content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is only a cross-reference directing readers to another section for risk discussion and does not itself describe cybersecurity governance, management, processes, third-party risk, incidents, or strategy impacts. Because it contains no substantive cybersecurity facts, its specificity is Generic Boilerplate.

provider: openai

stage: benchmark


reasoning: This paragraph is only a cross-reference incorporating another section by reference and does not itself describe cybersecurity governance, management, processes, third-party risk, incidents, or strategy impacts. Because it contains no qualifying domain, firm-specific, or verifiable cybersecurity facts, its specificity is Generic Boilerplate.


reasoning: This paragraph is primarily a cautionary statement and cross-reference to risk factors rather than a substantive description of governance, management, risk processes, third-party risk, incidents, or strategy impacts. It contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, so specificity remains Generic Boilerplate.


reasoning: This paragraph is a cross-reference directing readers to the Risk Factors section for more information, rather than describing cybersecurity governance, management, processes, third-party risk, an actual incident, or a business impact assessment. Because it contains no substantive cybersecurity disclosure and None/Other paragraphs are treated as boilerplate, the specificity is Generic Boilerplate.


content_category: Third-Party Risk

reasoning: The paragraph is primarily about how the company is addressing cybersecurity risks from third-party service providers, making Third-Party Risk the best fit. Its language is generic and does not include qualifying domain-specific technical terms, firm-unique organizational details, or externally verifiable facts, so specificity is Generic Boilerplate.


content_category: Board Governance

fact: The CIO reports on cybersecurity matters to the General Counsel, Chief Accounting Officer, Chief Financial Officer, Chief Executive Officer, and the Audit Committee.

fact: The Board of Directors oversees cybersecurity risks in coordination with management and the Audit Committee, and the full Board has access to Audit Committee cybersecurity presentations.

specificity_confidence: medium

reasoning: The paragraph primarily explains how the board oversees cybersecurity, including the reporting flow from management to the Audit Committee and full Board, so Board Governance is the best fit. Specificity rises to Firm-Specific because it includes a firm-specific senior cybersecurity/IT role (the CIO) and a concrete internal reporting structure, but no externally verifiable dates, numbers, or named third-party firms.


content_category: Strategy Integration

category_confidence: medium

reasoning: The paragraph primarily addresses whether cybersecurity incidents have affected or could affect the company’s business, financial condition, liquidity, and results of operations, which fits Strategy Integration. Its statements are generic and largely speculative, and the negative assertion that no material incidents have occurred to date is not externally verifiable, so no qualifying specificity-elevating facts are present.


reasoning: The paragraph primarily provides a materiality/business-impact assessment by stating that past cybersecurity incidents have not materially affected the company or its financial condition and results, which fits Strategy Integration. It does not include qualifying domain-specific terminology, firm-specific organizational details, or externally verifiable facts, so specificity remains Generic Boilerplate.


fact: Vice-President of Information Technology ("VPIT") presents cybersecurity topics to the Board

fact: Director - Information Security ("DIS") presents cybersecurity topics to the Board

reasoning: The paragraph primarily describes how cybersecurity information reaches the board and how the board is educated on cybersecurity matters, which is board oversight. Specificity is elevated to Firm-Specific because it names company-specific cybersecurity/IT leadership roles (VPIT and DIS), but it includes no externally verifiable quantified claim.


content_category: Incident Disclosure

fact: In 2017, the company experienced a material cybersecurity incident.

fact: The incident followed a criminal attack on the company's systems.

fact: The incident involved the theft of personal information of U.S., Canadian and U.K. consumers.

reasoning: The paragraph is primarily anchored on a real cybersecurity event that occurred in 2017 and describes its nature and scope, so it is best classified as Incident Disclosure rather than a purely hypothetical risk statement. Specificity is Quantified-Verifiable because it includes an externally checkable year and concrete details about the incident and affected consumer populations.


reasoning: The paragraph is a high-level statement of commitment to protecting IT assets, data, intellectual property, and products, but it does not describe any actual governance structure, management role, risk management activity, third-party oversight, incident, or business impact assessment. Because it contains no qualifying domain-specific, firm-specific, or verifiable facts, its specificity is Generic Boilerplate.


reasoning: The paragraph primarily describes oversight responsibilities—reviewing regulatory examination reports, findings, and emerging information security issues—which fits board-level cybersecurity governance. It does not include qualifying domain-specific cybersecurity terminology, firm-unique roles/committees, or externally verifiable facts, so specificity remains generic boilerplate.


fact: The company manages third-party cyber risk through a named Third-Party Risk Management (TPRM) program.

reasoning: The paragraph is primarily about how the company manages cybersecurity risks posed by vendors and other external service providers, so Third-Party Risk is the best fit. Its specificity rises above boilerplate because it identifies a named internal program, the Third-Party Risk Management (TPRM) program, but does not provide externally verifiable numbers, dates, or named outside firms.


content_category: Management Role

fact: The company has an Enterprise Cybersecurity Management Review Group (Enterprise Cybersecurity MRG) that functions as a steering committee for the enterprise cybersecurity program.

fact: The Enterprise Cybersecurity MRG is composed of senior leaders with cross-functional responsibilities.

fact: The Enterprise Cybersecurity MRG meets with the Chief Information Security Officer to review the enterprise cybersecurity program and related risks.

reasoning: The paragraph primarily explains how management is organized to handle cybersecurity through a named management steering committee, its composition, responsibilities, and interaction with the CISO, so Management Role fits best. Specificity is Firm-Specific because it includes a named internal committee and a named cybersecurity leadership role, but no externally verifiable numbers, dates, certifications, or named outside firms.


fact: The Board of Directors oversees cybersecurity through a Cybersecurity Committee.

reasoning: The paragraph primarily explains how the board oversees cybersecurity risk—specifically that oversight is conducted through the Board's Cybersecurity Committee—so Board Governance is the best fit. Specificity rises to Firm-Specific because it names a non-generic internal committee, while the rest of the language is otherwise largely generic and the materiality statement is not externally verifiable.


fact: On June 13, 2023, Brunswick disclosed an IT security incident

fact: Normal global business operations resumed over the course of nine days following the incident

type: quantified

fact: The incident resulted in estimated lost revenue of approximately $80 million to $85 million

fact: The incident resulted in estimated operating earnings impact of $35 million to $40 million

reasoning: The paragraph primarily describes an actual cybersecurity event, the company’s response, operational disruption, and recovery timeline, so it is best classified as Incident Disclosure. Its specificity is Quantified-Verifiable because it includes a precise incident date and concrete, externally checkable numerical impacts and duration figures.


reasoning: The paragraph provides only generic background about being a target of cyber threats due to handling personal information; it does not describe oversight, management roles, a cybersecurity program, third-party risk management, a real incident, or a materiality/business-impact assessment. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts, so specificity remains Generic Boilerplate.


content_category: Risk Management Process

reasoning: The paragraph primarily describes what the company’s cybersecurity program does—risk assessments, security controls, training, incident response, and use of outside assistance—so it is best categorized as Risk Management Process. Although it mentions third-party service providers and vendors, those are presented as components of the broader program, and the language remains generic without domain-specific technical terms, firm-unique roles, or verifiable facts.


reasoning: The paragraph’s primary substantive disclosure is the conclusion that, as of the stated date, the company is not aware of cybersecurity incidents that have materially affected or are reasonably likely to materially affect its business, results, or financial condition, which is a Strategy Integration materiality assessment. The rest of the paragraph is high-level, generic cybersecurity governance and process language without qualifying domain-specific, firm-specific, or externally verifiable facts for specificity purposes.


fact: The Company identifies its CISO as one of the management members primarily responsible for assessing and managing cybersecurity risks.

fact: The Company identifies its Chief Information and Technology Officer as one of the management members primarily responsible for assessing and managing cybersecurity risks.

reasoning: This paragraph primarily answers how management is organized to handle cybersecurity by identifying which executives are responsible for assessing and managing cyber risk. Its specificity is Firm-Specific because it names company-specific cybersecurity leadership roles (CISO and Chief Information and Technology Officer), but includes no externally verifiable dates, numbers, or certifications.


fact: cyber intrusions through the Cloud

fact: phishing attempts

fact: ransomware

fact: malware

fact: computer viruses

reasoning: The paragraph primarily gives a company-level assessment that it is not aware of any material cybersecurity incidents impacting the business, which fits Strategy Integration under the materiality-assessment rule. Its specificity rises above boilerplate because it names concrete cyber threat types such as phishing, ransomware, malware, and cloud intrusions, but it does not include firm-specific or externally verifiable cybersecurity facts.


fact: The company has a Vendor Management department

reasoning: The paragraph primarily explains how the company manages cybersecurity-related risks from external third parties and vendors, making Third-Party Risk the best fit. Specificity rises to Firm-Specific because it identifies an internal Vendor Management department, but otherwise the language is largely generic and the materiality statement is a non-verifiable negative assertion.


fact: During March 2021, the company experienced a systems outage caused by a cybersecurity incident.

fact: The company engaged forensic information technology firms and legal counsel to investigate the incident.

fact: The incident caused delays and disruptions to business operations, including brewery operations, production, and shipments.

fact: The incident shifted production and shipments from the first quarter of 2021 to the balance of fiscal year 2021.

