Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
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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.
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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