fact: penetration testing of customer facing domains

fact: implementation of the CIS Critical Security Controls

reasoning: The paragraph primarily describes what the company's cybersecurity program does—using third parties, testing controls, incident response preparedness, and ongoing detection/mitigation—so Risk Management Process is the best fit. Its specificity rises above boilerplate because it includes cybersecurity-domain details such as penetration testing and the CIS Critical Security Controls, but it does not include firm-unique roles/committees or externally verifiable quantified claims.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily provides a materiality assessment, stating that potential cybersecurity threats or incidents are not currently believed to be reasonably likely to materially affect results of operations or financial condition, which fits Strategy Integration. Its only concrete-seeming statements are negative self-assertions about no breaches and no currently material risks, which do not count as verifiable or specificity-elevating facts under the rubric.

provider: openai

stage: benchmark


content_category: None/Other

reasoning: This paragraph is only a cross-reference directing readers to risk factors elsewhere in the report and does not substantively describe cybersecurity governance, management, processes, third-party risk, incidents, or strategy. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, its specificity is Generic Boilerplate.


reasoning: This paragraph is primarily a generic forward-looking risk statement about potential IT disruption and cyberattack consequences, with a cross-reference to Risk Factors, rather than a substantive disclosure about governance, management, processes, third-party risk, incidents, or a materiality assessment. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts, so its specificity is Generic Boilerplate.


content_category: Board Governance

fact: In February 2024, the Board delegated oversight of cybersecurity and other information technology risks to the Audit Committee.

specificity_confidence: medium

reasoning: The paragraph primarily describes how the board oversees cybersecurity risk, including delegation to a board committee and reporting flows from management to the board, which makes Board Governance the best fit. Specificity is elevated to Quantified-Verifiable because it includes a concrete, externally checkable date-based governance action ('In February 2024').


reasoning: The paragraph primarily provides a materiality assessment that known cybersecurity threats and prior incidents have not materially affected, and are not reasonably likely to materially affect, the company, which is Strategy Integration under the materiality rule. Its statements about cyber insurance coverage and a risk-factor cross-reference are generic and do not add domain-specific, firm-specific, or externally verifiable facts.


reasoning: The paragraph primarily provides management’s conclusion about whether known cybersecurity threats are reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition, which is a Strategy Integration assessment. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts beyond generic materiality language and a cross-reference to risk factors.


content_category: Management Role

fact: The company's cybersecurity program is overseen by a named management-level body, the Security Governance Council (SGC).

fact: The SGC is chaired by the CISO.

fact: The SGC includes senior leaders and key personnel from specific departments including Operations, Information Technology, Finance, Internal Audit, Legal, Human Resources and Organizational Development, and Risk Management.

reasoning: This paragraph primarily explains how management is organized to handle cybersecurity through the Security Governance Council, including its chair, membership, and responsibilities, so Management Role is the best fit. Specificity is Firm-Specific because it names a company-specific committee, a CISO leadership role, and the committee's cross-functional departmental composition, but includes no externally verifiable quantified claim.


fact: The Chief Information Consultant works with management to prioritize risk management processes and mitigate cybersecurity threats likely to have a material business impact.

category_confidence: medium

reasoning: The paragraph primarily describes the oversight and reporting chain for cybersecurity risk, culminating in reporting to the Board’s Audit Committee, which makes Board Governance the best fit. Specificity rises above boilerplate because it includes the firm-specific role of Chief Information Consultant, while references to the CFO and Audit Committee do not count toward specificity under the rules.


reasoning: The paragraph primarily describes how the Board and a board committee oversee cybersecurity risk, so it is best classified as Board Governance. Its details are generic oversight statements, and the only named bodies are the Board and Audit Committee, which do not count as specificity-elevating facts under the rubric.


reasoning: The paragraph primarily explains how the Audit Committee oversees cybersecurity within the company’s broader risk governance structure, so it is best classified as Board Governance. Its details are generic oversight and ERM statements, and the only named body is the Audit Committee, which does not count as specificity-elevating under the rules.


reasoning: The paragraph primarily provides a materiality assessment, stating that no identified cybersecurity threat or incident has materially affected the company while noting such threats could reasonably likely materially affect it in the future, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts beyond generic cybersecurity and risk language, so specificity is Generic Boilerplate.


fact: CTO Vaidyanathan Raghavan is identified as a member of management implementing and maintaining cybersecurity risk assessment and management processes

fact: Vaidyanathan Raghavan previously served as General Manager of Technology at Wayfair

fact: Vaidyanathan Raghavan holds a Master of Science in Electrical Engineering degree from the University of Minnesota

fact: Vice President of Information Technology and Security Brendan Hamilton is identified as a member of management implementing and maintaining cybersecurity risk assessment and management processes

fact: Brendan Hamilton previously worked as a Vice President at an international bank with supervisory responsibility for cybersecurity issues

fact: Brendan Hamilton is a Certified Information Systems Security Professional (CISSP)

reasoning: The paragraph primarily answers how management is organized and qualified to handle cybersecurity by identifying the responsible executives and describing their backgrounds and credentials. Specificity is Quantified-Verifiable because it includes externally checkable facts such as named individuals, prior employment at Wayfair, an academic degree, and CISSP certification.


content_category: Risk Management Process

fact: The Company uses the Ontrack software solution ("Ontrack") to monitor and track risk assessment activities

fact: Ontrack is also used to track cybersecurity incidents and remediation tasks

reasoning: The paragraph primarily describes an operational element of the cybersecurity risk program—ongoing monitoring, incident tracking, and remediation—so it fits Risk Management Process. Its specificity is elevated by the named system Ontrack, which is a firm-specific implementation detail, while the rest of the language is otherwise fairly generic.


reasoning: The paragraph primarily explains how management is organized for cybersecurity by describing the information systems organization and management team’s responsibility for developing and implementing cybersecurity policies, along with their qualifications and training. It does not provide qualifying domain-specific terminology, firm-distinct roles/committees, or externally verifiable facts, so the specificity remains generic boilerplate.


reasoning: This paragraph primarily describes how the board oversees cybersecurity risk, including delegation to a board committee and reporting up to the board, so Board Governance is the best fit. Its details remain generic boilerplate because the named governance elements here are common and excluded from specificity credit (e.g., Board, Audit Committee, CFO, regular/annual updates), and it includes no qualifying domain-specific, firm-specific, or verifiable facts.


reasoning: This paragraph is primarily a cross-reference to Item 1A risk factors and contains hypothetical, forward-looking risk language rather than a substantive disclosure about governance, management, process, third-party oversight, incidents, or strategy. Because it provides no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, its specificity is Generic Boilerplate.


reasoning: The paragraph primarily provides management’s assessment that prior attacks have not had, and current threats are not reasonably likely to have, a material impact on the company’s business, results, or financial condition, which makes it a Strategy Integration disclosure. Its language is highly generic and contains no qualifying domain-specific technical terms, firm-specific organizational details, or externally verifiable facts that would elevate specificity above boilerplate.


reasoning: The paragraph primarily explains how the Board oversees cybersecurity, including alignment with strategy, risk appetite, and resource allocation, so it is best classified as Board Governance. It contains no qualifying domain-specific cybersecurity terminology, firm-unique governance facts, or externally verifiable claims beyond generic board oversight language.


fact: The management team includes the CTO

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity—who is responsible for the program and who they supervise—rather than detailing specific security processes. Specificity is elevated by the firm-specific management role of the CTO; the remaining language is otherwise generic.


fact: confidentiality, integrity, and availability of critical systems and information

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

type: framework

fact: HIPAA

fact: Service Organization Control Type 2 (SOC 2 Type II)

fact: Sarbanes-Oxley IT General Controls (SOX ITGC)

reasoning: The paragraph primarily describes what the company’s cybersecurity program does and the standards it references to assess and manage cyber risk, which makes it a Risk Management Process disclosure. Its specificity is Domain-Adapted because it uses cybersecurity-specific concepts and named frameworks, but it does not provide firm-unique organizational details or externally verifiable claims such as certifications actually held.


reasoning: This is a generic purpose statement about reducing breach likelihood and maintaining stakeholder trust, without describing board oversight, management roles, specific cyber processes, third-party risk, an actual incident, or a material business-impact assessment. It contains no domain-specific terminology, firm-specific details, or verifiable facts, so specificity is Generic Boilerplate.


fact: Protect the confidentiality, integrity, and availability of data

fact: Cybersecurity risks include ransomware

fact: Cybersecurity risks include denial-of-service attacks

fact: Threats from advanced, persistent, or organized actors, including nation-state actors targeting critical infrastructure sectors

fact: References the social, physical, and logical aspects of cybersecurity

reasoning: The paragraph primarily describes the company's cybersecurity risk environment and the need for protective measures, which fits Risk Management Process more than governance, management, or incident disclosure. Its specificity is Domain-Adapted because it uses genuine cybersecurity terminology and threat concepts (e.g., confidentiality/integrity/availability, ransomware, denial-of-service, nation-state actors) but does not provide firm-specific or externally verifiable details.