fact: The company incurred $2.4 million of incremental one-time costs for the year ended December 31, 2021, related to consultants, experts, and data recovery efforts, net of insurance recoveries.

reasoning: This paragraph primarily discloses a real cybersecurity incident, describing when it occurred, operational effects, investigation/response actions, and resulting business disruption. Specificity is Quantified-Verifiable because it includes externally checkable details such as the March 2021 timing and the stated $2.4 million in one-time costs.


fact: professionals in identity and access management

fact: professionals in cyber defense operations

fact: professionals in security engineering

fact: Executive Vice President / Chief Information Security Officer

fact: Chief Information Officer

fact: the Chief Information Security Officer has over 25 years' experience in cybersecurity risk management

fact: the Chief Information Officer has over 27 years' experience in technology risk management

fact: third parties are engaged for penetration testing

fact: third parties are engaged for threat intelligence

fact: third parties are engaged for managed security services

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity, focusing on team composition, senior leadership roles, and reporting lines rather than the operation of the cybersecurity program itself. Specificity reaches Quantified-Verifiable because it includes checkable claims about the CISO's and CIO's years of experience, along with firm-specific leadership roles and several cybersecurity domain terms.


fact: The Board's Risk Management Committee has primary oversight responsibility for cybersecurity risk

fact: The Risk Management Committee is supported by a Cybersecurity and Technology Subcommittee

fact: The Cybersecurity and Technology Subcommittee has oversight responsibility for cybersecurity risk management and cyber resiliency

fact: The Board's Risk Management Committee and Audit Committee receive a report from the Company's CISO on cybersecurity threats and preparedness

fact: cyber resiliency

fact: cybersecurity threats

fact: executive-level crisis exercise including a cybersecurity component to test resiliency response, completeness of playbooks, and communication protocols

reasoning: This paragraph primarily describes how the board and its committees oversee cybersecurity, including delegation to the Risk Management Committee and Cybersecurity and Technology Subcommittee and the reporting flow from management to the board, so it is Board Governance. Specificity is Firm-Specific because it includes company-specific governance bodies and the CISO role; while it also contains some cyber domain terminology, it does not include externally verifiable dates, quantities, or named outside firms.


reasoning: The paragraph primarily provides a materiality assessment, stating that the company is not aware of any cybersecurity incidents that have materially impacted or are reasonably likely to materially impact operations or financial condition, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the dated negative assertion does not elevate specificity.


fact: The Company's information security efforts are led by its Chief Information Security Officer (CISO).

fact: The CISO meets with the EXCO.

fact: The CISO meets with the Senior Leadership Team (SLT).

reasoning: The paragraph primarily describes how cybersecurity information flows to the Board and senior governing bodies, including regular briefings and board-level exercises, so Board Governance is the best fit. Specificity rises to Firm-Specific because it names a CISO and firm-specific internal bodies (EXCO and SLT), but it does not include externally verifiable dates, numbers, or named third parties.


fact: computer malware

fact: cyberattacks

reasoning: The paragraph primarily provides a materiality conclusion that no cybersecurity incidents are known to have materially affected, or be reasonably likely to materially affect, the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration. Its specificity rises above boilerplate only because the cross-referenced risk description includes cyber-domain threat terms such as malware and cyberattacks; otherwise the paragraph is largely generic and the negative no-incidents assertion is not externally verifiable.


fact: Management is informed through threat intelligence

reasoning: The paragraph primarily explains how management stays informed and monitors cybersecurity issues, which makes it about management’s role rather than board oversight or the underlying risk program itself. Specificity rises above boilerplate because it references threat intelligence, a cybersecurity-specific term, but it does not include firm-specific roles, committees, or verifiable details.


fact: automated event-detection notifications

fact: security operations team

fact: incident response team investigates the incident, determines the nature of the event, and assesses the severity and sensitivity of compromised data

reasoning: The paragraph primarily describes how the company’s cybersecurity program detects and analyzes incidents, which is a risk management process rather than a governance or management-organization discussion. Its specificity rises above boilerplate because it uses cybersecurity-operational concepts such as automated event detection, security operations monitoring, and incident investigation/severity assessment, but it does not include firm-unique or externally verifiable facts.


fact: Two members of the audit committee have obtained certifications in cybersecurity oversight.

fact: The chief information officer reports to the audit committee on cybersecurity risks and controls.

fact: The chief information security officer reports to the audit committee on cybersecurity risks and controls.

reasoning: This paragraph primarily describes how cybersecurity information flows to the board and how the board, especially the audit committee, oversees cybersecurity, so Board Governance is the best fit. Specificity reaches Quantified-Verifiable because it includes the externally checkable claim that two audit committee members hold cybersecurity oversight certifications, along with firm-specific reporting roles for the CIO and CISO.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and partners, making Third-Party Risk the best fit. It stays at Generic Boilerplate because it describes only generic vendor vetting, monitoring, and compliance oversight without any domain-specific cyber controls, firm-unique structures, or verifiable details.


fact: Senior Director of Governance & Information Security ("Senior Director, GIS")

reasoning: The paragraph primarily describes how the board oversees cybersecurity risk through delegation to a board committee and reporting up to the full Board, which is board governance. Its specificity is elevated to Firm-Specific by the named security-related management role, Senior Director of Governance & Information Security; the Audit Committee, CFO, and generic reporting cadences do not count toward specificity.


fact: forensic investigations

fact: cybersecurity containment and remediation efforts

fact: remediation and recovery activities following a cybersecurity incident

reasoning: The paragraph primarily describes what the company’s cybersecurity program does when an incident occurs—containment, remediation, recovery, escalation, and plan updates—so it is best categorized as Risk Management Process. Its specificity rises above boilerplate because it includes incident-response domain terminology such as containment, remediation, recovery, and forensic investigations, but it does not include qualifying firm-specific or externally verifiable facts.


fact: The CISO regularly informs the Cybersecurity Executive Steering Body of cybersecurity risks and incidents.

fact: Cybersecurity Executive Steering Body

reasoning: The paragraph primarily describes the escalation and oversight chain for cybersecurity matters up to the board, which makes it Board Governance. Its specificity is Firm-Specific because it includes company-specific governance elements such as the CISO and the named Cybersecurity Executive Steering Body.


reasoning: The paragraph primarily describes how the full Board oversees cybersecurity risk through the enterprise risk management program, management reporting, escalation of severe incidents, and use of outside experts, which makes Board Governance the best fit. It does not include qualifying domain-specific cybersecurity terminology, firm-unique governance details, or externally verifiable facts beyond generic oversight language.


reasoning: This paragraph is a cross-reference directing readers to Item 1A risk factors rather than providing substantive disclosure about governance, management, risk processes, third-party risk, incidents, or strategy integration. Because it contains no qualifying cybersecurity-specific facts beyond generic references to risks and legal compliance, its specificity is Generic Boilerplate.


fact: The Company's information security efforts are led by its Chief Information Security Officer (CISO).

fact: The CISO meets with the ELT.

reasoning: This paragraph primarily describes how cybersecurity information flows to the Board and senior leadership, including the Board’s involvement in oversight exercises, so Board Governance is the best fit. Its specificity is Firm-Specific because it names a CISO and identifies internal leadership groups (ELT and SLT), while the rest of the language is mostly generic oversight/process description.


fact: Cybersecurity risks include targeted attacks, ransomware, malware, phishing attacks, data theft, and other data or security breaches

fact: Attacks to operational technology are identified as a cyber risk area

fact: Layered technical protective capabilities and detective surveillance controls are part of the program

fact: Employee training includes phishing and social engineering awareness

reasoning: The paragraph primarily describes what the company's cybersecurity program does to identify, assess, and manage cyber risk, so it is best classified as Risk Management Process rather than governance or management structure. Its specificity rises above boilerplate because it uses concrete cybersecurity threat and control concepts such as ransomware, malware, phishing, social engineering, operational technology, and detective controls, but it does not provide firm-unique or externally verifiable facts.


fact: updated cybersecurity dashboard featuring key metrics such as threat detection rates and response times

fact: external penetration tests

reasoning: The paragraph primarily describes how the Audit Committee oversees cybersecurity risk and receives information, which makes it a board oversight disclosure. Specificity rises above boilerplate because it includes cybersecurity-specific concepts such as a dashboard with threat detection/response metrics and penetration testing, but it lacks qualifying firm-specific or externally verifiable facts.


fact: migration of business-critical systems, including the Company's ERP system, to Tier-1 cloud service providers

fact: enhancements to endpoint protection

fact: enhanced encryption

fact: two-factor authentication (2FA)

fact: real-time threat monitoring

reasoning: The paragraph primarily describes what the company's cybersecurity program does to identify, mitigate, and monitor cyber risk, so it is a Risk Management Process disclosure. Its specificity is Domain-Adapted because it includes cybersecurity-specific technical measures such as endpoint protection, encryption, 2FA, threat monitoring, and cloud migration, but no firm-unique roles/committees or externally verifiable facts.


reasoning: The paragraph primarily provides a materiality/business-impact assessment of cybersecurity incidents and discusses cyber risk insurance, which fits Strategy Integration. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts; the negative assertion about no material adverse effect is not independently verifiable under the rubric.


