content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is primarily about the board of directors' oversight of cybersecurity risk, with management reporting described only in service of that oversight, so Board Governance is the best fit. I agree with Annotators B and C: the board is the central subject, and there are no qualifying specific facts such as a named committee, CISO, framework, date, or other firm-unique detail.

provider: openai


content_category: Risk Management Process

reasoning: This paragraph is centered on the company’s internal cybersecurity risk management activities—assessments, audits, exercises, penetration testing, incident response preparedness, and training—so Risk Management Process is the best fit. I agree with Annotator C’s specificity analysis: 'Cyber Incident Response Plan' is a generic program name under the codebook, and the rest of the paragraph contains only common practices and generic references rather than qualifying firm-specific facts.


specificity_confidence: medium

reasoning: This is Board Governance because the paragraph centers on a board committee’s oversight responsibilities for cybersecurity risk. Annotator A’s interpretation is most persuasive: while much of the language is boilerplate, the named committee 'Audit and Risk Committee' is a firm-specific governance fact under the codebook’s treatment of non-generic risk-oriented committees.


content_category: Management Role

reasoning: The paragraph is centered on a named management executive’s role, responsibilities, and background, so Management Role is the best fit. Annotators A and C are correct on category; specificity is Firm-Specific rather than Quantified-Verifiable because the paragraph provides one clear qualifying fact (the January 2022 date), while 'over 20 years' is not an exact enough duration to count as a second hard verifiable fact.


category_confidence: medium

reasoning: This is best classified as Board Governance because the substance of the sentence is that the Audit Committee is informed about cybersecurity incidents, i.e., committee oversight through incident reporting. Although 'Management' is the grammatical subject, the paragraph does not identify any specific management cyber role or qualifications, so Management Role is less applicable.


reasoning: I agree with Annotators A and B that this paragraph is principally about the CIO’s identity, qualifications, responsibilities, and reporting lines, so Management Role is the best fit. It is Firm-Specific because it includes cybersecurity-specific role and committee facts, but the experience-based numbers do not cleanly meet the stricter Quantified-Verifiable threshold for two hard externally verifiable facts.


content_category: Third-Party Risk

reasoning: The paragraph’s central topic is vendor qualification and due diligence before sharing confidential information or implementing services, so Third-Party Risk is the best fit. I agree with Annotators A and C on specificity: terms like pre-engagement process, tier level, and Risk Dependency Assessment do not clearly qualify as unique named programs or other firm-specific facts under the codebook, so this remains generic boilerplate.


reasoning: The paragraph describes the company’s internal incident response and escalation process—how incidents are detected, handled, and escalated—so Risk Management Process is the best fit. I agree with Annotators B and C on category, and on specificity because the named internal teams CIRT and Cyber Security Watch Team make the disclosure company-specific rather than generic boilerplate.


reasoning: This paragraph is primarily about the company’s internal process for identifying, evaluating, and managing cybersecurity risk through its ERM program, so Risk Management Process is the best fit. I agree most with Annotator B: board reporting is only incidental here, and the reference to the company’s ERM program makes the disclosure more firm-specific than pure boilerplate, though this is a borderline call.


reasoning: The paragraph is about Garmin’s own cybersecurity risk management program—how it assesses, identifies, manages, and integrates cyber risk into internal operations—so Risk Management Process is the best fit. I agree most with Annotator A because, beyond naming NIST, it includes a firm-specific organizational detail: integration with the product development and technology management teams, while the third-party references are only supporting components of the internal process.


reasoning: The paragraph is centered on a specific management executive’s qualifications, experience, and cybersecurity-related responsibilities, so Management Role is the best fit. I agree most closely with Annotator B: the two exact tenure figures are specific quantified facts, which push this beyond Firm-Specific to Quantified-Verifiable, although that call is somewhat borderline.


reasoning: This paragraph is primarily about the company’s internal cybersecurity risk activities—identifying, assessing, monitoring, mitigating, and maintaining cybersecurity programs—which fits Risk Management Process. Annotators A and C are correct; Annotator B is too literal because generic 'management' alone does not make this a Management Role disclosure under the codebook.


