6 unchanged sentences
information systems.
−Removed: Any of these systems are susceptible to compromise, whether by employees, clients, or other authorized individuals,
+Added: Any of these systems is susceptible to compromise, whether by employees, clients, or other authorized individuals,
as well as by malicious actors employing sophisticated and continuously evolving software, tools, and strategies.
7 unchanged sentences
to assessing, identifying, and managing cybersecurity risks and threats, including:
−Removed: · Maintaining policies and procedures
−Removed: regarding security operations and governance through the implementation of an Information Security Program;
−Removed: · Establishing a committee responsible
−Removed: for security administration, including regular assessments of our systems, existing controls, vulnerabilities, and potential improvements;
−Removed: · Implementing multi-layered controls
−Removed: to avoid reliance on single controls;
−Removed: · Utilizing both preventative and
−Removed: detective tools to monitor and block suspicious activity and to alert of potential threats;
−Removed: · Keeping abreast of new technology
−Removed: and evaluating tools to help respond to threats to cybersecurity in real time;
−Removed: · Managing and maintaining cybersecurity
−Removed: controls utilizing available people, processes and technology;
−Removed: · Utilizing a third-party risk
−Removed: management program for purposes of identifying, assessing and managing risks involved with external service providers;
−Removed: · Conducting thorough due diligence
−Removed: concerning our third-party service providers, including evaluating their cybersecurity practices;
−Removed: · Collaborating with third-party
−Removed: cybersecurity consultants, who perform regular penetration testing, vulnerability assessments, and other procedures to identify potential
−Removed: weaknesses in our systems and processes;
−Removed: · Providing regular cybersecurity
−Removed: training for both our employees and Board of Directors.
−Removed: The Information Security Program, overseen by our Executive
−Removed: Project and Technology Risk Committee (“EPTRC”), plays a vital role in our overall risk management system.
+Added: Maintaining policies and procedures regarding security operations and governance through the implementation of an Information Security Program;
+Added: Establishing a committee responsible for security administration, including regular assessments of our systems, existing controls, vulnerabilities, and potential improvements;
+Added: Implementing multi-layered controls to avoid reliance on single controls;
+Added: Utilizing both preventative and detective tools to monitor and block suspicious activity and to alert of potential threats;
+Added: Keeping abreast of new technology and evaluating tools to help respond to threats to cybersecurity in real time;
+Added: Managing and maintaining cybersecurity controls utilizing available people, processes and technology;
+Added: Utilizing a third-party risk management program for purposes of identifying, assessing and managing risks involved with external service providers;
+Added: Conducting thorough due diligence concerning our third-party service providers, including evaluating their cybersecurity practices;
+Added: Collaborating with third-party cybersecurity consultants, who perform regular penetration testing, vulnerability assessments, and other procedures to identify potential weaknesses in our systems and processes;
+Added: Providing regular cybersecurity training for both our employees and Board of Directors.
+Added: The Information Security Program, overseen by our
+Added: Executive Project and Technology Risk Committee (“EPTRC”), plays a vital role in our overall risk management system.
It encompasses
5 unchanged sentences
events that may warrant Board notification and a Form 8-K cybersecurity notice.
−Removed: Occasionally, we have encountered cybersecurity threats
−Removed: necessitating adjustments to our procedures and the integration of extra safeguards.
−Removed: Although these specific threats or incidents haven't
−Removed: significantly impacted us thus far, it is possible that future threats and incidents we detect could potentially have a material adverse
−Removed: effect on our business strategy, results of operations, and financial condition.
+Added: From time to time, we have experienced cybersecurity
+Added: threats and incidents and have made adjustments to our processes and implemented additional safeguards in response.
+Added: To date, these threats
+Added: and incidents have not materially affected the Company, including our business strategy, results of operations, or financial condition.
+Added: However, future cybersecurity incidents or threats could materially affect us, including our business strategy, results of operations,
+Added: or financial condition.
Our management team is tasked with the daily management
1 unchanged sentence
Our EPTRC, in turn, oversees the assessment of information security,
−Removed: the creation of policies, standards, and procedures, as well as testing, training, and security reporting processes for our Company.
−Removed: EPTRC is comprised of management with the appropriate expertise and authority to ensure effective oversight of the Information Security
+Added: the development of policies, standards, and procedures, as well as testing, training, and security reporting processes for our Company.
+Added: The EPTRC is comprised of management with the appropriate expertise and authority to ensure effective oversight of the Information Security
+Added: Members of the EPTRC and other members of management with responsibility for cybersecurity risk management possess relevant expertise,
+Added: which may include prior experience in information security, risk management, information technology operations, incident response, and
+Added: vendor oversight, as well as relevant education and/or industry certifications.
Furthermore, our Board of Directors, both collectively
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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.