6 unchanged sentences
Our Chief Information Security Officer (the "CISO") is primarily responsible for this cybersecurity component and is a key member of the risk management organization, reporting directly to the Senior Management Team (“SMT”) and our Tech Oversight Committee.
−Removed: Our Tech Oversight Committee includes members of our Board and management.
+Added: Our Tech Oversight Committee includes members of our Board of Directors and management.
Our CISO has served in this capacity for more than a decade and maintains multiple certifications issued by the Information Systems Audit and Control Association ("ISACA") and the SANS Institute.
21 unchanged sentences
Our company recognizes the importance of safeguarding company and customer information.
−Removed: Therefore, the Board of Directors recognizes that the protection of this information ranks as one of our highest priorities.
−Removed: The Board of Directors is responsible for reviewing and approving the ICSPP and ICSIRP at least annually and monitoring material risks facing our company.
−Removed: The Board recently added a member who possesses specialized expertise in cybersecurity matters.
+Added: Therefore, our Board of Directors recognizes that the protection of this information ranks as one of our highest priorities.
+Added: Our Board of Directors is responsible for reviewing and approving the ICSPP and ICSIRP at least annually and monitoring material risks facing our company.
+Added: In January 2025, our Board of Directors added a member who possesses specialized expertise in cybersecurity matters.
Director Sara A.
Schmidt currently serves as chief information security officer for US Foods and executive sponsor of the West Michigan Cyber Security Consortium.
−Removed: The Board has tasked the SMT with overseeing efforts to develop, implement and maintain an effective information and cybersecurity program.
+Added: Our Board of Directors has tasked the SMT with overseeing efforts to develop, implement and maintain an effective information and cybersecurity program.
The SMT designates the CISO, who also serves as the IRT leader.
−Removed: As part of its oversight responsibilities, the Board of Directors is responsible for discussing with the SMT our company’s major risk exposures, such as cybersecurity, and the steps management has taken to monitor and control those exposures, including our risk assessment and risk management policies.
−Removed: The Board of Directors also monitors our compliance with legal and regulatory requirements and the risks associated therewith.
+Added: As part of its oversight responsibilities, our Board of Directors is responsible for discussing with the SMT our company’s major risk exposures, such as cybersecurity, and the steps management has taken to monitor and control those exposures, including our risk assessment and risk management policies.
+Added: Our Board of Directors also monitors our compliance with legal and regulatory requirements and the risks associated therewith.
On a regular basis, our Tech Oversight Committee reviews with the SMT significant areas of risk exposure involving cybersecurity.
5 unchanged sentences
The CISO prepares reports on IT general controls and cybersecurity metrics for the SMT and Tech Oversight Committee periodically.
−Removed: The Board of Directors meets with the CISO periodically to discuss cybersecurity.
+Added: Our Board of Directors meets with the CISO periodically to discuss cybersecurity.
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.