4 unchanged sentences
Our Program takes a risk-based approach and is integrated into our overall enterprise risk management program.
−Removed: We use the National Institute of Standards and Technology Cybersecurity Framework (the “NIST CSF”) as a benchmark to ensure that our Program is maintained in line with industry best practices.
+Added: We use the National Institute of Standards and Technology Cybersecurity Framework (the “NIST CSF”) as a benchmark to align our Program with industry best practices.
This does not imply that we meet any particular technical standards, specifications or requirements, but it does mean that we use the NIST CSF as a guide to help us identify, assess and manage cybersecurity risks relevant to our business.
3 unchanged sentences
Our Program includes:
−Removed: ● periodic risk assessments and penetration tests, which are integrated within our enterprise risk management framework processes, designed to identify cybersecurity and technology risks, as well as to formulate management actions to respond to, mitigate and remediate material issues (if any);
+Added: ● periodic risk assessments and penetration tests, which are integrated within our enterprise risk management framework processes, designed to identify material cybersecurity and technology threats to our critical systems and information, as well as to formulate management actions to respond to, mitigate and remediate material issues (if any);
● annual management reporting to the Board;
● reporting of the scope, objectives and results of internal audits on the procedures performed to validate the effectiveness of our control environment related to our information security systems and security controls to the Audit Committee at least two times a year;
−Removed: ● annual cybersecurity awareness training, including phishing simulation campaigns, to educate employees on recognizing cybersecurity threats and preventing actions that could unintentionally grant unauthorized access to our systems;
+Added: ● annual cybersecurity awareness training of our employees, including incident response personnel and senior management, such as phishing simulation campaigns, to educate employees on recognizing cybersecurity threats and preventing actions that could unintentionally grant unauthorized access to our systems;
● deployment of endpoint protection software, supported by external managed services, to attempt to proactively detect and block malicious code from affecting our systems;
−Removed: ● a cross-functional team principally responsible for managing our cybersecurity risk assessment processes and our response to cybersecurity incidents;
−Removed: ● the use of external service providers , where appropriate, to assess risk, monitor alerts, perform penetration testing or otherwise assist with aspects of our security controls and response to cybersecurity incidents;
+Added: ● a cross-functional team principally responsible for managing our cybersecurity risk assessment processes, our security controls and our response to cybersecurity incidents;
+Added: ● the use of external service providers with subject matter expertise, where appropriate, to assess risk, monitor alerts, perform penetration testing or otherwise assist with aspects of our security controls and response to cybersecurity incidents;
● a documented framework and supporting processes for handling security incidents that facilitates coordination across multiple parts of the Company;
−Removed: We have not identified risks from known cybersecurity threats, including as a result of any prior security breach, that have materially affected or are reasonably likely to materially affect us, including our business strategy, financial condition and results of operations.
+Added: ● a cybersecurity incident response process that includes defined escalation criteria that governs when cybersecurity events must be communicated to senior management and, when appropriate, to the Board within established timeframes;
+Added: ● evaluations and updates of our cybersecurity controls, investment in security monitoring tools, and enhancements of detection and response capabilities based on emerging threats and periodic assessments.
+Added: We have not identified risks from known cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially affected us to date or are reasonably likely to materially affect us.
+Added: However, cybersecurity risks could materially affect us in the future, including having a material impact on our business strategy, financial condition and results of operations.
We face certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to materially affect us, including our operations, business strategy, results of operations or financial condition.
5 unchanged sentences
This update provides an overall assessment of the effectiveness of our Program and a review of areas of focus for the upcoming year.
−Removed: The Board also receives periodic reports from our Vice President, Internal Audit, on the audit focus areas and control testing related to our information security systems and security controls, and our management team updates the Board, as necessary, regarding any significant cybersecurity incidents.
−Removed: Our management team, including our Senior Vice President and Chief Financial Officer, Senior Vice President and General Counsel, Vice President, Information Technology, and Vice President, Internal Audit , is responsible for assessing and managing our material risks from cybersecurity threats.
+Added: The Board also receives periodic reports from our Vice President, Internal Audit, on the audit focus areas and control testing related to our information security systems and security controls, and our management team updates the Board, where it deems appropriate, regarding any significant cybersecurity incidents.
+Added: Our management team, including our Executive Vice President and Chief Financial Officer, Executive Vice President and General Counsel, Vice President, Information Technology, and Vice President, Internal Audit , is responsible for assessing and managing our material risks from cybersecurity threats.
The team has primary responsibility for our Program and our Vice President, Information Technology, supervises both our internal information security personnel and our retained external cybersecurity consultants.
3 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.