1 unchanged sentence
Cybersecurity
−Removed: We maintain an information
−Removed: security and cybersecurity program, as well as a cybersecurity governance framework, which are designed to protect our information systems
−Removed: against operational risks related to cybersecurity.
−Removed: Cybersecurity Risk Management and Strategy
−Removed: We recognize the importance
−Removed: of assessing, identifying, and managing material risks associated with cybersecurity threats which include, among other things, operational
−Removed: risks, intellectual property theft, fraud or extortion, harm to employees or customers, violation of privacy or security laws and related
−Removed: litigation and legal risk, and reputational risks.
−Removed: We have developed and implemented
−Removed: a cybersecurity risk management program overseen by our Audit Committee intended to protect the confidentiality, integrity, and availability
−Removed: of our critical systems and information, and detect and contain any cybersecurity incidents that impact us.
−Removed: The program is integrated
−Removed: into our overall risk management systems and processes, and includes a cybersecurity risk assessment process that routinely evaluates
−Removed: potential impacts of cybersecurity risks on our business, including risks from cybersecurity threats associated with our use of third-party
−Removed: service providers.
+Added: maintain an information security and cybersecurity program, as well as a cybersecurity governance framework, which are designed to protect
+Added: our information systems against operational risks related to cybersecurity.
+Added: Cybersecurity
+Added: Risk Management and Strategy
+Added: recognize the importance of assessing, identifying, and managing material risks associated with cybersecurity threats which include,
+Added: among other things, operational risks, intellectual property theft, fraud or extortion, harm to employees or customers, violation of
+Added: privacy or security laws and related litigation and legal risk, and reputational risks.
+Added: have developed and implemented a cybersecurity risk management program overseen by our Audit Committee intended to protect the confidentiality,
+Added: integrity, and availability of our critical systems and information, and detect and contain any cybersecurity incidents that impact us.
+Added: The program is integrated into our overall risk management systems and processes and includes a cybersecurity risk assessment process
+Added: that routinely evaluates potential impacts of cybersecurity risks on our business, including risks from cybersecurity threats associated
+Added: with our use of third-party service providers.
These assessments inform our cybersecurity risk mitigation strategies.
−Removed: The results are regularly shared with our information
−Removed: technology committee comprised of our Vice President of Information Technology, our Information Technology Manager, our President and
−Removed: our Chief Financial Officer (the “IT Steering Committee”) and the Audit Committee of our Board as part of the committees’
−Removed: involvement in managing and overseeing cybersecurity risks.
−Removed: Our cybersecurity risk management
−Removed: program also includes processes to triage, assess the severity of, escalate, contain, investigate, and remediate an incident, as well
−Removed: as to comply with potentially applicable legal obligations and mitigate brand and reputational damage.
−Removed: If a cybersecurity incident is
−Removed: determined to be a potentially material cybersecurity incident, our disclosure controls and procedures define the steps to determine materiality
−Removed: and disclose such a material cybersecurity incident.
−Removed: In addition, we engage
−Removed: an independent third-party provider in connection with our cybersecurity risk management program to monitor cybersecurity threats and
−Removed: provide certain security measures.
−Removed: We regularly engage with this provider to aid in the identification and remediation of potential threats.
+Added: The results are
+Added: regularly shared with our information technology committee comprised of our Vice President of Information Technology, our Information
+Added: Technology Manager, our President and our Chief Financial Officer (the “IT Steering Committee”) and the Audit Committee of
+Added: our Board as part of the committees’ involvement in managing and overseeing cybersecurity risks.
+Added: cybersecurity risk management program also includes processes to triage, assess the severity of, escalate, contain, investigate, and
+Added: remediate an incident, as well as to comply with potentially applicable legal obligations and mitigate brand and reputational damage.
+Added: If a cybersecurity incident is determined to be a potentially material cybersecurity incident, our disclosure controls and procedures
+Added: define the steps to determine materiality and disclose such a material cybersecurity incident.
+Added: addition, we engage an independent third-party provider in connection with our cybersecurity risk management program to monitor cybersecurity
+Added: threats and provide certain security measures.
+Added: We regularly engage with this provider to aid in the identification and remediation of
+Added: potential threats.
This provider has qualifications that include Microsoft Certified:
−Removed: Security, Compliance, and Identity Fundamentals, Certified Information
−Removed: Systems Security Professional (CISSP), Certified Hacking Forensic Investigator, Certified Ethical Hacker (CEH) and Security+.