fact: The SVP of IT Security reports to the Audit Committee on cybersecurity matters.

reasoning: This paragraph primarily describes how the board, through its Audit Committee, receives cybersecurity oversight information, including escalation of incidents and regular reporting, which makes it Board Governance. Its specificity is elevated to Firm-Specific by the named management role 'SVP of IT Security'; the remaining items are largely generic oversight and reporting topics.


fact: The cybersecurity programs are overseen by the Vice President and Chief Information Officer.

fact: Day-to-day administration is led by the Director of Information Security, who directly reports to the Vice President and Chief Information Officer.

fact: The Vice President and Chief Information Officer has 27 years of technology leadership experience.

type: quantified

fact: The Vice President and Chief Information Officer holds a Doctor of Business Administration.

fact: The Director of Information Security has 27 years of experience in infrastructure and security operations.

fact: The Director of Information Security holds a degree in Information Technology Management.

fact: The Director of Information Security chairs the Company's Information Security Committee.

fact: The activities of the Information Security Committee are reviewed by the Executive Information Security Oversight Committee.

fact: The Executive Information Security Oversight Committee includes the Vice President and Chief Information Officer, Senior Vice President, Chief Legal Officer and Secretary, and Senior Vice President, Chief Human Resources Officer.

fact: The paragraph references security operations.

reasoning: The paragraph primarily describes how management is structured to administer cybersecurity, including leadership roles, reporting lines, committee structure, and management qualifications, so Management Role is the best fit. Specificity reaches Quantified-Verifiable because it includes externally checkable claims such as the two officers each having 27 years of relevant experience, alongside firm-specific titles and named committees.


fact: Board and Audit Committee members receive presentations on cybersecurity topics from the Chief Technology Officer

fact: The Board receives presentations from members of the Chief Technology Officer's team

reasoning: This paragraph primarily describes how cybersecurity information flows to the Board and Audit Committee and how the Board is educated on cyber matters, which is board oversight. Specificity rises to Firm-Specific because it identifies the Chief Technology Officer and that officer's team as part of the governance structure, but it does not include externally verifiable dates, numbers, or named vendors/products.


reasoning: The paragraph primarily provides a materiality assessment about whether cybersecurity threats have affected or are reasonably likely to affect the company's business strategy, results of operations, or financial condition, which fits Strategy Integration. Its remaining content is generic cautionary language and a risk-factor cross-reference, and it contains no qualifying domain-specific, firm-specific, or externally verifiable facts.


content_category: Third-Party Risk

reasoning: The paragraph is primarily about how the company manages cybersecurity risk from information technology suppliers that handle customer or personal data, so Third-Party Risk is the best fit. Its wording is generic process language without cybersecurity-specific domain terms, firm-unique structures, or verifiable details, so specificity is Generic Boilerplate.


reasoning: This paragraph primarily describes which management personnel are responsible for cybersecurity-related duties and decision-making, so it is about management organization and responsibilities rather than board oversight or program activities. It contains no qualifying domain-specific terminology, firm-specific cybersecurity roles, or externally verifiable claims that elevate specificity above generic boilerplate.


reasoning: The paragraph primarily provides a materiality assessment about whether cybersecurity threats or incidents have affected or are reasonably likely to affect the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration. Its statements are generic and include only a negative self-assertion about no material incidents in the last three fiscal years, which is not externally verifiable under the rubric, so specificity remains Generic Boilerplate.


reasoning: The paragraph primarily describes how cybersecurity information flows to the board and how the Audit Committee oversees cybersecurity matters, so Board Governance is the best fit. Although it mentions management roles and cybersecurity activities, the language is generic and does not include qualifying domain-specific terminology, firm-specific facts, or externally verifiable claims under the annotation rules.


fact: Topper Group employees are specifically identified as a population whose personal information could be affected

reasoning: The paragraph primarily gives a materiality assessment, stating that prior cybersecurity incidents have not had a material impact and are not reasonably likely to materially affect operations, which fits Strategy Integration. Specificity rises above boilerplate because it includes a company-specific reference to Topper Group employees, but it does not provide externally verifiable dates, numbers, or other hard facts.


reasoning: The paragraph primarily describes how the board oversees cybersecurity risk by assigning oversight responsibility to the Audit Committee, so Board Governance is the best fit. Its wording is generic and does not include qualifying domain-specific cyber practices, firm-unique roles/committees that count for specificity, or externally verifiable facts.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from vendors and service providers, making Third-Party Risk the best fit. Its descriptions of assessments, security questionnaires, and contractual obligations are generic vendor-risk practices that do not provide cybersecurity domain-specific detail, firm-unique organizational facts, or externally verifiable claims.


reasoning: This paragraph is primarily a cross-reference to risk factors and contains hypothetical adverse-consequences language rather than a substantive disclosure about governance, management, processes, third-party risk handling, strategy integration, or an actual incident. Because it provides no qualifying domain-specific, firm-specific, or verifiable cybersecurity facts, its specificity is Generic Boilerplate.


content_category: Incident Disclosure

fact: phishing attacks

fact: malware infections

fact: unauthorized access attempts

fact: state-sponsored actors

reasoning: The paragraph primarily describes actual cyber events the company experienced—attempts to compromise its systems, including the types of attacks involved—so it most directly answers what happened, which fits Incident Disclosure. Its specificity is elevated to Domain-Adapted because it uses concrete cybersecurity threat terminology such as phishing, malware, unauthorized access, and state-sponsored actors, but it provides no firm-unique or externally verifiable facts.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party service providers, making Third-Party Risk the best fit. Its language remains generic—describing due diligence, selection, oversight, and monitoring without domain-specific cybersecurity terminology, firm-unique structures, or verifiable details.


fact: The company states it experienced two separate cyber events

fact: The first event occurred in December 2021

fact: The December 2021 event was a targeted cyber-attack

fact: The attack led to a global shutdown of connectivity, operational, and accounting systems

fact: The disruption lasted approximately two weeks

fact: The incident temporarily impacted freight shipments, customs brokerage functions, and distribution activities

fact: The second event occurred in March 2024

fact: The March 2024 event involved the company's Canadian subsidiary

fact: The second attack was a targeted cybersecurity breach

fact: The attack was identified by endpoint protection software

fact: The company shut down its Canadian infrastructure in response

fact: The operations systems were restored and approved to return to service within one week

fact: Following the attacks, the company enhanced its security program with additional tools and strengthened system and network monitoring

reasoning: This paragraph primarily describes actual cybersecurity incidents, including their timing, operational effects, response actions, and recovery, so Incident Disclosure is the best fit. Specificity is Quantified-Verifiable because it includes externally checkable dates and durations such as December 2021, March 2024, approximately two weeks of disruption, and restoration within one week.


reasoning: This paragraph primarily describes how the Board is informed about cybersecurity matters, so it is best categorized as Board Governance. Its details are generic oversight language only; the annual reporting cadence and references to material or lower-impact incidents do not add qualifying domain-specific, firm-specific, or externally verifiable facts.


fact: The Global Director of IT has over 30 years of experience in various information technology roles

fact: That experience includes management of cybersecurity matters

fact: The Global Director of IT has over 20 years of experience as an IT Director

fact: The CFO has over 10 years of experience in risk management at the company and at similar companies, including risks arising from cybersecurity threats

reasoning: The paragraph primarily explains which management personnel are responsible for cybersecurity risk and incident handling, and emphasizes their qualifications and experience, making it a Management Role disclosure. Specificity is Quantified-Verifiable because it includes externally checkable experience claims of over 30, over 20, and over 10 years.


fact: An information security risk committee has been established at the management level

fact: The information security risk committee is chaired by the Chief Information Security Officer (CISO)

reasoning: The paragraph primarily explains how management is organized to handle cybersecurity, emphasizing the management-level information security risk committee and the CISO’s leadership role rather than detailing substantive security operations. Specificity is Firm-Specific because it includes company-specific organizational facts—a named management committee and the CISO role—but no externally verifiable quantified claim.


reasoning: The paragraph primarily describes how the board oversees cybersecurity by delegating oversight responsibility to a board committee, which makes this Board Governance. It contains only generic governance language and references to the board and audit committee, which do not qualify as specificity-elevating facts under the rubric.


reasoning: The paragraph primarily provides a materiality assessment, stating that no identified cybersecurity incidents or threats have materially affected or are reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration. Its remaining content is generic cautionary language and a risk-factor cross-reference, with no qualifying domain-specific, firm-specific, or externally verifiable facts.


fact: The cybersecurity risk management program is based on the National Institute of Standards and Technology Cybersecurity Framework (NIST CSF)

fact: The paragraph references the NIST CSF functions: Identify, Protect, Detect, Respond, and Recover

reasoning: The paragraph primarily describes how the company's cybersecurity program is structured and guided, which makes it a Risk Management Process disclosure. Its specificity is Domain-Adapted because it cites the NIST CSF and its core functions, but it does not include firm-unique organizational facts or externally verifiable claims such as certifications, dates, or quantified details.


