UNRESOLVED STAFF COMMENTS
−Removed: Not applicable.
CYBERSECURITY
1 unchanged sentence
Overall Risk Management.
−Removed: The Company has implemented a cyber risk management program to help ensure that the Company's electronic information and information systems are protected from various threats and are built on and follow the Cybersecurity Maturity Model Certification for information security requirements and the protection of sensitive information.
−Removed: The cyber risk management program is maintained as part of the Company's overall governance, enterprise risk management program and compliance program.
−Removed: The Company's information systems experience ongoing and often sophisticated cyberattacks by a variety of sources with the apparent aim to breach the Company's cyber-defenses.
−Removed: The Company may face increased cyber risk due to the increased use of employee-owned devices and work from home arrangements.
−Removed: The Company also has cyber event related insurance.
−Removed: The Company is continuously reevaluating the need to upgrade and/or replace systems and network infrastructure.
−Removed: These upgrades and/or replacements could adversely impact operations by imposing substantial capital expenditures, creating delays or outages, or experiencing difficulties transitioning to new systems.
−Removed: System disruptions, if not anticipated and appropriately mitigated, could adversely affect the Company.
−Removed: The Company continually assesses risks from cybersecurity threats and adapts and enhances its controls accordingly.
+Added: We have implemented a cyber risk management program to help ensure that our electronic information and information systems are protected from various threats and are built on and follow the Cybersecurity Maturity Model Certification for information security requirements and the protection of sensitive information.
+Added: The cyber risk management program is maintained as part of our overall governance, enterprise risk management program and compliance program.
+Added: Our information systems experience ongoing and often sophisticated cyberattacks by a variety of sources with the apparent aim to breach our cyber-defenses.
+Added: We also have cyber event related insurance.
+Added: We are continuously reevaluating the need to upgrade and/or replace systems and network infrastructure.
+Added: These upgrades and/or replacements could adversely impact operations by imposing increased expenses, creating delays or outages, or experiencing difficulties transitioning to new systems.
+Added: System disruptions, if not anticipated and appropriately mitigated, could adversely affect our company.
+Added: We continually assess risks from cybersecurity threats and adapt and enhance our controls accordingly.
Risks from Cybersecurity Threats.
−Removed: Although risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have not materially affected or are reasonably likely to materially affect the Company, including its business strategy, results of operations or financial condition, such incidents could have a material adverse effect in the future as cyberattacks continue to increase in frequency and sophistication.
+Added: Although risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have not materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition, such incidents could have a material adverse effect in the future as cyberattacks continue to increase in frequency and sophistication.
Employee Cybersecurity Training.
−Removed: The Company provides ongoing cybersecurity training and compliance programs to facilitate education for employees who may have access to the Company's data and critical systems.
+Added: We provide ongoing cybersecurity training and compliance programs to facilitate education for employees who may have access to our data and critical systems.
Employee phishing tests are conducted on a monthly basis.
Engage Third-parties on Risk Management .
−Removed: Periodic external reviews, including penetration tests and security framework assessments, are conducted by auditors, external assessors, and/or consultants to assess and ensure compliance with the Company’s information security programs and practices.
−Removed: Internal and external auditors assess the Company’s information technology general controls on an annual basis.
+Added: Periodic external reviews, including penetration tests and security framework assessments, are conducted by auditors, external assessors, and/or consultants to assess and ensure compliance with our information security programs and practices.
+Added: Internal and external auditors assess our information technology general controls on an annual basis.
Oversee Third-party Risk .
−Removed: The Company has a third-party management risk program to help monitor and reduce risks associated with the Company's vendors, which includes processes such as completing due diligence on third party service providers before engaging with them for their services;
+Added: We monitor risks associated with our vendors, which include processes such as completing due diligence on third party service providers before engaging with them for their services;
assessing the third party’s cybersecurity posture by reviewing audit reports of the third party, completing cyber questionnaires, and reviewing applicable certification;
6 unchanged sentences
The board, as a whole and through its committees, has responsibility for oversight of risk management.
−Removed: In its risk oversight role, the board of directors has the responsibility to satisfy itself that the risk management processes designed and implement by management are adequate for identifying, assessing, and managing risk.
