content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's internal ERM program and how cybersecurity risks are integrated into it, which clearly aligns with Risk Management Process. However, it contains no facts from the IS list: no cybersecurity-specific titles (CISO, CTO), no specific dates, no named products/tools, no named third-party firms, no specific numbers, and no certification claims. The ERM program is a generic business term, not a unique identifier like 'CIRP'. The reference to Item 106(a) of Regulation S-K is a regulatory citation, not a firm-specific fact. I agree with Annotator C's specificity assessment.

provider: z-ai


reasoning: The paragraph describes the company's internal incident response structure and escalation processes, which clearly falls under Risk Management Process for IR planning. For specificity, the paragraph names two internal teams with specific identifiers: 'CIRT' (an acronym identifier for the Incident Response Team) and 'Cyber Security Watch Team.' Under the codebook, named internal programs with unique identifiers like 'Cyber Incident Response Plan (CIRP)' qualify as firm-specific facts. The acronym 'CIRT' functions similarly—it's not merely 'the incident response team' but a named entity with a unique identifier. Annotator A and C correctly identified this as Firm-Specific, while Annotator B incorrectly treated these named teams as generic.


content_category: Board Governance

reasoning: The paragraph's primary focus is the board's oversight function and the information flow to the board regarding cybersecurity. Management is mentioned only in the context of reporting TO the board, not their qualifications or specific roles, making this Board Governance. No specific facts exist—'board of directors,' 'management,' 'periodic,' and 'when material' are all generic terms on the exclusion list.


content_category: Management Role

reasoning: The paragraph focuses on the CIO's identification, qualifications, experience, and reporting relationships, with management roles as the grammatical subject throughout. I agree with Annotators A and C on Firm-Specific: while the paragraph contains multiple quantified details (years of experience), these are durations rather than the specific dates, dollar amounts, headcounts, percentages, named third-party firms, or named tools/products required for Quantified-Verifiable status under the codebook's strict definition.


reasoning: The paragraph centers on the CDIO's identification, qualifications, and background with the CDIO as the grammatical subject throughout, clearly fitting Management Role. I agree with annotators B and C on specificity: the paragraph contains firm-specific facts (CDIO title, specific date January 2022, prior role title) but only ONE hard verifiable fact counting toward Quantified-Verifiable (the date). The 'over 20 years' experience is approximate, not an exact number, and named roles do not count toward the QV threshold per the codebook.


category_confidence: medium

reasoning: The paragraph describes the Audit Committee's oversight function through the mechanism of receiving updates from management on cybersecurity incidents, which aligns with Board Governance's focus on briefing cadence and committee oversight. While management is the grammatical subject, the substantive focus is on the board committee's information flow for oversight purposes. No specific facts exist—'Audit Committee' is explicitly generic per the codebook, 'management' and 'executives' are generic roles, and 'as necessary' is a vague cadence.


reasoning: The paragraph's grammatical subject is the VP of IT and supporting team, describing their cybersecurity responsibilities and qualifications, which clearly fits Management Role. For specificity, the VP of IT title is a cybersecurity-specific role from the ✓ IS list, making this Firm-Specific. However, it does not reach Quantified-Verifiable because: (1) named roles do not count toward QV threshold, (2) 'over 20 years' is approximate duration (not a hard fact like '17 years'), and (3) named frameworks (NIST, CIS, ISO 27001) only establish Sector-Adapted at most. Annotators A and C correctly identified Firm-Specific; Annotator B incorrectly counted frameworks and approximate experience toward QV.


reasoning: The paragraph describes Garmin's internal cybersecurity risk management program, including risk assessment, identification, and management processes, which directly aligns with Risk Management Process. Third-party providers are mentioned as components of internal processes, not as the central topic. The paragraph names the NIST Cybersecurity Framework but contains no firm-specific facts from the ✓ IS list (no cybersecurity-specific roles, named committees, specific dates, named firms, or quantified details), so it qualifies as Sector-Adapted. I agree with Annotators B and C on specificity; Annotator A incorrectly rated it as Firm-Specific when the team integrations mentioned are generic organizational descriptions, not specific facts.


reasoning: I agree with Annotator B. The paragraph's primary focus is board/committee oversight—the audit committee and Board of Directors are the grammatical subjects in three of four sentences, and the management reporting structure is described specifically to explain incident escalation TO the board. The ISO and CISO are cybersecurity-specific roles that qualify as firm-specific facts, but there are no hard verifiable facts (dates, amounts, named external firms/tools) to reach Quantified-Verifiable.


