−Removed: UNRESOLVED STAFF COMMENTS.
+Added: STAFF COMMENTS.
CYBERSECURITY.
management recognizes the importance of assessing, identifying, and managing material risks associated with cybersecurity threats, and
−Removed: manages those risks with a t risk-management cybersecurity program.
+Added: manages those risks with a risk-management cybersecurity program.
Among other things, these risks include operational risks, financial
13 unchanged sentences
Our cybersecurity program is designed to be aligned with applicable industry standards and is
−Removed: evaluated annually, including by our third-party auditors, as a part of our Sarbanes-Oxley information technology control testing procedures.
+Added: evaluated annually as a part of our Sarbanes-Oxley information technology control testing procedures.
have processes to assess, identify, manage, and address material cybersecurity threats and incidents.
14 unchanged sentences
service providers’ SOC 1 Type II reports for appropriate information technology controls, including security, to ensure that they
−Removed: adhere to these standards.
+Added: adhere to these standards, when available.
Cybersecurity
3 unchanged sentences
ongoing efforts and incidents at every Board of Directors meeting.
−Removed: In addition to our Board-level Audit Committee, management implemented
−Removed: a Cybersecurity Committee comprised of representatives of upper management, Legal, Marketing, Technology, and Operations to maintain
−Removed: and improve our cybersecurity strategy based on most current industry developments and recent incidents as needed.
−Removed: The Cybersecurity
−Removed: Committee formal meeting occurs biannually, with less formal status update meetings happening more often and as necessary.
−Removed: of the Cybersecurity Committee have prior work experience in various roles involving information technology, including security, auditing,
−Removed: compliance, systems and programming.
−Removed: These individuals are informed about, and monitor the prevention, mitigation, detection and remediation
−Removed: of cybersecurity incidents through their management of, and participation in, the Cybersecurity Committee, and report to the Audit Committee
−Removed: on any appropriate items.
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.