3 unchanged sentences
Our Company maintains a cyber risk management program designed to identify, assess, manage, mitigate, and respond to cybersecurity threats.
−Removed: The Board, Risk and Security Committee of the Board and senior management devote significant resources to cybersecurity and risk management processes to adapt to the changing cybersecurity landscape and respond to emerging threats in a timely and effective manner.
+Added: The Board of Directors and senior management devote significant resources to cybersecurity and risk management processes to adapt to the changing cybersecurity landscape and respond to emerging threats in a timely and effective manner.
We regularly assess the threat landscape with a layered cybersecurity strategy based on prevention, detection, and mitigation.
1 unchanged sentence
In addition, we have a set of Company-wide policies and procedures concerning cybersecurity matters, such as encryption standards, antivirus protection, remote access, multifactor authentication, confidential information and the use of internet, social media, email, and personal devices.
−Removed: The policies include standards from including, but not limited to, the National Institute of Standards and Technology framework, Payment Card Industry Data Security Standards and the Center for Internet Security Standards and are reviewed and approved by appropriate members of management.
+Added: The policies include standards from, among others, the National Institute of Standards and Technology framework, Payment Card Industry Data Security Standards and the Center for Internet Security Standards and are reviewed and approved by appropriate members of management.
Employees must be aware of the Company’s security policies and acknowledge their understanding and compliance to each of the policies annually.
−Removed: The Risk and Security Committee of the Board oversees the Company’s cybersecurity risk exposures and the procedures taken by management to monitor and mitigate the cyber risks.
−Removed: The Chief Information Officer oversees the IT team and is responsible for developing and implementing our information security program and reporting on cybersecurity matters to the Board and Risk and Security Committee of the Board.
+Added: The Board of Directors oversees the Company’s cybersecurity risk exposures, with primary oversight responsibility delegated to the Audit Committee.
+Added: In accordance with its charter, the Audit Committee periodically reviews and discusses with management the Company's cybersecurity and data privacy risks, the policies and procedures implemented to monitor and mitigate those risks, the adequacy of information technology and cybersecurity controls, and reports regarding cybersecurity incidents, assessments and remediation efforts, as appropriate.
+Added: The Chief Information Officer oversees the IT team and is responsible for developing and implementing our information security program and reporting on cybersecurity matters to the Audit Committee.
We view cybersecurity as a shared responsibility, and we periodically perform simulations and tabletop exercises at a management level and incorporate external resources and advisors as needed.
3 unchanged sentences
The Company faces risks from cybersecurity threats that could have a material adverse effect on our business, financial condition, results of operations, cash flows or overall reputation.
−Removed: Although we will continue to face such risks during our normal course of business, they have not materially affected our business, financial position and results of operations.
+Added: Although we will continue to face such risks during our normal course of business, to date, they have not materially affected our business, financial position and results of operations.
See “Failure to adequately maintain the security of our electronic and other confidential information could materially adversely affect our financial condition and results of operations” in Item 1A.
1 unchanged sentence
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.