Unresolved Staff Comments
−Removed: ACCENTURE 2024 FORM 10-K
Cybersecurity
−Removed: Cybersecurity
Cybersecurity Risk Management and Strategy
13 unchanged sentences
Accenture leadership reviews and monitors CDP monthly metrics, which are intended to provide oversight and accountability.
−Removed: All Accenture people complete annual core information security and data privacy training, delivered in multiple courses throughout the year, to stay up-to-date on security practices and threats.
−Removed: In addition, our people in internal- and client-data-sensitive roles complete specialized, targeted security training to increase knowledge about role-specific threats, concepts and practices.
+Added: All Accenture people are required to complete annual core information security and data privacy training, delivered in multiple courses throughout the year, to stay up-to-date on security practices and threats.
+Added: In addition, our people in data-sensitive roles are provided specialized, targeted security training to increase knowledge about role-specific threats, concepts and practices.
These interactive learning programs are focused on strengthening foundational knowledge and responding to emerging threats.
6 unchanged sentences
Risk Factors – “We face legal, reputational and financial risks from any failure to protect client and/or Accenture data from security incidents or cyberattacks”.
−Removed: To date these risks and incidents have not had a material impact on us, including our business strategy, results of operations, and financial condition;
+Added: To date these risks and incidents have not had a material impact on us, including our business strategy,
+Added: ACCENTURE 2025 FORM 10-K
+Added: Cybersecurity 27
+Added: results of operations, and financial condition;
however, there is no assurance that such impacts will not be material in the future.
1 unchanged sentence
Cybersecurity Governance
−Removed: Our enterprise risk management program is an annual and ongoing process designed to identify, assess and manage Accenture’s risk exposures over the short-, intermediate- and long-term.
+Added: Our enterprise risk management program is an annual and ongoing process designed to identify, assess and manage Accenture’s risk exposures over multiple time horizons.
Our enterprise risk management program and disclosure controls and procedures are designed to appropriately escalate key risks to the Board of Directors, as well as to analyze potential risks for disclosure .
−Removed: As part of our Board of Directors’ role in overseeing the Company’s enterprise risk
−Removed: ACCENTURE 2024 FORM 10-K
−Removed: Cybersecurity 34
−Removed: management program, the Board devotes time and attention to cybersecurity and data privacy-related risks, with the Audit Committee of the Board of Directors responsible for overseeing information technology risk exposures, including cybersecurity, data privacy and data security.
+Added: As part of our Board of Directors’ role in overseeing the Company’s enterprise risk management program, the Board devotes time and attention to cybersecurity and data privacy-related risks, with the Audit Committee of the Board of Directors responsible for overseeing information technology risk exposures, including cybersecurity, data privacy and data security.
The Audit Committee receives reports on cybersecurity and data privacy matters and related risk exposures from management, including our chief information security officer (“CISO”), at least twice a year and more frequently as applicable.
In addition, the Audit Committee’s quarterly enterprise risk management updates include developments regarding IT security and data protection.
−Removed: Recent topics included evolving generative AI threats, social engineering resistance and deepfake readiness.
+Added: Recent topics included integrated third-party risk management, the evolving AI security governance and innovation landscape and client data protection.
The Audit Committee regularly updates the Board on such matters and the Board also periodically receives reports from management directly.
12 unchanged sentences
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.