reasoning: This paragraph is a cross-reference to risk factors and describes hypothetical adverse consequences that cybersecurity threats could cause, rather than disclosing the company's governance, management, process, third-party oversight, incident details, or a materiality assessment. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, its specificity is Generic Boilerplate.


fact: The cybersecurity program leverages the NIST Framework.

fact: The company uses monitoring and detection tools to protect its network and information systems.

fact: The program addresses identified vulnerabilities.

reasoning: The paragraph primarily describes what the cybersecurity program does—its framework, tools, and protective activities—so it fits Risk Management Process rather than governance. Its specificity is Domain-Adapted because it includes cybersecurity-specific terminology and a named framework (NIST), but no firm-unique organizational facts or externally verifiable claims.


fact: Senior Vice President – Technology Solutions is responsible for the day-to-day management of the cybersecurity program

fact: The Senior Vice President – Technology Solutions reports directly to the President

fact: The Senior Vice President – Technology Solutions has served in this role for over four years

fact: The Senior Vice President – Technology Solutions has more than 25 years of experience in the aggregate in various information technology roles

fact: The Senior Vice President – Technology Solutions has more than ten years with the Company

reasoning: The paragraph primarily describes how the board-level audit committee oversees cybersecurity risk and how management reports up to that committee, so Board Governance is the best fit. Specificity is Quantified-Verifiable because it includes checkable tenure and experience claims for the Senior Vice President – Technology Solutions, along with a firm-specific named role.


reasoning: This paragraph is only a cross-reference to the Risk Factors section for additional discussion of cybersecurity risks and impacts, rather than describing governance, management, processes, third-party risk, incidents, or strategy integration. Because it contains no substantive cybersecurity measures, structures, or verifiable facts, it is generic boilerplate.


reasoning: The paragraph primarily describes who in management is responsible for cybersecurity risk management and the general qualifications and information flows supporting that responsibility, which makes it a Management Role disclosure. Its details remain generic because it does not provide qualifying firm-specific roles, named certifications, hard numbers, dates, or cybersecurity-domain specifics beyond broad boilerplate descriptions.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk from third-party service providers, especially through security certifications and breach-reporting requirements imposed on them. It contains no qualifying domain-specific cybersecurity terminology, firm-unique organizational details, or externally verifiable facts, so specificity remains Generic Boilerplate.


reasoning: The paragraph primarily describes the general purpose of the company’s cybersecurity program—protecting systems, networks, data, and information from unauthorized access, disruption, or misuse—so it best fits Risk Management Process. It contains no domain-specific cybersecurity terminology, firm-specific organizational details, or externally verifiable facts, making it Generic Boilerplate.


fact: The Company's cybersecurity policies, standards, processes, and practices are based on recognized frameworks established by the National Institute of Standards and Technology

fact: The Company's cybersecurity policies, standards, processes, and practices are based on recognized frameworks established by the International Organization for Standardization

reasoning: The paragraph primarily describes the Board's oversight role by stating that the Board is actively involved in the Company's risk management program and that cybersecurity is part of that oversight structure. Specificity rises above boilerplate because it references recognized cybersecurity frameworks from NIST and ISO, but it does not include firm-specific roles, committees, dates, numbers, or other externally verifiable facts.


fact: Mr. Lee provides cybersecurity incident and threat updates to the Board of Directors and the Audit Committee

reasoning: The paragraph primarily describes how cybersecurity information flows to the board, which is board oversight/governance. Specificity is elevated to Firm-Specific because it names a specific individual, Mr. Lee, as part of that governance process; the rest of the language is otherwise generic.


reasoning: The paragraph primarily describes how the board and its committee oversee cybersecurity, which squarely fits Board Governance. It contains only generic governance language (board oversight, delegation to the Audit Committee, management implementation) and no qualifying domain-specific, firm-specific, or externally verifiable facts.


reasoning: The paragraph primarily explains that the board oversees risk management and receives presentations on material risks, which is a board oversight disclosure. It contains only generic governance language and no qualifying cybersecurity domain terms, firm-specific roles/committees, or externally verifiable facts.


fact: The company recently obtained its second ISO 27001 certification.

fact: ISO 27001 certification is referenced.

reasoning: The paragraph primarily describes cybersecurity program activities, including control reviews, external testing, employee training, and use of third-party providers, which makes it a risk management process disclosure. Its specificity reaches Quantified-Verifiable because it includes the externally checkable claim that the company recently obtained its second ISO 27001 certification.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from vendors by conducting due diligence, periodic reviews, and imposing contractual requirements on third parties. Its details remain generic and do not include cybersecurity domain-specific terminology that passes the ERM test, firm-unique organizational facts, or externally verifiable claims.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company is not aware of cybersecurity threats that have materially affected or are likely to affect its business strategy, results of operations, or financial condition, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the remaining language is generic hypothetical impact and a cross-reference to risk factors.


reasoning: The paragraph primarily describes how the company’s incident response process operates—escalating incidents, using an internal response team, and reporting certain incidents upward—so it most directly answers what the cybersecurity program does. Its details remain generic for specificity purposes because the references to the CFO, audit committee, and incident response team are not qualifying firm-specific or verifiable facts under the rubric.


reasoning: The paragraph primarily provides a materiality-oriented assessment that cybersecurity threats have not materially affected, and are not reasonably likely to materially affect, the company's business strategy, results of operations, or financial condition; it also discusses insurance only at a high level in that same business-impact frame. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts, so the specificity is Generic Boilerplate.


fact: IT Security Steering Committee

fact: IT Security Team

fact: the Director of Information Systems and Security and the VP of Software Engineering collectively have over 40 years of experience

fact: test and monitor for vulnerabilities and threats

reasoning: The paragraph primarily explains how management is organized to oversee and administer cybersecurity, focusing on the IT Security Steering Committee, the IT Security Team, and their leadership roles and experience. Specificity reaches Quantified-Verifiable because it includes firm-specific organizational elements and a checkable claim that the two leaders collectively have over 40 years of experience.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts; the negative assertion and risk-factor cross-reference do not elevate specificity.


reasoning: This paragraph is a high-level statement of commitment and importance, but it does not describe board oversight, management roles, cybersecurity processes, third-party risk, a real incident, or a business/materiality assessment. It contains no qualifying domain-specific, firm-specific, or verifiable facts, so the specificity is Generic Boilerplate.


reasoning: The paragraph primarily gives the company's materiality assessment, stating that cybersecurity threats and prior incidents have not materially affected and are not reasonably likely to materially affect the business, operations, or financial condition, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; these are generic negative assertions about impact.


reasoning: This sentence is a high-level statement of concern about protecting information and value from cyber threats, but it does not describe any actual governance structure, management role, risk process, third-party oversight, incident, or business-impact assessment. It contains no qualifying domain-specific, firm-specific, or verifiable facts, so the specificity is Generic Boilerplate.


fact: Security program is based on ISO 27001

fact: Security program is based on NIST 800-53

fact: Security program is based on GDPR

reasoning: The paragraph primarily describes what the company's cybersecurity program does and how it operates—framework alignment, threat identification and monitoring, mitigation, and escalation—so it is best classified as Risk Management Process. Its specificity is elevated by named cybersecurity/privacy frameworks (ISO 27001, NIST 800-53, GDPR), but it does not include firm-unique roles/committees or externally verifiable quantified claims.


reasoning: The paragraph primarily describes how cybersecurity information flows from management to the Board and its audit committee, which is board oversight. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the references to the executive team, industry standards, and audit committee are generic.


reasoning: This paragraph is biographical background about Mr. Tao’s general business experience and does not substantively describe cybersecurity governance, management, processes, third-party risk, incidents, or strategy impact. Because it is non-cybersecurity content, it is classified as None/Other and defaults to Generic Boilerplate.


reasoning: The paragraph primarily describes what the company's cybersecurity program does after assessments—adjusting safeguards, monitoring and testing them, and training employees—so it is best categorized as Risk Management Process. Its wording is generic and does not include qualifying domain-specific technical terms, firm-unique structures, or externally verifiable facts, so specificity remains Generic Boilerplate.


reasoning: The paragraph primarily describes how the Board oversees cybersecurity-related risk through coordination with the Audit Committee, which is a board oversight function. It contains only generic governance language about reviewing measures to identify and mitigate risks, without domain-specific cybersecurity detail, firm-specific organizational facts that qualify, or externally verifiable claims.


reasoning: This paragraph primarily states that, as a blank check company with no operations, the company has no internal cybersecurity personnel or processes and relies on third parties, which does not describe a substantive cybersecurity program, governance structure, or actual incident. It contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, so specificity is Generic Boilerplate.


