodically").

3. "The Board will also be provided updates on any material incidents relating to information systems security and cybersecurity incidents." - Board receiving incident updates.

Two of the three sentences focus on Board governance and information flow, while the first sentence assigns cyber oversight responsibility to the CEO—a generic C-suite role. The paragraph's primary emphasis is on Board oversight mechanisms, though it does establish that the CEO holds responsibility for cybersecurity risk management. for oversight, then the Board receives updates. The primary communicative purpose seems mixed. The CEO mention could be Management Role, but CEO is generic C-suite. The Board sentences are Board Governance.

Given Rule 2: "Board/committee is the grammatical subject" → Board Governance for sentences 2-3. Sentence 1 has CEO as subject. By dominant category (2/3 sentences about Board), this leans Board Governance.

But wait - sentence 1 names a specific person (Dana Green) with management responsibility. This could be Management Role. However, CEO/President are NOT cybersecurity-specific titles per the IS/NOT lists. The paragraph overall seems to be about governance structure - who oversees cyber risk (CEO) and how the Board stays informed.

I'll go with **Board Governance** as dominant - the Board is the primary actor in 2 of 3 sentences.

Now I'm looking at Dana Green's name more closely. While naming a specific individual would normally push toward Specificity 4, the title attached to that name—CEO and President—falls into the generic C-suite category that's explicitly on the NOT list. The name itself is given, but without cybersecurity-specific context or quantifiable details, it doesn't carry the weight of a concrete fact like a headcount or dollar amount would. on the NOT list, I'm reconsidering whether naming a specific person like Dana Green actually makes this firm-specific. The name itself is a verifiable, company-identifiable fact, even if the CEO title is generic—but I'm uncertain whether the codebook treats named individuals as inherently firm-specific the way it does for third-party firms or products. The named individual "Dana Green" pushes this toward Firm-Specific since it's company-particular information that wouldn't transfer to another filing, even though the CEO title itself is on the generic list. I'm settling on Firm-Specific as my final call.

fact: Named individual 'Dana Green' identified as responsible for cybersecurity oversight


content_category: None/Other

reasoning: This paragraph describes a generic risk scenario (IP theft from unauthorized access) without any substantive cybersecurity disclosure — no processes, frameworks, governance structures, or incident details. It reads as general risk language that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity controls, monitoring, training, and continuous improvement processes. Third-party outsourcing is mentioned as one component of the internal program, not the central topic. NIST is named as a framework alignment, triggering Sector-Adapted, but no firm-specific facts (no named roles, tools, dates, or quantified details) elevate it beyond that.

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity processes - controls, technologies, NIST alignment, outsourced IT, monitoring tools, training. This is about the company's own processes.

Category: Risk Management Process - describes internal cybersecurity processes, framework adoption, monitoring, training.

Third-party mention ("outsourced for monitoring and maintenance to third parties") is one component of the internal program, not the central topic. Per Rule 3, this stays Risk Management Process.

Specificity: Names NIST framework → Sector-Adapted at minimum. Any firm-specific facts? Let me check the IS list:
- No cybersecurity-specific titles

- No named committees
- No specific dates
- No named tools/products
- No named firms
- No specific numbers
- No certifications held

The outsourcing mention and generic practices like monitoring, training, and threat intelligence aren't specific facts. Since NIST is a named framework, this lands at Sector-Adapted (2).

fact: NIST (National Institute of Standards and Technology)


reasoning: The paragraph describes operational security controls around digital asset (SOL) custody — access monitoring, multi-person consensus for transfers, account segregation, and insurance through a trust company. While framed as asset custody rather than traditional cybersecurity, these are security controls disclosed in Item 1C describing the company's internal processes for protecting digital assets. No named frameworks, cybersecurity-specific roles, named firms/tools, or other specific facts from the IS list are present; 'Custodians,' 'Asset Management Company,' and 'Trust Company' are all unnamed generic references.

thinking:
This paragraph describes custodian arrangements for SOL (Solana cryptocurrency) treasury management. It's about safekeeping crypto assets, not cybersecurity disclosure. Let me classify it.

This is about asset custody controls for cryptocurrency, not cybersecurity risk management. It mentions access controls and monitoring but in the context of financial asset custody, not cybersecurity programs.

Actually, let me reconsider. This is in Item 1C (Cybersecurity section). The paragraph discusses controls around digital asset custody - access monitoring, consensus requirements for transfers, segregation. These could be considered security controls for digital assets.

But the primary topic is financial asset custody/safekeeping, not cybersecurity.

The controls mentioned—consensus of two individuals, monitoring access, controlled transfers, asset segregation—are technically security controls, and they're in the cybersecurity section. But the framing is entirely about custodian arrangements for SOL cryptocurrency rather than a cybersecurity risk management program. This feels borderline between a financial controls disclosure and a security controls description.

I'm leaning toward Risk Management Process since it does describe specific security controls, even if the context is crypto custody. On specificity though, there's nothing here that meets the IS list criteria—no named frameworks, no cybersecurity-specific roles, no dates or amounts. "Consensus of a minimum of two individuals" is a concrete control detail, but it's not a named standard or framework reference.


reasoning: The board of directors is the grammatical subject receiving cybersecurity presentations from management, making this Board Governance. All elements are generic: 'board of directors' and 'senior management team' are on the NOT list, 'regular basis' is a vague cadence, and the listed topics (vulnerability assessments, network integrity testing, infrastructure updates) are common practices with no named frameworks, specific roles, dates, or firm-specific facts.

thinking:
Let me analyze this paragraph.

