4 unchanged sentences
These risks include, among other things:
−Removed: operational risks, harm to our employees, suppliers or industry partners, intellectual property theft, fraud, extortion, and violation of data privacy or security laws.
+Added: operational risks, harm to our employees, suppliers or industry partners, intellectual property theft, fraud, extortion, and violation of data
+Added: privacy or security laws.
We use a risk management framework based on applicable laws and regulations and informed by industry standards and industry-recognized practices for identifying and managing cybersecurity risks within our operations, infrastructure and corporate resources.
18 unchanged sentences
We have business continuity, contingency and disaster recovery plans and procedures in place in the event of a cybersecurity incident.
−Removed: These plans are tested in conjunction with the Company’s annual testing of its cybersecurity incident response readiness and reporting through tabletop exercises.
+Added: These plans are tested in conjunction with the Company’s annual testing of our cybersecurity incident response readiness and reporting through tabletop exercises.
To date, risks from cybersecurity threats have not previously materially affected us, and we currently do not expect that the risks from cybersecurity threats are reasonably likely to materially affect us, including our business, strategy, results of operations or financial condition.
−Removed: That said, as discussed more fully under “Item 1A – Risk Factors”, the sophistication of cyber
−Removed: threats continues to increase, and the preventative actions we take to reduce the risk of cyber incidents and protect our systems and information may be insufficient.
+Added: That said, as discussed more fully under “Item 1A – Risk Factors”, the sophistication of cyber threats continues to increase, and the preventative actions we take to reduce the risk of cyber incidents and protect our systems and information may be insufficient.
Accordingly, no matter how well designed or implemented our controls are, we will not be able to anticipate all security breaches of these types, including security threats that may result from third parties improperly employing AI technologies, and we may not be able to implement effective preventive measures against such security breaches in a timely manner.
−Removed: Role of our Board of Directors
−Removed: The Nominating and Corporate Governance Committee of the Board of Directors is primarily responsible for the oversight
−Removed: of our information security programs and cybersecurity incident response plans.
−Removed: We established a cyber subcommittee comprised of our senior management team that reports directly to the Board and its Committees regarding our cyber risks and threats, the status of initiatives strengthen our information security systems, assessments of our cybersecurity program and incident response plan, and our views of the emerging threat landscape.
−Removed: Our Executive Vice President – Business Intelligence and our head of Internal Audit report directly to the Nominating and Corporate Governance Committee as well as the Audit Committee regarding these matters and are responsible for reporting to the Committees on our company-wide enterprise risk assessment, and that assessment also includes an evaluation of cyber risks and threats.
−Removed: The Chair of the Nominating and Corporate Governance Committee regularly reports to the Board of Director on cybersecurity risks and other matters reviewed by the Nominating and Corporate Governance Committee in conjunction with the management team.
+Added: Cybersecurity Governance - Role of our Board of Directors
+Added: The Nominating and Corporate Governance Committee of the Board of Directors is primarily responsible for the oversight of our information security programs and cybersecurity incident response plans.
+Added: We established a cyber subcommittee comprised of our senior management team that reports directly to the Board and its Committees regarding our cyber risks and threats, the status of initiatives strengthens our information security systems, assessments of our cybersecurity program and incident response plan, and our views of the emerging threat landscape.
+Added: Our Chief Information and Compliance Officer and our head of Internal Audit report directly to the Nominating and Corporate Governance Committee as well as the Audit Committee regarding these matters and are responsible for reporting to the Committees on our company-wide enterprise risk assessment, and that assessment also includes an evaluation of cyber risks and threats.
+Added: The Chair of the Nominating and Corporate Governance Committee regularly reports to the Board of Director on cybersecurity risks and other matters reviewed by the
+Added: Nominating and Corporate Governance Committee in conjunction with the management team.
All materials or presentations on cybersecurity provided to the Nominating and Corporate Governance Committee are provided to all Board members.
As a matter of process, the Nominating and Corporate Governance Committee annually reviews, and recommends to the Board of Directors its approval of, our information security policy and cybersecurity program and our incident response plans.
−Removed: Furthermore, on an annual basis, the Board of Directors and its Committees review and discuss our technology strategy with our Executive Vice President – Business Intelligence and approve our technology strategic plan.
−Removed: Role of our Management Team
−Removed: Our Executive Vice President - Business Intelligence is responsible for the day-to-day management of our cybersecurity risks and for recommending the strategies and technologies used by the organization to collect, integrate and analyze business information to support the organization's strategic decisions.
−Removed: He is supported by a cross-disciplinary team from the Company’s accounting, legal and risk oversight functions and its internal audit group.
+Added: Furthermore, on an annual basis, the Board of Directors and its Committees review and discuss our technology strategy with our Chief Information and Compliance Officer and approve our technology strategic plan.
+Added: Cybersecurity Governance - Role of our Management Team
+Added: Our Chief Information and Compliance Officer is responsible for the day-to-day management of our cybersecurity risks and for recommending the strategies and technologies used by the organization to collect, integrate and analyze business information to support the organization's strategic decisions.
+Added: He is supported by a cross-disciplinary team from the Company’s accounting, legal and risk oversight functions and our internal audit group.
This incident response team meets quarterly and as needed to review the Company’s cybersecurity risk management initiatives and progress and cybersecurity metrics.
7 unchanged sentences
Our Information Security Coordinator, members of our incident response team and our third party consultants each have extensive experience in the information technology area.
−Removed: The Executive Vice President of Business Intelligence has over 10 years of experience in the information technology area and holds a Master of Business Administration with a focus in Technology from Oklahoma Christian University.
+Added: The Chief Information and Compliance Officer has over 11 years of experience in the information technology area and holds a Master of Business Administration with a focus in Technology from Oklahoma Christian University.
Additionally, our Vice President of Technology and Analytics has 11 years of professional experience in the information security area.
Additionally, our management team's internal cybersecurity risk management and strategy processes are supported with third party consultants with extensive work experience in various roles involving information technology, including security, auditing, compliance, systems and programming.
−Removed: These individuals are informed about, and monitor the prevention, mitigation, detection and remediation of cybersecurity incidents through their management of, and participation in, the cybersecurity risk management and strategy processes described above, including the operation of our incident response plan, and report to the
−Removed: Board of Directors, Nominating and Corporate Governance Committee and Audit Committee, as the case may be, on any appropriate items.
+Added: These individuals are informed about, and monitor the prevention, mitigation, detection and remediation of cybersecurity incidents through their management of, and participation in, the cybersecurity risk management and strategy processes described above, including the operation of our incident response plan, and report to the Board of Directors , Nominating and Corporate Governance Committee and Audit Committee, as the case may be, on any appropriate items.
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.