Unresolved Staff Comments
+Added: 2025 ANNUAL REPORT 21
Cybersecurity
3 unchanged sentences
The company’s cybersecurity program is designed to detect, contain and respond to cybersecurity threats and incidents in a prompt and effective manner with the primary goals of protecting information assets, preventing the misuse and loss of those assets, minimizing disruptions to the business, and establishing the basis for audits and risk assessments.
−Removed: 2024 ANNUAL REPORT 21
Elements of the cybersecurity program include:
18 unchanged sentences
The company regularly engages third parties to assess its information security environment.
−Removed: The company’s Internal Audit function also annually evaluates compliance with the company’s overall information technology policies, and the Vice President of Internal Audit reports the results of these assessments to the Audit Committee.
+Added: The company’s Internal Audit function also annually evaluates compliance with the company’s overall information technology policies, and the Director of Internal Audit reports the results of these assessments to the Audit Committee.
+Added: SNAP-ON INCORPORATED
In addition, the company has established a data incident response plan, which provides employees with the process and mechanism to report any suspected or confirmed cybersecurity threat or data incident.
4 unchanged sentences
The Incident Response Team also coordinates communications with internal and external stakeholders.
−Removed: SNAP-ON INCORPORATED
The Incident Response Team leads the materiality assessment with input and guidance from senior management, including the Chief Executive Officer, Chief Financial Officer, and Chief Accounting Officer.
10 unchanged sentences
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.