Unresolved Staff Comments.
−Removed: Not applicable.
Cybersecurity.
−Removed: Risk Management & Strategy
−Removed: We maintain a cyber risk
−Removed: management program designed to identify, assess, manage, mitigate and respond to cybersecurity threats.
−Removed: This program, in conjunction with
−Removed: our enterprise risk management assessment processes , address cybersecurity risks to the corporate information technology, or IT, environment
−Removed: including systems, hardware, software, data, people and processes.
+Added: Management & Strategy
+Added: maintain a cyber risk management program designed to identify, assess, manage, mitigate and respond to cybersecurity threats.
+Added: This program,
+Added: in conjunction with our enterprise risk management and data privacy programs , address cybersecurity risks to the corporate information
+Added: technology, or IT, environment including systems, hardware, software, data, people and processes.
The underlying processes
4 unchanged sentences
strong cybersecurity posture.
−Removed: Utilizing NIST CSF enables us to systemically identify, assess, and manage cybersecurity risks most relevant
−Removed: and impactful to our business operations.
+Added: Utilizing the NIST CSF enables us to systemically identify, assess and manage cybersecurity risks most
+Added: relevant and impactful to our business operations.
It is important to note that using the NIST CSF as a guide does not imply our cybersecurity
2 unchanged sentences
strategy includes the following approach:
−Removed: We have an annual assessment
−Removed: performed by a third-party specialist of the Company’s cyber risk management program against the NIST CSF.
+Added: Annually, we engage third-party
+Added: specialists to perform an assessment of the Company’s cyber risk management program against the NIST CSF.
The annual risk assessment
identifies, quantifies and categorizes significant cyber risks.
−Removed: In addition, we, in conjunction with the third-party cyber risk management
−Removed: specialists, developed a risk mitigation plan to address such cyber risks, and where necessary, remediate potential vulnerabilities identified
−Removed: through the annual assessment process.
−Removed: In addition, we maintain policies over areas such as protecting
−Removed: and handling confidential information, processing of personal data, access on/off boarding, user management, acceptable use, and IT change
+Added: In addition, we, in conjunction with the third-party cyber risk
+Added: management specialists, develop a risk mitigation plan to address such cyber risks, and where necessary, remediate potential vulnerabilities
+Added: identified through the annual assessment process.
+Added: In addition, we maintain policies over areas such as protecting and
+Added: handling confidential information, processing of personal data, access on/off boarding, user management, acceptable use and IT change
control management to help govern the processes put in place by management designed to protect our IT assets, data and services from threats
2 unchanged sentences
of an IT assets inventory, periodic network scans, identity access management controls including restricted access to privileged accounts,
−Removed: and physical security measures at our facilities.
−Removed: We also utilize information protection/detection systems, or IPS/IDS, including maintenance
−Removed: of firewalls and anti-malware tools, network and data traffic monitoring with automated alerting, ongoing cybersecurity user awareness
−Removed: training, industry-standard encryption protocols, formalized change management processes and critical data backups to reduce cybersecurity
−Removed: Cybersecurity partners, including assessors, consultants, advisors
−Removed: and other third-party service providers, are a key part of our cybersecurity risk management strategy and infrastructure.
−Removed: We partner with
−Removed: industry recognized cybersecurity providers leveraging third-party technology and expertise and engage with these partners to monitor
−Removed: and maintain the performance and effectiveness of IT assets, data and services.
−Removed: The cybersecurity partners provide services including,
−Removed: but not limited to systems inventory monitoring, configuration management, periodic network scanning, user management, mobile device monitoring,
−Removed: capacity monitoring, network protection and monitoring, IPS/IDS management, remote access monitoring and management, user activity monitoring,
−Removed: data backups management, infrastructure maintenance, incident response, cybersecurity strategy, and cyber risk advisory, assessment and
−Removed: We have implemented third-party risk management processes to manage
−Removed: the risks associated with reliance on vendors, critical service providers, and other third parties that may lead to a service disruption
−Removed: or an adverse cybersecurity incident.
−Removed: This includes processes for performing third-party risk ratings and data classification mapping
−Removed: of current and ongoing vendors.
−Removed: The program promotes good cybersecurity practices with our third-party vendors and helps to ensure their
−Removed: adherence to our cybersecurity standards.
−Removed: In evaluating the risks identified
−Removed: as a result of the annual cybersecurity assessment process, our cybersecurity partners assist the Company to assess the likelihood, severity,
−Removed: and impact of relevant risks, including the impact on employees, stakeholders, and vendors.
