3 unchanged sentences
Cybersecurity Risk Management and Strategy
−Removed: We have integrated cybersecurity risk management into our broader risk management framework to promote a company-wide culture of cybersecurity risk management.
−Removed: This integration is intended to make cybersecurity considerations an integral part of our decision-making processes.
−Removed: Our cybersecurity risk management program is integrated into our overall enterprise risk management program, and shares common methodologies, reporting channels and governance processes that apply across the enterprise risk management program to other legal, compliance, strategic, operational, and financial risk areas.
−Removed: Our cybersecurity risk management program includes:
−Removed: risk assessments designed to help identify material cybersecurity risks to our critical systems, information, products, services, and our broader enterprise information technology environment;
+Added: We have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information.
+Added: We design and assess our program based on the National Institute of Standards and Technology Cybersecurity Framework (“NIST CSF”).
+Added: This does not imply that we meet any particular technical standards, specifications or requirements, only that we use the NIST CSF as a guide to help us identify, assess and manage cybersecurity risks relevant to our business.
+Added: Our cybersecurity risk management program is integrated into our overall risk management program, and shares common methodologies, reporting channels and governance processes that apply across the risk management program to other legal, compliance, strategic, operational, and financial risk areas.
+Added: Key elements of our cybersecurity risk management program include, but are not limited to the following:
+Added: risk assessments designed to help identify material cybersecurity threats to our critical systems and information;
a management team responsible for managing ( 1 ) our cybersecurity risk assessment processes, ( 2 ) our security controls and ( 3 ) our response to cybersecurity incidents;
−Removed: the use of external service providers , where appropriate, to assess, test or otherwise assist with aspects of our security controls;
−Removed: cybersecurity awareness training of our employees, incident response personnel, and senior management;
+Added: the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security processes;
+Added: cybersecurity awareness training of our employees, including incident response personnel and senior management;
a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents;
−Removed: a third -party risk management process for service providers, suppliers, and vendors.
−Removed: We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.
+Added: a third -party risk management process for key service providers, based on our assessment of their criticality to our operations and respective risk profile.
+Added: We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition.
+Added: We face risks from cybersecurity threats that, if realized, are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.
+Added: See “Risk Factors – We rely significantly on information technology and any failure, inadequacy, interruption or security lapse of that technology, including any cybersecurity incidents, could harm us.”
Cybersecurity Governance
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The Committee reports to the full Board regarding its activities, including those related to cybersecurity.
−Removed: The full Board also receives briefings from management on our cyber risk management program.
+Added: The full Board also periodically receives briefings from management on our cyber risk management program.
Board members receive presentations on cybersecurity topics from internal security staff or external experts as part of the Board’s continuing education on topics that impact public companies.
−Removed: Our Senior Director of Information Technology and Senior Vice President, Quality Assurance, who report to the Chief Financial Officer and Chief Executive Officer, respectively, are primarily responsible for assessing and managing our material risks from cybersecurity threats.
−Removed: The Senior Director of Information Technology and Senior Vice President, Quality Assurance have primary responsibility for our overall cybersecurity risk management program and supervises both our internal technology and quality assurance compliance personnel and our retained external cybersecurity consultants.
+Added: Our management team, including our Senior Director of Information Technology and Senior Vice President, Quality Assurance, who report to the Chief Financial Officer and Chief Executive Officer, respectively, are primarily responsible for assessing and managing our material risks from cybersecurity threats.
+Added: The Senior Director of Information Technology and Senior Vice President, Quality Assurance have primary responsibility for our overall cybersecurity risk management program and supervise both our internal technology and quality assurance compliance personnel and our retained external cybersecurity consultants.
Our Senior Director of Information Technology has more than 20 years of experience in IT Management, including cybersecurity, and our Senior Vice President, Quality Assurance has more than 20 years of experience in computerized system and IT infrastructure controls, compliance, and risk management.
3 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.