3 unchanged sentences
We have established policies and processes for assessing, identifying, and managing material risk from cybersecurity threats, and have integrated these processes into our overall risk management systems and processes.
−Removed: We routinely assess material risks from cybersecurity threats, including any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality, integrity, or availability of our information systems or any information residing therein.
+Added: We routinely assess material risks from cybersecurity threats, including any potential unauthorized occurrence on or conducted through our
+Added: information systems that may result in adverse effects on the confidentiality, integrity, or availability of our information systems or any information residing therein.
We conduct periodic risk assessments to identify cybersecurity threats, as well as assessments in the event of a material change in our business practices that may affect information systems that are vulnerable to such cybersecurity threats.
3 unchanged sentences
and regularly monitor the effectiveness of our safeguards.
−Removed: We devote significant resources and designate high-level personnel, including our Chief Financial Officer, to manage the risk assessment and mitigation processes.
+Added: We devote significant resources and designate high-level personnel, including our Director of IT who reports to our Chief Financial Officer, to manage the risk assessment and mitigation processes.
As part of our overall risk management system, we monitor and test our safeguards and train our employees on these safeguards, in collaboration with human resources, IT, and management.
7 unchanged sentences
Our board of directors administers its cybersecurity risk oversight function directly as a whole, as well as through the audit committee.
−Removed: Our Chief Financial Officer is primarily responsible for the assessment and management of our material risks from cybersecurity threats, and the oversight of our cybersecurity policies and processes, including those described in “Risk
−Removed: Management and Strategy” above.
−Removed: Our Chief Financial Officer and our IT consultant collectively have significant prior work experience in various roles involving managing information security and implementing effective information and cybersecurity programs.
+Added: Our Chief Financial Officer and Director of IT are primarily responsible for the assessment and management of our material risks from cybersecurity threats, and the oversight of our cybersecurity policies and processes, including those described in “Risk Management and Strategy” above.
+Added: Our Chief Financial Officer, our Director of IT, and our IT consultant collectively have significant prior work experience in various roles involving managing information security and implementing effective information and cybersecurity programs.
They are informed about and monitor the prevention, mitigation, detection and remediation of cybersecurity incidents.
1 unchanged sentence
We have implemented processes to monitor security threats and vulnerabilities and respond to all cybersecurity incidents that could have an impact on our business operations, including prompt escalation and communication of major security incidents to senior leadership and our board of directors.
−Removed: Our Chief Financial Officer provides annual briefings to the audit committee regarding the Company’s cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity systems testing, activities of third parties, and the like.
+Added: Our Chief Financial Officer and Director of IT provide annual and as needed briefings to the audit committee regarding the Company’s cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity systems testing, activities of third parties, and the like.
The audit committee provides regular updates to the board of directors on such reports.
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.