−Removed: While we believe that our
−Removed: business strategy, results of operations or financial condition have not been materially adversely affected by any cybersecurity incidents,
−Removed: cybersecurity threats are pervasive and, similar to other institutions, we, as well as our employees, customers, regulators, service providers,
−Removed: and other third parties have experienced a significant increase in information security and cybersecurity risk in recent years and will
−Removed: likely continue to be the potential target of cyber attacks.
−Removed: We continue to assess the risks and changes in the cyber environment and
−Removed: invest in enhancements to our cybersecurity capabilities as deemed necessary to promote advancements in our cybersecurity capabilities.
−Removed: Cybersecurity Governance
−Removed: Our cybersecurity risk management
−Removed: program is overseen by the Audit Committee and led by the IT Steering Committee.
−Removed: Our Audit Committee is responsible in overseeing risks
−Removed: from cybersecurity threats, and has the authority to regularly review the adequacy of our cybersecurity, information and technology security,
−Removed: and data privacy programs, procedures, and policies.
−Removed: Our IT Steering Committee, led by the Vice President of Information Technology,
−Removed: is primarily responsible for monitoring, assessing, and managing material risks from cybersecurity threats.
−Removed: The Audit Committee regularly
−Removed: receives updates from the IT Steering Committee / management with respect to our efforts to manage data protection, cybersecurity, and
−Removed: information and technology risks, and assesses the results of reviews from internal audits.
−Removed: Materials presented to our Audit Committee
−Removed: by our IT Steering Committee include updates on our data security posture, results from internal audit and third-party assessments, our
−Removed: incident response plan, and certain cybersecurity threat risks or incidents and developments, as well as the steps management has taken
−Removed: to respond to such risks.
−Removed: The Audit Committee / IT Steering Committee also regularly engages with management on technology risk-related
−Removed: Our processes also allow for our Board and the
−Removed: Audit Committee to be informed of key cybersecurity risks outside the regular reporting schedule.
−Removed: While the Audit Committee meets periodically,
−Removed: the Audit Committee is authorized to meet with management or individual directors at any time it deems appropriate to discuss matters
−Removed: relevant to the committee.
−Removed: Our policy is for the Board and the Audit Committee to receive prompt and timely information regarding any
−Removed: cybersecurity risk (including any incident) that meets reporting thresholds, as well as ongoing updates regarding any such risk.
+Added: Security, Compliance, and Identity Fundamentals,
+Added: Certified Information Systems Security Professional (CISSP), Certified Hacking Forensic Investigator, Certified Ethical Hacker (CEH)
+Added: and Security+.
+Added: we believe that our business strategy, results of operations or financial condition have not been materially adversely affected by any
+Added: cybersecurity incidents, cybersecurity threats are pervasive and, similar to other institutions, we, as well as our employees, customers,
+Added: regulators, service providers, and other third parties have experienced a significant increase in information security and cybersecurity
+Added: risk in recent years and will likely continue to be the potential target of cyber-attacks.
+Added: We continue to assess the risks and changes
+Added: in the cyber environment and invest in enhancements to our cybersecurity capabilities as deemed necessary to promote advancements in
+Added: our cybersecurity capabilities.
+Added: Cybersecurity
+Added: cybersecurity risk management program is overseen by the Audit Committee and led by the IT Steering Committee.
+Added: Our Audit Committee is
+Added: responsible for overseeing risks from cybersecurity threats and has the authority to regularly review the adequacy of our cybersecurity,
+Added: information and technology security, and data privacy programs, procedures, and policies.
+Added: Our IT Steering Committee, led by the Vice
+Added: President of Information Technology, is primarily responsible for monitoring, assessing, and managing material risks from cybersecurity
+Added: Audit Committee regularly receives updates from the IT Steering Committee / management with respect to our efforts to manage data protection,
+Added: cybersecurity, and information and technology risks, and assesses the results of reviews from internal audits.
+Added: Materials presented to
+Added: our Audit Committee by our IT Steering Committee include updates on our data security posture, results from internal audit and third-party
+Added: assessments, our incident response plan, and certain cybersecurity threat risks or incidents and developments, as well as the steps management
+Added: has taken to respond to such risks.
+Added: The Audit Committee / IT Steering Committee also regularly engages in management on technology risk-related
+Added: processes also allow for our Board and the Audit Committee to be informed of key cybersecurity risks outside the regular reporting schedule.
+Added: While the Audit Committee meets periodically, the Audit Committee is authorized to meet with management or individual directors at any
+Added: time it deems appropriate to discuss matters relevant to the committee.
+Added: Our policy is for the Board and the Audit Committee to receive
+Added: prompt and timely information regarding any cybersecurity risk (including any incident) that meets reporting thresholds, as well as ongoing
+Added: updates regarding any such risk.
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.