fact: The company has an Incident Response Team that includes the Senior Vice President, Finance and the General Counsel.

fact: The Senior Director, Information Technology has over twenty years of experience in information technology, security and cybersecurity.

fact: The paragraph references cybersecurity assessment and prevention, incident responses, breach notifications, and remediation.

reasoning: This paragraph is primarily about how management is organized to handle cybersecurity risk, identifying the Incident Response Team, who is on it, and the experience of the senior IT leader, so Management Role fits best. Specificity reaches Quantified-Verifiable because it includes a checkable claim that the Senior Director, Information Technology has over twenty years of relevant experience, along with firm-specific team composition and domain-specific cybersecurity terms.


fact: vulnerability management processes

fact: cybersecurity incident response processes

reasoning: The paragraph primarily explains management’s role in handling cybersecurity matters by describing how the Principal Accounting Officer is informed, collaborates with the incident response team, and participates in materiality determinations. Its specificity is elevated to Domain-Adapted by the use of cybersecurity-specific program terms such as vulnerability management and incident response, but it does not include firm-specific or externally verifiable facts.


reasoning: The paragraph primarily provides the company's conclusion about whether cybersecurity risks or prior incidents have materially affected, or are reasonably likely to materially affect, its business strategy, results, and financial condition, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the negative no-material-impact assertion is not independently verifiable.


fact: The ISO reports security incidents directly to the CISO

fact: The paragraph identifies a CISO role in the company's cybersecurity reporting structure

fact: The paragraph identifies an ISO role in the company's cybersecurity reporting structure

reasoning: This paragraph primarily describes how the Board and its audit committee oversee cybersecurity and how incident information escalates to them, which makes it Board Governance. Specificity rises to Firm-Specific because it includes company-specific cybersecurity roles in the reporting chain, notably the CISO and ISO, even though most of the governance language is otherwise generic.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from vendors and business partners, making Third-Party Risk the best fit. Its language remains high-level and generic—describing vendor assessments and policy alignment without domain-specific technical terms, firm-unique structures, or verifiable details.


fact: Chief Information Officer ("CIO") provides periodic executive-session updates to the Board on cybersecurity matters

reasoning: The paragraph primarily explains how the Board oversees cybersecurity risk through regular reviews and updates from management, which is board-level oversight. Specificity is Firm-Specific because it identifies the CIO as a named cybersecurity-relevant leadership role involved in reporting to the Board, but it does not include externally verifiable dates, numbers, or named firms.


fact: The Enterprise Risk Management Committee (ERMC) is responsible for overall risk governance and management across Tompkins

fact: The ERMC reviews minutes from the TISC meetings

reasoning: This paragraph primarily describes how management is organized to handle cybersecurity and risk oversight through the ERMC—its responsibilities, composition, chairing, and reporting line—so Management Role is the best fit. Specificity rises to Firm-Specific because it includes named internal committees (ERMC and TISC), but it does not contain hard numbers, dates, or other externally verifiable cybersecurity facts.


reasoning: The paragraph primarily addresses whether cybersecurity incidents could affect the company’s business or finances, and includes a backward-looking assertion that it has not encountered cybersecurity incidents since its IPO, which fits Strategy Integration rather than process or governance. Its language is otherwise generic and speculative, with no qualifying domain-specific terminology, firm-unique organizational facts, or externally verifiable cybersecurity details.


reasoning: The paragraph primarily states a materiality conclusion about cybersecurity incidents—namely that the company has not experienced material events and that third-party incidents have not had a material impact—so it is best classified as Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the statements are generic negative assertions and therefore remain Generic Boilerplate.


reasoning: The paragraph primarily describes how the Board would oversee cybersecurity, including delegation to a board committee or board-appointed officer, which makes this a board oversight/governance statement. Its language is generic and does not include qualifying domain-specific terminology, named firm-specific governance bodies, or verifiable facts.


reasoning: The paragraph primarily provides the company's materiality assessment of whether cybersecurity threats or prior incidents have affected or are reasonably likely to affect business strategy, operations, or financial condition, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the negative no-material-effect assertion does not elevate specificity.


fact: Senior Director - Information Security

fact: The Senior Director - Information Security has over 15 years' experience in the information technology and cybersecurity field

fact: The Senior Director - Information Security has over 15 years' experience in auditing information security

fact: Previous roles included information security architecture

fact: Previous roles included information security audit and governance

fact: Completed a CISO Academy Workshop

fact: Received a BA in math and computer science from Ohio Wesleyan University

fact: Holds an Information Systems Auditor certification

reasoning: This paragraph primarily describes the qualifications, background, and training of a specific cybersecurity leader, so it is about how management is organized and qualified rather than about the cybersecurity program itself. Specificity is Quantified-Verifiable because it includes externally checkable claims such as over 15 years of experience, a degree from Ohio Wesleyan University, and a held auditor certification.


reasoning: The paragraph primarily explains how the company addresses cybersecurity risks arising from suppliers, vendors, and service providers, making third-party risk the central topic. It remains generic boilerplate because it provides only high-level statements about relying on the Adviser's risk, legal, IT, and compliance personnel, without any qualifying domain-specific cybersecurity terminology, firm-unique structures, or verifiable facts.


reasoning: The paragraph primarily describes a component of the company’s cybersecurity risk management program—using an external party to assess its cybersecurity risk management practices—so it fits Risk Management Process rather than Third-Party Risk. It contains no qualifying domain-specific terms, firm-specific roles/committees, or externally verifiable facts, so specificity remains Generic Boilerplate.


fact: In June 2024, a cybersecurity incident occurred

fact: The incident involved CDK, a third-party provider of certain information systems used by the company

reasoning: The paragraph primarily describes an actual cybersecurity event, its operational disruption, activation of the response plan, and the company's assessment of the outcome, so Incident Disclosure is the best fit. Specificity is Quantified-Verifiable because it includes a concrete date (June 2024) and a named third party (CDK), both independently checkable facts.


fact: denial of service attacks

fact: cyber intrusions

fact: unauthorized access, destruction, disclosure, disruption and modification of information and systems

reasoning: The paragraph primarily describes the nature of cybersecurity risk and the purpose of information security activities, which fits Risk Management Process rather than governance or management structure. Its specificity is elevated above boilerplate by the use of concrete cybersecurity threat and security concepts such as cyber intrusions and denial of service attacks, but it contains no firm-unique organizational details or externally verifiable claims.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company knows of no cybersecurity incident that has had or is likely to have a material effect on its business strategy, results of operations, or financial condition, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts because the negative assertion about no material incidents is not independently verifiable.


reasoning: The paragraph primarily explains how the company addresses cybersecurity risks related to third parties, making Third-Party Risk the best fit. However, it uses only generic language about consultants, processes, and procedures without any domain-specific controls, firm-unique structures, or verifiable details, so the specificity is Generic Boilerplate.


fact: The Company's cyber risk management program is led by the Vice President of Information Systems

reasoning: The paragraph primarily describes how cybersecurity information flows to the Board and Audit Committee and how those bodies oversee cyber risk, so Board Governance is the best fit. Its specificity is elevated to Firm-Specific by the company-specific leadership role of Vice President of Information Systems; the remaining details are largely generic governance structure.


fact: Director of Information Security and Privacy leads the information security team

fact: Director of Information Security and Privacy holds CISSP (Certified Information Systems Security Professional) certification

fact: Director of Information Security and Privacy holds CCSP (Certified Cloud Security Professional) certification

fact: penetration testing

fact: email phishing test campaigns

fact: email security monitoring

fact: real-time vulnerability scanning

fact: intrusion detection

fact: information security management system

reasoning: The paragraph primarily describes what the cybersecurity program does—testing, monitoring, scanning, phishing exercises, and related security activities—so Risk Management Process is the best fit, even though it opens with management qualifications. Specificity reaches Quantified-Verifiable because it includes externally verifiable certification claims (CISSP and CCSP), along with firm-specific role detail and multiple cybersecurity domain terms.


fact: The information technology team is led by the Chief Information Officer.

fact: The company has a cybersecurity governance committee.