−Removed: The audit committee of the board of directors of the Company is responsible for oversight of risks from cybersecurity threats.
+Added: In its risk oversight role, the board of directors has the responsibility to satisfy itself that the risk management processes designed and implemented by management are adequate for identifying, assessing, and managing risk.
+Added: The audit committee of the board of directors of our company is responsible for oversight of risks from cybersecurity threats.
Management's Role Managing Risk.
3 unchanged sentences
Cybersecurity Incident Response.
−Removed: The Company has an incident response plan to identify, protect, detect, respond to, and recover from cybersecurity threats and incidents that is also tested on an annual basis.
+Added: We have an incident response plan to identify, protect, detect, respond to, and recover from cybersecurity threats and incidents that is also tested on an annual basis.
The incident response plan is updated based on results of the test or as new cyber related developments occur.
2 unchanged sentences
Monitor, Manage, and Safeguard Against Cybersecurity Incidents and Risks.
−Removed: The Company's vice president of support services, along with the supervisor of cybersecurity, a designated security team of professionals and third-party cybersecurity experts are responsible for assessing and managing risks as well as developing and implementing policies, procedures, and practices based on the range of threats faced by the Company.
−Removed: processes around access management, data security, encryption, asset management, secure system development, security operations, network and device security to provide safeguards from a cybersecurity incident along with continual monitoring of various threat intelligence feeds.
+Added: Our vice president of support services, along with the supervisor of cybersecurity, a designated security team of professionals and third-party cybersecurity experts are responsible for monitoring, assessing and managing risks as well as developing and implementing policies, procedures, and practices based on the range of threats we face.
+Added: There are processes around access management, data security, encryption, asset management, secure system development, security operations, network and device security to provide safeguards from a cybersecurity incident along with continual monitoring of various threat intelligence feeds.
Cyber Risk Management Personnel.
Through training and compliance programs, the concept that all employees are responsible for the data and critical systems they access is reinforced.
−Removed: The information technology department for the Company has the responsibility to implement cybersecurity controls under the overall guidance of the cybersecurity team.
+Added: The information technology department has the responsibility to implement cybersecurity controls under the overall guidance of the cybersecurity team.
This cybersecurity team includes internal cybersecurity experts that have a combined 28 years of general information technology experience and 18 years of cyber specific related experience.
−Removed: The internal cyber team have obtained various degrees and certificates in network administration, security administration and information system management.
−Removed: The Company also partners with a third-party cybersecurity firm that assists the Company and many other clients in setting direction, implementing cybersecurity technology and supporting the Company’s security operations center.
−Removed: The information technology department is led by two directors, one with over 20 years experience in information technology leadership roles at Knife River and the other with 14 years of combined experience in information technology roles at MDU Resources and Knife River.
+Added: The internal cyber team members have obtained various degrees and certificates in network administration, security administration and information system management.
+Added: We also partner with a third-party cybersecurity firm that assists us and many other clients in setting direction, implementing cybersecurity technology and supporting our security operations center.
+Added: Our internal information technology department is led by two directors, one with 25 years of experience in information technology leadership roles at Knife River and the other with 15 years of experience in information technology roles at MDU Resources and Knife River combined.
The information technology department, including the cybersecurity team, reports to the vice president of support services, who has 18 years of information technology leadership and operational leadership experience with Knife River and over 30 years of total information technology experience.
1 unchanged sentence
Cyber Risk Oversight Committee.
−Removed: Additionally, the Company established CyROC to provide executive management and the audit committee with analyses, appraisals, recommendations, and pertinent information concerning cyber defense of the Company's electronic information, information technology and operation technology systems.
−Removed: The CyROC is responsible for guiding the Company's comprehensive cybersecurity policies.
−Removed: The CyROC is chaired by the Company's supervisor of cybersecurity and is comprised of members from financial and operations management, as well as technology leaders.
+Added: Additionally, we established CyROC to provide executive management and the audit committee with analyses, appraisals, recommendations, and pertinent information concerning cyber defense of our electronic information, information technology and operation technology systems.
+Added: The CyROC is responsible for guiding our comprehensive cybersecurity policies.
+Added: The CyROC is chaired by our supervisor of cybersecurity and is comprised of members from financial and operations management, as well as technology leaders.
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.