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Risk Management Strategy
−Removed: Our cybersecurity risk management strategy is comprised of several key elements and is overseen by our Global Information Security team ("GIS"), which is incorporated into our Enterprise Risk Management ("ERM") function.
−Removed: The oversight of our cybersecurity risk is integrated into our ERM processes and procedures.
+Added: The oversight of our cybersecurity risk is integrated into our Enterprise Risk Management ("ERM") function and processes and procedures.
Our ERM framework integrates our information technology and data management systems and related policies and practices into the larger framework to help guide and prioritize our cybersecurity and information technology-related investments, activities, and risk management strategy.
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The training is administered to employees on an annual basis, and we use a third-party provider for the content to ensure that the training is periodically updated to incorporate new cybersecurity-related developments and best practices.
−Removed: In the event of a reported potential cybersecurity incident, GIS determines whether such incident triggers our cybersecurity threat evaluation and response plan (the “Response Plan”).
+Added: In the event of a reported potential cybersecurity incident, the Global Information Security team ("GIS") determines whether such incident triggers our cybersecurity threat evaluation and response plan (the “Response Plan”).
If triggered, our cybersecurity response team, which includes representatives from GIS, our business team, and executive leadership, as needed under the circumstances (the “Cyber Response Team”), is convened.
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Cybersecurity processes are adjusted based on the information provided from these assessments.
−Removed: GIS oversees our cybersecurity program and is responsible for identifying, assessing, monitoring, managing and communicating our cybersecurity risks.
−Removed: GIS is led by our Chief Information Security Officer (“CISO”) and is comprised of information security professionals with a variety of cybersecurity certifications and accreditations.
−Removed: GIS is aided by the Executive Risk Management Committee, which is comprised of senior leaders and subject matter experts throughout our company, including our Chief Information Security Officer (“CISO”) and Chief Compliance Officer (“CCO”), who serve on the committee to assess and mitigate specific business unit risks, promote an understanding of potential issues, and provide risk resolution and prevention support.
+Added: As of the date of this filing, we do not believe that any risks from cybersecurity threats, including as a result of past cybersecurity incidents, have had, or are reasonably likely to have, a material effect on our business strategy, results of operations or financial condition, but we cannot assure that our business strategy, results of operations and financial condition will not be materially affected in the future by cybersecurity risks or future cybersecurity incidents.
+Added: Our Chief Information Security Officer (“CISO”) leads GIS, and together with our Chief Compliance Officer (“CCO”) are responsible for managing and assessing cybersecurity risk and strategy.
+Added: They oversee our cybersecurity program and are responsible for identifying, assessing, monitoring, managing and communicating our cybersecurity risks.
+Added: GIS is comprised of information security professionals with a variety of cybersecurity certifications and accreditations.
+Added: GIS is aided by the Executive Risk Management Committee, which is comprised of senior leaders and subject matter experts throughout our company, including our CISO and CCO, who serve on the committee to assess and mitigate specific business unit risks, promote an understanding of potential issues, and provide risk resolution and prevention support.
GIS and the Executive Risk Management Committee are responsible for keeping the Audit Committee apprised of developments with respect to our cybersecurity strategy and risks.
−Removed: Our CISO has served in various roles in information technology and information security for more than 30 years, including serving as the Chief Information Security Officer at two other large public companies and has been with ACI since 2015.
−Removed: Our CCO has over 30 years of experience in compliance program leadership and process design, risk management and financial services operations, including serving as Head of Compliance for several banking and financial services technology organizations including two other publicly traded companies.
+Added: Our CISO has served in various roles in information technology and information security for more than 30 years, including 20 years in Financial Services, along with serving as the Deputy Head of Global Information Security at ACI prior to being designated as CISO and has been with ACI since 2008.
+Added: Our CCO has served in various risk and compliance roles in both global and regulated entities within financial services technology organizations, along with serving as the Head of Enterprise Risk at ACI prior to being designated as CCO and has been with ACI since 2022.
+Added: The CCO’s expertise focuses on designing, maturing, and embedding risk and compliance frameworks;
+Added: credentials also include a Juris Doctor, a Masters of Business Administration with a focus in Finance and emphasis in consulting, and a Bachelors of Science in Business Administration.
The Audit Committee oversees our cybersecurity strategy and risks.
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Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.