reasoning: The paragraph describes Cheniere's internal cybersecurity processes including assessments, audits, risk exercises, incident response planning, penetration testing, and training programs. Third-party involvement is a supporting component of these internal processes, not the central topic.


specificity_confidence: medium

reasoning: The paragraph primarily describes the company's risk management program structure—how assessment, identification, and management of cybersecurity risks are executed through their Manager and IT Service Provider. The third-party provider is a component of explaining their internal process architecture rather than the central topic of vendor oversight activities. The statement 'We have no employees' is a specific, verifiable headcount (zero) that distinguishes this disclosure from generic boilerplate, elevating it to Firm-Specific despite the SOC 2 reference.


reasoning: The grammatical subject is 'Senior management,' which is responsible for creating and recommending cybersecurity risk appetite metrics to the Board. The Board is the object receiving management's recommendations, not the subject, so this fits Management Role per the codebook's subject-based assignment rule. No cybersecurity-specific roles (CISO, CTO, CIO), named frameworks, dates, or other firm-specific facts appear—only generic governance terms like 'Senior management' and 'Board of Directors.'


content_category: None/Other

reasoning: I agree with Annotators B and C. This paragraph is standard risk disclosure language describing general IT reliance and hypothetical incident impacts, ending with a cross-reference to Risk Factors. The vague acknowledgment that the company has 'from time-to-time experienced cybersecurity incidents' lacks any incident narrative, dates, or scope details, so it does not qualify as Incident Disclosure. The materiality statement is boilerplate risk language, not substantive Strategy Integration content about business impact analysis or materiality assessment processes. There are no named entities, frameworks, dates, or verifiable facts—only generic business terminology.


reasoning: The paragraph describes the company's internal cybersecurity processes including framework oversight, risk assessment, and training programs, which clearly fits Risk Management Process. However, 'Software Engineer' is not a cybersecurity-specific title (not on the IS list like CISO, CTO, CIO), 'IT Team' is generic, no named frameworks are specified, and no dates, numbers, or named firms appear. The paragraph could apply to any company unchanged.


reasoning: I agree with Annotator C. This paragraph contains no substantive disclosure—it is purely introductory, generic language about the importance of cybersecurity and IT dependence that could appear in any company's filing unchanged. It does not describe actual risk management processes, governance structures, incidents, or strategy elements (no materiality assessments, insurance, budget, or frameworks). The mention of 'developing, implementing, and maintaining robust cybersecurity measures' is aspirational boilerplate, not a description of specific processes. The section header 'Risk Management and Strategy' further signals this is introductory framing rather than substantive content.


reasoning: The paragraph describes the company's incident response structure and team composition, which falls under IR planning within Risk Management Process. While the CEO is the grammatical subject of the first sentence, the paragraph's substantive content concerns internal incident response processes rather than management qualifications or reporting lines. The CEO is explicitly a generic C-suite role per the codebook and does not trigger Management Role. The specificity is Firm-Specific because the detailed team composition (cybersecurity, IT support, mining operations, software engineering, compliance, legal, contractors, and partners) constitutes a specific departmental composition per the codebook's example of 'Legal, Compliance, and Finance' teams.


reasoning: The paragraph clearly centers on Board and Audit Committee oversight of cybersecurity risk, with the Audit Committee as the grammatical subject, making Board Governance the correct category. For specificity, after filtering the ✗ NOT list, no qualifying facts remain: 'Audit Committee' is explicitly excluded as a standard committee; 'annual assessments,' 'quarterly reporting,' and 'regular updates' are generic cadences without exact dates; and 'cybersecurity and data privacy leadership team' is a team name, not a composition like 'Legal, Compliance, and Finance' that would identify specific departments. No named frameworks, cybersecurity-specific roles (CISO, CTO), dates, or verifiable facts are present.


reasoning: The paragraph describes Liberty Broadband's internal processes for managing cybersecurity risks through a services agreement with its parent entity Liberty, which constitutes Risk Management Process rather than Third-Party Risk. The tiebreaker specifies that 'internal processes mentioning vendors as one component' should be classified as Risk Management Process, and here the services agreement is the mechanism for accessing risk management processes, not vendor oversight as the central topic. No facts from the ✓ IS list qualify—Liberty and GCI are related entities (not external third-party firms like Mandiant), and no cybersecurity-specific roles, named frameworks, dates, or verifiable specifics appear.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, including ERM integration, penetration testing protocols, and review procedures. While Board and Audit Committee oversight are mentioned, they serve as context for describing the operational risk management framework rather than being the central focus. The detailed examples (i, ii, iii) describe process activities, not governance structures.