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity, including leadership by the CIO, the role of the IT team, and the composition and responsibilities of a management-level cybersecurity governance committee. Specificity rises to Firm-Specific because it includes firm-unique organizational facts such as the CIO leadership role and the named cybersecurity governance committee, but it does not provide externally verifiable dates, numbers, or certifications.


fact: The IT Risk and Compliance Team monitors certain IT systems controls.

fact: The IT Risk and Compliance Team reports to the VP Security.

reasoning: The paragraph primarily describes management’s organizational structure and reporting lines for cybersecurity-related oversight, especially the IT Risk and Compliance Team and its reporting to the VP Security, rather than detailing a broader cybersecurity process. Specificity is Firm-Specific because it includes a named internal team and a VP-level security role, but no externally verifiable dates, quantities, or named external firms.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks posed by vendors and business partners, making Third-Party Risk the best fit. It stays at Generic Boilerplate because it describes common vendor-risk measures in generic terms without cyber-specific domain terminology that passes the ERM test, firm-unique roles/program names, or verifiable facts.


reasoning: This sentence is a forward-looking, hypothetical risk statement about possible disruption, costs, or reputational harm rather than a substantive disclosure about governance, management, risk processes, third-party risk, incidents, or strategy. It contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, so specificity is Generic Boilerplate.


fact: The cybersecurity program is managed by the Deputy Chief Executive Officer and Chief Financial Officer.

fact: The Deputy Chief Executive Officer and Chief Financial Officer has more than seven years of operational responsibility for IT.

reasoning: This is primarily about oversight structure: the board oversees cybersecurity and management executes the program, which makes Board Governance the best fit under the governance-chain rule. Specificity reaches Quantified-Verifiable because the paragraph includes a concrete, externally checkable claim that the Deputy CEO/CFO has more than seven years of IT operational responsibility.


reasoning: The paragraph primarily states a materiality conclusion about cybersecurity incidents—namely that the company has not experienced a cyber threat or incident with a material adverse impact—so it fits Strategy Integration. Its remaining content is generic forward-looking caution and a risk-factor cross-reference, and it contains no qualifying domain, firm-specific, or externally verifiable facts.


reasoning: The paragraph primarily describes a component of the company’s cybersecurity program—using outside consultants to support assessment and improvement activities—so it is best classified as Risk Management Process rather than Third-Party Risk. Although third parties are mentioned, they are service providers to JLL’s internal program, and the language remains generic without domain-specific terms, firm-unique details, or verifiable facts.


reasoning: This is a cross-reference directing readers to the Risk Factors section and does not provide any substantive cybersecurity disclosure about governance, management, processes, incidents, third parties, or strategy. Because it contains no qualifying domain-specific, firm-specific, or verifiable facts, its specificity is Generic Boilerplate.


fact: In the fourth quarter of fiscal 2025, the company became aware of unauthorized activity on certain of its information technology systems.

fact: The company refers to the event as the "Cybersecurity Incident."

fact: The company proactively took certain systems offline as a containment measure.

fact: The incident temporarily impacted the company’s ability to fulfill and distribute customer orders.

fact: The incident affected core systems used by customers and suppliers before business operations normalized.

fact: The company states that in the fourth quarter of fiscal 2025 the incident caused reduced sales volume and increased operational costs, negatively affecting results of operations.

reasoning: This paragraph primarily describes a real cybersecurity event, the company’s response actions, operational disruption, and resulting effects, so it is best categorized as Incident Disclosure. Its specificity rises to Quantified-Verifiable because it includes a concrete time period tied to the incident and specific incident consequences, rather than only generic risk language.


reasoning: The paragraph primarily explains how the company evaluates and manages cybersecurity risks posed by vendors and other service providers, so Third-Party Risk is the best fit. It remains generic boilerplate because it describes common vendor assessment and contractual review practices without any domain-specific security terminology, firm-unique structures, or verifiable details.


fact: In the third quarter of fiscal year 2023, the company experienced a material cybersecurity incident

fact: Personal information of a significant number of individuals was accessed by an unauthorized third party

fact: The incident involved exploitation of a zero-day vulnerability

fact: The exploited weakness was in a third-party vendor's file transfer application

fact: The company recorded expenses related to investigation and remediation activities for the incident

reasoning: The paragraph primarily describes a real cybersecurity event—when it occurred, how it happened, what data was affected, and the company’s response—so Incident Disclosure is the best fit. Specificity reaches Quantified-Verifiable because it includes a time-specific incident in the third quarter of fiscal year 2023, alongside concrete incident details and the domain-specific term zero-day vulnerability.


reasoning: The paragraph primarily states a conclusion about material impact—specifically that the company has not had any material cybersecurity incidents as of the stated date—then shifts to general cautionary language about potential adverse effects, which fits Strategy Integration under the materiality rule. Its wording is otherwise generic and the dated negative assertion is not externally verifiable, so there are no qualifying specificity-elevating facts.


reasoning: The paragraph primarily provides the company's materiality assessment of cybersecurity threats and whether such threats have affected or are reasonably likely to affect its business, operations, results, or financial condition, which fits Strategy Integration. Its statements are generic and self-reported, and the risk-factor cross-references do not add domain-specific, firm-specific, or externally verifiable facts.


reasoning: This paragraph does not describe governance, management, processes, third-party risk, an actual incident, or a materiality assessment; it is a forward-looking disclaimer with a cross-reference to Risk Factors. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, its specificity is Generic Boilerplate.


fact: ransomware attack

fact: On January 18, 2023, the Company announced a ransomware attack

fact: The attack impacted certain Information Technology (IT) systems

fact: The incident resulted in the closure of fewer than 300 restaurants in one market for one day

fact: Data was taken from the company's network

fact: The affected data was limited to certain personal information of former and current employees

reasoning: This paragraph primarily describes a real cybersecurity event, including its timing, nature, operational impact, and affected data, so it is best classified as Incident Disclosure. Specificity is Quantified-Verifiable because it includes externally checkable facts such as the January 18, 2023 date and the quantified impact of fewer than 300 restaurant closures for one day.


fact: A dedicated monitoring platform provides real time threat detection and mitigation

fact: Management monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents

reasoning: The paragraph primarily describes how the company’s cybersecurity program operates—using a monitoring platform, threat detection, mitigation, and incident monitoring—so Risk Management Process is the best fit rather than Management Role. Its specificity rises above boilerplate because it includes cybersecurity-specific operational concepts, but it does not provide firm-unique named structures or externally verifiable facts.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk from service providers, so Third-Party Risk is the best fit. Although it lists vendor oversight activities, the language remains generic and does not include cybersecurity domain terms that pass the ERM test, firm-specific organizational details, or verifiable facts.


reasoning: The paragraph is centrally about how the company manages cybersecurity risk from vendors, which squarely fits Third-Party Risk. Its language remains generic—vendor risk assessments, cybersecurity controls, and compliance monitoring are described at a high level without domain-specific technical terms, firm-unique structures, or verifiable details.


reasoning: The paragraph primarily describes how the board oversees cybersecurity risk, including direct oversight by the full board and delegation through a board committee, which makes Board Governance the best fit. Its language is generic and does not include qualifying domain-specific cybersecurity terminology, firm-specific roles beyond excluded generic governance bodies, or externally verifiable facts.


reasoning: The paragraph primarily describes the company's cybersecurity risk assessment activities and methodology, which makes it a Risk Management Process disclosure. However, it uses generic risk-management language without cybersecurity-specific domain terms, firm-unique organizational details, or verifiable facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company has not identified cybersecurity threats that have materially affected or are reasonably likely to materially affect its business strategy, results of operations, or financial condition, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the statements are generic and include non-verifiable negative assertions and a cross-reference to risk factors.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats or incidents have not materially affected the company's strategy, results of operations, or financial condition, which fits Strategy Integration under the materiality rule. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the negative assertion is self-reported and not independently verifiable.


fact: Internal and external asset identification procedures

fact: Asset monitoring and classification procedures

reasoning: The paragraph primarily describes what the cybersecurity program does—identifying, assessing, monitoring, and classifying assets to evaluate and mitigate cyber risk—so it fits Risk Management Process. Its specificity is Domain-Adapted because it includes cybersecurity asset-management concepts beyond generic risk language, but no firm-specific roles, committees, or verifiable facts.


reasoning: The paragraph primarily provides the company's conclusion that cybersecurity risks and prior incidents have not materially affected, and are not reasonably likely to materially affect, its business strategy, results of operations, or financial condition, which makes it a Strategy Integration disclosure. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the remainder is generic cautionary language and a cross-reference to risk factors.


reasoning: The paragraph primarily describes what the company's cybersecurity program does—maintaining policies, controls, and assessments to identify and manage cyber risk—so it fits Risk Management Process. However, it uses generic process language without cybersecurity-domain terminology, firm-specific organizational details, or externally verifiable facts, so specificity is Generic Boilerplate.


reasoning: The paragraph primarily states a materiality conclusion that cybersecurity incidents have not materially affected, and are not reasonably likely to materially affect, the company's business strategy, results of operations, or financial condition, which fits Strategy Integration. The remaining statements about updating systems and educating personnel are generic and do not add domain-specific, firm-specific, or externally verifiable facts.


fact: The management team's experience includes industry-recognized certifications such as CISSP

fact: The management team's experience includes industry-recognized certifications such as CISM

fact: The management team's experience includes industry-recognized certifications such as CISA

reasoning: The paragraph primarily explains management’s cybersecurity responsibilities and qualifications, so it is about how management is organized and equipped to handle cybersecurity. Specificity reaches Quantified-Verifiable because it states that management holds named certifications (CISSP, CISM, CISA), which are externally checkable; the remaining references to experience and prior employers are more general.


