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We have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity and availability of our critical systems and information.
−Removed: Our cybersecurity risk-management program includes a cybersecurity incident response plan.
−Removed: We design and assess our program based on the National Institute of Standards and Technology Cybersecurity Framework, or NIST CSF, also integrating security best practices typically used to support the Health Insurance Portability and Accountability Act, or HIPAA, and General Data Protection Regulation, or GDPR, implementations.
−Removed: We use the NIST CSF and such security best practices as a guide to help us monitor, identify, assess and manage cybersecurity risks relevant to our business;
−Removed: however, this does not imply that we meet any particular technical standards, specifications or compliance requirements.
−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.
+Added: We design and assess our cybersecurity risk management program based on the National Institute of Standards and Technology Cybersecurity Framework, or NIST CSF, and integrate recognized security best practices relevant to our business.
+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: As our operations scale and we transition to commercialization, our cybersecurity risk management program is designed to scale accordingly, including through enhanced governance, layered security controls, third-party oversight and continuous monitoring.
+Added: Our cybersecurity risk management program is integrated into our overall risk management framework , and shares common methodologies, reporting channels and governance processes across legal, compliance, strategic, operational and financial risk areas.
Key elements of our cybersecurity risk management program include but are not limited to:
• risk assessments designed to help identify material risks from cybersecurity threats to our critical systems and information;
−Removed: • adoption of various cybersecurity software, including but not limited to cloud-based malware, ransomware and antivirus software, phishing monitoring and artificial intelligence-based anomaly detection;
−Removed: • a security team principally 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 processes ;
−Removed: • cybersecurity awareness training of our employees, incident response personnel and senior management;
+Added: • adoption of layered cybersecurity controls, including enhanced identity and access controls, automated detection and remediation for email threats, endpoint and network protections, centralized security monitoring and retention of security logs sufficient to support investigations and audit evidence;
+Added: • a security team principally responsible for managing (1) our cybersecurity risk-assessment processes, (2) our security controls, (3) our response to cybersecurity incidents, and (4) the ongoing improvement of our security posture through measurement, testing, threat-hunting and lessons-learned activities;
+Added: • the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security processes, including 24/7 monitoring and additional technical expertise, and periodic penetration and vulnerability testing ;
+Added: • cybersecurity awareness training for our employees, including incident response personnel and senior management;
• a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents;
−Removed: • security audits and a third-party risk assessment process for key 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: • security audits and a third-party risk assessment process for key service providers, suppliers and vendors 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 or are reasonably likely to materially affect us, including our 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.
For more information, see the section titled “Risk Factor—Risks Related to Data Privacy and Cybersecurity—Cyberattacks or other failures in our telecommunications or information technology, or IT, systems, or those of our collaborators, contract research organizations, third-party logistics providers, distributors or other contractors or consultants, could result in information theft, data corruption and significant disruption of our business operations.”
Our Board of Directors considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit Committee oversight of cybersecurity and risks, including oversight of management's implementation of our cybersecurity risk management program.
−Removed: T he Audit Committee receives periodic reports from management on our cybersecurity risks.
+Added: The Audit Committee receives regular updates from management on cybersecurity risks, control maturity and significant cybersecurity matters, including those related to systems surrounding commercial operations.
In addition, management updates the Audit Committee, when it deems appropriate, regarding cybersecurity incidents it considers to be significant or potentially significant.
The Audit Committee reports to the full Board regarding its activities, including those related to cybersecurity.
−Removed: We have an internal cybersecurity team, reporting to our Chief Financial Officer , who is responsible for (i) managing our overall cybersecurity risk-management program;
−Removed: (ii) assessing and managing our risks from cybersecurity threats;
−Removed: and (iii) overseeing retained cybersecurity consultants and providers for additional external expertise.
+Added: We maintain an internal cybersecurity team, reporting to our Chief Financial Officer , who is responsible for managing our cybersecurity risk-management program, assessing and mitigating cyber risks, and overseeing retained cybersecurity consultants and providers for additional external expertise.
This internal team is led by our Vice President of Information Technology, who has over 20 years of experience managing cybersecurity, systems architecture and complex data operations for biotechnology and pharmaceutical companies.
3 unchanged sentences
review of any threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us;
−Removed: and alerts and reports produced by security tools deployed in the IT environment.
−Removed: We sublease a facility containing 25,445 square feet of office space, which is located at 99 High Street, Boston, Massachusetts 02110.
−Removed: Our sublease expires on January 31, 2026.
−Removed: We believe that our current facility is sufficient to meet our current and near-term needs and that, should it be needed, suitable additional space will be available.
+Added: and alerts and reports produced by security tools deployed in our IT environment.
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.