5 unchanged sentences
The ISP regularly performs cyber assessments and assists our Adviser and Administrator in monitoring our cyber and information security programs.
−Removed: The ISP proposes recommendations for improvements to our Adviser’s Head of Resource Management, Director of IT and Chief Compliance Officer ("CCO"), which then are considered by other relevant officers of our Adviser and Administrator before implementation.
+Added: The ISP proposes recommendations for improvements to our Adviser’s Head of Resource Management, Director of IT and Chief Compliance Officer ("CCO"), which then are considered by other relevant officers of our Adviser and Administrator before improvements are implemented to our information technology strategy, cybersecurity, and incident response policies, processes and procedures.
In addition, regular ongoing cybersecurity threat risk assessments, which also cover third-party business applications, are performed throughout the year and reported to our officers and Board of Directors by our CCO no less than quarterly.
5 unchanged sentences
• implementation of industry leading Cloud solutions and business applications which possess integrated cybersecurity safeguards;
+Added: • restrict access to known devices only;
• anti-malware, antivirus and threat detection software;
9 unchanged sentences
In addition to the ongoing dialogue and technology interaction between the Director of IT, our Adviser and Administrator and the ISP, any significant findings in these reports are shared with us, including our Board of Directors and other officers, to enhance ongoing monitoring and assessment of our information technology and cybersecurity risk management.
−Removed: Our Adviser and Administrator also regularly trains employees working on our behalf on the evolving threats and educates them on cybersecurity risks to provide an additional protection barrier through end-user knowledge.
+Added: While our ISP works to create a hardened information technology systems environment, our Adviser and Administrator also regularly train employees working on our behalf on the evolving threats and educates them on cybersecurity risks.
+Added: Whether it is communicating information about the latest cybersecurity threats, assessing employees’ awareness through mock fraud exercises, social engineering and phishing campaigns, or providing access to a library of educational material about past and newly evolving cybersecurity attacks, our Adviser and Administrator work in concert with the ISP, on our behalf, to keep employees servicing us informed so as to provide an additional protection barrier through end-user knowledge.
Notwithstanding our risk management and strategy described above, we may not be successful in preventing or mitigating a cybersecurity incident that could have a material adverse effect on us.
15 unchanged sentences
Certain members of our Board of Directors have, or previously held, positions with other companies, including other public companies, that involved managing risks associated with their cyber and information technology systems.
+Added: Our Board of Directors regularly receives updates from third parties on various business risks, which include cybersecurity matters.
We do not own any real estate or other physical properties material to our operations.
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.