Unresolved Staff Comments
−Removed: We have no unresolved comments from the staff of the SEC.
+Added: Not applicable.
Cybersecurity
3 unchanged sentences
Century’s cybersecurity policies, standards, processes and practices are based on recognized security frameworks and applicable industry standards.
−Removed: In general, Century seeks to address cybersecurity risks through a comprehensive, cross-functional approach that is focused on preserving the confidentiality, security and availability of the information that Century generates, collects and stores by identifying, preventing and mitigating cybersecurity threats and effectively responding to cybersecurity incidents when they occur.
+Added: In general, Century seeks to address cybersecurity risks through a comprehensive approach that is focused on preserving the confidentiality, security and availability of the information that Century generates, collects and stores by identifying, preventing and mitigating cybersecurity threats and effectively responding to cybersecurity incidents when they occur.
As one of the critical elements of the Company’s overall ERM approach, the Company’s cybersecurity program is focused on the following key areas:
2 unchanged sentences
• Collaborative Approach:
−Removed: The Company has implemented a comprehensive, cross-functional approach to identifying, preventing and mitigating cybersecurity threats and incidents, while also implementing controls and procedures that provide for the prompt escalation of certain cybersecurity incidents so that decisions regarding the public disclosure and reporting of such incidents can be made by management in a timely manner.
+Added: The Company has implemented a comprehensive approach to identifying, preventing and mitigating cybersecurity threats and incidents, while also implementing controls and procedures that provide for the prompt escalation of certain cybersecurity incidents so that decisions regarding the public disclosure and reporting of such incidents can be made by management in a timely manner.
• Technical Safeguards:
1 unchanged sentence
• Incident Response and Recovery Planning:
−Removed: The Company has established and maintains comprehensive incident response and recovery plans that address the Company’s response to a cybersecurity incident, and such plans are regularly evaluated and updated.
+Added: The Company has established and maintains incident response and recovery plans that address the Company’s response to a cybersecurity incident.
• Third-Party Risk Management :
−Removed: The Company maintains a comprehensive, risk-based approach to identifying and overseeing cybersecurity risks presented by third parties, including vendors, service providers and other external users of the Company’s systems, as well as the systems of third parties that could adversely impact our business in the event of a cybersecurity incident affecting those third-party systems.
+Added: The Company maintains a risk-based approach to identifying and overseeing cybersecurity risks presented by third parties, including vendors, service providers and other external users of the Company’s systems, as well as the systems of third parties that could adversely impact our business in the event of a cybersecurity incident affecting those third-party systems.
• Network Penetration Testing:
3 unchanged sentences
Upon detection, we took steps to address the incident, including engaging both internal resources and a team of third-party experts to investigate and respond to this intrusion.
−Removed: While the February 2022 cybersecurity intrusion did not materially and adversely affect our results of operations, such events have the potential to have a material adverse affect on our business strategy, results of operations and financial condition, including by damaging or interrupting access to our information systems or networks, compromising confidential or otherwise protected information, destroying or corrupting data, or otherwise disrupting our operations.
+Added: While the February 2022 cybersecurity intrusion did not materially and adversely affect our results of operations, such events have the potential to have a material adverse effect on our business strategy, results of operations and financial condition, including by damaging or interrupting access to our information systems or networks, compromising confidential or otherwise protected information, destroying or corrupting data, or otherwise disrupting our operations.
Such events could also damage our reputation and our competitive position and could result in litigation with third parties, regulatory action, loss of business, potential liability and increased remediation costs, any of which could have a material adverse effect on our financial condition and results of operations.
12 unchanged sentences
requiring timely application of security and software patches on servers;
−Removed: antivirus endpoint protection upgrades;
+Added: antivirus endpoint protection;
performing 24-hour/7-day a week network monitoring;
12 unchanged sentences
This involvement ensures that cybersecurity considerations are integrated into the broader strategic objectives of the Company.
−Removed: The Board conducts an annual
−Removed: review of the company’s cybersecurity posture and the effectiveness of its risk management strategies.
+Added: The Board conducts an annual review of the company’s cybersecurity posture and the effectiveness of its risk management strategies.
This review helps in identifying areas for improvement and ensuring the alignment of cybersecurity efforts with the overall risk management framework.
1 unchanged sentence
Primary responsibility for assessing, monitoring and managing our cybersecurity risks rests with the Chief Information Officer.
−Removed: The Chief Information Officer extensive experience working in and leading the Company's information systems.
+Added: The Chief Information Officer has extensive experience working in and leading the Company's information systems.
In addition, a dedicated Cybersecurity team, including the Chief Technology Officer and Cybersecurity Manager, provide regular updates to the Chief Information Officer.
11 unchanged sentences
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.