19 unchanged sentences
The assessment, identification and management of cybersecurity-related risks are integrated into the Company’s overall Enterprise Risk Management (“ERM”) process.
−Removed: Cybersecurity risk is included among the significant residual risks identified during the Company’s assessment of business risk.
+Added: Technology risk, which includes cybersecurity risk, is included among the significant residual risks identified during the Company’s assessment of business risk.
This risk assessment process is used to inform the Company’s strategic planning process, and to develop action plans to appropriately address and manage risk.
4 unchanged sentences
We engage third-party subject matter experts and consultants to conduct evaluations of our security controls, including, but not limited to, penetration testing, maturity assessments or consulting on our response to emerging threats.
−Removed: Results of these evaluations are used to help determine priorities and initiatives to improve the overall
+Added: Results of these evaluations are used to help determine priorities and initiatives to improve the overall Program.
As necessary, we also engage third-party experts and consultants to assist with the incident response process to augment our internal security operation center team.
7 unchanged sentences
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.