1 unchanged sentence
CYBERSECURITY
−Removed: We are increasingly dependent on sophisticated
−Removed: software applications and computing infrastructure to conduct key operations.
−Removed: We depend on both our own systems, networks, and technology
−Removed: as well as the systems, networks and technology of our contractors, consultants, vendors and other business partners.
+Added: Risk management and strategy
+Added: We are increasingly dependent on sophisticated software
+Added: applications and computing infrastructure to conduct key operations.
+Added: We depend on both our own systems, networks, and technology as well
+Added: as the systems, networks and technology of our contractors, consultants, vendors and other business partners.
Cybersecurity Program
6 unchanged sentences
and industry benchmarking.
−Removed: We also require cybersecurity trainings
−Removed: when onboarding new employees, as well as cybersecurity awareness training for our employees.
−Removed: Our program leverages standard industry
−Removed: frameworks to strengthen our program effectiveness and reduce cybersecurity risks.
−Removed: We use a risk-based approach with respect to our
−Removed: use and oversight of third-party service providers, tailoring processes according to the nature and sensitivity of the data accessed,
−Removed: processed, or stored by such third-party service provider.
−Removed: We use a number of means to assess and manage cyber risks related to our third-party
−Removed: service providers, including conducting due diligence in connection with onboarding new vendors and seeking to include appropriate security
−Removed: terms in our contracts where applicable.
+Added: We are implementing cybersecurity awareness
+Added: trainings for all employees.
+Added: Our program leverages standard industry frameworks to strengthen our program effectiveness and reduce cybersecurity
+Added: We use a risk-based approach with respect to our use
+Added: and oversight of third-party service providers, tailoring processes according to the nature and sensitivity of the data accessed, processed,
+Added: or stored by such third-party service provider.
+Added: We use a number of means to assess and manage cyber risks related to our third-party service
+Added: providers, including conducting due diligence in connection with onboarding new vendors and seeking to include appropriate security terms
+Added: in our contracts where applicable.
Process for Assessing, Identifying and Managing Material Risks from
8 unchanged sentences
Management Oversight
−Removed: The controls and processes employed to assess,
−Removed: identify and manage material risks from cybersecurity threats are implemented and overseen by the use of consultants as the Company does
−Removed: not have a full-time dedicated cybersecurity position in the Company.
−Removed: Our consultant has over 20 years of experience in information technology
−Removed: matters and is responsible for the day-to-day management of the cybersecurity program, including the prevention, detection, investigation,
−Removed: response to, and recovery from cybersecurity threats and incidents, and are regularly engaged to help ensure the cybersecurity program
−Removed: functions effectively in the face of evolving cybersecurity threats.
+Added: controls and processes employed to assess, identify and manage material risks from cybersecurity threats are implemented and
+Added: overseen by the use of consultants as the Company does not have a full-time dedicated cybersecurity position in the Company.
+Added: Our consultants
+Added: have over 20 years of experience in information technology matters and are responsible
+Added: for the day-to-day management of the cybersecurity program, including the prevention, detection, investigation, response to, and
+Added: recovery from cybersecurity threats and incidents, and are regularly engaged to help ensure the cybersecurity program functions
+Added: effectively in the face of evolving cybersecurity threats.
Board Oversight
10 unchanged sentences
Cybersecurity Risks
−Removed: Our cybersecurity risk management processes are
−Removed: integrated into our overall information technology (“ IT ”) processes.
−Removed: As part of our IT process, we identify, assess
−Removed: and evaluate risks impacting our operations across the Company, including those risks related to cybersecurity.
−Removed: We also maintain cybersecurity
−Removed: insurance providing coverage for certain costs related to cybersecurity-related incidents that impact our own systems, networks, and technology
+Added: Our cybersecurity risk management processes are integrated
+Added: into our overall information technology (“ IT ”) processes.
+Added: As part of our IT process, we identify, assess and evaluate
+Added: risks impacting our operations across the Company, including those risks related to cybersecurity.
+Added: We also maintain cybersecurity insurance
+Added: providing coverage for certain costs related to cybersecurity-related incidents that impact our own systems, networks, and technology
or the systems, networks and technology of our contractors, consultants, vendors and other business partners.
−Removed: As of December 31, 2023, we are not aware of any material risks from
−Removed: cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially affected the business strategy,
−Removed: results of operations or financial condition of the Company or are reasonably likely to have such a material effect.
−Removed: While we maintain
−Removed: a robust cybersecurity program, the techniques used to infiltrate information technology systems continue to evolve.
−Removed: Accordingly, we may
−Removed: not be able to timely detect threats or anticipate and implement adequate security measures.
+Added: As of December 31, 2024, we are not aware of any material
+Added: risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially affected the business
+Added: strategy, results of operations or financial condition of the Company or are reasonably likely to have such a material effect.
+Added: maintain a robust cybersecurity program, the techniques used to infiltrate information technology systems continue to evolve.
+Added: we may not be able to timely detect threats or anticipate and implement adequate security measures.
For additional information, see “Item
1 unchanged sentence
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.