1 unchanged sentence
are no unresolved staff comments at December 31, 2025.
−Removed: – Cybersecurity
+Added: 1C – CYBERSECURITY
Cybersecurity
Risk Management
−Removed: We face several cybersecurity risks in connection with our business.
−Removed: Our business strategy,
−Removed: results of operations, and financial condition have not, to date, been affected by risks from cybersecurity threats.
−Removed: reporting period, we have not experienced any material cyber incidents, nor have we experienced a series of immaterial incidents,
−Removed: which would require disclosure.
−Removed: the ordinary course of our business, we use, store and process data including data of our employees, partners, collaborators,
−Removed: To effectively prevent, detect, and respond to cybersecurity threats, we maintain a cyber risk management program,
−Removed: which is comprised of a wide array of policies, standards, architecture, and processes.
−Removed: The cyber risk management program falls
−Removed: under the responsibility of our Director of Information Technology (“IT”), who has cross-functional expertise
−Removed: in IT, computer science, cyber security, and more than 20 years of experience.
−Removed: The IT Director leads a team of IT specialists
−Removed: with similar IT and cybersecurity backgrounds.
−Removed: Under the guidance of our IT Head, we develop, maintain, and evidence the policies,
−Removed: standards, and processes in a manner consistent with applicable legal requirements.
−Removed: We also utilize a variety of cybersecurity
−Removed: software from reputable vendors in cybersecurity.
+Added: face several cybersecurity risks in connection with our business.
+Added: Our business strategy, results of operations, and financial
+Added: condition have not, to date, been affected by risks from cybersecurity threats.
+Added: During the reporting period, we have not experienced
+Added: any material cyber incidents, nor have we experienced a series of immaterial incidents, which would require disclosure.
+Added: In the ordinary course of our business, we use, store and process data
+Added: including data of our employees, partners, collaborators, and vendors.
+Added: To effectively prevent, detect, and respond to cybersecurity threats,
+Added: we maintain a cyber risk management program, which is comprised of a wide array of policies, standards, architecture, and processes.
+Added: cyber risk management program falls under the responsibility of the head of our Information Technology (“IT”), who has cross-functional
+Added: expertise in IT, computer science, cyber security, and more than 20 years of experience.
+Added: The IT head leads a team of IT specialists with
+Added: similar IT and cybersecurity backgrounds.
+Added: Under the guidance of the IT head, we develop, maintain, and evidence the policies, standards,
+Added: and processes in a manner consistent with applicable legal requirements.
+Added: We also utilize a variety of cybersecurity software from reputable
+Added: vendors in cybersecurity.
have implemented a cybersecurity risk management program that is designed to identify, assess, and mitigate risks from cybersecurity
threats to this data and our systems and ensure the effectiveness of our security controls.
−Removed: Our cybersecurity risk management
−Removed: program is intended to address applicable NIST 800-171 & CMMC requirements for our business.
−Removed: Our cybersecurity risk management
−Removed: program incorporates several components, including information security program assessments, continuous monitoring of critical
−Removed: risks from cybersecurity threats using automated tools, backup testing, periodic threat testing, and documented standards, policies,
+Added: cybersecurity risk management program is intended to address applicable NIST 800-171 & CMMC requirements for our business.
+Added: Our cybersecurity
+Added: risk management program incorporates several components, including information security program assessments, continuous monitoring of
+Added: critical risks from cybersecurity threats using automated tools, backup testing, periodic threat testing, and documented standards, policies,
and procedures.
−Removed: We deploy a wide range of security tools across the environment, and implement access control policies to further
−Removed: limit access to data within the systems.
+Added: We deploy a wide range of security tools across the environment, and implement access control policies to further limit
+Added: access to data within the systems.
periodically engage third parties to conduct risk assessments, including penetration testing, tabletops and other system vulnerability
4 unchanged sentences
Board of Directors ("Board") is responsible for the oversight of cybersecurity risk management.
−Removed: The Board delegates
−Removed: oversight of the cybersecurity risk management program to the Information Security Oversight Committee (“ISOC").
−Removed: Chief Financial Officer (“CFO”), who serves on ISOC, provides updates to the Audit Committee on our cybersecurity
−Removed: risk management program, including any critical cybersecurity risks, ongoing cybersecurity initiatives and strategies, and applicable
−Removed: regulatory requirements and industry standards on a quarterly basis.
−Removed: The CFO also notifies the Board and Audit Committee of any
−Removed: cybersecurity incidents (suspected or actual) and provides updates on the incidents as well as cybersecurity risk mitigation activities
−Removed: as appropriate.
+Added: The Board delegates oversight
+Added: of the cybersecurity risk management program to the Information Security Oversight Audit Committee ("ISOC").
+Added: The Chief Financial
+Added: Officer ("CFO"), who serves on ISOC, provides updates to the Audit Committee on our cybersecurity risk management program,
+Added: including any critical cybersecurity risks, ongoing cybersecurity initiatives and strategies, and applicable regulatory requirements
+Added: and industry standards on a quarterly basis.
+Added: The CFO also notifies the Board and Audit Committee of any cybersecurity incidents (suspected
+Added: or actual) and provides updates on the incidents as well as cybersecurity risk mitigation activities 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.