fact: Enterprise Risk Management Committee ("ERM Committee")

fact: SOC1 reports

type: framework

reasoning: The paragraph primarily describes the governance chain for cybersecurity risk oversight: risks are reviewed by the ERM Committee and reported to the Audit Committee, which makes Board Governance the best fit. Specificity rises to Firm-Specific because it names the company's ERM Committee; the reference to SOC1 reports adds domain-specific detail but does not exceed Level 3.


fact: Emergency Incident Response Team

reasoning: The paragraph primarily describes an operational cybersecurity preparedness activity—management and a response team reviewing and drilling on an incident-related plan—so it fits Risk Management Process more than organizational role description. Specificity rises to Firm-Specific because it names the company's Emergency Incident Response Team; the remaining language is otherwise generic.


reasoning: The paragraph primarily provides a materiality/business-impact assessment by stating that cybersecurity breaches have not materially affected the company to date and could materially affect its business strategy, results of operations, or financial condition in the future. Its language is generic and cross-referential, without cybersecurity domain-specific terminology, firm-unique organizational details, or externally verifiable facts.


fact: security incident and event manager interface

fact: behavioral analytics

fact: live metrics and reports of attempted breaches

fact: logs of firewalls

fact: authentication attempts

fact: anti-malware

fact: attempted intrusions

fact: external and internal penetration testing

fact: system security assessments

reasoning: This paragraph primarily describes what the company’s cybersecurity program does to detect and respond to incidents, including monitoring tools and testing activities, so it fits Risk Management Process. Its specificity is Domain-Adapted because it uses concrete cybersecurity terminology such as SIEM, behavioral analytics, firewall/authentication logging, anti-malware, and penetration testing, but does not include firm-unique roles, committees, named systems, or externally verifiable facts.


fact: cybersecurity threats originating from the increased use of AI

fact: threat actors including criminal hackers, hacktivists, state-sponsored organizations, and nation states

fact: the company monitors for, identifies, investigates, responds to, and remediates cybersecurity incidents and vulnerabilities

fact: cybersecurity vulnerabilities

reasoning: The paragraph primarily gives a materiality-oriented business impact assessment—stating that cybersecurity risks or incidents have not had a material adverse effect on the company—so Strategy Integration is the best fit. Its specificity rises above boilerplate because it uses cybersecurity-specific threat terminology such as AI-related threats, hacktivists, state-sponsored actors, and vulnerabilities, but it does not include firm-specific or externally verifiable facts.


fact: Management is led by the Vice President, Information Systems and Technology in reporting cybersecurity matters upward.

reasoning: The paragraph primarily describes how the board oversees cybersecurity risk, including the reporting path through the Audit Committee, so Board Governance is the best fit. Its specificity is elevated to Firm-Specific by the company-specific management role of Vice President, Information Systems and Technology; the remaining details are otherwise generic governance language.


reasoning: The paragraph primarily explains that the trust has no active operations, customers, or sensitive data, rather than describing any substantive cybersecurity governance, management, process, third-party oversight, incident, or strategy impact. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, the specificity is Generic Boilerplate.


reasoning: The paragraph primarily provides a cybersecurity materiality assessment, stating that the company is not aware of incidents that have materially affected or are reasonably likely to materially affect its business, results, or financial condition, which fits Strategy Integration under the materiality rule. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts because the negative assertion and cross-reference do not elevate specificity.


fact: Cybersecurity risk oversight is delegated to two Board committees.

fact: The Aerospace Safety Committee oversees cybersecurity risks related to aerospace products and services.

fact: The Chief Information Officer and Senior Vice President, Information Technology & Data Analytics (CIO), provides presentations to the Audit Committee on cybersecurity risks.

fact: The Chief Security Officer (CSO) provides presentations to the Audit Committee on cybersecurity risks.

fact: Briefings include the threat landscape, incident updates, and cybersecurity risk mitigation and governance investments.

fact: One Audit Committee member with cyber risk management expertise meets regularly with management to review cybersecurity strategy and key initiatives.

fact: In a potentially material cybersecurity event, the Chair of the Audit Committee is notified and briefed.

fact: The Aerospace Safety Committee receives updates from the Chief Engineer, Chief Aerospace Safety Officer, and Chief Product Security Engineer regarding cybersecurity threats or incidents affecting safe operation of aerospace products.

fact: The CIO provides annual briefings to the Board on information technology and data analytics matters, including cybersecurity.

reasoning: The paragraph primarily describes how the board and its committees oversee cybersecurity, how information is escalated, and how management reports upward, which makes it Board Governance. Specificity reaches Quantified-Verifiable because it includes a concrete, checkable fact that oversight is delegated to two Board committees, along with multiple firm-specific roles and a named committee.


reasoning: The paragraph is primarily about how the company evaluates and manages cybersecurity risks arising from third-party service providers, including assessments, reassessments, and contractual 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 that would raise specificity above generic boilerplate.


reasoning: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats have not materially affected and are not reasonably likely to 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 beyond generic disclosure language, so specificity is Generic Boilerplate.


reasoning: The paragraph is background context about the company's reliance on technology systems, third-party applications, and sensitive data, but it does not describe governance, management roles, cybersecurity processes, third-party oversight, an actual incident, or a materiality/business-impact assessment. Because it contains no qualifying domain-specific, firm-specific, or verifiable cybersecurity facts, its specificity is Generic Boilerplate.


fact: IBM's Enterprise & Technology Security (E&TS) organization oversees security for IBM's internal systems and external offerings

fact: E&TS addresses cybersecurity risks associated with third party suppliers

fact: IBM has a dedicated Chief Information Security Officer (CISO)

fact: The CISO's team leads enterprise-wide information security strategy, policy, standards, architecture, and processes for IBM's internal systems

fact: The CISO manages the CSIRT

fact: IBM has a Product Security Incident Response Team (PSIRT)

fact: PSIRT focuses on product vulnerabilities affecting offerings sold to customers

fact: IBM has Business Information Security Officers (BISO) who coordinate with the Office of the CISO on segment-specific security issues

reasoning: The paragraph primarily explains how IBM management is organized to handle cybersecurity, detailing the responsibilities and reporting structure of E&TS, the CISO, PSIRT, and BISOs, so Management Role is the best fit. Specificity is Firm-Specific because it includes multiple IBM-unique organizational names and roles, but no hard quantitative or independently verifiable claim that would elevate it to Quantified-Verifiable.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from third-party service providers, making Third-Party Risk the best fit. It does not include domain-specific cybersecurity terminology, firm-unique organizational details, or verifiable facts, so the specificity remains Generic Boilerplate.


reasoning: The paragraph primarily provides a materiality-style assessment that the company did not experience a material cybersecurity incident during the covered year, which fits Strategy Integration under the SEC disclosure rules. Its remaining content is speculative future-risk language, a cross-reference, and a section header, and it contains no qualifying domain, firm-specific, or externally verifiable cybersecurity facts.


reasoning: The paragraph primarily explains how the company evaluates cybersecurity risk from new third-party service providers before onboarding, making third-party risk the central topic. Its language remains high-level and generic—e.g., risk assessments, documented processes, and internal sharing of reports—without domain-specific cyber controls, firm-unique structures that qualify, or externally verifiable facts.


fact: The Head of Cyber Security provides reports to the Audit Committee on cybersecurity matters.

reasoning: The paragraph primarily describes the board oversight structure for cybersecurity: the Board delegates oversight to the Audit Committee, receives information through management reporting, and the committee escalates findings to the full Board. Specificity rises to Firm-Specific because it identifies a company-specific cybersecurity leadership role, the Head of Cyber Security, but does not include externally verifiable numbers, dates, named firms, or certifications.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from third-party service providers, so Third-Party Risk is the best fit. Its descriptions of preliminary assessments, due diligence, onboarding reviews, and security requirements remain generic and do not include domain-specific cyber terminology, firm-unique organizational facts, or externally verifiable claims.


fact: The Trust uses isolated computer workstations as part of its cybersecurity protocols.

fact: Interactions with the Trust's information facilities use passwords and passphrases.

fact: Interactions with the Trust's information facilities use two-factor or independent authorizations.

reasoning: The paragraph primarily describes what the Trust's cybersecurity program does—its protective measures and access controls—so it fits Risk Management Process. Specificity rises above boilerplate because it includes cybersecurity-specific controls such as isolated workstations and two-factor authorization, but it does not provide firm-unique roles, committees, or verifiable quantified facts.


fact: The paragraph describes an information security team supporting the CSO in detection, reporting, security, and mitigation functions

fact: The company develops and implements tools and processes to identify, contain, and remediate cybersecurity incidents

fact: The company conducts phishing tests

reasoning: The paragraph primarily explains what the cybersecurity program does operationally—incident identification, containment, remediation, testing, training, and use of consultants—so it is best classified as Risk Management Process rather than management organization. Specificity reaches Firm-Specific because it includes the firm-specific cybersecurity leadership role of the CSO, and it also contains domain-adapted terms such as phishing tests and incident remediation.


fact: In April 2022, the company experienced a cybersecurity incident.

fact: The incident temporarily disrupted a subset of hospital operations.

fact: The incident involved the exfiltration of certain confidential company and patient information.

fact: The company implemented enhancements to its Security Operations Center following the incident.

fact: The company enhanced system backups after the incident.

fact: The company enhanced detection tools and capabilities after the incident.

