What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-04-15 compared with 2024-04-01 · 40 added, 34 removed, 16 unchanged (82% of the section changed)

4 unchanged sentences

materially adversely affect our operations, performance and results of operations.

We maintain a cyber risk management program designed to identify, assess, manage, mitigate, and respond to cybersecurity threats.

This program addresses cybersecurity risks to the corporate information technology (“IT”) environment including systems,

hardware, software, data, people, and processes.

maintain a cyber risk management program designed to identify, assess, manage, mitigate, and respond to cybersecurity threats.

addresses cybersecurity risks to the corporate information technology (“IT”) environment including systems, hardware, software,

data, people, and processes.

Audit Committee of the Board of Directors oversees management’s processes for identifying and mitigating risks, including cybersecurity

Our VP of Information Security regularly briefs senior leadership on our cybersecurity and information security posture including

on the prevention, detection, mitigation, and remediation of cybersecurity incidents, and senior leadership will then brief the Audit

In the event of an incident, we intend to follow our incident response playbook, which outlines our planned response from

incident detection to mitigation, recovery and notification, including notifying functional areas (e.g.

legal), as well as senior leadership

and the Board, as appropriate.

Our Head of Information Security has primary responsibility for our entity-wide information security program.

Our current Head

of Information Security has held that position since 2019 and has broad information technology and cybersecurity experience as a result

of that role and past work experience which includes cybersecurity consulting.

Our Head of Information Security regularly briefs senior

leadership on our cybersecurity and information security posture including on the prevention, detection, mitigation, and remediation

of cybersecurity incidents, and senior leadership will then brief the Audit Committee.

In the event of an incident, we intend to follow

our incident response playbook, which outlines our planned response from incident detection to mitigation, recovery and notification,

including notifying functional areas (e.g.

legal), as well as senior leadership and the Board, as appropriate.

security team is responsible for our overall information security strategy, including policy, security engineering, operations and cyber

2 unchanged sentences

initiatives, and processes.

Employees outside of our security team also have a role in our cybersecurity defenses, and they are given

training which we believe improves our cybersecurity.

parties also play a role in our cybersecurity risk management strategy.

We engage third parties to conduct risk assessments and

evaluations of our security controls.

Employees outside of our security team and third parties also have a role in our cybersecurity defenses.

Such employees are given training which we believe improves our cybersecurity.

We engage third parties to conduct risk assessments and evaluations

of our security controls.

Such risk assessment and evaluations identify, quantify, and categorize any cyber risks.

addition, we, along with third party cyber risk management specialists, develops a risk mitigation plan to address such risks, and

where necessary, remediate potential vulnerabilities identified through the assessment and evaluation process.

cybersecurity risk management engagement also includes activities such as penetration testing, independent audits or consulting on

best practices to address new challenges.

In addition, we, along

with third party cyber risk management specialists, develops a risk mitigation plan to address such risks, and where necessary, remediate

potential vulnerabilities identified through the assessment and evaluation process.

have processes to oversee and identify cybersecurity risks associated with the use of third party service providers in our organization’s

Third party cybersecurity risk management engagement also includes activities such as penetration testing, independent audits

or consulting on best practices to address new challenges.

We include security and privacy addendums to our contracts where applicable.

commenced third party risk management assessments to help manage the risks associated with reliance on vendors, critical service providers,

and other third-parties that may lead to a service disruption or an adverse cybersecurity incident.

VP of Information Security and cybersecurity stakeholders regularly brief the senior leadership team on cyber vulnerabilities identified

through the risk management process, the effectiveness of our cyber risk management program, the emerging threat landscape,

and new cyber risks on at least an annual basis.

This includes updates on our processes to prevent, detect, and mitigate

cybersecurity incidents.

We also perform third party risk management assessments to help manage the risks associated with reliance on vendors, critical

service providers, and other third-parties that may lead to a service disruption or an adverse cybersecurity incident.

Head of Information Security and cybersecurity stakeholders regularly brief the senior leadership team on cyber vulnerabilities identified

through the risk management process, the effectiveness of our cyber risk management program, the emerging threat landscape, and new cyber

risks on at least an annual basis.

This includes updates on our processes to prevent, detect, and mitigate cybersecurity incidents.

Notwithstanding

1 unchanged sentence

a material adverse effect on us.

While we maintain cybersecurity insurance, the costs related to cybersecurity threats or

disruptions may not be fully insured.

We have not identified any 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 our operations,

business strategy, regulatory compliance, results of operations, or financial condition.

proactively seeks to detect and investigate unauthorized attempts and attacks against Company IT assets, data, and services, and to

prevent their occurrence and recurrence where practicable through changes or updates to internal processes and tools and changes or

updates to Company service delivery;

however, potential vulnerabilities to known or unknown threats will still remain.

While we maintain cybersecurity insurance, the costs related to cybersecurity threats or disruptions

may not be fully insured.

We have not identified any 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 our operations, business strategy, regulatory

compliance, results of operations, or financial condition.

The Company proactively seeks to detect and investigate unauthorized attempts

and attacks against Company IT assets, data, and services, and to prevent their occurrence and recurrence where practicable through changes

or updates to internal processes and tools and changes or updates to Company service delivery;

however, potential vulnerabilities to

known or unknown threats will still remain.

“Risk Factors” for a discussion of cybersecurity risks.

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.

What changed 10-K

Item 1B. Unresolved Staff Comments