What changed in this filing

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Item 1B. Unresolved Staff Comments

2026-02-26 compared with 2025-02-27 · 29 added, 27 removed, 40 unchanged (58% of the section changed)

5 unchanged sentences

(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 :

and availability of our critical information systems and the information residing therein and are aligned with the National

Institute of Standards and Technology Cybersecurity Framework.

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, but are not limited to the following:

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

19 unchanged sentences

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.

performance of our Cybersecurity and Privacy Programs, 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 &

responsible for our overall Cybersecurity and Privacy Programs.

Our Security Team also 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

& Compliance.

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

9 unchanged sentences

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.

Under the Cybersecurity and Privacy Programs, our Security Team takes steps to stay informed, monitor, prevent,

detect, mitigate, and remediate 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 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