reasoning: The paragraph is about the company’s cybersecurity assessment methodology—how systems are stratified, evaluated, and reported—so Risk Management Process is the best fit. I agree with Annotator A on specificity: MLPS is a named framework, but the remaining details (third party, government oversight, CFO review) are not qualifying firm-specific facts under the codebook, and 'IT Manager' is not clearly a cybersecurity-specific title.


reasoning: The paragraph is primarily about the company’s internal cybersecurity controls and response preparedness—application design, backups, monitoring, anti-malware, training, audits, and threat response—so Risk Management Process is the best fit. I agree with Annotator B on category; however, unlike Annotator C, the identification of the Head of IT department as the person overseeing cybersecurity risks makes the paragraph Firm-Specific under the codebook.


reasoning: I agree with Annotator B: the paragraph is primarily about Board and audit committee oversight of cybersecurity, with management escalation details serving as supporting context. It is Firm-Specific because it identifies cybersecurity-specific roles (ISO and CISO), but it includes no two hard verifiable facts needed for Quantified-Verifiable.


reasoning: This is best classified as Management Role because senior management is the grammatical subject and the paragraph describes management’s responsibility for setting and recommending cybersecurity risk appetite metrics. I agree with Annotators A and B: the Board is only the approval recipient here, and there are no qualifying specific facts, so the paragraph is generic boilerplate.


content_category: Strategy Integration

reasoning: The paragraph’s main function is to describe the potential business/financial impact of cybersecurity incidents and state that such risks have not materially affected the company to date. Under the tiebreaker, a brief mention of past incidents combined with a materiality-focused conclusion belongs in Strategy Integration, not None/Other.


reasoning: I agree with Annotator A: the paragraph is about the company's own cybersecurity measures and dependence on IT systems, which fits internal risk management/process disclosure better than Strategy Integration or None/Other. It is highly general and contains no qualifying specific facts, frameworks, dates, roles, or named programs, so it is Generic Boilerplate.


reasoning: The paragraph is chiefly about the company’s internal cybersecurity practices—risk-informed decision-making, mitigation, external assessments, and employee training—so Risk Management Process is the best fit. I agree with Annotators A and C on specificity: 'IT Team' and 'Software Engineer' are not qualifying firm-specific facts under the codebook, and the paragraph includes no named framework, dates, products, firms, or other verifiable details.


reasoning: The paragraph is centrally about oversight of vendors and third-party service providers, so Third-Party Risk is the best fit. I agree with Annotator C on specificity: after filtering out generic vendor-risk language, due diligence/monitoring practices, and the generic program label 'Third-Party Risk Management Program,' the paragraph does not contain a qualifying firm-specific fact under the codebook.


reasoning: This paragraph is chiefly about the company's own cybersecurity posture—its lack of personnel, limited resources, reliance on third parties as part of that posture, and a general incident-response/reporting approach—so Risk Management Process is the best fit. I agree with Annotators B and C that third-party reliance is not the central standalone topic and that the paragraph contains no qualifying firm-specific facts under the codebook.


reasoning: Management Role is the best fit because the paragraph centers on the VP of IT's cybersecurity oversight and qualifications, with the team and frameworks as supporting context. Annotators B and C are correct on specificity: the named VP of IT is a firm-specific fact, but the frameworks and 'over 20 years' do not supply the two hard verifiable facts required for Quantified-Verifiable.


reasoning: The paragraph primarily explains how the company’s cybersecurity risk management is implemented through its external manager and affiliated IT service provider, so vendor involvement is a component of the company’s own process rather than a standalone vendor oversight discussion. Annotators B and C are therefore closer to the codebook; Annotator A’s reliance on 'we have no employees' does not supply a qualifying firm-specific cybersecurity fact under the specificity rules.


reasoning: This paragraph is primarily about the company’s internal cybersecurity risk mitigation processes—business application design, backup systems, monitoring and detection, anti-malware, training, audits, and response capabilities—so Risk Management Process is the best fit. Annotator C’s interpretation is more persuasive because the management-role sentence is secondary to the broader process description; the named Head of IT role makes the paragraph Firm-Specific.


reasoning: The paragraph's main substance is the company's internal cybersecurity program and processes—framework-based controls, monitoring through a security operations center, and readiness exercises—so Risk Management Process is the best fit. I agree with Annotator A over B/C because the CIO/CISO references primarily explain who oversees the program rather than making management qualifications the paragraph's central topic.


