2 unchanged sentences
The operating systems of Federated Hermes, and its offerings, customers, shareholders and service providers are dependent on the effectiveness of information security policies and procedures (both at Federated Hermes and at third parties, such as its service providers) which seek to ensure that such systems are protected from cybersecurity incidents.
−Removed: Federated Hermes has established a robust cybersecurity program aimed at assessing, identifying and managing material risks from cybersecurity threats.
+Added: Federated Hermes has
+Added: established a robust cybersecurity program aimed at assessing, identifying and managing material risks from cybersecurity threats.
Federated Hermes’ board of directors has ultimate oversight responsibility for cybersecurity risks and threats.
5 unchanged sentences
Federated Hermes’ Global Technology Organization (GTO), which is headed by Federated Hermes’ CIO, has a dedicated Information Security Group (ISG) responsible for day-to-day oversight of the cybersecurity program.
−Removed: The ISG, which is headed by Federated Hermes’ Chief Information Security Officer (CISO), coordinates cybersecurity activities with Federated Hermes’ business functions and third-party service providers.
−Removed: The ISG also oversees and coordinates cybersecurity efforts with counterparts at FHL.
+Added: The ISG, which is headed by Federated Hermes’ Chief Information Security Officer (CISO), coordinates cybersecurity activities with Federated Hermes’ business functions (including FHL) and third-party service providers.
Federated Hermes’ Information Security and Data Governance Committee (ISDG) provides executive management oversight of the ISG and Federated Hermes’ cybersecurity program.
−Removed: Federated Hermes’ Chief Compliance Officer (CCO), CRO and General Counsel, as well as Federated Hermes’ CIO, CISO, Chief Financial Officer, and other senior members of Federated Hermes’ management, are members of, and Federated Hermes’ Chief Audit Executive attends meetings of, the ISDG.
+Added: Federated Hermes’ Chief Compliance Officer (CCO), CRO and General Counsel, as well as Federated Hermes’ CIO, CISO, Chief Financial Officer, and other senior members of Federated Hermes’ management, and the Global Head of Investment Technology at FHL are members of, and Federated Hermes’ Chief Audit Executive attends meetings of, the ISDG.
The ISDG’s primary functions are to:
15 unchanged sentences
Some of the measures employed by Federated Hermes to mitigate cybersecurity risk include, among others, use of firewalls, system segmentation, system monitoring, virus scanning, and periodic penetration and phishing testing.
−Removed: Federated Hermes’ cybersecurity program also includes a detailed incident response plan for responding to
−Removed: cybersecurity threats.
+Added: Federated Hermes’ cybersecurity program also includes a detailed incident response plan for responding to cybersecurity threats.
Federated Hermes’ cybersecurity program also requires periodic training of employees on cybersecurity threats, including phishing and cybersecurity awareness campaigns.
2 unchanged sentences
Due diligence consists of reviewing several key data points regarding service providers.
−Removed: These include, but are not limited to, the business processes the service provider will provide, the sensitivity of the data they will store, process, transmit or access, and network connectivity with the service provider.
+Added: These include, but are not limited to, the business
+Added: processes the service provider will provide, the sensitivity of the data they will store, process, transmit or access, and network connectivity with the service provider.
Using this criteria, Federated Hermes will categorize the service provider into a tiered structure.
The tiering defines the requirements for conducting the initial and ongoing due diligence.
−Removed: Federated Hermes’ CIO has nearly 30 years of technology experience.
+Added: Federated Hermes’ CIO has more than 30 years of technology experience.
Prior to assuming his current role in 2016, Federated Hermes’ CIO served in senior technology roles with a large U.S.
1 unchanged sentence
He holds a Bachelor of Science (BS) in Electrical Engineering from the University of Pittsburgh, a Master of Science (MS) in Engineering from Youngstown State University, and a Master of Business Administration (MBA) from Carnegie Mellon University.
−Removed: Federated Hermes’ CISO has nearly 20 years of technology experience, including deep experience in cybersecurity risk management.
+Added: Federated Hermes’ CISO has 20 years of technology experience, including deep experience in cybersecurity risk management.
Prior to assuming his current role in 2020, Federated Hermes’ CISO served as information security officer and director of technology for a large publicly traded travel center company and, prior to that, as information security officer for a leading retail chain.
10 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.