3 unchanged sentences
We have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information.
−Removed: Our cybersecurity risk management program is integrated into our overall enterprise risk management program, and shares common methodologies, reporting channels and governance processes that apply across the enterprise risk management program to other legal, compliance, strategic, operational, and financial risk areas.
+Added: Our cybersecurity risk management program is integrated into our overall risk management program, and shares common methodologies, reporting channels and governance processes that apply across the enterprise risk management program to other legal, compliance, strategic, operational, and financial risk areas.
We perform an annual assessment to measure the maturity of our information security program in a manner aligned with the National Institute of Standards and Technology (“NIST”) Cybersecurity Framework (“CSF”).
This does not imply that we meet any specific technical standards, specifications, or requirements, only that we use the NIST CSF as a guide to implement controls to combat and respond to cybersecurity risks.
−Removed: Key elements of our cybersecurity risk management program include:
−Removed: • risk assessments designed to help identify material cybersecurity risks to our critical systems, information, products, services, and our broader enterprise IT environment;
+Added: Key elements of our cybersecurity risk management program include, but are not limited to, the following:
+Added: • risk assessments designed to help identify material risks from cybersecurity threats to our critical systems and information;
• a designated team responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls, and (3) our response to cybersecurity incidents;
4 unchanged sentences
We face risks from cybersecurity threats that, if realized, are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.
−Removed: See “Item 1A:
−Removed: Risk Factors” above for additional information on risks related to, for example risks related to cyber-attacks, information and system breaches, and technology disruptions and failures;
+Added: See Item 1A, "Risk Factors” above for additional information on risks related to, for example risks related to cyber-attacks, information and system breaches, and technology disruptions and failures;
our reliance on using and protecting certain intellectual property rights;
5 unchanged sentences
The Committee receives periodic reports from management on our cybersecurity risks.
−Removed: In addition, management updates the Committee, as where it deems appropriate, regarding any material cybersecurity incidents, as well as certain incidents with lesser impact potential.
+Added: In addition, management updates the Committee, as where it deems appropriate, regarding any material cybersecurity incidents.
The Committee reports to the full Board regarding its activities, including those related to cybersecurity.
−Removed: Our management and senior IT team, including our Interim Chief Executive Officer, Chief Financial Officer and Operating Officer, Chief Legal Officer, Sr.
−Removed: Director, IT Infrastructure and Operations, and SVP, People & Culture, are responsible for assessing and managing our material risks from cybersecurity threats.
+Added: Our management and senior IT team, including our Chief Executive Officer, Chief Financial Officer, Chief Legal Officer, Global Head of Technology, and SVP, People & Culture , are responsible for assessing and managing our material risks from cybersecurity threats.
The team has primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our retained external cybersecurity consultants.
−Removed: This team's experience includes over 40 years in system engineering, risk management, data privacy and compliance monitoring.
+Added: Our Global Head of Technology's experience includes over 20 years in system engineering, risk management, data privacy and compliance monitoring .
We also engage an external Data Protection Officer to monitor data collection and security in the European Union.
3 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.