reasoning: Risk Management Process is the best fit because the paragraph primarily describes the company's cyber risk management activities and how they are integrated into enterprise risk management, including internal review and testing practices. I agree most with Annotator C: the Board and Audit Committee are mentioned as oversight recipients, but the paragraph's main focus is the underlying process rather than board governance itself.


reasoning: The paragraph is about the company’s own cybersecurity approach—receiving consultant updates, using threat intelligence, and employing security tools—so it fits Risk Management Process rather than Third-Party Risk. Annotator C’s specificity reading is correct: the consultant is unnamed, the tools are unnamed, and “over 30 years” is not a qualifying hard verifiable fact under the codebook, leaving no specific facts.


reasoning: The grammatical subject is the CEO, and the paragraph is primarily about management briefing the Audit Committee on cybersecurity matters, which fits Management Role under the codebook's subject-based rule. Annotator A's interpretation is the strongest because "Audit Committee," "CEO," and an annual briefing cadence are all treated as generic rather than specific facts.


reasoning: The paragraph is about the company’s own cybersecurity controls and recovery practices—monitoring, patching, internal hosting, and backups—so Risk Management Process is the best fit. Annotator C’s interpretation is correct on specificity: references to 'Layer 7 firewall solutions,' antivirus/antimalware, internal cloud hosting, and tape backups are generic control descriptions, not qualifying named tools, frameworks, dates, firms, or other ✓ IS facts.


reasoning: Management Role is the best fit because the paragraph is led by a management actor—the Chief Executive Officer—describing his oversight and leadership responsibilities for cybersecurity and incident response. I agree most with Annotator C on category, but not on using the CEO as a specific fact; the Firm-Specific rating is supported instead by the unusually detailed incident response team composition.


reasoning: The paragraph focuses on the company’s participation in processes for assessing, identifying, and managing cybersecurity risk, so the central topic is its internal risk management approach rather than vendor oversight. I agree with Annotators B and C: the services agreement is just the mechanism, and no qualifying specific facts remain after filtering out company/self-references and generic language.


reasoning: This paragraph is about the potential business, financial, legal, and reputational impact of a hypothetical cyberattack, culminating in a material adverse effect statement, which fits Strategy Integration. Annotators A and C are correct because the paragraph is substantive cyber-risk impact disclosure, not a non-substantive header or disclaimer, but it remains entirely generic and contains no qualifying specific facts.


reasoning: This paragraph is mainly about Audit Committee/Board oversight of cybersecurity risk and the flow of updates to that committee, so Board Governance is the best fit. I agree with Annotators B and C that 'Audit Committee,' annual/quarterly reporting, and the referenced leadership teams do not qualify as specific facts under the codebook after filtering out generic governance language.


reasoning: The paragraph is primarily about the company’s internal ERM-based cybersecurity risk identification, monitoring, and mitigation process, so Risk Management Process is the best fit; board discussion is secondary. I agree with Annotator A on category, but unlike B and C, the reference to an enterprise risk management committee is a named non-generic committee, which makes the paragraph Firm-Specific under the codebook.


reasoning: The paragraph is primarily about Centuri’s own cybersecurity risk assessment, control implementation, risk tracking, and external evaluations as part of its internal program, so Risk Management Process is the best fit. I agree with Annotators B and C on category, and with their lower specificity view, because NIST CSF is the only qualifying specific fact; items like quarterly reviews, the Executive Leadership Team, unnamed third parties, and a generic 'Cybersecurity Risk Register' do not elevate this to Firm-Specific under the codebook.


reasoning: This paragraph is about the company’s own cybersecurity controls and practices—monitoring, access controls, encryption, training, phishing simulations, and related procedures—so Risk Management Process is the best fit. Annotators A and B are correct on specificity: "Information Systems Security department" is too generic to qualify as a firm-specific fact under the codebook, and the paragraph includes no dates, named firms, named tools, named frameworks, or other qualifying specific facts.


reasoning: I agree with Annotators A and B: the paragraph’s main topic is the company’s cybersecurity risk management approach and its integration into the broader risk management framework, so Risk Management Process is the best fit. The Board is mentioned only as an oversight layer, not as the primary subject, and the paragraph contains no qualifying specific facts or named standards.


