4 unchanged sentences
Risk Management
−Removed: We, like other companies in our industry, face several cybersecurity risks in connection with our business.
−Removed: Our business strategy, results of operations, and financial condition have not, to date, been affected by risks from cybersecurity threats.
−Removed: During the reporting period, we have not experienced any material cyber incidents, nor have we experienced a series of immaterial incidents,
+Added: We face several cybersecurity risks in connection with our business.
+Added: Our business strategy,
+Added: results of operations, and financial condition have not, to date, been affected by risks from cybersecurity threats.
+Added: reporting period, we have not experienced any material cyber incidents, nor have we experienced a series of immaterial incidents,
which would require disclosure.
−Removed: the ordinary course of our business, we use, store and process data including data of our employees, partners, collaborators, and vendors.
−Removed: To effectively prevent, detect, and respond to cybersecurity threats, we maintain a cyber risk management program, which is comprised
−Removed: of a wide array of policies, standards, architecture, and processes.
−Removed: The cyber risk management program falls under the responsibility of
−Removed: our Director of Information Technology (“IT”), who has cross-functional expertise in IT, computer science, cyber security,
−Removed: and more than 20 years of experience.
−Removed: The IT Director leads a team of IT specialists with similar IT and cybersecurity backgrounds.
−Removed: the guidance of our IT Head, we develop, maintain, and evidence the policies, standards, and processes in a manner consistent with applicable
−Removed: legal requirements.
−Removed: We also utilize a variety of cybersecurity software from reputable vendors in cybersecurity.
−Removed: We have implemented a cybersecurity
−Removed: risk management program that is designed to identify, assess, and mitigate risks from cybersecurity threats to this data and our systems
−Removed: and ensure the effectiveness of our security controls.
−Removed: Our cybersecurity risk management program is intended to address applicable NIST
−Removed: 800-171 & CMMC requirements for our business.
−Removed: Our cybersecurity risk management program incorporates several components, including
−Removed: information security program assessments, continuous monitoring of critical risks from cybersecurity threats using automated tools, backup
−Removed: testing, periodic threat testing, and documented standards, policies, and procedures.
−Removed: We deploy a wide range of security tools across
−Removed: the environment, and implement access control policies to further limit access to data within the systems.
−Removed: We periodically engage third
−Removed: parties to conduct risk assessments, including penetration testing, tabletops and other system vulnerability analyses.
−Removed: As a result of
−Removed: these assessments and testing, we have not identified any material cybersecurity risks and are constantly hardening our environment.
−Removed: Additionally,
−Removed: our program includes annual cybersecurity training for all employees.
−Removed: Cybersecurity Governance
−Removed: Our Board of Directors (“Board”)
−Removed: is responsible for the oversight of cybersecurity risk management.
−Removed: The Board delegates oversight of the cybersecurity risk management
−Removed: program to the Information Security Oversight Committee (“ISOC").
−Removed: The Chief Financial Officer (“CFO”), who serves
−Removed: on ISOC, provides updates to the Audit Committee on our cybersecurity risk management program, including any critical cybersecurity risks,
−Removed: ongoing cybersecurity initiatives and strategies, and applicable regulatory requirements and industry standards on a quarterly basis.
−Removed: The CFO also notifies the Board and Audit Committee of any cybersecurity incidents (suspected or actual) and provides updates on the incidents
−Removed: as well as cybersecurity risk mitigation activities as appropriate.
+Added: the ordinary course of our business, we use, store and process data including data of our employees, partners, collaborators,
+Added: To effectively prevent, detect, and respond to cybersecurity threats, we maintain a cyber risk management program,
+Added: which is comprised of a wide array of policies, standards, architecture, and processes.
+Added: The cyber risk management program falls
+Added: under the responsibility of our Director of Information Technology (“IT”), who has cross-functional expertise
+Added: in IT, computer science, cyber security, and more than 20 years of experience.
+Added: The IT Director leads a team of IT specialists
+Added: with similar IT and cybersecurity backgrounds.
+Added: Under the guidance of our IT Head, we develop, maintain, and evidence the policies,
+Added: standards, and processes in a manner consistent with applicable legal requirements.
+Added: We also utilize a variety of cybersecurity
+Added: software from reputable vendors in cybersecurity.
+Added: have implemented a cybersecurity risk management program that is designed to identify, assess, and mitigate risks from cybersecurity
+Added: threats to this data and our systems and ensure the effectiveness of our security controls.
+Added: Our cybersecurity risk management
+Added: program is intended to address applicable NIST 800-171 & CMMC requirements for our business.
+Added: Our cybersecurity risk management
+Added: program incorporates several components, including information security program assessments, continuous monitoring of critical
+Added: risks from cybersecurity threats using automated tools, backup testing, periodic threat testing, and documented standards, policies,
+Added: and procedures.
+Added: We deploy a wide range of security tools across the environment, and implement access control policies to further
+Added: limit access to data within the systems.
+Added: periodically engage third parties to conduct risk assessments, including penetration testing, tabletops and other system vulnerability
+Added: As a result of these assessments and testing, we have not identified any material cybersecurity risks and are constantly
+Added: hardening our environment.
+Added: Additionally, our program includes annual cybersecurity training for all employees.
+Added: Cybersecurity
+Added: Board of Directors (“Board”) is responsible for the oversight of cybersecurity risk management.
+Added: The Board delegates
+Added: oversight of the cybersecurity risk management program to the Information Security Oversight Committee (“ISOC").
+Added: Chief Financial Officer (“CFO”), who serves on ISOC, provides updates to the Audit Committee on our cybersecurity
+Added: risk management program, including any critical cybersecurity risks, ongoing cybersecurity initiatives and strategies, and applicable
+Added: regulatory requirements and industry standards on a quarterly basis.
+Added: The CFO also notifies the Board and Audit Committee of any
+Added: cybersecurity incidents (suspected or actual) and provides updates on the incidents as well as cybersecurity risk mitigation activities
+Added: as appropriate.
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.