2 unchanged sentences
Risk Management and Strategy
−Removed: We have developed and implemented various processes to oversee and manage the cybersecurity risks that may impact our business and have integrated this cybersecurity risk management framework into our Company’s broader risk management framework.
+Added: We have developed and implemented various processes to oversee and manage cybersecurity risks that may impact our business and have integrated this cybersecurity risk management framework into our Company’s broader risk management framework.
Managing Material Risks & Integrated Overall Risk Management
8 unchanged sentences
applying patches in a timely manner;
−Removed: conducting penetration tests and implementing recommended corrective actions in a timely manner;
+Added: conducting penetration tests and implementing recommended corrective actions in a
+Added: timely manner;
maintaining a well-defined incident response plan and supporting procedures;
13 unchanged sentences
The control group is comprised of members of senior leadership, including in-house legal counsel, and multiple independent third-party Certified Information Systems Security Professional (CISSP) Information Technology and Cybersecurity consultants.
−Removed: Specifically, we have retained a Virtual Cheif Information Security Officer and other members of our cybersecurity control group, each of whom supports our cybersecurity risk management and governance practices.
+Added: Specifically, we have retained a Virtual Chief Information Security Officer and other members of our cybersecurity control group, each of whom supports our cybersecurity risk management and governance practices.
Such retained individuals have substantial prior work experience in various roles involving cybersecurity risk management and information technology, including security, compliance, systems and programming, and bring a wealth of expertise in their roles.
1 unchanged sentence
Monitor Cybersecurity Incidents
−Removed: Our internal cybersecurity control group meets on a monthly or more frequent basis to discuss and assess risks related to cybersecurity threats and review any reported cybersecurity incidents.
+Added: Our internal cybersecurity control group meets monthly or on a more frequent basis if needed, to discuss and assess risks related to cybersecurity threats and review any reported cybersecurity incidents.
The reviews include a review of the incident log, assessments of risks identified by multiple independent third parties and a review of our cyber risk as well as cybersecurity threat modeling.
3 unchanged sentences
The Audit Committee of our Board of Directors has oversight responsibility for the policies, processes and risks relating to cybersecurity.
−Removed: A senior member of our internal group attends all scheduled Audit Committee meetings and provides in-depth reports to the committee on cybersecurity risks and updates on the status of projects to strengthen the Company's cybersecurity systems and improve cyber readiness.
+Added: A senior member of our internal control group attends all scheduled Audit Committee meetings and provides in-depth reports to the committee on cybersecurity risks and updates on the status of projects to strengthen the Company’s cybersecurity systems and improve cyber readiness.
Moreover, on a quarterly basis, a senior member of our internal control group reports to the Audit Committee and assists the committee with its review of relevant cybersecurity risks and evaluation and updating of our Cyber Risk Controls.
−Removed: Certain members of our Audit Committee have specific experience in information security and cybersecurity, and the Company has made cybersecurity training available to members of the Audit Committee.
+Added: Certain members of our Audit Committee have specific experience in
+Added: information security and cybersecurity, and the Company has made cybersecurity training available to members of the Audit Committee.
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.