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We are committed to maintaining effective governance and oversight of cybersecurity risks.
−Removed: Our cybersecurity strategy focuses on implementing effective and efficient mechanisms, controls, technologies, systems and other processes across our global IT networks and systems to assess, identify and manage material risks from potential unauthorized occurrences on or through our IT systems that may result in adverse effects on the confidentiality, integrity or availability of our IT systems and the data residing therein.
+Added: Our cybersecurity strategy centers on implementing effective controls, technologies and processes across our global IT environments to identify, assess and manage material risks that could compromise the confidentiality, integrity or availability of our IT systems and data.
These processes are designed to promote (i) robust controls across our IT ecosystem, (ii) transparency across our IT infrastructure so that our information security team can detect, identify and escalate anomalies for further analysis and action, and (iii) a sound enterprise security architecture with security integrated into each phase of system implementation.
−Removed: We believe that the processes and controls we have established to protect our stakeholders’ interests, including with respect to our current regulated products and internal systems, are robust and generally aligned with applicable cybersecurity regulations and informed in part by certain industry standards, principles and frameworks, such as those set by the National Institute of Standards and Technology.
+Added: We believe that the processes and controls we have established to protect our stakeholders’ interests, including with respect to our current regulated products and internal systems, are generally aligned with applicable cybersecurity regulations and informed in part by certain industry standards, principles and frameworks, such as those set by the National Institute of Standards and Technology.
This includes security by design, regular penetration testing, vulnerability scanning and standardization where possible of cybersecurity architecture principles.
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Additionally, we periodically offer training and education to our employees on cyber risks and remind our employees of critical end-user best practices, such as current phishing trends.
−Removed: Information security risk is managed by a cross-functional team, which includes our procurement, compliance, privacy and legal teams, allowing for a holistic view of risks related to the safety and privacy of critical data, such as customer account details, financial
−Removed: data and intellectual property.
+Added: Information security risk is managed by a cross-functional team, which includes our procurement, compliance, privacy and legal teams,
+Added: allowing for a holistic view of risks related to the safety and privacy of critical data, such as customer account details, financial data and intellectual property.
We aim to secure our data and information throughout their lifecycle – from creation, collection and processing to dissemination, use, storage and disposition.
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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.