Unresolved Staff Comments .
−Removed: Not applicable.
Cybersecurity Risk Management, Strategy and Governance.
2 unchanged sentences
Risk Assessment .
−Removed: Our internal cybersecurity team conducts regular assessments designed to assess, identify, and manage material risks from cybersecurity threats and vulnerabilities within our systems and processes.
+Added: O u r internal cybersecurity team conducts regular assessments designed to assess, identify, and manage material risks from cybersecurity threats and vulnerabilities within our systems and processes.
These assessments are part of our ongoing risk management strategy and inform strategic decisions regarding security investments and policy developments.
5 unchanged sentences
We maintain a set of cybersecurity policies and procedures that are regularly reviewed and updated.
−Removed: These policies are crafted in accordance with certain components of the National Institute of
−Removed: Standards and Technology Cybersecurity Framework, which provides a policy foundation for critical infrastructure security.
+Added: These policies are crafted in accordance with certain components of the National Institute of Standards and Technology Cybersecurity Framework, which provides a policy foundation for critical infrastructure security.
These policies govern our cybersecurity program, including but not limited to access control, system development life cycle management, change management, and incident response.
9 unchanged sentences
We are cognizant of the ever-evolving landscape of cybersecurity threats and their potential to materially impact our operations.
−Removed: To date, we do not believe that we have experienced any cybersecurity incidents that have had a material adverse effect on our business strategy, operations or financial condition.
+Added: To date, to our knowledge we do not believe that we have experienced any cybersecurity incidents that have had a material adverse effect on our business strategy, operations or financial condition.
However, we recognize that cybersecurity threats are a significant risk factor for any organization, especially those involved in digital infrastructure.
20 unchanged sentences
We utilize vulnerability management software, which helps us identify risks within our environment.
−Removed: Our Audit Committee meets quarterly to review cyber security compliance initiatives as they are escalated from our cybersecurity team through management and reviews the enterprise risk matrix prepared by management on an annual basis.
−Removed: Our Information Security Manager has over 15 years of cybersecurity experience in information security and holds CISSP, CRISC, and Security+ certifications and has a MS in Information Assurance.
−Removed: Our Enterprise Risk Committee is briefed quarterly on cybersecurity threats and mitigation strategies by security.
+Added: Our Audit Committee meets quarterly to review cyber security compliance initiatives as they are escalated from our cybersecurity team through management and reviews the enterprise risk matrix prepared by management on at least an annual basis.
+Added: Our Information Security Manager has over 15 years of cybersecurity
+Added: experience in information security and holds CISSP, CRISC, and Security+ certifications and has a MS in Information Assurance.
+Added: Our senior leadership team is briefed quarterly on cybersecurity threats and mitigation strategies by security.
Updates include incident trends, compliance status, and responses to emerging threats.
6 unchanged sentences
The Information Security Coordinator promptly notifies the Chair of our Audit Committee of any significant security events reviewed by the SIRT, the SIRT’s determination of whether a security event is reportable on Form 8-K pursuant to the SEC Cyber Rule and the factors underlying that determination.
−Removed: If the SIRT determines that a cybersecurity incident is likely material and therefore reportable on Form 8-K, a draft of the Form 8-K will be provided to our Audit Committee for review and comment prior to us filing the Form 8-K within the deadline specified by the SEC’s cybersecurity disclosure rules.
+Added: If the SIRT determines that a cybersecurity incident is likely material and therefore reportable on Form 8-K, a Form 8-K will be prepared and filed, in consultation with our Audit Committee.
Our Audit Committee’s active engagement with and oversight of our cybersecurity program helps foster a culture of security awareness throughout our company.
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.