12 unchanged sentences
• a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents;
−Removed: • a third-party risk management process for partners and vendors .
+Added: • a third-party risk management process for partners and vendors based on each partner’s or vendor’s respective risk profile and level of criticality to our operations .
Our cybersecurity risk management program is a key component of our overall process concerning assessment and management of enterprise risk.
1 unchanged sentence
We face certain continuing and ongoing material risks from cybersecurity threats, which the SEC defines as any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality, integrity, or availability of our information systems or any information residing therein.
−Removed: See "Risk Factors—Risks Relating to Cybersecurity or Data Privacy—A breach or other compromise of our security measures or those of third parties we rely on could materially and adversely impact our reputation, business, financial condition and results of operations.” Otherwise, however, we have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.
+Added: See "Risk Factors—Risks Relating to Cybersecurity or Data Privacy—A breach or other compromise of our security measures or those of third parties we rely on could materially and adversely impact our reputation, business, financial
+Added: condition and results of operations.” Otherwise, however, we have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.
Cybersecurity Governance
6 unchanged sentences
Directors receive presentations on cybersecurity topics from our CISO as part of the board of directors’ continuing education.
−Removed: Although our CISO resigned in January of 2025, we have elevated an internal candidate to the role of interim CISO while we search for a replacement.
−Removed: As designed, our CISO and CCO are members of the management team and are primarily responsible for assessing and managing our
−Removed: material risks from cybersecurity threats, as well as our overall cybersecurity risk management program.
−Removed: As designed, our CISO is responsible for supervising both our internal cybersecurity personnel and our retained external cybersecurity consultants.
−Removed: Our interim CISO’s experience includes over 20 years of helping to build global cybersecurity programs in various industries.
+Added: Our CISO and CCO are members of the management team and are primarily responsible for assessing and managing our material risks from cybersecurity threats, as well as our overall cybersecurity risk management program.
+Added: Our CISO is responsible for supervising both our internal cybersecurity personnel and our retained external cybersecurity consultants.
+Added: Our CISO’s experience includes over 15 years of helping to build global cybersecurity programs in companies ranging from Fortune 500 to high-growth middle stage entities.
Our CCO, who is responsible for our technology risk management program, has over 30 years of experience building and leading risk management and compliance programs in large institutions across multiple geographies.
4 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.