fact: The paragraph identifies ransomware attacks as an ongoing threat to healthcare providers.

reasoning: The paragraph primarily describes a real cybersecurity event—when it occurred, what it affected, and the company’s remediation—so Incident Disclosure is the best fit. Specificity reaches Quantified-Verifiable because it includes a concrete, externally checkable date for the incident (April 2022), along with several cybersecurity-specific terms such as exfiltration, Security Operations Center, backups, detection tools, and ransomware.


fact: security operations center

fact: Chief Information Security Officer (CISO)

fact: Cybersecurity Incident Response Plan

fact: cybersecurity crisis response team (the "Crisis Response Team")

fact: Chief Information Officer

fact: Public Disclosure Committee

reasoning: The paragraph primarily explains how cybersecurity threats and incidents are identified, escalated, assessed, and disclosed, which makes it chiefly about the company’s cyber risk and incident-handling process rather than board oversight or management qualifications. Its specificity rises to Firm-Specific because it includes company-specific roles and structures such as the CISO, the Cybersecurity Incident Response Plan, the Crisis Response Team, and the Public Disclosure Committee.


fact: The Company's Cyber Security Group conducts formal screening of applicable vendors as part of the procurement process.

fact: Vendors are risk ranked based on the type of work performed.

fact: Periodic rescreening is performed on critical vendors.

fact: The Company bars sourcing from countries on the Department of Homeland Security's list of Prohibited Nations.

fact: The paragraph references operational technology in connection with cyber insurance coverage.

reasoning: This paragraph is primarily about how the company manages cybersecurity risk from vendors and supply chain partners, so Third-Party Risk is the best fit. Specificity rises to Firm-Specific because it includes a named internal team (Cyber Security Group) and concrete company-specific vendor controls, though it does not contain a clear externally verifiable quantified fact.


fact: The Company's Chief Information Security Officer (CISO) reports to the Audit Committee or provides reports through representatives regarding cybersecurity risks

reasoning: The paragraph primarily explains how the board, through the Audit Committee, oversees cybersecurity by receiving regular reports on risks, threats, assessments, and program updates, so it is Board Governance. Its specificity rises above boilerplate because it names a firm-specific cybersecurity leadership role (the CISO), but it does not include externally verifiable dates, quantities, or named vendors.


reasoning: The paragraph primarily provides a cybersecurity materiality assessment, stating that cybersecurity issues have not materially affected the company's business strategy, operations, or financial condition, which fits Strategy Integration. Its specificity is Generic Boilerplate because the only substantive claim is a negative self-assertion about the absence of material impact, which is not externally verifiable and includes no qualifying domain-specific, firm-specific, or quantified facts.


fact: defense-in-depth and layered strategy

fact: endpoint detection and response

fact: network anomaly detection

fact: multi-factor authentication

fact: threat intelligence services

fact: phishing simulation exercises

reasoning: The paragraph primarily describes what the company’s cybersecurity program does—its protective measures, monitoring, training, and handling of cyber risks—so it is best classified as Risk Management Process. Its specificity is Domain-Adapted because it uses cybersecurity-specific practices and architecture terms such as defense-in-depth, EDR, network anomaly detection, MFA, threat intelligence, and phishing simulations, but it does not include firm-unique roles, named systems, or externally verifiable facts.


fact: risk assessments of suppliers with respect to cybersecurity

fact: real-time security scoring of supplier technology services

fact: threat intelligence

fact: suppliers' cybersecurity risk posture

fact: continuous threat intelligence monitoring to identify potential cybersecurity incidents involving third parties

fact: contractual cybersecurity provisions with suppliers

reasoning: The paragraph is primarily about how the company manages cybersecurity risk from suppliers and other third parties, so Third-Party Risk is the best fit. Its specificity is elevated by cybersecurity-specific vendor oversight concepts such as real-time security scoring and threat intelligence monitoring, but it does not include firm-unique roles/committees or externally verifiable facts.


fact: The company collects, hosts, stores, transfers, processes, discloses, uses, secures, retains and disposes of personal and business information for clients, client employees, vendors, partners, and its workforce.

fact: The company collects funds from client accounts and transmits them to employees, tax authorities, and other payees.

fact: malicious tactics

fact: malicious code

fact: viruses

reasoning: The paragraph primarily explains why cybersecurity risk is especially relevant to the business—because of the sensitive data and client funds ADP handles—so Strategy Integration is the best fit. Specificity rises to Firm-Specific because it includes company-distinguishing operational facts about handling client information and transmitting client funds, alongside some domain-specific threat terminology.


fact: network and perimeter defense

fact: cloud security

fact: endpoint protection

fact: identity management

fact: network segmentation

fact: cybersecurity threat intelligence

reasoning: The paragraph primarily describes what the cybersecurity program does—technical safeguards used to protect systems and improve defenses—so it is best classified as Risk Management Process. Its specificity is Domain-Adapted because it includes cybersecurity-specific practices and architectural concepts such as endpoint protection, network segmentation, and threat intelligence, but no firm-unique or externally verifiable facts.


reasoning: The paragraph primarily addresses whether cybersecurity threats or incidents have affected, or could affect, the company’s business and operations, including a negative material-impact assessment and discussion of potential business costs, which fits Strategy Integration. Its statements are generic and hypothetical, and the one materiality assertion is a non-verifiable negative claim, so no qualifying specificity-elevating facts are present.


fact: A 24/7 security operations center is utilized

fact: security operations center

fact: real-time situational awareness across the cyber-threat environment

fact: insider threat protection program

fact: operational technology

reasoning: The paragraph primarily describes what the cybersecurity program does—incident response, monitoring, insider-threat assessment, plan updates, testing, and employee awareness—so it is best classified as Risk Management Process. Its specificity rises to Firm-Specific because it includes the organization-specific claim that the company utilizes a 24/7 security operations center, alongside several cybersecurity domain terms.


reasoning: The paragraph primarily provides a materiality/business-impact assessment, stating that cybersecurity threats and prior incidents have not materially affected 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 is self-reported and not independently verifiable.


fact: RCSC receives cybersecurity discussions and updates

fact: The CISO provides updates on cybersecurity matters to RCSC

reasoning: The paragraph primarily describes the oversight and reporting flow for cybersecurity matters—specifically how management informs a board-level or governance committee—so Board Governance is the best fit. Specificity is Firm-Specific because it names a specific internal committee (RCSC) and a cybersecurity leadership role (CISO), but does not include externally verifiable quantities or claims.


fact: TEP's Enterprise Cybersecurity team

fact: Certified Information Systems Security Professional (CISSP)

fact: Global Industrial Cyber Security Professional (GICSP)

fact: Electricity Information Sharing and Analysis Center

fact: Cybersecurity and Infrastructure Security Agency

fact: threat intelligence

fact: network monitoring

fact: vulnerability scanning

reasoning: The paragraph primarily explains what the cybersecurity function does—using threat intelligence and internal tools for monitoring, assessment, and response—so Risk Management Process is the best fit despite mentioning the team and certifications. Specificity reaches Quantified-Verifiable because it includes externally verifiable certifications (CISSP and GICSP) and named external organizations, along with domain-specific practices like network monitoring and vulnerability scanning.


reasoning: The paragraph primarily provides a materiality-oriented assessment by stating that the company has not experienced any material cybersecurity incidents in the last three fiscal years and cross-referencing potential business impacts, which fits Strategy Integration under the SEC materiality rule. It contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, so specificity remains Generic Boilerplate.


reasoning: The paragraph primarily provides a business-impact/materiality assessment, stating that cybersecurity risks have not materially affected the company’s business or results of operations to date, which fits Strategy Integration. Its remaining content is generic forward-looking risk language and a cross-reference, with no domain-specific cyber terms, firm-specific organizational details, or externally verifiable facts.


fact: In February 2023, the company experienced a cyberattack

fact: The incident resulted in the temporary interruption of the company's systems

fact: The incident resulted in disclosure of certain confidential information

fact: The incident led to litigation

fact: The incident led to governmental inquiries

reasoning: This paragraph primarily describes an actual cybersecurity event and its consequences, so it is best classified as Incident Disclosure rather than a generic risk or cross-reference. Specificity is Quantified-Verifiable because it includes a concrete, externally checkable date marker ('February 2023') tied to a real incident, along with specific outcomes of that incident.


fact: The CISO provides a cybersecurity dashboard to the Board

fact: The dashboard includes key performance indicators for cybersecurity process maturity, operational performance, and enterprise performance toward Transportation Security Administration (TSA) compliance

fact: The CIO and/or CISO presents to the Board regarding cybersecurity risks and strategies

fact: The CIO presents to the Audit Committee regarding cybersecurity, including in conjunction with internal audits related to cybersecurity

reasoning: This paragraph primarily explains how the board and its committee oversee cybersecurity, how information is reported upward, and when escalation to the board occurs, so Board Governance is the best fit. Specificity reaches Firm-Specific because it includes firm-unique governance details centered on named management roles (CISO and CIO), while the paragraph contains no hard externally verifiable dates, quantities, or certifications.


