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Cybersecurity
−Removed: Assessment, Identification and Management of Material Risks from Cybersecurity
+Added: Assessment, Identification and Management of Material Risks from Cybersecurity Threats
We rely on the cybersecurity strategy and policies implemented by Ares Management, the parent company of our Sponsor.
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Ares Management’s cybersecurity risk management process seeks to monitor cybersecurity vulnerabilities and potential attack vectors, evaluate the potential operational and financial effects of any threat and mitigate such threats.
−Removed: The assessment of cybersecurity risks,
−Removed: Table of Content s
−Removed: including those which may impact us, our Sponsor or Ares Management, is integrated into Ares Management’s Enterprise Risk Management program, which is overseen by the Ares Enterprise Risk Committee (the “Ares Management ERC”), as discussed below.
−Removed: In addition, Ares Management periodically engages with third-party consultants and key vendors to assist it in assessing, enhancing, implementing, and monitoring its cybersecurity risk management programs and responding to incidents.
−Removed: The Ares Management cybersecurity risk management and awareness programs include periodic identification and testing of vulnerabilities, regular phishing simulations and annual general cybersecurity awareness and data protection training, including for all of the employees of Ares Management.
+Added: The assessment of cybersecurity threats, including those which may impact us, our Sponsor or Ares Management, is integrated into Ares Management’s Enterprise Risk Management program, which is overseen by the Ares Enterprise Risk Committee (the “Ares Management ERC”), as discussed below.
+Added: In addition, Ares Management periodically engages with third-party consultants and engages with key vendors to assist it in assessing, enhancing, implementing, and monitoring its cybersecurity risk management programs and responding to incidents.
+Added: The Ares Management cybersecurity risk management and awareness programs include periodic identification and testing of vulnerabilities, regular phishing simulations and annual general cybersecurity awareness and data protection training.
Ares Management’s cybersecurity training programs also include annual certification requirements for employees of Ares Management with respect to certain policies supporting the cybersecurity program including information security and electronic communications, data protection and privacy.
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Ares Management also completes periodic external reviews of its cybersecurity program and practices, which include assessments of relevant data protection practices and targeted attack simulations.
−Removed: In the event of a cybersecurity incident impacting us, our Sponsor or Ares Management, Ares Management has developed an incident response plan that provides guidelines for responding to such an incident and facilitates coordination across multiple operational functions of Ares Management.
+Added: In the event of a cybersecurity incident impacting us, our Sponsor or Ares Management, Ares Management has developed an incident response plan that provides guidelines for responding to an incident and facilitates coordination across multiple operational functions of Ares Management.
The incident response plan includes notification to the applicable members of cybersecurity leadership, including Ares Management’s Chief Information Security Officer (“CISO”), and, as appropriate, escalation to the full Ares Management ERC and/or an internal ad-hoc group of senior employees, tasked with helping to manage the cybersecurity incident.
Depending on their nature, incidents may also be reported to the audit committee or full board of directors of Ares Management, as well as to the audit committee of our board of directors and to our full board of directors, if appropriate.
−Removed: Material Impact of Cybersecurity Risks
−Removed: Since our inception, we have not experienced a material information security breach incident and we are not aware of any cybersecurity risks that are reasonably likely to materially affect our business.
+Added: Material Impact of Risks from Cybersecurity Threats
+Added: We have not experienced an information security breach incident that has materially affected our business strategy, results of operations or financial condition and have not incurred any expenses from information security breach incidents.
+Added: We are not aware of any cybersecurity risks that are reasonably likely to materially affect our business.
However, future incidents could have a material impact on our business strategy, results of operations, or financial condition.
For additional discussion of the risks posed by cybersecurity threats, see “Item 1A.
−Removed: Risk Factors— General Risk Factors— Cybersecurity failures and data security incidents could adversely affect our business by causing a disruption to our operations, a compromise or corruption of our confidential, personal or other sensitive information and/or damage to our business relationships or reputation, any of which could negatively impact our business, financial condition and operating results.”
+Added: Risk Factors— General Risk Factors— Security incidents or cyber-attacks could adversely affect our business by causing a disruption to our operations, a compromise or corruption of our confidential, personal or other sensitive information and/or damage to our business relationships or reputation, any of which could negatively impact our business, financial condition and operating results.”
Oversight of Cybersecurity Risks
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The team is led by Ares Management’s CISO who has a Master’s degree in Cybersecurity from Brown University and over 25 years of experience advising on, and managing risks from cybersecurity threats as well as developing and implementing cybersecurity policies and procedures.
−Removed: The Ares Management’s CISO is also a member of the Ares Management ERC.
−Removed: The Ares Management ERC is a cross-functional committee that governs and oversees the Ares Management Enterprise Risk Program, including cybersecurity.
−Removed: The Ares Management ERC includes members of Ares Management’s senior executive management, including its Chief Executive Officer, Chief Financial Officer, General Counsel, Global Chief Compliance Officer, Chief Information Officer, CISO, and Head of Enterprise Risk, who acts as chairperson of the Ares Management ERC.
+Added: The Ares Management’s CISO reports cybersecurity updates to the Ares Management ERC.
+Added: The Ares Management ERC is a committee that governs and oversees the Ares Management Enterprise Risk Program, including cybersecurity.
+Added: The Ares Management ERC includes members of Ares Management’s senior executive management, including its Chief Executive Officer, Co-Presidents, Chief Financial Officer, General Counsel, Global Chief Compliance Officer and Head of Enterprise Risk, who acts as chairperson of the Ares Management ERC.
The Ares Management ERC, through regular consultation with the Ares Management internal cybersecurity team, assesses, discusses, and prioritizes Ares Management’s approach to high-level risks, mitigating controls, and ongoing cybersecurity efforts.
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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.