The board of directors is the grammatical subject receiving presentations on cybersecurity risks. This is about board oversight.

Category: Board Governance - the board receives presentations from management on cyber topics.

Specificity: Let me check the facts.
- "board of directors" - generic, on the NOT list
- "senior management team" - generic
- "regular basis" - generic cadence
- Topics listed (vulnerability assessments, network integrity testing, etc.) - common practices
- No named frameworks, no specific roles (CISO etc.), no dates, no named committees beyond the board

Everything here is generic. No IS-list facts. No named standards.

→ Generic Boilerplate (1)


reasoning: This is introductory/contextual language about why cybersecurity matters to the company. It describes the types of data handled (PHI, PII) and acknowledges generic cybersecurity threats, but contains no substantive disclosure of governance, processes, management roles, incidents, or strategy. It is general business preamble that could apply to any healthcare-adjacent company.

thinking:
Let me analyze this paragraph.

It's general business language about why cybersecurity matters to the company. No specific processes, frameworks, roles, or incidents described. It mentions PHI and PII but in a generic context. No materiality assessment. No board/management discussion.

This is essentially introductory/contextual language - general business language about cybersecurity importance.

None/Other? Or Risk Management Process? Let me check Rule 5: "Assign None/Other ONLY when the paragraph contains no substantive cybersecurity disclosure content."

This paragraph doesn't describe any process, governance, management role, incident, or strategy. It's general context about why cybersecurity matters to the company.

Since this is just preamble without substantive disclosure, I'm marking it as None/Other with a specificity score of 1.


reasoning: The paragraph's communicative purpose is describing how the board-level Audit and Reserves Committee maintains cybersecurity oversight through semi-annual and annual briefings. While the Managing Director, IT is the grammatical subject, the content focuses on the committee's oversight mechanism — what topics are covered, at what cadence, and what reviews occur — making Board Governance the dominant category. The Audit and Reserves Committee is a named non-generic committee (distinct from a standard Audit Committee), qualifying as a firm-specific fact.

thinking:
Let me analyze this paragraph.

The paragraph describes the Managing Director of IT providing updates to the Audit and Reserves Committee. The primary actor providing updates is the MD of IT, but the recipient is the committee. Let me think about category.

The paragraph describes briefing cadence and topics covered in reports to a board committee. The Audit and Reserves Committee is the oversight body receiving reports. But the Managing Director, IT is the grammatical subject performing the action (provides updates, reviews with).

Per Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). Here the Managing Director, IT is the primary actor providing updates to the committee. But this is about the reporting relationship and briefing content to the board committee.

I'm reconsidering the focus here—while the MD IT is the grammatical subject, the real substance is about how the board committee receives cybersecurity information and the cadence of those briefings. That oversight structure seems to be the main point, which would make this Board Governance rather than Management Role. The MD IT is really just the messenger here—the substance is about what oversight the committee actually gets and how often. Even though the MD IT is grammatically the subject, the real focus is on the committee's governance role and their cybersecurity monitoring cadence. I'm leaning toward Board Governance as the category. Also, "Managing Director, Information Technology" isn't a specialized cybersecurity title like CISO or CIO, so it's less specific to the domain.

Now looking at the specificity markers: "Audit and Reserves Committee" stands out as a named, company-specific committee rather than a generic audit function—that's a firm-specific detail. The cadences mentioned are just standard intervals. Since there's only one substantive firm-specific fact here, this falls into Firm-Specific rather than Quantified Value.

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


reasoning: The paragraph describes internal incident response communication and escalation processes, making it about the function rather than the person. The Managing Director of IT is mentioned as attribution, but the substantive content is the incident response plan and escalation procedures. 'Managing Director, Information Technology' is a general IT leadership title (not cybersecurity-specific per the IS list), CFO/General Counsel are generic C-suite, 'Board of Directors' is standard, and 'incident response plan' is a generic program name — no specific facts survive the NOT-list filter.

thinking:
Let me analyze this paragraph.

The paragraph describes the Managing Director of IT working with CFO and General Counsel on incident response and risk management processes, and describes escalation processes including board notification.

Category: This is about internal processes - incident response communication plan, escalation processes. The Managing Director of IT is mentioned but the paragraph is about what the processes do, not about the person's credentials/background. The board mention is subordinate (escalation notification). This is Risk Management Process.

Wait - let me reconsider. The grammatical subject is "The Managing Director, Information Technology" - but the content is about processes (incident response plan, escalation). The person-vs-function test: remove the title and the paragraph still describes processes. → Risk Management Process.

Now I'm checking the specificity of the roles and terms mentioned. The Managing Director title is generic IT leadership rather than cybersecurity-specific, and the other parties involved—CFO, General Counsel, Board of Directors—are all on the exclusion list. The incident response plan itself is a generic program name without any named frameworks or specific dates, so this doesn't meet the specificity threshold either.


content_category: Third-Party Risk

reasoning: The entire paragraph is about the company's third-party risk program — assessing vendors, managing contractual security requirements, and overseeing third-party relationships throughout their lifecycle. Vendor oversight is the central topic, not a component of an internal process description. No named frameworks, firms, tools, dates, or specific numbers are present, so this is Generic Boilerplate.

