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Item 1B. Unresolved Staff Comments

2025-02-27 compared with 2024-02-29 · 59 added, 19 removed, 8 unchanged (91% of the section changed)

3 unchanged sentences

Cybersecurity Risk Management and Strategy

We have established and implemented a cybersecurity risk management program and information privacy program (collectively, our “Cybersecurity and Privacy Programs”) that are collectively intended to protect the confidentiality, integrity, and availability of our critical information systems and the information residing therein.

These programs are integrated into, and form a part of, our overall enterprise risk management program, and share similar methodologies, reporting channels and governance processes to those that apply across the broader enterprise risk management framework.

Our Cybersecurity and Privacy Programs include:

• Teams responsible for managing security and privacy controls, risk assessments, and responding to cybersecurity incidents;

We have established and implemented a cybersecurity risk management program and information privacy program

(collectively, our “Cybersecurity and Privacy Programs”) that are collectively intended to protect the confidentiality, integrity,

and availability of our critical information systems and the information residing therein.

These programs are integrated into,

and form a part of, our overall risk management program, and share similar methodologies, reporting channels and

governance processes to those that apply across the broader risk management framework.

Key elements of our Cybersecurity and Privacy Programs include, bu t are not limited to the following :

• Teams responsible for managing security and privacy controls, risk assessments, and responding to

cybersecurity incidents;

• Security and privacy awareness training of our employees;

• Privacy and security risk assessments designed to identify material privacy and/or cybersecurity risks to our systems, processes, and assets;

• The use of external service providers to assist with privacy and security controls, including vulnerability management;

• Privacy and security risk assessments designed to identify material privacy and/or cybersecurity risks to our

systems, processes, and assets;

• The use of external service providers to assist with privacy and security controls, including vulnerability

• An incident response plan with trained personnel and personnel that are trained to execute the plan;

• A third-party risk management process for service providers and vendors.

We are subject to an evolving threat landscape that could pose various risks to our business, and such risks are regularly evaluated and managed via our Cybersecurity and Privacy Programs by internal and external experts.

We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.

For more information regarding risks related to cybersecurity matters, please see Part I, Item 1A, “Risk Factors—We depend on our information technology systems, and those of our third-party vendors, contractors and consultants, and any failure or significant disruptions of these systems, security breaches or loss of data could materially adversely affect our business, financial condition and results of operations.”

We are subject to an evolving threat landscape that could pose various risks to our business, and such risks are

regularly evaluated and managed via our Cybersecurity and Privacy Programs by internal and external experts.

identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have

materially affected us , including our operations, business strategy, results of operations, or financial condition.

information regarding risks related to cybersecurity matters, please see Part I, Item 1A, “Risk Factors—We depend on our

information technology systems, and those of our third-party vendors, contractors and consultants, and any failure or

significant disruptions of these systems, security breaches or loss of data could materially adversely affect our business,

financial condition and results of operations.”

Cybersecurity Governance

Our Board and its committees have an active role in overseeing risk management and they have delegated to the Compliance Committee oversight over our cybersecurity and data privacy risks.

The Compliance Committee oversees management’s implementation of our Cybersecurity and Privacy Programs, except to the extent direct oversight by the Board is required by the FTC Order.

The Compliance Committee receives periodic reports from management regarding cybersecurity and privacy risks, any material updates thereto and a summary of any cybersecurity and/or privacy events or incidents that have occurred, in each case, since the most recent update provided to the Compliance Committee.

The Compliance Committee reports to the full Board regarding its activities, including those related to cybersecurity and privacy.

In addition, at least once every twelve months and promptly after the occurrence of certain specified cybersecurity/data privacy incidents, the Board and our Interim Chief Executive Officer receive the written Cybersecurity and Privacy Program materials, which include the results of the most recent cybersecurity and privacy risk assessment and any evaluations thereof or updates thereto (collectively, the “Reporting Materials”).

On an annual basis, management also leads the Board through a comprehensive review of the Reporting Materials, including, among other things, a review of the identified material cybersecurity and privacy risk exposures and the safeguards implemented to control such risk exposures.

Our Security Team is responsible for assessing and managing our material risks from cybersecurity threats and is primarily responsible for our overall Cybersecurity and Privacy Programs and collaborates with other employees and third parties to identify and mitigate applicable risks.

The Security Team’s experience includes various industry certifications (e.g., CISSP, CISM, CCSP, CISA, etc.), and industry experience (e.g., healthcare, technology, critical infrastructure, etc.).

Under the Cybersecurity and Privacy Programs, our Security Team monitors, prevents, detects, mitigates, and remediates cybersecurity risks and incidents via various means, including monitoring threat intelligence from various sources, internal and external vulnerability management, and alerts and reports produced by security tools.

Reporting of such risks is regularly provided to the Board and the Compliance Committee, as applicable.

Our Board and its committees have an active role in overseeing risk management and they have delegated to the Audit

and Risk Committee oversight over our cybersecurity and data privacy risks, including oversight of management’s

implementation of our Cybersecurity and Privacy Programs, except to the extent direct oversight by the Board is required by

the FTC Order.

The Audit and Risk Committee oversees management’s implementation of our Cybersecurity and Privacy

Programs, except to the extent direct oversight by the Board is required by the FTC Order.

The Audit and Risk Committee receives periodic reports from management regarding cybersecurity and privacy risks,

any material updates thereto and a summary of any cybersecurity and/or privacy events or incidents that have occurred, in

each case, since the most recent update provided to the Audit and Risk Committee.

The Audit and Risk Committee reports

to the full Board regarding its activities, including those related to cybersecurity and privacy.

In addition, at least once every

twelve months and promptly after the occurrence of certain specified cybersecurity/data privacy incidents, the Board and our

Chief Executive Officer and President receive the written Cybersecurity and Privacy Program materials, which include the

results of the most recent cybersecurity and privacy risk assessment and any evaluations thereof or updates thereto

(collectively, the “Reporting Materials”).

On an annual basis, management also leads the Board through a comprehensive

review of the Reporting Materials, including, among other things, a review of the identified material cybersecurity and privacy

risk exposures and the safeguards implemented to control such risk exposures.

Our Security Team is responsible for assessing and managing our material risks from cybersecurity threats and is

primarily responsible for our overall Cybersecurity and Privacy Programs and collaborates with other employees and third

parties to identify and mitigate applicable risks.

Our Security Team is composed of certified cybersecurity professionals

responsible for assessing and managing cybersecurity risks, led by the Senior Director of Information Security &

The qualifications of our Security Team include the following industry-recognized certifications:

ISC2 Certified

Information Systems Security Professional (CISSP), Certified Ethical Hacker (C|EH), Certified Incident Handler (GCIH),

Certified Intrusion Analyst (GCIA), GSEC, CompTIA Security+, A+ Network+, CISM, CCSK, MCSA, MCSE, MCP, MCT, and

Cisco Certified Network Associate (CCNA).

The Senior Director of Information Security & Compliance reports to our Chief

Technology Officer, who has over 19 years of experience in information technology.

The Senior Director of Information

Security & Compliance brings over 13 years of experience in risk management, cybersecurity and compliance.

Team’s experience in information security and cybersecurity spans across various industries, including healthcare,

technology, and critical infrastructure.

Under the Cybersecurity and Privacy Programs, our Security Team monitors, prevents, detects, mitigates, and

remediates cybersecurity risks and incidents via various means, including monitoring threat intelligence from various

sources, internal and external vulnerability management, and alerts and reports produced by security tools.

such risks is regularly provided to the Board and the Audit and Risk Committee, as applicable.

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.

What changed 10-K

Item 1B. Unresolved Staff Comments