fact: The Chief Information Officer (CIO) is responsible for assessing and managing cybersecurity risks

fact: The Chief Information Security Officer (CISO) is responsible for assessing and managing cybersecurity risks

fact: The CIO is a member of the Company's Executive Committee

reasoning: The paragraph primarily explains which management roles are accountable for cybersecurity—especially the CIO and CISO and their responsibilities—so it is best classified as Management Role. Its specificity rises above boilerplate because it identifies firm-specific leadership roles and reporting context, but it does not include externally verifiable dates, quantities, or certifications.


fact: The Security and Technology Risk Leadership Committee is chaired by the CISO

fact: Privacy and Data Governance Committee

fact: The Privacy and Data Governance Committee is chaired by the Chief Privacy Officer

fact: Data Security and Privacy Governance Committee

reasoning: This paragraph primarily describes management’s cybersecurity-related organizational structure, including named management committees, who chairs them, and their reporting relationships, so it fits Management Role. Its specificity is Firm-Specific because it includes multiple named internal committees and named leadership roles, but no hard verifiable claims that would raise it to Quantified-Verifiable.


fact: Key third-party service providers are required to undergo an annual SOC 1 audit

fact: The company reviews SOC 1 audit reports for third-party service providers

fact: The review focuses on IT security and business process controls

reasoning: The paragraph primarily explains how the company oversees cybersecurity risk arising from vendors, making Third-Party Risk the best fit. Its specificity is Domain-Adapted because it uses cybersecurity-relevant control evidence and terminology such as SOC 1 audits/reports and IT security controls, but does not include firm-unique roles, committees, or externally verifiable facts.


fact: References specific cybersecurity threat types including insider threats

fact: References cyber intrusion as a form of cybersecurity breach

reasoning: The paragraph primarily answers whether cybersecurity has affected or could affect the company’s business, results, or financial condition, including the explicit statement that prior threats have not materially affected those outcomes, which makes it Strategy Integration. Specificity is Domain-Adapted because it includes cybersecurity threat terminology such as insider threats and cyber intrusion, but no firm-specific organizational details or externally verifiable facts.


fact: "defense-in-depth" approach

fact: aligns with the National Institute of Standards and Technology Cyber Security Framework

fact: Written Information Security Program

fact: vulnerability scanning

fact: penetration testing

fact: incident response exercises based on realistic scenarios

fact: endpoint technology including encryption, threat management, monitoring, investigation support, and backups

fact: identity and access management controls

fact: multi-factor authentication

fact: elevated privileges

fact: continuous monitoring

fact: cyber risk scoring

reasoning: The paragraph primarily describes what the company's cybersecurity program does—its control framework, monitoring, testing, endpoint and access controls, training, and vendor-risk procedures—so it is best classified as Risk Management Process rather than Third-Party Risk. Specificity reaches Firm-Specific because, beyond multiple cybersecurity domain terms and the NIST framework, it names the company’s internal "Written Information Security Program," which is a firm-unique program identifier.


reasoning: This paragraph primarily provides a high-level statement that cybersecurity risk is part of enterprise risk management and directs the reader to another section, rather than describing governance, management, process, third-party risk, incident details, or a materiality assessment. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts, so specificity remains Generic Boilerplate.


fact: confidentiality, integrity and availability of data

reasoning: The paragraph primarily describes the company’s cybersecurity risk management program by stating it has policies, procedures, and systems to identify and address cybersecurity risks and incidents. Specificity rises above boilerplate because it uses the security-specific CIA triad concept—confidentiality, integrity, and availability—even though the rest of the language is generic.


fact: DTI organization

fact: CDT function

fact: Company's CIO

fact: Company's CISO

fact: CDT team

fact: Incident Response team

reasoning: The paragraph primarily describes how the company's cybersecurity program operates when threats or incidents are detected, escalated, evaluated, and remediated, so it is best classified as Risk Management Process rather than Management Role. Its specificity is Firm-Specific because it includes company-specific organizational elements and roles such as the DTI organization, CDT function/team, CIO, CISO, and Incident Response team, but no externally verifiable quantified facts.


reasoning: The paragraph primarily gives a business-impact/materiality assessment, stating that cyberattacks or security incidents have not had material impacts on the company’s business, operations, or reputation, which fits Strategy Integration. Its remaining language is generic commitment and vigilance language, and the negative no-impact assertion is not externally verifiable, so no specificity-elevating facts are present.


reasoning: This paragraph is primarily background threat-environment and generalized risk language about cyber threats facing banks, not a description of board oversight, management organization, a cybersecurity program, third-party risk, strategy/materiality assessment, or an actual incident. Because it falls into None/Other, the specificity is Generic Boilerplate.


fact: Incidents involved use of compromised credentials

fact: A third-party vendor experienced a cybersecurity incident in 2023

fact: The incident was due to a previously unknown zero-day vulnerability

fact: The affected file sharing software was MOVEit Transfer

reasoning: The paragraph primarily describes real cybersecurity incidents that occurred, including their nature, vectors, and one concrete example involving a vendor, so Incident Disclosure is the best fit. Specificity is Quantified-Verifiable because it includes a specific year tied to an actual incident and names the software involved (MOVEit Transfer), alongside domain-specific terms like compromised credentials and zero-day vulnerability.


fact: The information security program uses a "defense in depth" strategy

fact: The company uses data loss prevention technology for sensitive data

fact: The company uses transport layer security encryption for its applications

fact: The training references threats such as phishing

fact: The training references threats such as malware

fact: The training references social engineering testing

reasoning: This paragraph primarily describes what the cybersecurity program does—technical safeguards and employee security training—so it is best classified as Risk Management Process. Its specificity is elevated by multiple cybersecurity-specific terms and practices such as defense in depth, data loss prevention, transport layer security, and named threat types, but it does not include firm-unique or externally verifiable facts.


reasoning: The paragraph is primarily about how the company manages cybersecurity requirements imposed on vendors and service providers, making Third-Party Risk the best fit. Although it describes vendor obligations in some detail, it does so using largely generic compliance and safeguard language without domain-specific cybersecurity terminology that clearly passes the ERM test or any firm-specific/verifiable facts.


fact: The company sustained a cybersecurity attack in May 2022

fact: The incident involved ransomware

fact: The attack caused a network disruption and impacted certain systems

fact: The company engaged a team of third-party forensic experts in response to the incident

fact: The company notified law enforcement

fact: The company restored network systems and resumed normal operations

fact: The company added multi-factor authentication after the incident

reasoning: This paragraph is primarily about a real cybersecurity event—its timing, nature, response, and outcome—so Incident Disclosure is the best fit despite including some materiality and remediation language. Specificity is Quantified-Verifiable because it includes a concrete incident date ('May 2022'); it also contains cybersecurity-specific terms such as ransomware and multi-factor authentication.


fact: The information security program is supervised by the EVP, Chief Digital and Innovation Officer (CDIO)

fact: The information security program is supervised by the Vice President of Platforms, Infrastructure and Cybersecurity

fact: The CDIO and VP of Platforms, Infrastructure and Cybersecurity share responsibility for assessing and managing the Company's cybersecurity risks

fact: Both the CDIO and the VP of Platforms, Infrastructure and Cybersecurity have over 20 years of related experience

reasoning: This paragraph primarily explains which management leaders oversee cybersecurity and highlights their responsibilities and qualifications, so it is best categorized as Management Role. Specificity is Quantified-Verifiable because it includes firm-specific officer titles and a concrete, externally checkable claim that both leaders have over 20 years of related experience.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk from vendors and supply-chain service providers, making Third-Party Risk the best fit. Its language remains generic—vendor assessments, contractual requirements, and incident notification obligations are common boilerplate and do not include domain-specific cyber terminology, firm-unique structures, or verifiable facts.


reasoning: This paragraph is primarily a generic introductory risk statement about potential consequences of cybersecurity failures and breaches, rather than a substantive description of board oversight, management roles, processes, third-party risk controls, incidents, or business impact assessments. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts, so its specificity is Generic Boilerplate.


fact: VF has processes to manage cybersecurity risk from third parties, including service providers, through risk assessments and contractual requirements that include cybersecurity measures.

fact: VF maintains a program designed to protect the confidentiality, integrity, and availability of information and systems.

fact: VF's cybersecurity program is overseen by VF's CISO and CSBDO.

fact: The program includes a cyber incident response plan for timely and accurate reporting of material cybersecurity incidents.

fact: VF's CISO has over thirty years of experience as a cybersecurity professional.

fact: VF's CISO has experience serving as the CISO of two large retailers.

fact: VF's CISO reports to VF's CSBDO.

fact: VF's CSBDO leads the company's digital and technology functions and has nearly twenty years of experience enabling digital transformation for global companies.

fact: VF has information security, IT, and privacy teams involved in cybersecurity technologies, initiatives, and processes.

fact: VF engages service providers, consultants, and other third parties to augment cybersecurity capabilities, provide strategic advice, assess process effectiveness, and assist in incident response.

fact: VF maintains a cybersecurity risk insurance policy.

reasoning: The paragraph primarily describes what VF's cybersecurity program does—protecting information, handling incident response, training users, and managing third-party-related cyber risk—so Risk Management Process is the best fit despite management-role details. Specificity is Quantified-Verifiable because it includes externally checkable claims such as the CISO having over thirty years of experience, prior service as CISO of two large retailers, and the CSBDO having nearly twenty years of experience.