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

Specificity: No named frameworks, no named tools, no specific dates, no named firms, no specific numbers. No cybersecurity-specific titles. The program is described generically. → Generic Boilerplate.


reasoning: This paragraph describes the types of sensitive data the company handles and the generic risks of cybersecurity incidents, cross-referencing Item 1A Risk Factors. It contains no substantive cybersecurity disclosure — no program description, governance structure, incident detail, or materiality assessment. It is general risk language that could apply to any financial institution.

thinking:
Let me analyze this paragraph.

It describes the types of data the company handles and the risks associated with cybersecurity incidents. It cross-references Item 1A Risk Factors. There's no description of any program, process, governance structure, or specific incident. It's general risk language about data handling and potential consequences.

No materiality assessment ("materially affected" language is absent). No specific facts. This is generic risk language that could apply to any financial institution.

Category: None/Other - This is general business/risk language about data types and potential consequences, with a cross-reference to Risk Factors. No substantive cybersecurity disclosure.

This is just boilerplate language without any real substance or specificity.


reasoning: The paragraph's primary content is about the IT team's qualifications, industry experience, and background (including prior experience with specific compliance regimes and named former employer Ibeo), making it about the people rather than the processes they run. Ibeo is a named third-party firm (one QV-eligible fact), and NIST SP800-171 and TISAX are named standards, but with only one QV-eligible hard fact the paragraph reaches Firm-Specific, not Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the IT team's responsibility for cybersecurity, mentions employee experience with NIST SP800-171 and TISAX compliance, mentions former Ibeo employees, and notes plans to establish a dedicated cybersecurity team.

Category: This is about management/team responsible for cybersecurity. The paragraph describes who handles cybersecurity day-to-day (IT team), their qualifications and experience. But is it Management Role or Risk Management Process?

The paragraph is about the people - their knowledge, experience, background. It's telling us about who the people are and what qualifies them. This is more Management Role - it's about the team's qualifications and experience rather than describing processes.

Actually, I'm reconsidering whether "IT team" fits the Management Role category since it's not a cybersecurity-specific title on the IS list. But the focus is clearly on the people themselves and their qualifications rather than any processes they manage, so Management Role still seems right. I'll stick with that classification.

Now looking at the specific facts: "former Ibeo employees" references a named third-party firm, which counts as one QV-eligible fact. The frameworks mentioned—NIST SP800-171 and TISAX—aren't QV-eligible since they're standards rather than specific quantifiable details. There's no dates, dollar amounts, headcounts, or named tools to add another QV fact, so this lands as Firm-Specific.

fact: TISAX compliance

fact: former Ibeo employees


reasoning: The paragraph discusses continued investment of 'financial resources' in cybersecurity and makes a cautionary materiality statement ('no assurance that any breach or incident will not have a material impact on our operations and financial results'). While it cross-references Item 1A for the full materiality discussion, the paragraph itself contains strategy-adjacent content about resource allocation and potential material impact, placing it in Strategy Integration over None/Other. All language is entirely generic with no named entities, dates, amounts, or frameworks.

thinking:
Let me analyze this paragraph.

The paragraph discusses continued investment in security, acknowledges limitations, and then cross-references Item 1A Risk Factors for materiality discussion. The key question is whether this is Strategy Integration or None/Other.

Looking at the content: "There can be no assurance that any breach or incident will not have a material impact on our operations and financial results." - This is hedging language, not an explicit materiality assessment. It doesn't say "have not materially affected" - it says there's no assurance it won't.

Then: "See Item 1A... for a discussion of whether and how any risks from cybersecurity threats are reasonably likely to materially affect us" - This is a cross-reference TO where the materiality assessment lives, not the assessment itself.

The investment statement reads like a strategy claim, but it's too vague to constitute a clear materiality determination. The paragraph hedges with cautionary language and ultimately defers the actual materiality assessment to the Risk Factors section, which per the codebook means this is a pure cross-reference without a materiality conclusion. The investment claim and materiality hedge do make substantive statements about cybersecurity's business impact, even if they're generic and heavily cross-referenced. I'm settling on Strategy Integration at Specificity 1 since the paragraph addresses resource allocation and potential material consequences, with no specific facts from the disclosure list.


reasoning: The paragraph describes internal cybersecurity processes (prevent, detect, mitigate, remediate) using management as brief attribution. The substantive content is about the function — threat intelligence, security tools, external consultants — not about who the people are. All entities are unnamed ('external security personnel', 'external consultants', 'security tools'), and no frameworks, specific roles, or firm-specific facts are mentioned.


reasoning: The paragraph describes the company's incident response plan, its review process, and the actions it coordinates — all internal cybersecurity processes. The specific departmental composition of the review team (finance and technology) is a firm-specific fact, but there are no QV-eligible hard facts (no dates, dollar amounts, named firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes incident response plan, processes, controls, team composition, plan review cadence. This is about internal cybersecurity processes.

Category: Risk Management Process - describes IRP, internal processes, controls, team review.

