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● a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents;
−Removed: ● a third party risk management process for certain service providers, suppliers, and vendors.
+Added: ● a third party risk management process for certain service providers that is calibrated based on our assessment of each provider’s operational criticality, level of access to our systems and data, and respective risk profile.
There can be no assurance that our cybersecurity risk management program and processes, including our policies, controls or procedures, will be fully implemented, complied with or effective in protecting our systems and information.
We regularly experience cyberattacks and other incidents and will continue to experience varying degrees of attacks and incidents in the future.
−Removed: To date, we have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents (including the Cybersecurity Incident), that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition , however we cannot guarantee that material incidents will not occur in the future.
+Added: To date, we have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition , however we cannot guarantee that material incidents will not occur in the future.
+Added: See “Risk Factors ─ Risks Relating to Regulation and Litigation ─ “A failure in our e-commerce operations, security breaches and cybersecurity risks could disrupt our business and lead to reduced sales and growth prospects and reputational damage.“ and “Disruptions or breaches involving our or our third-party providers’ IT Systems or Confidential Information could interrupt our operations, compromise our reputation, expose us to litigation, government enforcement actions and costly response measures and could have a material adverse effect on our business, financial condition and results of operations.” included in Part I, Item 1A of this Form 10-K.
Cybersecurity Governance
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In addition, management updates the Committee in addition to the full Board, as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential.
−Removed: Information Security is responsible for leading enterprise-wide cybersecurity strategy, policy, standards, architecture, and processes.
−Removed: Information Security reports to the Chief Administrative and Legal Officer, who, together with other members of our management team, including the Chief Financial Officer and President, is responsible for assessing and managing our material risks from cybersecurity threats based on regular reports from Information Security and information technology (“IT”) teams.
−Removed: Management receives periodic reporting on the status of projects to strengthen the security of our IT systems and efforts regarding the prevention, detection, mitigation, and remediation of cybersecurity events.
+Added: Our Chief Information Security Officer (“CISO”) is primarily responsible for leading enterprise-wide cybersecurity strategy, policy, standards, architecture, and processes.
+Added: Our CISO reports to the Chief Administrative and Legal Officer, and together with our Chief Technology Officer, regularly updates our management team on efforts regarding the prevention, detection, mitigation, and remediation of cybersecurity events and security enhancements.
Reports may include briefings that have been informed by internal security personnel, threat intelligence and other information obtained from governmental, public, or private sources in addition to alerts and reports produced by security tools deployed in the IT environment.
+Added: Our CISO has approximately 30 years of IT and cybersecurity leadership.
+Added: With a strong foundation in risk management and oversight, his previous roles included overseeing technology infrastructure and secured operations in addition to leading IT audit and assurance teams at multi-billion-dollar manufacturers.
+Added: Our CISO holds an MBA, a B.S.
+Added: in Computer Engineering, is CISSP, CISM, CISA, and CRISC certified and is a specialist in securing operational technology.
Information Security has significant experience in incident response, forensics, vulnerability management, network security administration, fraud prevention, and other governance, risk, and compliance areas.
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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.