reasoning: The paragraph primarily provides a materiality/business-impact assessment, stating that cybersecurity threats and any previous incidents have not materially affected the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration. Its other content is a generic risk reference and a negative self-assessment, neither of which adds qualifying domain, firm-specific, or externally verifiable facts.


fact: The Enterprise Risk and Compliance Committee of the Company's Board of Directors (the "ERC Committee") receives material findings, notable weaknesses, and suggestions.

reasoning: The paragraph primarily explains how cybersecurity-related information is escalated to a board-level committee, so it is about board oversight. Its specificity is Firm-Specific because it names the company's board committee, the Enterprise Risk and Compliance Committee (ERC Committee), which is a company-distinguishing governance detail.


fact: CISO

fact: threat intelligence briefings

fact: FedEx Executive Committee

fact: DTRC

fact: CyTOC

reasoning: The paragraph primarily describes oversight and escalation flows for cybersecurity risk and incidents from management up to the Executive Committee, DTRC, CyTOC, and the full Board, which makes Board Governance the best fit. Specificity rises to Firm-Specific because it includes company-distinct governance elements and roles such as the CISO, DTRC, CyTOC, and FedEx Executive Committee, along with the domain-specific term 'threat intelligence briefings.'


reasoning: The paragraph is primarily about how the company manages cybersecurity risk from third-party service providers, especially through contract review and renewal requirements, so Third-Party Risk is the best fit. It does not include qualifying domain-specific technical terms, firm-unique organizational details, or externally verifiable facts, so specificity remains Generic Boilerplate.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats and prior incidents have not materially affected and are not reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration. Its remaining content is generic cautionary language and a cross-reference, and it contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts.


fact: The Board has delegated oversight responsibility for cybersecurity risks to the Board's Technology Committee.

reasoning: This paragraph primarily explains how the board oversees cybersecurity risk, including delegation from the full Board to a board-level committee, which makes it Board Governance. Its specificity is Firm-Specific because it identifies the Board's Technology Committee, a named board committee unique enough to distinguish the company's governance structure.


fact: Cleco's CSIRPs (Cybersecurity Incident Response Plans)

fact: detection

fact: analysis

fact: containment

fact: eradication

fact: recovery

fact: post-incident review

reasoning: The paragraph primarily describes what Cleco's cybersecurity response program does—its incident response workflow and escalation process—so it is best categorized as Risk Management Process rather than Board Governance. Specificity rises to Firm-Specific because it includes the company-specific CSIRPs program name, along with several cybersecurity response-stage domain terms.


reasoning: The paragraph primarily describes the company's general approach to handling cybersecurity risk—identifying and mitigating threats—so it fits Risk Management Process. It contains no qualifying domain-specific technical terms, firm-specific organizational details, or externally verifiable facts, so specificity is Generic Boilerplate.


reasoning: This paragraph is a standard forward-looking statements disclaimer describing legal cautionary language and cross-referencing risk factors, not a substantive cybersecurity disclosure. Because it contains no qualifying cybersecurity domain terms, firm-specific cyber governance details, or verifiable cyber-related facts, specificity is Generic Boilerplate.


reasoning: The paragraph is primarily about cyber risk arising from third-party service providers and the company's monitoring of those provider-related risks, so Third-Party Risk is the best fit. It remains generic boilerplate because it provides no cybersecurity-specific domain detail, no firm-specific organizational facts, and no externally verifiable claims.


reasoning: This paragraph is primarily regulatory/contextual and includes a cross-reference to another section, rather than describing the company's cybersecurity governance, management, process, third-party risk, incident details, or business impact. Under the annotation rules, such non-substantive/cross-reference content is classified as None/Other, which therefore receives Generic Boilerplate specificity.


fact: The cybersecurity program is under the Chief Information Officer (CIO) and led by the Chief Information Security Officer (CISO).

fact: The CIO has over 20 years of experience managing and securing global enterprises.

fact: The CISO has over 20 years of experience managing and securing global enterprises.

reasoning: The paragraph primarily describes the oversight chain for cybersecurity—Board delegation to the Audit Committee and updates from the CIO/CISO—so Board Governance is the best fit. Specificity reaches Quantified-Verifiable because it includes named cybersecurity leadership roles and verifiable claims that both the CIO and CISO have over 20 years of relevant experience.


reasoning: The paragraph primarily gives a materiality-oriented conclusion that the company has not experienced a cybersecurity threat that has materially affected it, which fits Strategy Integration under the negative-assertion rule. Its remaining content is a cross-reference to risk factors, and it contains no qualifying domain-specific, firm-specific, or externally verifiable facts that elevate specificity above boilerplate.


fact: The Company has designated the Chief Risk Officer as the Chief Privacy Officer

fact: The Chief Privacy Officer coordinates with the Chief Information Security Officer

fact: The Chief Privacy Officer provides periodic reports to the Board's Risk Oversight Committee

fact: The Chief Privacy Officer reports on the status of the Company's Information Security Program

fact: The Chief Information Security Officer is responsible for day-to-day management of the Information Security Program and Security Incident Response Policy and Plan

fact: The Chief Privacy Officer previously served as the Company's Chief Financial Officer for over 13 years

fact: The Chief Information Security Officer has over 20 years of work experience in cybersecurity at financial institutions

reasoning: This paragraph is primarily about how management is organized to handle cybersecurity, describing the roles, responsibilities, reporting relationships, and qualifications of the Chief Privacy Officer and Chief Information Security Officer. Specificity is Quantified-Verifiable because it includes checkable tenure and experience claims ('over 13 years' and 'over 20 years'), in addition to firm-specific role and committee details.


reasoning: The paragraph primarily provides a materiality assessment, stating that known cybersecurity risks and prior incidents have not materially affected and are not reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the negative assertion about lack of material effect is not independently verifiable, and the cross-reference to Risk Factors does not elevate specificity.


reasoning: This paragraph is primarily a generic risk/disclaimer statement about potential cyberattacks and includes a cross-reference to Risk Factors, rather than describing governance, management, processes, third-party risk management, a real incident, or a materiality assessment conclusion. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, its specificity is Generic Boilerplate.


reasoning: This paragraph is primarily a cross-reference to risk factors and a generic statement that cybersecurity threats may materially affect the company or its vendors, without describing governance, management, processes, third-party oversight, a real incident, or a materiality assessment conclusion. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable facts, its specificity is Generic Boilerplate.


reasoning: The paragraph primarily provides a materiality-oriented assessment that prior cybersecurity incidents did not materially affect operations, strategy, financial condition, or results of operations, which fits Strategy Integration rather than Incident Disclosure. It contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts; the dated reporting period and negative no-material-impact assertion do not elevate specificity.


fact: Management's Technology Steering Committee is responsible for overseeing the Company's cybersecurity risk management processes.

reasoning: The paragraph primarily describes the board-level oversight structure for cybersecurity, including delegation to committees, which makes Board Governance the best fit. Its specificity rises to Firm-Specific because it names the Technology Steering Committee, a non-generic internal committee unique enough to distinguish the company's governance structure.


reasoning: The paragraph primarily describes the Board of Directors' oversight responsibility for cybersecurity risk, which squarely fits Board Governance. It contains no qualifying domain-specific terminology, firm-unique governance details, or externally verifiable facts beyond generic board oversight language.


reasoning: The paragraph primarily describes elements of the company’s cybersecurity program—its incident response planning and employee training—so it fits Risk Management Process. However, the language is generic and does not include cybersecurity-specific domain terms that pass the ERM test, firm-unique organizational details, or externally verifiable facts.


fact: The Company has an Information Security Officer role

fact: The Company has a Chief Information Officer role

reasoning: The paragraph primarily describes management responsibility and organization by identifying which officers are tasked with cybersecurity-related training, so it fits Management Role. Specificity is Firm-Specific because it names company roles (Information Security Officer and Chief Information Officer), but includes no externally verifiable dates, numbers, or certifications.


reasoning: This paragraph is primarily regulatory/contextual and cross-referential rather than describing the company’s board oversight, management organization, cybersecurity processes, third-party risk, incident details, or strategy impact. Under the rules, None/Other paragraphs are assigned Generic Boilerplate specificity.


fact: The company states it has a CISO who is primarily responsible for leading cybersecurity strategy centrally at Roivant and most of its Vants.

reasoning: The paragraph primarily describes management organization and responsibility by identifying the CISO as the leader of cybersecurity strategy, which is a management-role disclosure rather than a process description. Specificity rises to Firm-Specific because it includes a firm-unique cybersecurity leadership role (CISO), but it does not provide verifiable numbers, dates, certifications, or named outside firms.


fact: regularly scanning our environment for vulnerabilities

fact: performing penetration testing

reasoning: The paragraph primarily describes what the company’s cybersecurity program does to identify and assess cyber risk, so it is best categorized as Risk Management Process. Its specificity is elevated by concrete cybersecurity practices—vulnerability scanning and penetration testing—but it does not include firm-unique roles, committees, or externally verifiable facts.