reasoning: The paragraph describes the company's internal cybersecurity processes including firewalls, antivirus systems, internal cloud infrastructure, and backup procedures, which clearly fits Risk Management Process. However, it contains no facts from the ✓ IS list: 'Layer 7 firewall solutions' is a generic technical description (not a named product like Palo Alto or Cisco), 'internal cloud system' and 'magnetic tapes' are generic technology references, and 'daily'/'monthly' are generic cadences rather than specific dates. No named roles, committees, frameworks, firms, or quantified facts appear, making this generic boilerplate that could describe any company's basic security measures.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk mitigation processes (monitoring, detection, anti-malware, training, audits, backup systems) with the Head of IT role mentioned as one component explaining who oversees these processes. While the final two sentences have the Head of IT as grammatical subject, the bulk and main focus of the paragraph is on the company's risk management activities rather than on the role's qualifications or detailed responsibilities.


reasoning: The paragraph describes Centuri's internal cybersecurity risk management processes—quarterly reviews, framework adoption, risk assessments, and a risk register—which clearly aligns with Risk Management Process. The third-party mention is a minor component of internal practices, not vendor oversight. For specificity, the paragraph names NIST CSF (a recognized framework) but contains no firm-specific facts: 'Executive Leadership Team' is generic management, 'Cybersecurity Risk Register' is a generic program name without unique identifiers, 'quarterly' is a generic cadence, and 'third parties' are unnamed entities. Annotators A and B correctly identified this as Sector-Adapted.


reasoning: This paragraph is primarily a cross-reference to Item 1A risk factor disclosures with malformed text that appears to include regulatory prompt language ('describe whether and how...'). The fragment at the end about 'risk management processes' and 'Board and management' focus contains no substantive disclosure—no specific governance structures, roles, processes, or assessments. I agree with Annotators B and C: this meets the 'None/Other' definition for cross-references and non-substantive content. Annotator A's 'Strategy Integration' classification is incorrect because the materiality language quoted is part of the cross-reference description to Item 1A, not an actual materiality assessment or conclusion by the company.


reasoning: The paragraph describes the company's approach to cybersecurity risk management and its integration into the broader risk management framework, which fits Risk Management Process. Board oversight is mentioned briefly at the end but is not the primary subject - the grammatical subject is 'Our approach to cybersecurity risk management.' The paragraph contains no specific facts, named frameworks, or verifiable details, making it generic boilerplate.


reasoning: I agree with Annotator C. While the first sentence identifies management roles, they are not the grammatical subjects—the subjects are 'our information security function' and 'our Information Security Team.' The bulk of the paragraph describes internal processes for risk identification, assessment, monitoring, vulnerability assessments, and tabletop exercises, which aligns with Risk Management Process. The management roles serve only to introduce who performs these processes, not as the central focus.


reasoning: This paragraph is a generic forward-looking risk factor statement describing hypothetical business impacts of a potential cyber-attack. It does not contain substantive disclosure about governance structures, management roles, internal processes, third-party oversight, actual incidents, or concrete strategy/financial planning (insurance, budget, materiality assessments). The language 'could inhibit our business operations' is classic risk factor disclaimer language, fitting None/Other.


reasoning: This paragraph is pure forward-looking risk disclaimer language describing hypothetical cybersecurity scenarios and their potential consequences ('could result,' 'may also result,' 'could have'). It contains no substantive disclosure about actual governance structures, management roles, risk management processes, real incidents, or concrete strategy elements like insurance coverage or budget. The codebook explicitly assigns None/Other to 'forward-looking disclaimers' with 'NO substantive disclosure at all.' While Annotators A and C classified this as Strategy Integration, the codebook's Strategy Integration category is meant for actual business/financial impact assessments, materiality conclusions about real situations, or concrete strategy elements—not hypothetical risk factor language that could appear in any company's filing.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, which clearly falls under Risk Management Process. However, it contains no specific facts from the ✓ IS list — no named cybersecurity-specific roles (CISO, CTO), no named departments (just generic 'cybersecurity professionals' and 'data privacy professionals' describing job types, not organizational units), no named frameworks, no dates, no numbers, and 'external experts' is an unnamed entity per the ✗ NOT list. This paragraph could appear in any company's filing unchanged.


reasoning: The paragraph describes the company's internal cybersecurity posture—specifically the lack of personnel, processes, and resources for cybersecurity protection—and outlines a basic incident response reporting mechanism. The mention of third parties relates to the company's dependence on them due to having no internal capabilities, not vendor oversight or contractual requirements, so Third-Party Risk does not apply.