Specificity analysis:
- "outsourced security team" - unnamed, generic
- "written incident response plan" - generic program name
- "team comprised of finance and technology personnel" - this is a specific team composition ("finance and technology") - this is on the IS list as specific team/department compositions
- "annually" - generic cadence
- The rest is generic process description

So one IS fact: specific team composition (finance and technology personnel). That gives Firm-Specific.

No quantifiable details like dates, dollar amounts, named firms, tools, or headcounts present. This lands as Risk Management Process, Firm-Specific.

fact: Team comprised of finance and technology personnel reviews the plan


reasoning: The paragraph discusses limitations of the company's security controls and risk-based approach, which relates to risk management processes. However, the content is entirely generic — no named frameworks, roles, tools, or firm-specific details. It reads more like risk factor language than substantive disclosure, but the reference to 'as described above' and 'risk-based approach' ties it to the company's own internal process description, narrowly favoring Risk Management Process over None/Other.

thinking: This paragraph discusses limitations of security controls in generic terms.


reasoning: The paragraph describes a general commitment to cybersecurity measures for information systems and data protection. While it mentions 'Management and Strategy,' this is not about a specific person's role or qualifications — it's a generic statement about maintaining cybersecurity processes. No named frameworks, roles, dates, or firm-specific details are present, making this Generic Boilerplate.


reasoning: This paragraph is generic business language acknowledging that information systems are vulnerable to cybersecurity threats that could potentially impact the company. It does not describe any process, governance structure, management role, incident, or third-party relationship. While it references potential material impact, it does not make a definitive materiality assessment ('have not materially affected') — it merely states threats 'could potentially' have impact, which is a truism applicable to any company. No substantive cybersecurity disclosure content is present.

thinking:
Classify this paragraph.

This is generic language about information systems being vulnerable to cybersecurity threats. It mentions potential material impact on business strategy/results/financial condition.

Category: This mentions potential material impact but doesn't make a definitive materiality assessment - it says threats "could potentially have a material impact." This is more like generic risk language than a materiality assessment. It's not describing any process, board oversight, management role, incident, or third-party risk. It's generic business language about cybersecurity risks.

Wait - does "could potentially have a material impact on our business strategy, results of operations and financial condition" count as a materiality assessment? Per the codebook, Strategy Integration includes materiality disclaimers where the paragraph "explicitly assesses whether cybersecurity risks have or could 'materially affect' the company." But this is more of a generic risk acknowledgment - it says threats "could potentially" have impact, not an actual assessment of whether they have or haven't materially affected.

The codebook distinguishes between actual assessments like "have not materially affected" versus speculative language like "could potentially." This paragraph is just acknowledging that threats exist and could be bad, without making a substantive assessment. It doesn't fit Strategy Integration or Risk Management Process, so it's likely just generic business language with no specific disclosure category.


reasoning: The paragraph describes the company's process for identifying, assessing, and managing cybersecurity risks — meeting cadence, risk discussion, severity assessment — which is squarely Risk Management Process. The board/audit committee mentions are incidental components of the process, not the primary topic. 'CyberTeam' is a named internal team unique to this company, making it Firm-Specific, but there is only one IS-list fact (no second hard verifiable fact for QV).

thinking:
Let me analyze this paragraph.

Content: Describes a process for incorporating cybersecurity risks into overall risk management, involving "CyberTeam" meeting with executive leadership and board/audit committee to discuss risks.

Category: This is about the risk management process - how the company identifies, assesses, and manages cybersecurity risks. The mention of board/audit committee is incidental. The primary topic is the process itself.

Wait - "CyberTeam" is a named internal program/team. That's a firm-specific fact.

Specificity: "CyberTeam" - this is a named internal team/program with a unique identifier → Firm-Specific. No other hard verifiable facts (no dates, dollar amounts, named firms, etc.). Just one specific fact → Firm-Specific (3).

fact: CyberTeam (named internal cybersecurity team)


reasoning: The paragraph primarily describes internal cybersecurity processes — designing safeguards, addressing gaps, monitoring effectiveness — making it Risk Management Process. The 'IT consultant who reports to management' is brief attribution of responsibility, not a description of the person's qualifications or background, and 'IT consultant' is not a cybersecurity-specific title on the IS list. No named frameworks, tools, dates, or firm-specific facts are present, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment follow-up activities (re-design, implement, maintain safeguards, monitor effectiveness) and assigns responsibility to "an IT consultant who reports to management."

Category: This is primarily about internal processes - safeguards, monitoring, risk assessment. The IT consultant mention is brief attribution. The paragraph is about what the company does (processes), not about who the person is. → Risk Management Process

Specificity: Let me check for specific facts:
- "IT consultant" - not a cybersecurity-specific title from the IS list (not CISO, CTO, CIO, etc.)

- "reports to management" - generic
- No frameworks, no dates, no named tools, no specific numbers
- All generic practices: safeguards, monitoring, risk assessments

This looks like generic boilerplate language without concrete details or industry-specific terminology.


reasoning: The paragraph identifies which management roles are responsible for cybersecurity — the CIO directing the IT team and the executive team's responsibilities (hiring, budgets, approving processes, reviewing assessments). While it lists functions these roles perform, the primary communicative purpose is to establish WHO is responsible at the management level, not to describe the processes in detail. CIO is a cybersecurity-specific title on the IS list, triggering Firm-Specific; CEO and CFO are generic C-suite and do not count.

thinking:
Let me analyze this paragraph.

