5 unchanged sentences
Cybersecurity threats are assessed as part of our enterprise risk management assessments.
−Removed: Our cybersecurity strategy includes procedures for identifying material cybersecurity risks, prioritizing risks and analyzing risk mitigation.
−Removed: Our cybersecurity strategy also includes developing and implementing policies and procedures, escalating any issues as necessary that present a material risk and ensuring that all employees have sufficient cybersecurity training.
+Added: Our cybersecurity strategy includes procedures for identifying material cybersecurity risks, and prioritizing appropriate risk mitigations.
+Added: Our cybersecurity strategy also includes developing and implementing policies, procedures, and controls, escalating issues as necessary that present a material risk, and ensuring that all employees have sufficient cybersecurity training.
We have engaged consultants and other third parties in connection with our enterprise risk management assessments, including with respect to cybersecurity.
1 unchanged sentence
We examine and validate our program with third parties, measuring it against industry standards and established frameworks to help identify areas for focus, improvement and compliance.
−Removed: We have comprehensive plans to ensure that any non-routine events are properly escalated.
+Added: We have comprehensive incident response plans to ensure that any non-routine events are properly escalated and addressed.
These plans are validated through cyber incident exercises to consider the types of decisions that would need to be made in the event of a cyber incident.
We have engaged in scenario planning exercises around cyber incidents with cybersecurity consultants in this process.
−Removed: Our security awareness platform aims to reduce vulnerabilities in our systems if they are the target of phishing or social engineering through simulations of attacks coupled with employee training.
+Added: Our security awareness program utilizes simulations of attacks coupled with employee training in order to reduce risks to our systems if they are the target of phishing or social engineering.
We assess third party vendors who have access to our data or systems to measure their adherence to relevant industry practices and standards, including due diligence and monitoring compliance with security assessments.
1 unchanged sentence
Despite our efforts, we cannot eliminate all risks from cybersecurity threats, or provide assurance that we have not experienced an undetected cybersecurity incident.
−Removed: For more information about these risks, please see “Risk Factors—Cybersecurity vulnerabilities or other failures in information systems could result in information theft, data corruption and significant disruption of our business operations.”
+Added: For more information about these risks, please see “Risk Factors—Cybersecurity vulnerabilities, failures in information systems or risks associated with the use of artificial intelligence could result in information theft, data corruption and significant disruption of our business operations.”
The board of directors has adopted a Cyber Security and Personal Data Breach Policy in order to reflect the importance of appropriate security, processes and procedures to the protection of data and assets, and in an effort to establish a foundation for successful protection against cyber-crime and to minimize any potential negative impacts of a successful cyber-attack.
5 unchanged sentences
The audit committee receives updates about the results of assessments conducted by outside advisors who provide independent assessments of our technology systems.
−Removed: Our executive offices are located at 110 East 59 th Street, New York, NY 10022, and are provided by the Manager.
+Added: Our executive offices are located at 110 East 59 th Street, New York, NY 10022.
We believe that our office facilities are suitable and adequate for our business as it is contemplated to be conducted.
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.