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Our Board of Directors administers its cybersecurity risk oversight function directly and through the Audit Committee, which conducts regular risk assessments related to all matters affecting the enterprise, including cybersecurity, and receives periodic reports on the Company’s cybersecurity risks and activities.
−Removed: Our Chief Financial Officer and our Senior Director, Head of IT and Informatics are the Company employees primarily responsible for assessing and managing material risks from cybersecurity threats with assistance from third-party service providers.
+Added: Our Chief Financial Officer and our Senior Director, Head of IT are the Company employees responsible for developing and implementing a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information.
+Added: We partner with external cybersecurity vendors to enact a layered defense approach with controls deployed that seek to meet the requirements of the NIST Cybersecurity Framework.
Our Chief Financial Officer has served as a biotechnology executive for 20 years, whose responsibilities have included direct oversight of his companies’ cybersecurity risks.
−Removed: Our Senior Director, Head of IT and Informatics has served as an information technology professional for over ten years and has held senior IT positions at multiple biotechnology companies, where his primary responsibilities included maintaining direct oversight over his companies' cybersecurity risks.
+Added: Our Senior Director, Head of IT has served as an Information Technology professional for over ten years and has held senior IT positions across several companies including a large pharmaceutical company.
We have established policies and processes for assessing, identifying, and managing material risk from cybersecurity threats, and have integrated these processes into our overall risk management systems and processes.
+Added: Our Senior Director, Head of IT oversees the cybersecurity program through risk management, employee security training, and oversight and escalation of threat monitoring and incident response.
We routinely assess material risks from cybersecurity threats, including any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality, integrity, or availability of our information systems or any information residing therein.
−Removed: We conduct periodic risk assessments to identify cybersecurity threats, as well as assessments in the event of a material change in our business practices that may affect information systems that are vulnerable to such cybersecurity threats.
−Removed: These risk assessments include identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that could result from such risks, and the sufficiency of existing policies, procedures, systems, and safeguards in place to manage such risks.
−Removed: Following these risk assessments, we re-design, implement, and maintain reasonable safeguards to minimize identified risks;
−Removed: address any identified gaps in existing safeguards;
−Removed: and regularly monitor the effectiveness of our safeguards.
−Removed: Primary responsibility for assessing, monitoring and managing our cybersecurity risks is delegated to our Senior Director, Head of IT and Informatics, who reports on IT operations, risk mitigation and assessment efforts, and other general cybersecurity matters to our Chief Financial Officer, to manage the risk assessment and mitigation process.
−Removed: The cybersecurity risk management program includes tools and activities to prevent, detect, and analyze current and emerging cybersecurity threats, and plans and strategies to address threats and incidents.
−Removed: As part of our overall risk management system, we monitor and test our safeguards and train our employees on these safeguards, in collaboration with our internal IT function and management.
−Removed: We engage consultants or other third parties in connection with our risk assessment processes.
−Removed: These service providers assist us in designing and implementing our cybersecurity policies and procedures, and monitoring and testing our safeguards.
−Removed: We require each third-party service provider to certify that it has the ability to implement and maintain appropriate security measures, consistent with all applicable laws, to implement and maintain reasonable security measures in connection with their work with us, and to promptly report any suspected breach of its security measures that may affect our Company.
−Removed: Our Chief Financial Officer and Senior Director, Head of IT and Informatics provide periodic briefings to the Audit Committee regarding our Company’s cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity systems testing, activities of third parties, and related matters.
+Added: In the event of a major security incident, we have established an escalation path for stakeholder notification and remediation efforts, and major incidents are immediately escalated to the Head of IT, Chief Financial Officer, and Chief Operations Officer.
+Added: In 2024, we proactively conducted a thorough and robust cybersecurity assessment, performed by an external cybersecurity partner, to evaluate our risks and identify key areas to improve our cybersecurity posture.
+Added: We have implemented processes when evaluating third-party service providers, for example by reviewing available audit reports including the System and
+Added: Organization Controls (SOC 2) reports and requesting disclosure of any previous cybersecurity events.
+Added: We also perform quality audits of certain regulated vendors, which includes an assessment of the vendor’s information technology system and associated controls.
+Added: Additionally, we conduct periodic risk assessments to identify and monitor against potential cybersecurity threats and incidents, as well as assess for any changes in our business practices that may affect our cybersecurity position.
+Added: This risk oversight includes identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that could result from such risks, and the sufficiency of existing policies, procedures, systems, and safeguards in place to manage such risks.
+Added: Following these risk assessments, we re-design, implement, and maintain reasonable safeguards to minimize identified risks and address any identified gaps in existing safeguards.
+Added: Primary responsibility for assessing, monitoring and managing our cybersecurity program is delegated to our Senior Director, Head of IT, who reports on IT operations, risk mitigation and assessment efforts, and other general cybersecurity matters to our Chief Financial Officer, to manage the risk assessment and mitigation process.
+Added: As part of our overall risk management system, we monitor and test our safeguards and train our employees on these safeguards.
+Added: We continue to work with third-party cybersecurity vendors to assist us in best practices for implementing strengthened cybersecurity procedures .
+Added: All Company employees and third-party vendors are instructed to promptly report any suspected breach of its security measures that may affect our Company to the Senior Director, Head of IT.
+Added: Our Chief Financial Officer and Senior Director, Head of IT provide periodic briefings to the Audit Committee regarding our Company’s cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity systems testing, activities of third-parties, and related matters.
The Audit Committee provides regular updates to the full Board of Directors on such reports.
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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.