Content: Describes management roles responsible for cybersecurity - CIO directing IT team, executive team (CEO, CFO) responsibilities including hiring, budget approval, incident prep, process approval, reviewing assessments.

Category: This is about management's role in cybersecurity. The grammatical subjects are "Company management," "executive team," "CIO." It describes what management does (functions) but also identifies who fills these roles. Let me apply the person-vs-function test: if I remove the role titles, does it still describe processes? Partially - it describes hiring, budgeting, approving processes, reviewing reports. But the primary purpose is to identify WHO is responsible, not to describe the processes themselves in detail.

Looking at the structure more carefully, this is fundamentally about management responsibilities—hiring, integrating cybersecurity into enterprise risk management, approving budgets, preparing for incidents, approving processes, and reviewing assessments. The CIO directs the IT team, and the executive team handles the broader governance. The focus is on who's accountable for what at the management level rather than the mechanics of those activities themselves. Since the CIO is a cybersecurity-specific title on the IS list, this falls under Firm-Specific.

fact: Chief Information Officer directs the information technology team


reasoning: The Board of Directors and Audit Committee are the grammatical subjects performing oversight of cybersecurity risk, making this Board Governance. All entities mentioned (Board, Audit Committee, 'Company management', 'approximately annually') are on the NOT list — no cybersecurity-specific roles, named frameworks, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

The paragraph is about Board/Audit Committee oversight of cybersecurity. The Board and Audit Committee are the grammatical subjects performing oversight actions.

Category: Board Governance - the board and audit committee are the primary actors overseeing cyber risk.

Specificity: Let me check the facts:
- "Board of Directors" - NOT list (generic governance)
- "Audit Committee" - NOT list (generic governance)
- "approximately annually" - NOT list (generic cadence)
- No cybersecurity-specific roles, no named frameworks, no specific dates, no named tools/firms

No IS-list facts, no named standards → Generic Boilerplate (1)


reasoning: The paragraph describes the company's internal approach to cybersecurity risk management — preserving confidentiality/security/availability, identifying and mitigating threats, and responding to incidents. The mention of moving servers off-site due to 'prior cybersecurity exposure' is a vague allusion to a past event but lacks any specific dates, named systems, frameworks, roles, or other facts from the IS list. 'Cross-functional approach' names no specific departments. All language is generic enough to apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes a cross-functional approach to cybersecurity risks focused on confidentiality, security, availability. Mentions reviewing trends and moving servers off-site due to prior cybersecurity exposure.

Category: This describes the company's internal processes for managing cybersecurity risk. Risk Management Process.

Specificity: Let me check for specific facts:
- "cross-functional approach" - generic, not naming specific departments
- "prior cybersecurity exposure" - vague reference, no details
- "moved some of our internal servers to off-site locations" - this is a firm-specific action but vague

No named frameworks, no named roles, no dates, no named tools. The mention of moving servers off-site due to prior exposure is somewhat firm-specific but... "moved some of our internal servers to off-site locations" - is this a specific fact per the IS list? It doesn't match any of the IS list items.

Looking at what's actually here, there are no specific titles, committees, dates, tools, or metrics—just general language about their approach. This reads as generic boilerplate.


reasoning: The paragraph opens with an explicit materiality assessment — no reportable breaches and no material adverse effect on business operations or financial condition — which triggers Strategy Integration per Rule 6. The remainder is entirely hypothetical risk language about what could happen if a breach occurred (reputation damage, data loss, ransom), which is generic risk-factor boilerplate. The fiscal year end date is a standard reporting-period reference, not a cybersecurity-specific fact, and all other language (material adverse effect, business operations, financial condition) is boilerplate.

thinking:
Let me analyze this paragraph from MDB Capital Holdings' 10-K filing.

The paragraph starts with a statement about no reportable breaches and no material adverse effect - that's a materiality assessment. Then it goes into extensive hypothetical language about what could happen if there were a breach - reputation damage, loss of data, disruption, ransom, etc.

This is mostly hypothetical risk language. The first two sentences contain a materiality assessment ("no material adverse effect on our business operations or financial condition"). The rest is generic hypothetical language about potential impacts.

Category: The materiality assessment in the first two sentences makes this Strategy Integration per Rule 6. The rest is generic risk factor language.

Now I'm checking the specificity - the fiscal year ended December 31, 2023 is a specific date that qualifies as a firm-specific fact, though it's a standard year-end date that appears in every 10-K rather than a cybersecurity-specific disclosure. Looking at the calibration example about materiality statements being boilerplate, I realize this paragraph follows the same pattern—the fiscal year reference is just a standard reporting period, not a cybersecurity-specific date, so I'll classify it as Generic Boilerplate.


reasoning: The vast majority of this paragraph describes the company's internal cybersecurity processes — risk identification, evaluation, prioritization, and mitigation strategies aligned with NIST CSF. The named individual (Chris Dennis) appears only at the end as attribution for who runs the program; applying the person-vs-function test, the paragraph is about the function, not the person. NIST CSF alone would be Sector-Adapted, but the named individual (Chris Dennis) is a firm-specific fact that elevates to Firm-Specific. Only one QV-eligible fact (named individual is not on the QV list), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes Xtant Medical's cybersecurity program - risk assessment methodology, NIST framework, risk prioritization, mitigation strategies. Then at the end it names "Director of Information Technology, Chris Dennis" as responsible for day-to-day cybersecurity risk management.