reasoning: The paragraph primarily gives a materiality assessment that no cybersecurity breaches identified in 2023 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 references are generic and the dated negative assertion is not externally verifiable under the rubric, so no specificity-elevating facts are present.


fact: On February 22, 2024, the company disclosed the occurrence of a cybersecurity incident.

fact: The incident was believed to have been committed by cybercrime threat actors.

reasoning: The paragraph primarily describes an actual cybersecurity incident, its ongoing investigation, and preliminary understanding of the threat actor, so Incident Disclosure is the best fit. Specificity is Quantified-Verifiable because it includes a concrete, externally checkable date tied to a disclosed incident.


reasoning: The paragraph is a high-level statement about the importance of cybersecurity governance, but it does not actually describe board oversight, management roles, or concrete cybersecurity processes. Because it contains no specific roles, committees, frameworks, domain practices, or verifiable facts, it remains generic boilerplate.


reasoning: The paragraph primarily gives a materiality assessment of how cybersecurity incidents and threats have affected, or are reasonably likely to affect, the company’s business strategy, results of operations, and financial condition, which fits Strategy Integration. It contains no qualifying domain-specific terms, firm-specific organizational details, or externally verifiable facts, so specificity remains Generic Boilerplate.


fact: Chief Information Security Officer (CISO) provides presentations and reports to the Risk Committee

fact: vulnerability assessments

reasoning: The paragraph primarily describes how the Board and its Risk Committee oversee cybersecurity risk, including management reporting and approval responsibilities, so Board Governance is the best fit. Specificity rises to Firm-Specific because it names the CISO as part of the oversight structure; it also includes a cybersecurity domain term ('vulnerability assessments'), but no externally verifiable quantified fact is present.


fact: The company states it is subject to regulatory compliance requirements established by the FRB, FDIC, and DFR.

reasoning: The paragraph primarily describes the existence and purpose of the company’s cybersecurity risk management program, so it is best categorized as Risk Management Process rather than Strategy Integration, since the material-adverse-effect language is hypothetical. Specificity rises to Quantified-Verifiable because it makes a concrete, externally checkable claim about regulation by the FRB, FDIC, and DFR; otherwise the program description is largely generic.


fact: The company has a Chief Information Security Officer (CISO) with primary responsibility for the development, operation, and maintenance of the information security program

fact: The CISO has 30 years of information technology experience

fact: The CISO has 17 years focused specifically on information security and risk management

reasoning: This paragraph primarily describes management organization and qualifications by identifying the CISO as the responsible executive and detailing his experience. Specificity is Quantified-Verifiable because it includes externally checkable experience claims (30 years in IT and 17 years in information security/risk management), in addition to the firm-specific CISO role.


fact: Cybersecurity risks from third party vendors and service providers are overseen through an extensive Vendor Management process

fact: The Vendor Management process is overseen by the Vendor Management Committee

fact: All new vendors undergo due diligence analysis by the Corporation's Vendor Management team

reasoning: The paragraph is primarily about how the company manages cybersecurity risks posed by vendors and service providers, making Third-Party Risk the best fit. Its specificity rises above boilerplate because it identifies firm-specific governance structures—the Vendor Management Committee and Vendor Management team—even though the underlying due diligence activities are otherwise fairly generic.


reasoning: The paragraph primarily provides a materiality-oriented assessment that cybersecurity threats have not, to date, been material to Verizon’s operations or financial condition, which fits Strategy Integration under the materiality rule. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts, since the negative assertion and cross-reference are not counted for specificity.


fact: Unisys has a Third Party Risk Management (TPRM) program integrated into its procurement process

fact: The TPRM program requires cybersecurity due diligence reviews on vendors based on supplier/service risk profile

reasoning: The paragraph is primarily about how the company manages cybersecurity risk arising from vendors and service providers, making Third-Party Risk the best fit. Specificity rises above boilerplate because it identifies a firm-specific program by name and acronym (TPRM), while also using a more specific cybersecurity practice of vendor due diligence reviews.


reasoning: The paragraph primarily explains how the company manages cybersecurity risk from suppliers, vendors, and other third parties by imposing contractual security and data-use restrictions. It remains generic boilerplate because it contains no qualifying domain-specific cybersecurity terminology, no firm-unique roles or structures, and no verifiable dates, numbers, named firms, or certifications.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party service providers, making Third-Party Risk the best fit. It remains generic boilerplate because it uses high-level risk-management language without domain-specific cybersecurity terminology, named firm-specific structures, or verifiable facts.


reasoning: The paragraph primarily provides a materiality-oriented assessment that cybersecurity threats are 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, so its specificity remains Generic Boilerplate.


fact: The program encompasses the CSO and its policies, platforms, procedures, and processes

fact: confidentiality, integrity, or availability

reasoning: The paragraph primarily describes what the cybersecurity program is designed to do—protect information, assess and manage cyber risks, address third-party risk, and respond to incidents—so it is best classified as Risk Management Process. Specificity rises above boilerplate because it includes the firm-specific role reference to the CSO, and it also uses cybersecurity domain language through the confidentiality-integrity-availability formulation.


fact: Management engagement includes the Chief Information Officer (CIO)

fact: Management engagement includes the Chief Information Security Officer (CISO)

reasoning: The paragraph primarily describes how the Audit Committee oversees cybersecurity through quarterly reporting, direct engagement with management, and review of audit results, which makes it Board Governance. Its specificity is Firm-Specific because it names firm-level cybersecurity/IT leadership roles (CIO and CISO), but it does not include externally verifiable dates, quantities, or named outside firms.


fact: The cybersecurity program is led by the Senior Manager of the Enterprise IT Security Risk and Compliance team.

fact: The Senior Manager reports to the Managing Director of Enterprise IT.

fact: The Senior Manager has over 30 years of IT experience.

fact: The Senior Manager has over 20 years specializing in cybersecurity.

reasoning: This paragraph primarily explains how management is organized to lead cybersecurity, emphasizing the Senior Manager’s role, reporting line, experience, and executive reporting structure rather than detailing the cybersecurity program itself. Specificity is Quantified-Verifiable because it includes checkable experience claims ('over 30 years' and 'over 20 years') and firm-specific organizational details.


fact: denial of service attacks

fact: malicious software attacks

reasoning: The paragraph primarily answers how cybersecurity threats have affected or could affect the company, including the explicit materiality-oriented statement that it has not been materially impacted and discussion of potential losses from third-party breaches. Its specificity rises above boilerplate because it references concrete cybersecurity threat types such as denial-of-service and malicious software attacks, but it includes no firm-specific or externally verifiable facts.


fact: During 2023, the Corporation received written notice that certain customer data was potentially included in the global incident involving Progress Software Corporation's MOVEit Transfer.

fact: Progress Software Corporation was identified as the company involved in the global MOVEit Transfer incident.

fact: MOVEit Transfer was the platform involved in the incident.

fact: The affected third-party vendor was a prominent financial institution vendor that used MOVEit Transfer in services provided to the Bank.

fact: Customers who use online and mobile banking could have had personal information copied through the cyberattack.

fact: The vendor confirmed it implemented the recommended patches released by Progress Software Corporation for the platform.

fact: The Bank notified potentially affected customers after determining the potentially impacted population and extent of exposure.

fact: The incident did not impact the ongoing operations of the Bank.

fact: The Bank's cyber insurance is expected to cover many of the costs related to the incident.

fact: The MOVEit Transfer incident was the only cybersecurity incident that materially affected the Corporation during the 2023 fiscal year.

reasoning: This paragraph primarily describes an actual cybersecurity event—its source, scope, response, and effects—so Incident Disclosure is the best fit. Specificity is Quantified-Verifiable because it includes externally checkable facts such as the 2023 timeframe, the named firm Progress Software Corporation, and the named platform MOVEit Transfer.


fact: cybersecurity due diligence reviews on vendors

fact: monitoring principal suppliers and service providers using an outside-in, hacker perspective of a company's cybersecurity posture

reasoning: The paragraph is primarily about how the company manages cybersecurity risks arising from vendors and service providers, making Third-Party Risk the best fit. Its specificity rises above boilerplate because it describes cyber-specific vendor practices such as due diligence reviews and outside-in monitoring from a hacker perspective, but it does not include clear firm-unique or externally verifiable facts.


reasoning: The paragraph primarily provides management’s assessment of how cybersecurity threats and incidents have affected, and could affect, the company’s business strategy, results of operations, and financial condition, which fits Strategy Integration. It does not contain qualifying domain-specific technical terms, firm-unique organizational details, or externally verifiable facts that would elevate specificity above Generic Boilerplate.


