UNRESOLVED STAFF COMMENTS
−Removed: Table of C o ntents
CYBERSECURITY
21 unchanged sentences
The Company promotes a culture where cybersecurity awareness is recognized as everyone's responsibility.
−Removed: Regular communications about cybersecurity risk mitigation and intrusion prevention measures are shared with senior management and the Board of Directors.
+Added: Regular communications about cybersecurity risk mitigation and intrusion prevention measures are shared with senior management and the Board of i-80.
Incident History
1 unchanged sentence
Governance Structure
−Removed: IT Director’s Role
−Removed: • The IT Director leads the cybersecurity risk management program with over 25 years of experience in managing cybersecurity programs, auditing, and IT operations within the US mining and manufacturing sectors.
−Removed: They possess a bachelor’s degree in computer information security and a master’s degree in management information systems.
−Removed: Board of Directors Involvement
−Removed: • The Board is actively engaged in overseeing the cybersecurity program, receiving regular updates and assessments concerning governance and compliance.
−Removed: Quarterly updates from the IT Director cover the status of cybersecurity controls, exposures, and overall program results.
−Removed: The Board insists on being informed about any material cybersecurity incidents.
−Removed: This structured overview distills the essence of the cybersecurity risk management and governance processes within the Company, emphasizing the proactive approach to cybersecurity management and the involvement of leadership at all levels.
−Removed: Table of C o ntents
+Added: Board and Management Oversight
+Added: • The Company is confident that any material cybersecurity threats will be brought to the attention of the Board, as the Senior Management Team includes the affirmative responsibility to periodically review risk assessments from management with respect to cybersecurity, including assessments of the overall threat landscape and related strategies and investments.
+Added: One way in which the Senior Management Team fulfills that requirement is by receiving regular reports from the IT Director on not only known cybersecurity threats or incidents (including related risk assessments), but the landscape more generally, including with respect to known threats, technological advancements, best practices and current events.
+Added: Management regularly reviews cyber security planning, including development and management of the program, budgeting, and participation in the incident response plan.
+Added: The senior management team involved in this review includes our CEO, Chief Financial Officer ("CFO"), and the Director of IT .
+Added: These reviews can also provide topics for discussion at Board and/or Audit Committee meetings.
+Added: The Director of IT has a master’s degree in management information systems and over 28 years of experience.
+Added: The fully staffed department includes a third-party resource dedicated to cybersecurity who monitors our threat detection and response tools for any attempted or successful hacks or other incursions into our IT environment, both externally and internally.
+Added: These are reviewed and mitigated where appropriate, and escalated, if necessary, via the processes noted above.
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.