fact: threat actors target employees to gain unauthorized access to information systems

fact: information security and data privacy training

fact: phishing attempt

fact: phishing security test

reasoning: The paragraph primarily describes elements of the company's cybersecurity program—employee awareness training and phishing simulation testing—so it fits Risk Management Process rather than Third-Party Risk, since the vendor is only a delivery mechanism. Specificity is Domain-Adapted because it includes cybersecurity-specific concepts such as threat actors, unauthorized access, and phishing tests, but no firm-specific roles, named programs, or externally verifiable claims.


fact: utilize third-party risk monitoring security rating services

reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from vendors and external technology/services, making Third-Party Risk the best fit. Specificity rises above boilerplate because it mentions the cyber-specific practice/tool category of security rating services, but it does not provide firm-unique names, numbers, dates, or other externally verifiable details.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks posed by third-party service providers, making Third-Party Risk the best fit. Its language remains generic and process-oriented (initial assessments, further review, contracting rights and responsibilities) without domain-specific technical terms, firm-unique organizational details, or externally verifiable facts.


reasoning: This paragraph is primarily a generic risk statement about potential cybersecurity harms and hypothetical impacts rather than describing governance, management, processes, third-party oversight, an actual incident, or a materiality assessment conclusion. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable facts under the rubric, its specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes how cybersecurity information is escalated to a board-level committee for oversight, which makes it a Board Governance disclosure. It contains no qualifying domain-specific terminology, firm-specific roles or structures beyond the generic Audit Committee, or externally verifiable facts, so specificity is Generic Boilerplate.


fact: In August 2020, the company discovered ransomware on a server.

fact: ransomware

reasoning: The paragraph primarily describes a real cybersecurity incident—when it was discovered, what type of attack occurred, and how the company responded—so it is best classified as Incident Disclosure. Specificity reaches Quantified-Verifiable because it includes a concrete, externally checkable time marker ('In August 2020') tied to the incident, and also uses the cybersecurity-specific term 'ransomware.'


fact: The cybersecurity program is overseen by the IT Steering Committee.

fact: The paragraph references continuous cyber monitoring.

fact: The paragraph references reported vulnerabilities.

fact: The paragraph references trend analysis on attack vectors.

reasoning: The paragraph primarily explains what the cybersecurity program does—identifying, monitoring, mitigating, and evaluating cyber risks, including monitoring and threat/vulnerability analysis—so it is best classified as Risk Management Process. Specificity reaches Firm-Specific because it includes a named internal body, the IT Steering Committee, and also uses cybersecurity-specific terms such as vulnerabilities and attack vectors.


fact: The company assigns third-party cyber threat monitoring responsibilities to its Cybersecurity Program Manager

reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party service providers and vendors, so Third-Party Risk is the best fit. Its specificity rises above boilerplate because it identifies a firm-specific role, the Cybersecurity Program Manager, but otherwise uses largely generic vendor risk language without verifiable metrics or dates.


reasoning: This fragment primarily describes responsibility areas—overseeing implementation of cybersecurity policies and promoting organizational commitment—rather than detailing the cybersecurity program itself or board-level oversight. It contains no qualifying domain-specific terminology, firm-unique roles or committees, or externally verifiable facts, so specificity is Generic Boilerplate.


fact: unauthorized access to information systems affecting the confidentiality, integrity, or availability of systems or related information

fact: malicious computer viruses

fact: insider risk

fact: threat actors increasing their use of AI and machine-learning technologies

reasoning: The paragraph primarily describes the company's cybersecurity risk landscape and the nature of cyber threats to its systems, which fits best under Risk Management Process rather than governance, management organization, or incident disclosure. Its specificity is Domain-Adapted because it includes cybersecurity-specific concepts such as confidentiality/integrity/availability, ransomware, insider risk, and AI-enabled threat activity, but no firm-specific or externally verifiable facts.


fact: The Company engaged a third party to conduct phishing tests

fact: The Company engaged a third party to conduct penetration tests

fact: Vice President of Information Technology is involved in most risk-related activities

reasoning: The paragraph primarily describes cybersecurity program activities—testing by a third party and resulting process/tool improvements—so it is best categorized as Risk Management Process rather than Third-Party Risk or Management Role. Specificity reaches Firm-Specific because it includes a VP-level IT role; the phishing and penetration testing references also add domain-adapted detail.


fact: The Senior Director of Information Technology has experience in roles responsible for securing networks and application systems

fact: security assessments

reasoning: The paragraph primarily explains which members of management handle cybersecurity responsibilities, their duties, and escalation roles, so it is mainly about management organization rather than the underlying cybersecurity program. Specificity rises above boilerplate because it includes cyber-domain language such as securing networks and application systems and reviewing security assessments, but it does not include qualifying firm-specific or externally verifiable facts.


reasoning: The paragraph primarily provides a materiality assessment that no cybersecurity incidents materially affected, or are reasonably likely to materially affect, the company, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts, so specificity is Generic Boilerplate.


reasoning: The paragraph is general background and cautionary language about dependence on information systems and exposure to cyber threats, not a description of governance, management roles, risk processes, third-party oversight, strategy/materiality assessment, or a specific incident. Because it is classified as None/Other, its specificity is Generic Boilerplate.


fact: The company has a CISO involved in reviewing and managing cybersecurity policies and processes.

fact: The company has a Security Steering Committee involved in reviewing and managing cybersecurity policies and processes.

fact: Senior executives including the CTO participate in reviewing and managing cybersecurity policies and processes.

fact: The CISO receives prompt communication from the CSIRT regarding incident severity, impact, and status during incident handling.

fact: The CISO receives prompt communication from the PSIRT regarding incident severity, impact, and status during incident handling.

reasoning: The paragraph primarily explains how management is structured to oversee and handle cybersecurity—identifying the CISO, a management-level Security Steering Committee, and reporting flows from internal response teams. Specificity is Firm-Specific because it names company-specific roles, a named committee, and named teams (CSIRT and PSIRT), but does not include externally verifiable numbers, dates, or certifications.


fact: Uses proactive detection tools to safeguard assets and identify threats within its environment

reasoning: The paragraph primarily describes what the company’s cybersecurity program does—using external testing and consultations plus technology tools to evaluate and improve its defenses—so it is best categorized as Risk Management Process rather than Third-Party Risk. Specificity rises above boilerplate because it mentions a cybersecurity-specific practice/tool category ('proactive detection tools'), but it does not provide firm-unique roles, named systems, or externally verifiable details.


fact: System and Organizational Control (SOC) type reports are required from service providers

reasoning: The paragraph primarily describes what the company's cybersecurity program does to identify and mitigate risk, so Risk Management Process fits better than Third-Party Risk even though vendors are mentioned. Specificity rises above boilerplate because it references SOC-type reports, a cybersecurity/compliance artifact that reflects domain-specific knowledge, but it includes no firm-unique roles, committees, or externally verifiable facts.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors rather than describing cybersecurity governance, management, processes, third-party risk management, incidents, or strategy impacts itself. Because it contains no substantive cybersecurity measure or concrete qualifying fact, it is generic boilerplate.


fact: routine external and internal penetration testing of information systems

fact: emulate the common tactics and techniques of cyber threat actors

fact: processes to remediate identified vulnerabilities across a wide range of severities

reasoning: The paragraph is primarily about how the company manages cybersecurity risk from third-party service providers, with supporting detail on onboarding assessments, contractual terms, and ongoing reviews; the penetration-testing and insurance references are secondary. Specificity rises above boilerplate because it uses cybersecurity-specific terminology such as penetration testing, threat-actor tactics and techniques, and vulnerability remediation, but it does not include firm-unique roles/committees or externally verifiable facts.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats have not materially affected the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration. Its specificity is Generic Boilerplate because it contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the negative assertion and risk-factor cross-reference do not elevate specificity.


fact: In February and April 2025, Microsoft notified the Company about unauthorized activity

fact: Microsoft notified the Company about the activity

fact: The unauthorized activity occurred within the Company's Azure environment

fact: The activity was attributed to a suspected nation-state threat actor

fact: The Company immediately activated its incident response plan

fact: The Company issued security advisories

fact: The Company implemented enhanced rotation of credentials

fact: The Company strengthened security monitoring

reasoning: The paragraph primarily describes an actual cybersecurity event, including when it was identified, what happened in the Azure environment, and how the company responded, so Incident Disclosure is the best fit. Specificity is Quantified-Verifiable because it includes externally checkable facts such as the February and April 2025 timing, Microsoft as the notifying party, and the named Azure environment, along with cyber-specific response details.


reasoning: The paragraph primarily explains how the company addresses cybersecurity risks involving third-party vendors, customers, and external technology systems, so Third-Party Risk is the best fit. Its descriptions remain generic and do not include domain-specific technical terms, firm-unique structures, or verifiable details, so the specificity is Generic Boilerplate.