fact: John Bresney is identified as EVP & CIO with responsibility for IT operations and oversight of cybersecurity program implementation

fact: John Bresney reports directly to the Chief Executive Officer

fact: John Bresney has been employed by the company for approximately 30 years

fact: John Bresney has held various technology and information security roles of increasing responsibility

fact: John Bresney has a bachelor's degree in information systems and business

fact: John Bresney holds a Master's Certificate in Project Management

fact: John Bresney holds a Columbia University CIO Program Certificate

fact: Robert McKenna is identified as SVP of Enterprise Strategy and Execution

fact: Robert McKenna leads implementation of the cybersecurity program and enforcement of cybersecurity policies

fact: Robert McKenna oversees cybersecurity incidents under the Security Incident Response Plan ("IRP")

fact: Robert McKenna has been employed by the company for approximately 21 years

fact: Robert McKenna has over 27 years of technology and information security experience

fact: Robert McKenna has a master's degree in business administration

fact: Robert McKenna holds a Certificate in Project Management

fact: Robert McKenna is a Certified Insurance Counselor

fact: Christopher Cunniff is identified as SVP and CRO

fact: Christopher Cunniff leads the Reinsurance and ERM teams

fact: Christopher Cunniff chairs the ERC

fact: Christopher Cunniff chairs the Emerging Risk Committee

fact: Christopher Cunniff has been employed by the company for approximately six years

fact: Christopher Cunniff previously served as SVP of Actuarial Reserving

fact: Christopher Cunniff has over 32 years of insurance industry experience

fact: Christopher Cunniff has a bachelor's degree in mathematics

fact: Christopher Cunniff is a fellow of the Casualty Actuarial Society

fact: Christopher Cunniff is a member of the American Academy of Actuaries

reasoning: This paragraph primarily explains how management is organized to handle cybersecurity by describing specific officers’ roles, reporting lines, and qualifications, so Management Role is the best fit. Specificity is Quantified-Verifiable because it includes named executives, a named incident response plan and committees, and multiple externally checkable claims such as years of experience, degrees, and professional certifications or memberships.


reasoning: The paragraph primarily explains how the company evaluates and oversees cybersecurity risk in selecting and monitoring third-party service providers, so Third-Party Risk is the best fit. It remains generic boilerplate because it gives only high-level vendor oversight language without domain-specific cybersecurity terms, named standards, firm-specific structures, or verifiable details.


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


reasoning: The paragraph primarily describes how the board-level oversight structure works, with the Audit Committee and Board overseeing cybersecurity and IT risk matters, so it is Board Governance. It contains no qualifying domain-specific terminology beyond generic risk oversight language and no firm-specific or externally verifiable facts, so specificity is Generic Boilerplate.


fact: On February 21, 2024, Change Healthcare notified the company of a cybersecurity incident affecting some of its systems.

fact: Change Healthcare is identified as a subsidiary of UnitedHealth Group.

fact: Change Healthcare acts as an intermediary for processing the company's payment claims for all payors.

fact: The company and Change Healthcare severed business service connections between their systems in response to the incident.

fact: The company conducted forensics on its systems based on shared information regarding the Change Healthcare incident.

fact: As of February 28, 2024, the company had not identified any compromise or unauthorized access of its systems or networks.

fact: The incident affected operations with respect to the submission of payment claims.

reasoning: This paragraph primarily describes a real cybersecurity incident involving Change Healthcare, including timing, response actions, and operational effects, so Incident Disclosure is the best fit. Specificity is Quantified-Verifiable because it includes named firms, specific dates, and concrete incident-response details such as severing system connections and conducting forensics.


fact: The paragraph states that cybersecurity threats or incidents have not materially affected the company's results of operations and financial condition to date, and discusses potential material effects on business strategy, results of operations, and financial condition.

fact: security vulnerabilities

reasoning: This paragraph primarily answers how cybersecurity affects the business and finances by making materiality and business-impact statements, so Strategy Integration fits best. Its specificity rises above boilerplate because it references the cybersecurity-specific concept of security vulnerabilities, but it does not include firm-unique organizational details or externally verifiable quantified facts.


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, which fits Strategy Integration. It contains no qualifying domain-specific technical terms, firm-specific cybersecurity governance details, or externally verifiable cybersecurity facts, so specificity remains Generic Boilerplate.


fact: The company's cybersecurity risk management and strategy processes are led by its CDO and CISO.

fact: The CDO and CISO collectively have over 25 years of prior work experience in roles involving information security, cybersecurity strategy, and cybersecurity program implementation.

fact: Their job descriptions require relevant degrees and certifications, including ISACA Certified Information Security Manager (CISM).

fact: Their job descriptions require relevant degrees and certifications, including ISC2 Certified Information Systems Security Professional (CISSP).

reasoning: This paragraph primarily explains who in management leads cybersecurity and why they are qualified, which makes it a Management Role disclosure rather than a process description. Specificity reaches Quantified-Verifiable because it includes a measurable experience claim ('over 25 years') and named professional certifications (CISM and CISSP), alongside firm-specific leadership roles (CDO and CISO).


fact: Management briefings to the Audit Committee typically include the Vice President of Cybersecurity

reasoning: The paragraph primarily describes how the board and its committee oversee cybersecurity, including reporting and escalation to the board, so Board Governance is the best fit. Specificity rises to Firm-Specific because it identifies a company-specific cybersecurity leadership role, the Vice President of Cybersecurity; the rest of the paragraph is largely generic oversight language and generic cadences.


fact: Change Healthcare is identified as the affected third party.

fact: UnitedHealth Group is identified as Change Healthcare's parent company.

fact: Change Healthcare acted as an intermediary for processing the company's payment claims for all payors.

fact: The incident temporarily affected the company's ability to submit claims for payment until alternative submission modes were implemented.

fact: unauthorized access

reasoning: The paragraph primarily describes a real third-party cybersecurity incident, the company's response, and resulting operational disruption, so Incident Disclosure is the best fit. Specificity is Quantified-Verifiable because it includes a specific date and named firms (Change Healthcare and UnitedHealth Group), along with concrete incident-response details.


reasoning: The paragraph is primarily about how the company manages cybersecurity risks posed by vendors and service providers, making Third-Party Risk the best fit. Its language remains generic because it describes standard vendor risk activities—policies, assessments, reassessments, tracking, and remediation—without naming cyber-specific frameworks, tools, unique internal bodies, or verifiable facts.


reasoning: The paragraph primarily describes board-level oversight: the Audit Committee monitors internal audit coverage of cybersecurity-related matters and the Risk Committee coordinates review of information security issues. Its details remain generic for specificity purposes because the cited committees and oversight language are common governance boilerplate and do not include qualifying domain-specific, firm-unique, or externally verifiable facts.


fact: The company states it suffered a ransomware attack on its information technology systems in 2021.

fact: ransomware attack

reasoning: The paragraph is primarily about an actual cybersecurity incident that occurred, including its nature and stated impact, so Incident Disclosure fits best. Specificity reaches Quantified-Verifiable because it includes a concrete, externally checkable claim tied to a specific year (2021), and it also uses the cybersecurity-specific term 'ransomware attack.'


fact: Management reports to the Audit Committee include reports from the Chief Innovation Officer.

reasoning: The paragraph primarily describes how the Board and its Audit Committee oversee cybersecurity, including the flow of information from management to the committee and then to the full Board, which makes this Board Governance. Specificity is Firm-Specific because it identifies a company-specific cybersecurity reporting role—the Chief Innovation Officer—but does not provide externally verifiable quantities, dates, or named third-party firms.


reasoning: This paragraph is a cross-reference to Risk Factors in Item 1A rather than a substantive cybersecurity disclosure; it does not describe governance, management, processes, third-party risk, an actual 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: The paragraph primarily provides a materiality assessment, stating that cybersecurity threats and prior incidents have not materially affected the company’s business strategy, results of operations, or financial condition, which fits Strategy Integration. Its specificity remains Generic Boilerplate because the dated statement is a negative self-assessment and cross-reference, with no qualifying domain-specific, firm-specific, or externally verifiable facts.


fact: Director of Cybersecurity is identified as a management position responsible for assessing and managing cybersecurity risks

fact: Chief Information Officer (CIO) is identified as a management position responsible for assessing and managing cybersecurity risks

fact: The CIO and Director of Cybersecurity each have over 20 years of cybersecurity oversight experience

fact: The CIO previously served as CIO for a New York Stock Exchange-listed manufacturing company prior to joining the company

reasoning: This paragraph primarily describes who in management is responsible for cybersecurity and their qualifications, so it is best classified as Management Role. Specificity reaches Quantified-Verifiable because it includes named cybersecurity leadership roles and the verifiable claim that both leaders have over 20 years of cybersecurity oversight 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, financial condition, or results of operations, which fits Strategy Integration. Its remaining content is a generic cross-reference to Risk Factors, and it contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts.


reasoning: The paragraph primarily describes what the cybersecurity program does—incident response planning, testing, training, and use of outside experts—so it fits Risk Management Process. Its details remain generic because items like an incident response plan, related policies, simulation exercises, and an incident response team are common boilerplate and do not include qualifying domain-specific, firm-unique, or externally verifiable facts.


fact: The CIO has primary responsibility for identifying, assessing, monitoring, and managing cybersecurity risks

reasoning: The paragraph primarily describes how the Board of Directors oversees cybersecurity risk, including its direct review responsibilities and information flow from management, so Board Governance is the best fit. Specificity is elevated to Firm-Specific by the reference to the CIO as the responsible executive; other details like the Audit Committee and annual/quarterly cadence are too generic to raise specificity further.


fact: Performs forensic reviews of cybersecurity-related incidents

fact: Uses independent security assessments

reasoning: The paragraph primarily describes components of the company's cybersecurity program—using outside experts to evaluate threats, assess security, and support incident-related reviews—so it is best categorized as Risk Management Process rather than Third-Party Risk. Its specificity rises above boilerplate because it mentions cyber-domain practices such as forensic reviews and independent security assessments, but it does not include firm-unique roles or externally verifiable facts.