−Removed: These risks are prioritized and monitored
−Removed: by the cybersecurity partners and management of the Company.
−Removed: Our cybersecurity program
−Removed: includes an incident response plan that includes all relevant and critical members of management and third-party service providers alike.
−Removed: The team is responsible for assessing and managing cybersecurity incident response processes, response times, and communication plans
−Removed: in the event corrective actions and mitigation procedures are required to isolate and eradicate an incident.
+Added: backup and recovery, security information and event management, or SIEM, tools and physical security measures at our facilities.
+Added: utilize information protection/detection systems, or IPS/IDS, including maintenance of firewalls and anti-malware tools, network and data
+Added: traffic monitoring with automated alerting, ongoing cybersecurity user awareness training, industry-standard encryption protocols, formalized
+Added: change management processes and critical data backups to reduce cybersecurity risk.
+Added: Cybersecurity
+Added: partners, including assessors, consultants, advisors and other third-party service providers, are a key part of our cybersecurity risk
+Added: management strategy and infrastructure.
+Added: We partner with industry recognized cybersecurity providers leveraging third-party technology
+Added: and expertise and engage with these partners to monitor and maintain the performance and effectiveness of IT assets, data and services.
+Added: The cybersecurity partners provide services including, but not limited to systems inventory monitoring, configuration management, periodic
+Added: network scanning, user management, mobile device monitoring, capacity monitoring, network protection and monitoring, IPS/IDS management,
+Added: remote access monitoring and management, user activity monitoring, data backups management, infrastructure maintenance, SIEM monitoring,
+Added: incident response, cybersecurity strategy, and cyber risk advisory, assessment and remediation.
+Added: We have implemented third-party
+Added: risk management processes to manage the risks associated with reliance on vendors, critical service providers and other third parties
+Added: that may lead to a service disruption or an adverse cybersecurity incident.
+Added: This includes processes for performing third-party risk ratings
+Added: and data classification mapping of current and ongoing vendors.
+Added: The program promotes good cybersecurity practices with our third-party
+Added: vendors and helps to ensure their adherence to our cybersecurity standards.
+Added: In evaluating the risks
+Added: identified as a result of the annual cybersecurity assessment process, our cybersecurity partners assist us in assessing the likelihood,
+Added: severity, and impact of relevant risks, including the impact on employees, stakeholders, and vendors.
+Added: These risks are prioritized and
+Added: monitored by our cybersecurity partners and management team.
+Added: cybersecurity program includes an incident response plan that includes all relevant and critical members of management and third-party
+Added: service providers alike.
+Added: The team is responsible for assessing and managing cybersecurity incident response processes, response times,
+Added: and communication plans in the event corrective actions and mitigation procedures are required to isolate and eradicate an incident.
Governance & Oversight
−Removed: Our finance leadership team,
−Removed: led by our chief financial officer , in conjunction with third-party IT and cybersecurity service providers is responsible for oversight
−Removed: and administration of our cyber risk management program, and for informing senior management and other relevant stakeholders regarding
−Removed: the prevention, detection, mitigation and remediation of cybersecurity incidents.
−Removed: Our finance leadership team has experience selecting,
−Removed: deploying and overseeing cybersecurity technologies, initiatives, and processes directly or via selection of strategic third-party partners .
−Removed: We also rely on threat intelligence and other information obtained from governmental, public, or private sources, including external consultants
−Removed: engaged by us for strategic cyber risk management, advisory and decision making.
+Added: IT governance & oversight team led by our chief financial officer in conjunction with our director of IT and our third-party IT and
+Added: cybersecurity service providers is responsible for oversight and administration of our cyber risk management program, and for informing
+Added: senior management and other relevant stakeholders regarding the prevention, detection, mitigation and remediation of cybersecurity incidents .
+Added: Our team has experience selecting, deploying and overseeing cybersecurity technologies, initiatives, and processes directly or via selection
+Added: of strategic third-party partners.
+Added: We also rely on threat intelligence and other information obtained from governmental, public, or private
+Added: sources, including external consultants engaged by us for strategic cyber risk management, advisory and decision making.
The Audit Committee of the Board of Directors, or the Audit Committee ,
19 unchanged sentences
or unknown threats will still remain.
−Removed: Further, there is increasing regulation regarding responses to cybersecurity incidents, including
−Removed: reporting to regulators, investors and additional stakeholders, which could subject us to additional liability and reputational harm.
−Removed: In response to such risks, we have implemented initiatives such as our cybersecurity risk assessment process and development
−Removed: of an incident response plan.
“Risk Factors” for more information on Company cybersecurity risks.
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.