2 unchanged sentences
Cybersecurity Risk, Management and Strategy
−Removed: Cybersecurity is a significant and integrated component of the Company’s risk management strategy, designed to protect the confidentiality, integrity, and availability of sensitive information contained within the Bank’s information services.
+Added: Cybersecurity is a significant and integrated component of the Company’s risk management strategy, designed to protect the confidentiality, integrity, and availability of sensitive information contained within the Company’s information services.
As a financial services company, cyber threats are present and growing, and the potential exists for a cybersecurity incident disrupting business operations, compromising sensitive data or both.
4 unchanged sentences
Employees play a significant role in the defense against cybersecurity threats.
−Removed: Every employee is responsible for protecting the Bank and client information.
+Added: Every employee is responsible for protecting the Company’s and client’s information.
Accordingly, employees complete formal training and acknowledge security policies annually.
5 unchanged sentences
many of these vendors have access to sensitive and proprietary information.
−Removed: Third-party vendors continue to be a notable source of operational and informational risk.
+Added: Third-party vendors continue to be a notable source of operational
+Added: and informational risk.
Accordingly, the Company has implemented a Third-Party Risk Management program, which includes a detailed onboarding process and periodic reviews of vendors with access to sensitive company data.
7 unchanged sentences
Management Committee Oversight
−Removed: The Company has established an Information Technology and Security Management Committee consisting of department leaders across multiple functional areas including Data Engineering, Enterprise Applications, Strategic Planning, Technology, and Cybersecurity.
+Added: The Company has established an Information Technology and Security Management Committee consisting of department leaders across multiple functional areas including Data Engineering, Enterprise Applications, Strategic Planning, Technology, IT Governance, and Cybersecurity.
These functional areas are led by qualified financial service technology professionals, with extensive certifications and advanced degrees in cybersecurity.
3 unchanged sentences
All Information Security activity is led by the Chief Information Security Officer , which includes developing and implementing the information security program and reporting on cybersecurity matters to the Board .
−Removed: The Chief Information Security Officer has several years of experience leading cybersecurity operations in financial services, supported by a team with various security,
−Removed: technical, risk, audit and leadership certifications.
+Added: The Chief Information Security Officer has several years of experience leading cybersecurity operations in financial services, supported by a team with various security, technical, risk, audit and leadership certifications.
Management provides cybersecurity statistics and details to the board monthly.
6 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.