5 unchanged sentences
The ISP regularly performs cyber assessments and assists us in maintaining our cyber and information security programs.
−Removed: The ISP proposes recommendations for improvements to our Adviser’s Head of Resource Management, Director of IT, and Chief Compliance Officer (“CCO”), which are then considered by other officers and employees of our Adviser and Administrator
−Removed: Table of Content
−Removed: working on our behalf before improvements are implemented to our information technology strategy, cybersecurity, and incident response policies, processes, and procedures.
+Added: The ISP proposes recommendations for improvements to our Adviser’s Head of Resource Management, Director of IT, and Chief Compliance Officer (“CCO”), which are then considered by other officers and employees of our Adviser and Administrator working on our behalf before improvements are implemented to our information technology strategy, cybersecurity, and incident response policies, processes, and procedures.
In addition, regular ongoing cybersecurity threat risk assessments, which also cover third-party business applications, are performed throughout the year and reported to our officers and Board of Directors by our CCO no less than quarterly.
25 unchanged sentences
The reports are distributed to our Board of Directors, and our CCO engages in detailed discussions with the independent board members during the independent members’ session.
−Removed: The reports cover all potentially material cybersecurity threats facing us, as well as key
−Removed: Table of Content
−Removed: risks and mitigation efforts undertaken by us and our Adviser and Administrator.
+Added: The reports cover all potentially material cybersecurity threats facing us, as well as key risks and mitigation efforts undertaken by us and our Adviser and Administrator.
As significant threats or events are identified by management or the ISP between regular reporting periods, our CCO will inform our Board of Directors immediately and keep it informed as to the developments of assessing the risks, mitigating efforts, and potential disclosure.
6 unchanged sentences
These managers, as well as other management personnel, attend various professional continuing education programs that include cybersecurity matters.
−Removed: Certain members of our Board of Directors have, or previously held, positions with other companies, including other public companies, that involved managing risks associated with their cyber and information technology systems.
+Added: Certain members of our Board of Directors have, or previously held, positions with other companies, including other
+Added: public companies, that involved managing risks associated with their cyber and information technology systems.
Our Board of Directors regularly receives updates from third parties on various business risks, which include cybersecurity matters.
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.