4 unchanged sentences
Dow's comprehensive cybersecurity and information security framework includes risk assessment and mitigation through a threat intelligence-driven approach, application controls, and enhanced security with ransomware defense.
−Removed: The framework leverages International Organization for Standardizations 27001/27002 standards for general information technology controls, International Society of Automation/International Electrotechnical Commission standards for industrial automation, the National Institute of Standards and Technology Cyber Security
−Removed: Framework ("NIST CSF") for measuring overall readiness to respond to cyber threats, and Sarbanes-Oxley for assessment of internal controls.
−Removed: Dow contracts with external firms to assess Dow’s cybersecurity controls relative to its peers using the NIST CSF.
−Removed: Dow also has a third-party risk management program that assesses risks from vendors and suppliers.
+Added: The framework leverages International Organization for Standardizations 27001/27002 standards for general information technology controls, International Society of Automation/International Electrotechnical Commission standards for industrial automation, the National Institute of Standards and Technology Cyber Security Framework ("NIST CSF") for measuring overall readiness to respond to cyber threats, and Sarbanes-Oxley for assessment of internal controls.
In addition, the Company maintains business continuity and disaster recovery plans as well as a cybersecurity insurance policy.
+Added: Dow has comprehensive processes to manage cybersecurity risks when engaging with third-party service providers, including reviewing questionnaires and independent quantitative scores of the vendor’s cyber hygiene, maintaining robust controls to address and mitigate significant risks that may arise, and performing ongoing assessments and reviews throughout the duration of the engagement.
Dow has established cybersecurity and information security awareness training programs.
9 unchanged sentences
The Company also engages external firms to measure Dow’s NIST CSF maturity level.
−Removed: No risks from cybersecurity threats, including those resulting from any previous cybersecurity incidents, have materially affected, or are reasonably likely to materially affect, the Company, including its business strategy, results of operations or financial condition.
+Added: As of the date of this report, no risks from cybersecurity threats, including those resulting from any previous cybersecurity incidents, have materially affected, or are reasonably likely to materially affect, the Company, including its business strategy, results of operations or financial condition.
+Added: Although the Company has mature processes in place to identify and mitigate potential risks from cybersecurity threats, such risks cannot be completely eliminated.
+Added: More information on the risks of cybersecurity threats and potential impact to the Company can be found in Item 1A.
+Added: Risk Factors.
Role of Management
−Removed: Dow’s Information Systems organization led by Dow’s Chief Information and Digital Officer, is responsible for administration of the cybersecurity and information security framework and risk management, with oversight by the Audit Committee.
−Removed: The Company’s Chief Information and Digital Officer has formal education in information technology and extensive experience working in and leading Dow’s information systems and technology function.
−Removed: The Chief Information and Digital Officer receives regular updates on cybersecurity matters, results of mitigation efforts and cybersecurity incident response and remediation.
−Removed: The Company’s management responsible for developing and executing Dow’s cybersecurity policies is comprised of individuals with either formal education and degrees in information technology or cybersecurity, or with experience working in information technology and cybersecurity, including relevant industry experience in security related industries.
+Added: Dow’s Information Systems organization is led by Dow’s Chief Information and Digital Officer, who reports to Dow's Chief Operating Officer, and is responsible for administration of the cybersecurity and information security framework and risk management, with oversight by the Audit Committee of the Board.
+Added: The Company’s Chief Information and Digital Officer has formal education in information technology and more than 30 years of experience in information systems and technology, including as the vice president of Global Information Technology.
+Added: Prior to joining Dow, the Chief Information and Digital Officer held a variety of leadership roles including vice president of Information Technology at Cargill, Incorporated.
+Added: The Chief Information and Digital Officer receives
+Added: regular updates on cybersecurity matters, results of mitigation efforts and cybersecurity incident response and remediation.
+Added: The Company’s management responsible for developing and executing Dow’s cybersecurity policies is comprised of individuals with either formal education and degrees in information technology or cybersecurity, or with experience working in information technology and cybersecurity, including relevant experience in security related industries.
Additionally, leaders in the Company’s information technology function receive periodic training and education on cybersecurity related topics.
4 unchanged sentences
The CSOC is also responsible for activating the containment and resolution efforts and third-party service providers are engaged where appropriate to support the Company through the resolution of the incident.
−Removed: The CSOC escalates incidents with significant impact and pervasiveness to the Company’s Corporate Crisis Management Team for
−Removed: further action.
+Added: The CSOC escalates incidents with significant impact and pervasiveness to the Company’s Corporate Crisis Management Team for further action.
After initial identification, the CSOC monitors all cybersecurity incidents for changes in degree of impact or pervasiveness.
2 unchanged sentences
The Board is responsible for overseeing overall risk management for the Company, including review and approval of the enterprise risk management approach and processes implemented by management to identify, assess, manage and mitigate risk, at least annually.
−Removed: The Board has delegated responsibility for oversight of the Company’s cybersecurity and information security framework and risk management to the Audit Committee of the Board.
+Added: While the full Board is accountable for cybersecurity and AI risk management, the Board has delegated responsibility for oversight of the Company’s cybersecurity and information security framework and risk management to the Audit Committee of the Board.
The Audit Committee receives information and updates at least quarterly and actively engages with senior leaders, including the Chief Information and Digital Officer and Chief Information Security Officer, with respect to the effectiveness of the Company’s cybersecurity and information security framework, data privacy, and risk management.
In addition, the Audit Committee receives reports summarizing threat detection and mitigation plans, audits of internal controls, training and certification, and other cyber priorities and initiatives, as well as timely updates from senior leaders on material incidents relating to information systems security, including cybersecurity incidents.
+Added: The Audit Committee also reviews external firms’ assessments of the Company’s security posture and NIST CSF maturity level.
+Added: Information made available to the Audit Committee is also made available to the full Board.
The Audit Committee includes members with significant experience and/or expertise in technology or cybersecurity, including information systems.
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.