Content Category: The bulk of the paragraph describes the company's internal cybersecurity processes - risk identification, evaluation, prioritization, mitigation strategies. The NIST CSF is mentioned. The named individual appears only at the very end as attribution. Using the person-vs-function test: if you remove the Chris Dennis reference, the paragraph still fully describes processes. → Risk Management Process

Specificity: NIST Cybersecurity Framework is a named standard, and Chris Dennis is a named individual - both specific facts. The title "Director of Information Technology" is generic IT leadership, not cybersecurity-specific, so it doesn't add specificity on its own.

For QV eligibility, I'm checking against the list: specific dates, dollar amounts, headcounts, named third-party firms, named products, certifications, years of experience, named universities. Chris Dennis as a named individual doesn't match any of these categories, and there are no other QV-eligible facts present - no dates, no financial figures, no named tools or certifications mentioned.

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

fact: Chris Dennis, Director of Information Technology


reasoning: The paragraph describes the company's internal cybersecurity procedures — employee training, IT system evaluation, and risk assessment integration — making Risk Management Process the dominant category. No named frameworks, cybersecurity-specific titles, dates, tools, or other facts from the IS list are present; practices like phishing training and periodic evaluation are generic and common across filings.

thinking:
Let me analyze this paragraph.

Content: Describes internal risk management procedures - training, IT system evaluation, and explicitly notes no third-party engagement. The subject is "Management and Strategy" describing internal processes.

Category: Risk Management Process - describes internal cybersecurity processes (training, evaluation, procedures).

Specificity: Let me check for facts:
- "Management and Strategy" - generic
- "cybersecurity training upon hire and on a periodic basis" - common practice
- "training on phishing, malware, and other cybersecurity risks" - common practices
- No named frameworks, no specific dates, no named tools, no specific roles from the IS list

- This reads as generic boilerplate without any firm-specific details or named standards.


reasoning: The paragraph's primary subject is the Board of Directors' expected oversight of cybersecurity risks and management's expected reporting to the board, making Board Governance the dominant category. However, every statement is aspirational ('We expect that...'), indicating no program currently exists — this is closer to the SPAC/no-operations pattern but still frames board oversight as the topic. No specific facts appear: 'Board of Directors,' 'management,' 'senior management,' and 'quarterly' are all on the NOT list, and no cybersecurity-specific roles, named committees, frameworks, or verifiable details are present.

thinking:
This is a forward-looking paragraph about what the company "expects" to do regarding cybersecurity governance. Everything is aspirational - "We expect that..." repeated throughout. No actual program exists yet.

Category: This reads like a company that doesn't yet have a cybersecurity program in place. Every sentence is prefaced with "We expect" - nothing is actually implemented. This is similar to the SPAC/no-operations pattern. However, it does describe board oversight expectations substantively. Let me think...

The paragraph describes expected future board oversight and management reporting. Since everything is aspirational/forward-looking and no actual program exists, this leans toward None/Other.

But the codebook is pretty clear here - this is aspirational language about what they plan to do, not what they currently have. The SPAC rule applies: they're essentially disclosing the absence of a current program while describing future intentions. That's not substantive disclosure of actual practices, just what they expect to implement.

Wait, though - Rule 5 says I should only assign None/Other when there's truly no substantive cybersecurity content at all. This paragraph does address board governance structure and oversight mechanisms, even if everything is forward-looking. The core topic is how the board will oversee cybersecurity, not whether a program exists today.

I'm settling on Board Governance. The paragraph's main purpose is describing board-level oversight of cybersecurity - briefing frequency, management reporting lines, board responsibilities - even though it's all aspirational. The aspirational framing affects how specific the disclosure is, but the category itself is about governance structure.

Now checking specificity: there's nothing concrete here. No named frameworks, no specific committees beyond "Board of Directors," no cybersecurity-specific titles, and "quarterly" is actually on the NOT list. Everything is generic boilerplate language. This is Generic Boilerplate with a specificity score of 1.


reasoning: The paragraph's communicative purpose is to describe how the Audit Committee is kept informed about cybersecurity risks—the briefing topics, cadence, and information flow all serve to demonstrate board-level oversight. While 'Executive Team' is the grammatical subject, the content is subordinate to showing the Audit Committee's oversight mechanism. No specific facts from the IS list are present: 'Executive Team' is generic management, 'Audit Committee' is standard, 'outside consultants' are unnamed, and 'periodic basis' is a vague cadence.

thinking:
Let me analyze this paragraph.

The paragraph describes the Executive Team's role in informing the Audit Committee about cybersecurity risks. The primary actor is the "Executive Team" reporting to the Audit Committee. This is about management's role in briefing the board committee.

Let me think about category. The Executive Team is the grammatical subject. They monitor, review, and provide briefings to the Audit Committee. This is about what management does (briefing the board). Per Rule 2: "Management role reports TO the board → Management Role" and "CISO is primary actor → Management Role." The Executive Team is the primary actor here, reporting to the Audit Committee.

