2 unchanged sentences
Cybersecurity Risk Management and Strategy
−Removed: We have developed and implemented a cybersecurity program intended to manage risk, and protect the confidentiality, integrity, and availability of our critical systems and information.
−Removed: We design, assess and benchmark our program based on the National Institute of Standards and Technology Cybersecurity Framework.
−Removed: Our cybersecurity risk management program is integrated into our overall enterprise risk management program, and shares common methodologies, reporting channels and governance processes that apply across the enterprise risk management program, in areas such as legal, compliance, strategic, operational and financial risk.
+Added: We maintain a comprehensive cybersecurity risk management program designed to protect the confidentiality, integrity and availability of our systems and information.
+Added: We design, assess and benchmark our program based on the National Institute of Standards and Technology (NIST) Cybersecurity Framework.
+Added: This does not imply that we meet any particular technical standards, specifications or requirements, only that we use NIST as a guide to help us identify, assess and manage cybersecurity risks relevant to our business.
+Added: Our cybersecurity risk management program is integrated into our overall risk management program, and shares common methodologies, reporting channels and governance processes that apply across the risk management program, in areas such as legal, compliance, strategic, operational and financial risk.
+Added: Table of Co n t e n t s
Key elements of our cybersecurity program include but are not limited to the following:
4 unchanged sentences
• a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents;
−Removed: • a third-party risk management process for service providers, suppliers and vendors that have access to our critical systems and information based on our assessment of their criticality to our operations and respective risk profile.
−Removed: We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition.
+Added: • a third-party risk management process for key service providers based on our assessment of their criticality to our operations and respective risk profile, suppliers and vendors that have access to our critical systems and information based on our assessment of their criticality to our operations and respective risk profile.
+Added: We have not experienced any cybersecurity incidents that have materially affected our operations, business strategy, financial condition or results of operations.
We face 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.
2 unchanged sentences
Cybersecurity Governance
−Removed: Our board of directors considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit and Compliance Committee (Committee) oversight of cybersecurity risks, including oversight of management’s implementation of our cybersecurity risk management program, maintains a strategic role in coordinating cyber risk initiatives and policies, and confirming their efficacy.
−Removed: Table of Conten t s
−Removed: The Committee receives annual reports from management on our cybersecurity posture.
+Added: Our board of directors considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit and Compliance Committee (Audit Committee) oversight of cybersecurity risks, including oversight of management’s implementation of our cybersecurity risk management program, maintains a strategic role in coordinating cyber risk initiatives and policies, and confirming their efficacy.
+Added: The Audit Committee receives annual reports from management on our cybersecurity posture.
In addition, management updates the Committee where it deems appropriate regarding any cybersecurity incidents it considers to be significant or potentially significant.
−Removed: The Committee reports to the full board of directors regarding its activities, including those related to cybersecurity.
+Added: The Audit Committee reports to the full board of directors regarding its activities, including those related to cybersecurity.
The board of directors also receives periodic briefings from management on our cybersecurity program.
−Removed: The board members receive presentations on cybersecurity topics from our Chief Information Officer, internal security staff or external experts as part of the board of directors’ continuing education on topics that impact public companies.
+Added: The board members receive presentations on cybersecurity topics from our Chief Information Officer, internal security personnel or external experts as part of the board of directors’ continuing education on topics that impact public companies.
+Added: Our cybersecurity risk management program operates through a structured governance framework with oversight at multiple organizational levels.
+Added: The IT Steering Committee, comprised of our Chief Information Officer, Chief Financial Officer and other members of management, meets quarterly to provide strategic oversight on technology investments, risk management and cybersecurity initiatives.
+Added: The Audit Committee maintains independent oversight through quarterly reviews of security maturity, incidents and strategic investments.
+Added: Ongoing governance includes monthly executive dashboards, Sarbanes-Oxley IT controls monitoring and annual security tabletop exercises.
+Added: Our Chief Information Officer leads the program day-to-day, supervising internal cybersecurity personnel and external consultants, supported by cross-functional leadership with decades of combined experience in cybersecurity and risk management across commercial biotechnology organizations.
Our Chief Information Officer has over 25 years of experience in overseeing cybersecurity and risk management.
−Removed: In addition, our Chief Legal and Administrative Officer has over 25 years of risk management experience and our Chief Financial and Operations Officer has over 20 years of experience in overseeing risk management and cybersecurity.
−Removed: This team is responsible for assessing and managing our material risks from cybersecurity threats and has primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our retained external cybersecurity consultants.
−Removed: Our management team’s experience includes experience running cybersecurity programs at similarly situated commercial biotechnology organizations and navigating the associated risk landscape.
−Removed: Our management team takes steps to stay informed about and monitor efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel, threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us and alerts and reports produced by security tools deployed in the IT environment.
+Added: Our management team takes steps to stay informed about and monitor efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel, threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us and alerts and reports produced by security tools deployed in our IT environment.
+Added: Table of Co n t e n t s
+Added: We do not own any real estate or other physical properties materially important to our operations.
+Added: Our Waltham, Massachusetts headquarters is leased for four suites, all of which expire in July 2029.
+Added: In addition, we have lease agreements to lease office spaces in Milwaukee, Wisconsin and Newark, California which expire in February 2029 and May 2028, respectively.
+Added: LEGAL PROCEEDINGS
+Added: See information under the “Legal Proceedings and Claims ” caption in Note 19.
+Added: Commitments and Contingencies which we incorporated here by reference.
+Added: MINE SAFETY DISCLOSURES
+Added: Not applicable.
+Added: Table of Co n t e n t s
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.