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Our senior management makes the final materiality determinations and disclosure and other compliance decisions.
−Removed: Our full Board of Directors has oversight responsibility for risks and incidents relating to cybersecurity threats, including compliance with disclosure requirements, and, in conjunction with the Audit Committee, the related effects, if any, on financial reporting and internal controls.
−Removed: Our Chief Information Security Officer, Chief Technology Officer, and Chief Legal Officer regularly update the Board of Directors on the Company’s cybersecurity risk profile and incidents, if any, and our overall cybersecurity strategy and process improvements, including the results of “tabletop” exercises, as well as the Company’s insurance coverages and related matters .
+Added: Our full Board of Directors has oversight responsibility for risks and incidents relating to cybersecurity risk.
+Added: The Board of Directors reviews and discusses with management our policies and practices regarding risk assessment and management, including planning regarding business continuity and cybersecurity.
+Added: In addition, the Board of Directors receives regular reports from management on cybersecurity matters, including areas such as strategic plans and programs, threat intelligence, major cybersecurity risk areas, regulations, and cybersecurity incidents.
+Added: Our management team, including our Chief Information Officer (“CIO”), Chief Technology Officer (“CTO”), and Chief Legal Officer (“CLO”), are responsible for assessing and managing material risks from cybersecurity threats, including supervision of our internal security incident response team.
+Added: Each of these leaders have extensive experience assessing and managing cybersecurity programs and risk.
+Added: Our CIO joined Bentley in 2025 and is responsible for the Company’s internal technology infrastructure, systems, data, and security.
+Added: Our CIO has over 25 years of experience as a technologist across a wide variety of industries.
+Added: She brings significant experience leading enterprise technology organizations and developing cybersecurity and data‑protection practices to support large‑scale operational environments.
+Added: Our CTO joined Bentley in 2021 and is the principal architect of the Company’s technology directions.
+Added: Our CTO has over 20 years of technology leadership experience in startups, scaleups, and large organizations.
+Added: His strategic role includes ensuring that our software development and engineering are secure, resilient, and aligned with risk management needs.
+Added: Our CLO has been with Bentley since 1998 and is responsible for the day-to-day operations of the global Law and Corporate Advancement team.
+Added: Our CLO brings deep expertise in legal and regulatory frameworks, including cybersecurity and data protection, ensuring the organization’s compliance with evolving regulations.
+Added: He leads a global privacy team focused on best practices in safeguarding sensitive information and proactively manages risks related to cyber threats and privacy concerns.
+Added: Table of C ontents
+Added: Our management team brings extensive expertise in identifying and addressing cybersecurity risks across enterprise operations, encompassing information technology, information security, privacy and data protection, product security, physical security, and legal and regulatory considerations.
+Added: Additionally, our leadership team has substantial experience in overseeing risk management programs and possesses a deep understanding of the challenges faced by enterprise organizations.
+Added: Their significant operational background enables them to offer valuable guidance in developing, executing, and evaluating our strategic operating plan.
Our business strategy, results of operations, and financial condition have not been materially affected by risks from cybersecurity threats, but we cannot provide assurance that they will not be materially affected in the future by such risks or any future material incidents.
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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.