reasoning: The paragraph describes the company's internal risk assessment process using the MLPS framework, a recognized Chinese cybersecurity standard. While JiuGe Technology is named, it is not a fact on the IS list—it is a subsidiary entity, not a named third-party firm, named product/tool, cybersecurity-specific title, or other IS-listed category. IT Manager is not a cybersecurity-specific title (unlike CISO/CTO/CIO), and CFO is explicitly on the NOT list as generic C-suite. Therefore, the paragraph is Sector-Adapted for naming the MLPS framework.


reasoning: The paragraph's grammatical subject is consistently the Board and Audit Committee receiving reports and overseeing cybersecurity risks, which squarely fits Board Governance. After applying the validation filter, no facts from the ✓ IS list remain: Audit Committee is explicitly excluded as standard; 'Board' and 'management' are generic governance terms; 'periodic' is a vague cadence; 'incident response plan' is a generic program name; and 'Inland,' 'Advisor,' 'Sub-Advisor,' and 'Dealer Manager' are related entity references not on the IS list (they are not named cybersecurity firms, tools, or certifications). I agree with Annotators A and C on specificity—this is Generic Boilerplate with no verifiable firm-specific facts.


reasoning: I agree with Annotators A and C. The paragraph describes the company's own internal process for evaluating third-party providers, which constitutes risk management rather than pure third-party risk disclosure. The key tiebreaker states that 'Internal processes mentioning vendors as one component → Risk Management Process' — here, the vendor evaluation is presented as the company's internal assessment activity, not as contractual requirements imposed ON vendors. The brief Board/Audit Committee mention is generic governance boilerplate. No specific facts exist: 'Board of Directors' and 'Audit Committee' are explicitly listed as generic entities in the ✗ NOT list, and no named frameworks, dates, roles, or verifiable details appear.


reasoning: The paragraph describes the company's internal enterprise risk management process and how cybersecurity is integrated as a risk category, which squarely fits Risk Management Process (ERM integration). The committee is described functionally ('an enterprise risk management committee') rather than as a proper noun name, and all other elements—'key business and functional leaders,' 'management,' 'Board of Directors,' 'at least annually,' 'regularly'—are generic governance terms that could appear in any company's filing.


reasoning: I agree with Annotator A. While IT Engineer and Cybersecurity Council are grammatical subjects, the paragraph's substantive content describes the company's internal cybersecurity processes—program implementation, incident response plans, monitoring prevention/detection/mitigation/remediation, and reporting workflows. The management roles serve as actors carrying out these processes, but the central topic is the risk management process itself, not role identification or qualifications. The named committees (Cybersecurity Council, Risk Management Committee) qualify as firm-specific facts but do not meet the Quantified-Verifiable threshold since they are organizational structures rather than hard verifiable facts like dates, dollar amounts, or named third-party firms.


reasoning: The paragraph describes the Audit Committee's oversight function through receiving cybersecurity briefings from management. Although the CEO is the grammatical subject, the content focuses on board oversight mechanisms (briefing cadence, topics covered) rather than management qualifications or role details. Per the tiebreaker rule: 'Management mentioned briefly + board oversight as main focus → Board Governance.' All elements are generic: CEO is a standard C-suite role, Audit Committee is a standard committee, and 'once per year' is a generic cadence without specific dates.


reasoning: While the first sentence mentions the VP of IT, the grammatical subject is actually 'Our Cybersecurity Program and team' (the VP appears in a prepositional phrase). The paragraph's substance describes how the Cybersecurity Program operates—use of internal/external experts, monitoring activities, threat intelligence sources, and executive management briefings. Three of four sentences focus on process execution rather than management role identification.


reasoning: The paragraph describes the company's internal cybersecurity controls, testing, and monitoring processes, which squarely fits Risk Management Process. I agree with Annotator B that the team composition ('information security, technology, IT and operations personnel') qualifies as a Firm-Specific fact under the codebook's 'specific team/department compositions' criterion. However, I disagree with Annotator C that 'daily' alone constitutes a specific fact—the codebook explicitly lists generic cadences like 'quarterly' and 'periodic' as non-qualifying, and 'daily' is a frequency rather than a specific date or hard verifiable fact. No named frameworks (NIST, ISO 27001, etc.), specific dates, dollar amounts, headcounts, or named third-party firms appear, so the paragraph does not reach Sector-Adapted or Quantified-Verifiable.