reasoning: The paragraph is primarily about how the company manages cybersecurity risk posed by vendors, specifically by requiring third-party service providers to maintain security measures and by assessing those providers. It remains generic boilerplate because it does not include cybersecurity-specific technical terms, named frameworks, firm-specific structures, or verifiable details.


fact: The Corporate Risk Committee of the Board oversees information technology systems, including information security, compliance, and privacy.

fact: The CIO and/or CISO report on cybersecurity matters to the Corporate Risk Committee.

fact: The CIO provides updates to the Board of Directors.

reasoning: This paragraph primarily describes how the board and its committees oversee cybersecurity and receive reporting from management, which is board governance. Its specificity is elevated by firm-specific organizational details, including the named Corporate Risk Committee and the CIO/CISO reporting structure; generic items like the Audit Committee and reporting cadence do not drive specificity.


fact: Review of cybersecurity risks by management committees such as the Operational Risk Committees

fact: Review of cybersecurity risks by the Enterprise Risk Management Committee

fact: The company maintains a dedicated Information Security and Data Management Committee

fact: The Information Security and Data Management Committee is chaired by SHUSA's Chief Technology Officer

fact: The Enterprise Risk Management Committee is chaired by SHUSA's Chief Risk Officer

fact: The Operational Risk Committees are chaired by SHUSA's Head of Technology & Operations

reasoning: The paragraph primarily describes the governance and oversight structure for cybersecurity risk escalation and review, including committees and how senior leadership and the board are involved, which makes Board Governance the best fit. Its specificity is Firm-Specific because it names company-specific committees and identifies SHUSA leadership roles tied to those governance bodies, but it does not provide externally verifiable dates, numbers, or certifications.


fact: The Company's Vice President of Information Technology, Security and Business Intelligence is principally responsible for overseeing the Company's cybersecurity risk management program

fact: The Vice President of Information Technology, Security and Business Intelligence has served in information technology and information security roles for over 18 years

fact: The Vice President's prior experience includes roles at Biogen

fact: The Vice President's prior experience includes roles at AstraZeneca

fact: The Vice President's prior experience includes roles at Iron Mountain

fact: The Vice President's prior experience includes consulting roles at Charles River Labs

fact: The Vice President's prior experience includes consulting roles at Sunovion Pharmaceuticals

fact: The Vice President's prior experience includes consulting roles at Agero

fact: The Vice President's prior experience includes consulting roles at DentaQuest

fact: The Vice President holds a master's degree in business administration from Boston University

fact: The Vice President holds a master's degree in electrical and computer engineering from Utah State University

fact: The Vice President holds a bachelor's degree in electronics engineering from Mumbai University

fact: The Information Technology team has over 10 years of experience managing risks arising from cybersecurity threats

reasoning: This paragraph primarily explains how management is organized for cybersecurity by identifying the senior manager responsible and detailing that person's qualifications and experience, which makes it a Management Role disclosure. Specificity is Quantified-Verifiable because it includes externally checkable experience thresholds, named prior employers, and specific educational credentials.


fact: Information Security and Compliance teams coordinate on cybersecurity risk management oversight

fact: The CIO is responsible for discussing cybersecurity risk management with the Audit Committee and Board

fact: The Vice President of Information Security helps develop and implement cybersecurity policies, standards, processes, and practices

fact: The Information Technology Senior Leadership Team coordinates with the CIO and Vice President of Information Security

fact: Vulnerability assessments are among the cybersecurity topics reported to the Board and Audit Committee

reasoning: The paragraph primarily explains how the Board and Audit Committee oversee cybersecurity through reports, presentations, incident escalation, and direct engagement with management, so Board Governance is the best fit. Specificity reaches Firm-Specific because it includes firm-unique management roles and teams such as the Vice President of Information Security and the Information Technology Senior Leadership Team, along with one domain-specific term, vulnerability assessments.


reasoning: This paragraph is introductory framing language about the importance of cybersecurity and the purpose of the disclosure, but it does not describe board oversight, management roles, risk processes, third-party risk, incidents, or business-impact assessments. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts, so the specificity is Generic Boilerplate.


fact: The company has a Chief Information Security Officer (CISO).

fact: The CISO, Chief Legal Officer, and Chief Financial Officer comprise the Core Cybersecurity Management Team (CCMT).

fact: Teradata has a named Cyber Incident Response Plan (CIRP).

reasoning: The paragraph primarily explains how management is structured to oversee cybersecurity, identifying the management team and its responsibilities, so Management Role is the best fit. Specificity is Firm-Specific because it includes firm-unique organizational details such as the CISO, the named CCMT, and Teradata's named CIRP, but no externally verifiable quantified claim.


reasoning: The paragraph primarily addresses whether cybersecurity incidents are assessed for material effects on the company's business strategy, results of operations, or financial condition, and states that no such material effects have been identified, which fits Strategy Integration. Its details are generic SEC-style materiality and response language without qualifying domain-specific, firm-unique, or externally verifiable facts.


fact: The Board receives briefings from the company's CISO on cybersecurity matters

reasoning: The paragraph primarily describes how the board oversees cybersecurity through direct briefings and education, which is board governance. Its specificity is elevated by the firm-specific fact that the CISO briefs the Board; the annual/periodic cadence and external experts are too generic to further elevate specificity.


fact: third-party hosted applications

fact: information security posture

fact: System and Organization Controls (SOC) 2

reasoning: The paragraph is primarily about how the company manages cybersecurity risk from vendors and other service providers, so Third-Party Risk is the best fit. Its specificity rises above boilerplate because it includes cybersecurity-specific concepts and standards such as information security posture, hosted applications, SOC 2, and ISO 27001, but it does not provide firm-unique roles, committees, or externally verifiable quantified claims.


reasoning: This paragraph is a cross-reference directing the reader to risk factor disclosures in Item 1A rather than providing substantive cybersecurity governance, management, process, incident, third-party, or strategy detail itself. Because it contains no qualifying domain-specific, firm-specific, or externally verifiable cybersecurity facts, its specificity is Generic Boilerplate.


fact: security due diligence process for each acquisition target

fact: independent testing of the target technology prior to closing the acquisition

fact: vulnerability or risk is identified

reasoning: The paragraph is primarily about how the company manages cybersecurity risk posed by external parties in M&A transactions, so Third-Party Risk is the best fit. Its specificity rises above boilerplate because it references cyber-specific diligence concepts such as testing target technology and identifying vulnerabilities, but it does not include firm-unique roles/committees or externally verifiable facts.


fact: generally aligned with the National Institute on Standards and Technology Cybersecurity Framework

fact: third party security operation center

fact: multi-factor authentication

fact: email filtering

fact: firewalls

fact: intrusion prevention and detection systems

fact: partitioning and encryption of information

fact: malware defenses

fact: hardware and software updates and patching

reasoning: The paragraph primarily describes what the company’s cybersecurity program does—monitoring threats, escalating potential incidents, deploying technical safeguards, assessing control effectiveness, and training employees—so it fits Risk Management Process. Its specificity is Domain-Adapted because it includes multiple cybersecurity-specific frameworks and controls (for example NIST CSF, MFA, firewalls, IDS/IPS, encryption, patching) but no firm-unique roles, committees, named systems, or externally verifiable facts.


reasoning: The paragraph primarily provides a materiality-oriented business impact assessment, stating that the company has had no material incidents to date and that cyber threats could materially affect its business, results, or financial condition. It contains no qualifying domain-specific, firm-specific, or externally verifiable facts, so specificity remains generic boilerplate.


fact: Farmer Mac's CISO manages Farmer Mac's cybersecurity program

fact: The cybersecurity program is reviewed by the cybersecurity subcommittee

fact: The program is approved annually by the board enterprise risk committee

fact: The CISO has more than 20 years of experience in cybersecurity and information technology

fact: The CISO holds a Master's degree in Business Administration with a focus on Information Technology

fact: The CISO holds a Certified Information Security Manager (CISM) certification

fact: The CISO reports to Farmer Mac's Senior Vice President – Enterprise Risk Officer

fact: security incidents

reasoning: The paragraph primarily explains management's cybersecurity leadership structure by describing the CISO's responsibilities, qualifications, and reporting line, even though it also mentions board-level review. Specificity reaches Quantified-Verifiable because it includes externally checkable claims such as the CISO having more than 20 years of experience and holding CISM certification.


fact: The Chief Security Officer (CSO) is the senior-most security professional responsible for the Company's cybersecurity, product security, and corporate/physical security programs

fact: The CSO reports to the CFO

fact: The current CSO has served in that role for Zebra since 2018

fact: The current CSO has over 14 years of global executive cybersecurity experience

reasoning: This paragraph primarily describes management organization and leadership responsibilities, including the CSO’s role, reporting line, tenure, and qualifications, so it is Management Role. Specificity is Quantified-Verifiable because it includes externally checkable facts such as the CSO serving since 2018 and having over 14 years of cybersecurity experience.


reasoning: The paragraph primarily explains how the company manages cybersecurity risks arising from third-party vendors, making Third-Party Risk the best fit. It remains generic boilerplate because it only describes high-level vendor due diligence and review activities without any domain-specific cybersecurity terms, firm-specific structures, or verifiable details.