Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
None.
ITEM 1C. CYBERSECURITY
Our cybersecurity team, led by our Chief Technology
Officer, Peter Shelus, uses a multi-pronged approach to assessing, identifying, and managing material risks from cybersecurity threats .
This approach includes identifying and assessing risks through: (1) an enterprise risk management program, which is periodically refreshed
and includes an identification of our top risks, including cybersecurity risks; (2) formalized security and privacy reviews designed
to identify risks from many new features, software, and vendors; (3) a vulnerability management program designed to identify hardware
and software vulnerabilities; (4) an internal “red team” program, which simulates cyber threats, intended to allow us to
fix vulnerabilities before threat actors identify them; (5) a threat intelligence program designed to model and research our adversaries;
and (6) a privacy and security incident response program designed to investigate, respond to, and remediate known incidents. These processes
vary in scope and maturity across the business and are processes we work to continually improve.
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Our risk management approach is supplemented
by external and internal enterprise risk management audits, which are designed to test the effectiveness of our security controls. We
conduct penetration testing on a periodic basis, and have established an external bug bounty program to allow security researchers to
help identify vulnerabilities and weaknesses in our controls and configurations in our systems. We also maintain a vendor risk management
program designed to identify and mitigate potential risks associated with third-party suppliers and business partners. This program includes
pre-engagement diligence, use of contractual cybersecurity and notification provisions, and ongoing monitoring of vendors, as appropriate.
We use third-party service providers to assist
us from time to time to identify, assess, and manage material risks from cybersecurity threats, including for example professional service
firms (including legal counsel), threat intelligence services, and cybersecurity consultants.
The material cybersecurity threats identified
through these processes are managed by our CISO and, where appropriate, our risk and compliance committee, in consultation with management.
Together, they identify responsive actions for inclusion in our annual strategic planning, or earlier resolution depending on the nature
of the risk.
For a description of the risks from cybersecurity
threats that may materially affect us and how they may do so, see “Risk Factors” in Part I, Item 1A in this Annual Report
on Form 10-K.
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