reasoning: The paragraph is centered on the qualifications and experience of named cybersecurity-related management roles, so Management Role is the best fit. I agree most with Annotator C on specificity: the named roles and CISSP reference make the disclosure firm-specific, but the experience figures are approximate ('nearly 30 years,' 'more than 20 years') and therefore are not strong enough hard facts to clearly support Quantified-Verifiable under the codebook’s threshold.


reasoning: The paragraph is primarily about the company’s own cybersecurity risk management activities—assessments, testing, policy audits, external evaluations, and use of NIST—so Risk Management Process is the best fit. I agree most with Annotator C on category, and with A/C on specificity, because the named relationship with Harley-Davidson is a firm-specific fact beyond mere framework boilerplate.


reasoning: This paragraph is about the company’s own cybersecurity controls, monitoring, testing, and defensive practices, so Risk Management Process is the best fit. I agree most with Annotator C: 'daily' is just a cadence and does not make the paragraph firm-specific, but the stated cross-functional team composition does qualify as a firm-specific fact under the codebook.


content_category: None/Other

reasoning: This paragraph is primarily a cross-reference to Item 1A risk factors and does not itself provide substantive cybersecurity governance, management, process, or incident disclosure. I agree with Annotators A and C: the brief mention of risk management and Board/management focus is too generic to outweigh the paragraph’s essentially referential nature.


reasoning: This paragraph is best read as high-level cyber risk management context: it describes the company's sensitive data environment, reliance on IT systems, and the importance of maintaining confidentiality, integrity, and availability. I agree with Annotators A and C that third parties are only mentioned incidentally and, despite the lack of detailed process mechanics, the paragraph is still substantive cybersecurity risk-process context rather than None/Other.


reasoning: This is primarily about the company’s internal cybersecurity risk identification and assessment process: the bulk of the paragraph describes monitoring, assessments, audits, vulnerability reviews, and tabletop exercises. Annotator A is correct because the management titles are introductory context, while the main substantive disclosure concerns the company’s own risk management process.


reasoning: This paragraph is primarily a standalone materiality and business-impact disclosure: it states that known cybersecurity threats and prior incidents have not materially affected the company, while warning that future threats could do so. Although it briefly mentions the company's cybersecurity risk management program, the main point is the materiality conclusion rather than a substantive description of internal risk management processes, so Annotators B and C are correct.


reasoning: The paragraph’s main substantive content is the company’s security requirements and oversight of third-party service providers, so Third-Party Risk is the best fit. I agree with Annotator B: the closing sentence about the Board and Audit Committee is secondary and does not outweigh the paragraph’s central vendor-focused disclosure.


reasoning: This paragraph is best read as a business-impact statement: it says a cyber-attack could disrupt sales, production, and cash flows. I agree with Annotator C that this fits Strategy Integration better than None/Other, because it contains substantive cybersecurity-related operational and financial impact language rather than a pure header, disclaimer, or cross-reference.


reasoning: This paragraph is squarely about the Board and Audit Committee overseeing cybersecurity risk and receiving updates from management, so Board Governance is the best fit. I agree with Annotators A and C: after applying the codebook's filtering rules, no qualifying specific facts remain—'Audit Committee' is generic, 'periodic' is vague, and 'Inland's incident response plan' is still a generic plan name rather than a uniquely named program or other qualifying firm-specific fact.


reasoning: I agree with Annotator B: the paragraph is mainly about the company's internal cybersecurity program and response/monitoring processes, with the IT Engineer and Cybersecurity Council described as operators of that process rather than the paragraph primarily identifying management qualifications or reporting lines. It is Firm-Specific because it names non-generic internal committees, but it lacks two hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph's main thrust is the company's internal cybersecurity process—how its cybersecurity team, experts, monitoring inputs, and reporting operate within the Cybersecurity Program. I agree most with Annotator A: the Vice President of Information Technology is mentioned, but as context for who leads the program rather than as the central subject of the disclosure.


reasoning: The paragraph is principally about the company’s own cybersecurity risk management program and related internal processes, so Risk Management Process is the best fit. I agree most with Annotator C on specificity: while much of the language is boilerplate, the identified mix of cybersecurity and data privacy professionals is a specific team composition, which elevates it above purely generic disclosure.