reasoning: The paragraph primarily explains how the board, through the audit committee, oversees cybersecurity and receives information from management, which makes it a board governance disclosure. It contains only generic oversight language and excluded generic roles/committees (audit committee, CFO), with no qualifying domain-specific, firm-specific, or externally verifiable facts.


fact: Senior Director, Information Protection & Compliance participates in providing cybersecurity-focused briefings

fact: CIO participates in providing cybersecurity-focused briefings

fact: management committee on cybersecurity

reasoning: The paragraph primarily describes how cybersecurity information is reported to the Audit and Finance Committee and Board of Directors, so it is about board oversight rather than management’s operational role. Its specificity is Firm-Specific because it includes company-specific governance actors and structure, including the Senior Director, Information Protection & Compliance, the CIO, and a management committee on cybersecurity.


reasoning: The paragraph primarily provides a materiality assessment, stating that known cybersecurity threats are not reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration. It does not include cybersecurity domain terminology, firm-specific organizational details, or externally verifiable facts, so the specificity remains Generic Boilerplate.


fact: malware detection

fact: phishing simulations

reasoning: The paragraph primarily describes activities within the company’s cybersecurity program—training, simulations, and preparedness testing—so it fits Risk Management Process. Its specificity rises above boilerplate because it uses cybersecurity-specific practices such as malware detection and phishing simulations, but it does not include firm-unique or externally verifiable details.


reasoning: This paragraph primarily explains that the company is a SPAC with no operating business and therefore has not adopted a cybersecurity program; it does not provide substantive cybersecurity governance, management, or process detail. Under the no-operations/SPAC rule, this is None/Other, and with no qualifying domain, firm-specific, or verifiable cybersecurity facts, specificity is Generic Boilerplate.


reasoning: This paragraph is a generic statement that the company faces cybersecurity risks and primarily serves as a cross-reference to the risk factors section, without describing governance, management, processes, third-party risk, incidents, or strategy impacts. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, it is Generic Boilerplate.


fact: In December 2022, the Company learned of a cybersecurity threat to its information technology system

fact: Certain data, including personal data of employees, had been extracted from the Company's IT System

reasoning: This paragraph primarily describes an actual cybersecurity event, including when it was discovered, what occurred, and the company's response, so it is an Incident Disclosure. Specificity is Quantified-Verifiable because it contains a concrete date tied to a real incident and other event-specific facts about data extraction.


reasoning: The paragraph primarily provides a materiality assessment that known cybersecurity threats and prior incidents have not materially affected the company's operations, strategy, results, or financial condition, which fits Strategy Integration under the materiality rule. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the negative assertion about no material effect is not independently verifiable, so specificity remains Generic Boilerplate.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and service providers, so Third-Party Risk is the best fit. Its language remains high-level and generic—describing vendor assessments, tiering, questionnaires, and incident procedures without cybersecurity-specific technical terms, named frameworks, firm-specific roles/programs, or verifiable details.


reasoning: The paragraph is primarily about how the company oversees cybersecurity risks posed by outside service providers, so Third-Party Risk is the best fit. Its language remains generic—unnamed providers, generic due diligence, monitoring, communication, and incident response protocols—without domain-specific technical terms, firm-unique structures, or verifiable facts that would raise specificity.


reasoning: The paragraph primarily describes how the company manages cybersecurity risk from third-party service providers through diligence and contractual requirements, making Third-Party Risk the best fit. However, it uses generic vendor-risk language without cybersecurity-specific technical terms, firm-unique details, or verifiable facts, so specificity is Generic Boilerplate.


fact: The Board has delegated oversight of cybersecurity risks to the Audit Review Committee of the Board of Directors ("ARC").

fact: The ARC reviews the Company's cybersecurity risks, controls and procedures, mitigation plans, and response/remediation capability.

reasoning: The paragraph primarily explains how the board oversees cybersecurity, including delegation of oversight and reporting flow through a board committee, which makes Board Governance the best fit. Specificity is elevated to Firm-Specific by the named board committee 'Audit Review Committee (ARC)' and its described oversight role, but the paragraph contains no externally verifiable dates, quantities, or certifications.


reasoning: This paragraph is primarily a no-operations/SPAC disclaimer stating the company has no cybersecurity program, no significant current cyber risk, and no incidents, rather than describing a substantive governance, management, or risk process. Under the SPAC/no-operations rule, this is None/Other, and because it contains no qualifying domain-adapted, firm-specific, or externally verifiable cybersecurity facts, specificity is Generic Boilerplate.


reasoning: The paragraph primarily explains how the Board of Directors is informed about and oversees cybersecurity risk through briefings, dialogue, strategic involvement, and annual review, which makes Board Governance the best fit. It does not include qualifying domain-specific technical terms, firm-specific cybersecurity roles/committees, or externally verifiable facts that would elevate specificity above generic boilerplate.


fact: personally identifiable information (PII)

reasoning: The paragraph is primarily about how the company manages cybersecurity risks posed by vendors, making Third-Party Risk the best fit. Specificity rises above boilerplate because it identifies a cyber/privacy-specific data category—personally identifiable information—though the rest of the language is otherwise fairly generic.


fact: On April 28, 2023, the company identified that a payment was incorrectly made to an unauthorized payee

fact: The incorrect payment amount was $54,300

fact: The event resulted from a phishing attack

fact: Management investigated the matter at the direction of the board of directors and concluded the phishing attack was an isolated incident perpetrated by an external source

fact: With assistance from its bank, the company recovered all of the funds on June 29, 2023

fact: After the incident, the company implemented additional controls related to vendor verification and additional payment review procedures by several authorized individuals

reasoning: This paragraph primarily describes a real cybersecurity event, including what happened, when it was discovered, the investigation, recovery, and remediation, so it is Incident Disclosure. Specificity is Quantified-Verifiable because it includes externally checkable facts such as exact dates and the $54,300 payment amount.


fact: Many of the Company's IT systems operate with a hosted architecture

fact: The paragraph discusses third-party IT environments

reasoning: The paragraph primarily explains dependence on vendors and how the company monitors vendors handling sensitive data, so the central question answered is how third-party cyber risk is managed. Specificity rises above boilerplate because it uses technical IT/cyber concepts such as hosted architecture and third-party IT environments, but it provides no firm-unique roles, committees, dates, numbers, or other verifiable details.


fact: The Company's IT Lead has 5 years of experience in roles that include oversight of cybersecurity risk management programs.

reasoning: The paragraph primarily explains who in management is responsible for implementing cybersecurity processes and describes that person's experience, which makes it a management-organization disclosure rather than a process description. Specificity reaches Quantified-Verifiable because it includes a concrete, externally checkable claim that the IT Lead has 5 years of relevant experience.


fact: team of information security professionals leading enterprise-wide cybersecurity strategy, risk management, cyber defense, software security, security monitoring and related functions

fact: Chief Information Security Officer (CISO) oversees the information security team

fact: CISO reports to the Chief Information Officer (CIO)

fact: CISO works with the Chief Legal Officer

fact: cyber defense

fact: software security

fact: security monitoring

fact: The CISO has over 30 years of experience in cybersecurity and intelligence

fact: The CISO's experience includes service with the Department of Defense

fact: The CISO's experience includes the defense contracting community and publicly traded companies

fact: The CISO holds a CIO Program Certificate from the College of Information and Cyberspace, National Defense University

fact: The CISO maintains a Certified Information System Security Professional (CISSP) designation

fact: The CISO maintains a Certified Information Privacy Professional (CIPP) designation

reasoning: This paragraph primarily describes how management is organized to handle cybersecurity, focusing on the security team, the CISO’s reporting line, and the CISO’s qualifications, so Management Role is the best fit. Specificity is Quantified-Verifiable because it includes externally checkable claims such as the CISO having over 30 years of experience and holding named credentials including CISSP and CIPP.


fact: 24x7 Security Operations Center (SOC)

fact: Security Information and Event Management (SIEM) systems

reasoning: The paragraph primarily describes cybersecurity program operations—continuous monitoring and real-time threat response—so it fits Risk Management Process. Specificity is elevated by the firm-specific claim that the company has a 24x7 SOC, and also by the domain-specific reference to SIEM systems.


fact: penetration testing

fact: forensic analysis

fact: NIST framework

fact: Global Corporate Continuity Program

reasoning: The paragraph primarily explains how the company identifies, assesses, and monitors cybersecurity risks arising from third parties such as vendors and service providers, so Third-Party Risk is the best fit. Specificity rises above boilerplate through cybersecurity-specific terms like penetration testing and NIST, and reaches Firm-Specific because it names the company's Global Corporate Continuity Program.


reasoning: This paragraph is primarily a cross-reference to Risk Factors and a generic statement that the company faces cybersecurity and data leakage risks, without describing governance, management, processes, third-party risk, incidents, or a materiality assessment. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable facts, its specificity is Generic Boilerplate.