I'm second-guessing myself on the categorization. The focus is on how the Audit Committee receives information about cybersecurity, which could lean toward Board Governance, but the Executive Team is clearly the main actor performing the briefing. The tiebreaker rule suggests that when management roles are the primary focus, it's Management Role, even though board oversight is mentioned. The Executive Team is the grammatical subject here, so that points toward Management Role. But I keep circling back to the fact that this is really describing the board's oversight mechanism—how the Audit Committee stays informed about cybersecurity risks. The codebook is clear though: if the grammatical subject isn't the board or a board committee, it's not Board Governance. I'll stick with Management Role since the Executive Team is performing the actions, even though the underlying purpose is board oversight. I'm reconsidering whether the grammatical subject matters here—the Executive Team briefs the committee, but the real point is that the Audit Committee has this oversight mechanism in place. The paragraph's purpose is demonstrating board governance through the briefing structure, not highlighting a specific management role. So I'll categorize this as Board Governance with generic boilerplate language.


reasoning: The paragraph's central topic is oversight of third-party IT service providers and vendor management — obtaining reports from vendors handling sensitive data and following up on issues. This is vendor oversight as the primary subject, not an internal process that mentions vendors incidentally. No named standards, firms, roles, dates, or other specific facts appear; all language is generic and could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party IT environments, vendor management process, obtaining reports from vendors handling sensitive data. The central topic is oversight of external parties/vendors.

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

Specificity: No named standards, no named firms, no specific dates, no specific roles. "Vendors handling sensitive data" and "obtain reports" are generic. No IS-list facts.

→ Generic Boilerplate


reasoning: The paragraph makes an explicit materiality assessment ('materially affect... our operations'), which per Rule 6 classifies as Strategy Integration even though the language is boilerplate. No specific facts, dates, or named entities are present.


reasoning: The paragraph describes the company's own internal cybersecurity processes — risk assessment, monitoring, vulnerability testing, and ERM integration — making it Risk Management Process. Despite the misleading 'Management and Strategy' prefix, the substantive content is entirely about process activities. No named frameworks, specific roles, dates, tools, or any facts from the IS list are present; all language is generic and interchangeable across companies.

thinking:
Let me analyze this paragraph.

Content: Early-stage company describing generic risk assessment and monitoring practices. No specific frameworks, tools, roles, or dates mentioned.

Category: Risk Management Process - describes internal cybersecurity processes (risk assessment, monitoring, vulnerability testing, ERM integration).

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


reasoning: The paragraph's grammatical subject throughout is 'our management team' and 'our management,' describing who is involved in cybersecurity oversight and their collective experience. While it also touches on processes (risk assessment, incident response) and board escalation, the primary communicative purpose is identifying the management structure responsible for cybersecurity. No facts from the IS list are present: CFO is generic C-suite, VP of regulatory affairs is not a cybersecurity-specific title, the external IT company is unnamed, and Audit Committee/Board are generic governance terms.

thinking:
Let me analyze this paragraph.

Content: Management team's involvement in cybersecurity - assessing/managing risks, hiring personnel, ERM integration, incident response. Names CFO, VP of regulatory affairs, external IT company. Management escalates to Board/Audit Committee.

Category: This is about management's role in cybersecurity. The grammatical subject is "Our management team" throughout. It describes who is involved (CFO, VP of regulatory affairs, external IT company) and what they do. But the person-vs-function test: is this about the people or the function? It's a mix - it names specific roles and describes their collective experience, but also describes processes. The primary focus is on who management is and what they do in their management capacity.

Looking more carefully at the specific roles mentioned: the CFO falls on the NOT list as generic C-suite, and VP of regulatory affairs isn't cybersecurity-specific either. Since the paragraph centers on management's involvement and describes the management structure for cybersecurity rather than individual expertise, this falls under Management Role. The board escalation piece is secondary to the main point.

Now checking the specificity of the facts presented - the CFO is a generic C-suite title on the exclusion list, and the VP of regulatory affairs similarly isn't a specialized cybersecurity role.  The external IT company is unnamed, and references to the Audit Committee and Board are also generic. There are no named frameworks, specific dates, named firms, or cybersecurity-specific titles present. This is Generic Boilerplate with a Specificity score of 1.


reasoning: The paragraph describes the company's own internal cybersecurity processes — monitoring, testing safeguards, and employee training — which are core Risk Management Process activities. No named frameworks, cybersecurity-specific roles, dates, or firm-specific details are present; 'IT and management' and 'personnel at all levels' are generic references that appear on the IS-NOT list.

thinking:
Classify this paragraph.

Content: Describes internal cybersecurity processes - monitoring, testing safeguards, training employees. No board, no named roles, no incidents, no third-party focus, no materiality assessment.

Category: Risk Management Process

Specificity: No named frameworks, no named roles (just "IT and management" which are generic), no dates, no specific facts. "Personnel at all levels" is generic. This is boilerplate.

