UNRESOLVED STAFF COMMENTS
+Added: Table Contents
CYBERSECURITY
3 unchanged sentences
We also maintain insurance coverage for cybersecurity incidents.
−Removed: The Company also engages third parties to perform periodic assessments of certain aspects of our cybersecurity measures, including vulnerability assessments and audits and independent reviews of our information security control environment and operating effectiveness.
+Added: The Company engages third parties to perform periodic assessments of certain aspects of our cybersecurity measures, including vulnerability assessments, audits and independent reviews of our information security control environment and operating effectiveness.
The results of such assessments, audits and reviews are reported to the Nominating and Governance Committee and the Board of Directors, and the Company adjusts its cybersecurity policies, standards, processes and practices as necessary based on the information provided by these assessments, audits and reviews.
1 unchanged sentence
Executive management, inclusive of our Vice President of IT (“VP of IT”) in conjunction with our National Vice President of Finance (“NVP of Finance”) , provides regular updates to the Nominating and Governance Committee including any updates to our program in response to new or changed cybersecurity risks, as well as ongoing metrics around the effectiveness of our existing cybersecurity strategies.
−Removed: The VP of IT and the NVP of Finance work in coordination with the Cybersecurity Response Committee, which also includes our Chief Financial Officer (“CFO”) and representatives from legal, internal audit and SEC reporting functions.
+Added: The VP of IT and the NVP of Finance work in coordination with the Cybersecurity Response Committee, which also includes our Chief Financial Officer and representatives from legal, internal audit and SEC reporting functions.
In the event of a cyber incident, the Cybersecurity Response Committee utilizes a formal incident response plan based on the NIST Framework to assess and manage cybersecurity threats.
6 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.