Specificity: Generic Boilerplate


category_confidence: low

reasoning: This paragraph frames cybersecurity as part of 'operational strategy' and mentions protecting assets, continuity, and stakeholder trust — touching on strategic integration of cybersecurity. However, it contains no substantive disclosure content and is entirely generic. It could arguably be None/Other as a preamble, but the explicit link to 'operational strategy' gives it a slight Strategy Integration lean. No specific facts of any kind are present.


reasoning: The paragraph primarily describes the internal workflow for cybersecurity risk handling: risks are reported to IT, assessed, responded to, and escalated. The Director of Technology and qualifications mention is subordinate to this process description. 'Director of Technology' is a generic IT title not on the cybersecurity-specific IS list (not equivalent to CISO, CTO, or Director of IT Security), and qualifications described ('prior experience, education, and/or training') are completely generic, yielding no firm-specific facts.

thinking:
Let me analyze this paragraph.

Content: Describes how cybersecurity risks are reported to IT, assessed, and escalated to Director of Technology. Mentions qualifications of individuals.

Category: This mixes risk management process (risks reported, assessed, responded to) with management role (Director of Technology, qualifications). The dominant content is the process flow - how risks are identified, reported, assessed. The Director of Technology mention is part of the reporting chain. The qualifications sentence is brief. But "Director of Technology" is the named role receiving reports... Let me think about this more carefully.

The paragraph has three sentences:
1. Risks reported to IT, assessed and responded to → Risk Management Process

2. Actions/incidents reported to Director of Technology → could be Management Role (reporting lines) or RMP
3. Qualifications include experience, education, training → Management Role

The person-vs-function test: sentences 1-2 describe the process flow, while sentence 3 focuses on the Director of Technology's qualifications. The paragraph is fairly evenly split between explaining how risks flow through the organization and describing the role itself, though the process aspect seems slightly dominant.

Actually, looking more carefully at the full text: "Any actions taken or cybersecurity incidents identified are reported to the Director of Technology. Qualifications for these individuals include prior experience, education, and/or training in cybersecurity." Two of the three sentences center on the Director of Technology and their qualifications, which points toward Management Role. But the first sentence clearly describes a process flow.

The paragraph structure is ambiguous, but I'm leaning toward Risk Management Process since the overall narrative traces a workflow from identification through escalation, with the Director of Technology as part of that chain rather than the focus.

Actually, "Director of Technology" doesn't match the specificity I'd expect for a cybersecurity role—the list includes titles like CISO, CTO, CIO, or Director of IT Security, so this is more generic.


reasoning: The paragraph describes the company's internal cybersecurity processes: safeguard design/implementation, monitoring effectiveness, employee training, and engaging third parties for risk assessment. The CFO mention is incidental attribution (CFO is on the NOT list as generic C-suite), and third-party engagement is a component of internal processes rather than the central topic. No named frameworks, specific dates, named firms, cybersecurity-specific roles, or other IS-list facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment follow-up processes, safeguard implementation, monitoring, training, and third-party engagement. The CFO is mentioned as managing risk assessment, reporting to the Board. This is primarily about the company's internal risk management processes.

Category: Risk Management Process. The paragraph describes internal processes - safeguards, monitoring, training, third-party assistance with processes. The CFO mention is incidental attribution. The third-party mention is a component of internal processes, not the central topic.

Specificity: Let me check the facts:
- CFO: This is on the ✗ NOT list ("Generic C-suite: CEO, CFO, COO, President, General Counsel")

- "Board": Generic governance, on NOT list
- "third parties", "consultants, experts": unnamed entities, on NOT list
- "trainings", "monitor": common practices
- No named frameworks, no specific dates, no named firms, no specific numbers

No IS-list facts. No named standards. This is generic boilerplate.


reasoning: The paragraph describes the company's deliberate decision not to engage third-party assessors to review its cybersecurity risk management processes and controls. Per Rule 3, external assessors hired to test the company fall under Risk Management Process (they serve the company), making this a disclosure about the company's own internal risk management approach—specifically, the absence of external validation. No named frameworks, roles, dates, or firm-specific facts are present.

thinking:
Classify this paragraph.

This is about a company stating it does NOT engage third-party assessors. It's about the absence of third-party oversight. Given the context of AIRWA INC (YYAI) - this sounds like a small/shell company.

Category: This touches on third-party risk (assessors, vendors) but it's actually saying they DON'T do this. It also touches on risk management process. The paragraph is about the company's decision NOT to engage external assessors for cybersecurity review. This is describing an absence of a practice.

Given the SPAC/no-operations guidance: "Companies that explicitly state they have no operations, no cybersecurity program, or no formal processes receive None/Other." But this company isn't necessarily a SPAC - it's stating it doesn't use third-party assessors.

The core issue here is whether this disclosure about not using external assessors falls under Third-Party Risk or Risk Management Process. The paragraph mentions both the company's own decision to forgo external review and references to vendors' cybersecurity practices, so there's overlap between the two categories. The primary focus seems to be on the company's deliberate choice not to engage third-party auditors for their cybersecurity assessment.

Since the rule specifies that external assessors hired to test the company's processes fall under Risk Management Process, that's the better fit. The disclosure is fundamentally about the company's approach to managing its own risk through internal means rather than external validation. It's generic boilerplate with no specific frameworks, named roles, or concrete details from the information security list.


reasoning: The paragraph describes the company's internal cybersecurity risk management process (risk identification, mitigation plans, tracking to completion) and ERM integration. No named frameworks, roles, tools, or firm-specific details are present — this language could apply to any company.