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We have implemented and maintain various information security processes designed to identify, assess and manage material risks from cybersecurity threats to our critical computer networks, third-party hosted services, communications systems, hardware and software, and our critical data, including intellectual property, clinical trial data, customer data, manufacturing data, and confidential information that is proprietary, strategic or competitive in nature (“Information Systems and Data”).
−Removed: Our Vice President of Information Technology supervises our Information Technology Department (the “IT Department”) which coordinates with third -party service providers that perform security management roles, including those of a Chief Information Security Officer, to identify, assess and manage our cybersecurity threats and risks.
+Added: Our Vice President of Information Technology ("IT") supervises our Information Technology Department which coordinates with third -party service providers that perform security management roles, including those of a Chief Information Security Officer and help desk, to identify, assess and manage our cybersecurity threats and risks.
Our IT Department and security management team, including third -party service providers, identify and assess risks from cybersecurity threats by monitoring and evaluating our threat environment using various methods including, for example:
−Removed: manual and automated tools, subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and actors, conducting scans of the threat environment, internal audits relating to cybersecurity, conducting threat assessments for internal and external threats, third -party threat assessments, conducting vulnerability assessments to identify vulnerabilities, use of external intelligence feeds, evaluating our and our industry’s risk profile, and evaluating threats reported to us.
+Added: manual and automated tools, subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and threat actors, conducting scans of the threat environment, internal audits relating to cybersecurity, conducting threat assessments for internal and external threats, third -party threat assessments, conducting vulnerability assessments to identify vulnerabilities, use of external intelligence feeds, evaluating our and our industry’s risk profile, and evaluating threats reported to us.
Depending on the environment, we implement and maintain various technical, physical, and organizational measures, processes, standards and policies designed to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data, including, for example:
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systems monitoring;
−Removed: vulnerability management policy;
+Added: a vulnerability management policy;
risk assessments;
−Removed: encryption of certain of our data;
+Added: data encryption;
third -party cybersecurity staff;
network security controls;
−Removed: segregation of certain of our data;
+Added: data segregation;
access controls;
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For example, our IT Department works with management to prioritize our risk management processes and mitigate cybersecurity threats that are expected to be more likely to lead to a material impact to our business.
−Removed: In addition, our management evaluates material risks from cybersecurity threats against our overall business objectives and reports to the audit committee of our board of directors, which, together with our board of directors, evaluates our overall enterprise risk.
+Added: In addition, our management evaluates material risks from cybersecurity threats against our overall business objectives and reports to the audit committee of our board of directors, which, together with the rest of our board of directors, evaluates our overall enterprise risk.
We use third -party service providers to assist us to identify, assess, and manage material risks from cybersecurity threats, including, for example:
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Additionally, we rely on third -party service providers and technologies to operate critical business systems to process sensitive information in a variety of contexts, including, without limitation, cloud-based infrastructure, data center facilities, encryption and authentication technology, employee email, and content delivery.
−Removed: Third-party service providers we rely on include:
+Added: Other types of third -party service providers we rely on include:
application providers, distributors, hosting companies, supply chain resources, contract research organizations, and contract manufacturing organizations.
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For a description of the risks from cybersecurity threats that may materially affect us and how they may do so, see our risk factors under Part I, Item 1A.
−Removed: Risk Factors in this Annual Report on Form 10-K, including “Risk Factors – If our information technology systems or data, or those of third parties upon whom we rely, are or were compromised, this could result in adverse consequences resulting from such compromise including but not limited to regulatory investigations or actions;
+Added: Risk Factors in this Annual Report on Form 10-K, including “If our information technology systems or data, or those of third parties upon whom we rely, are or were compromised, we could experience adverse consequences resulting from such compromise including but not limited to regulatory investigations or actions;
fines and penalties;
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harm our reputation;
−Removed: triggering our breach notification obligations;
−Removed: prevent us from accessing critical information;
+Added: triggering of breach notification obligations;
+Added: inability to access critical information;
disruptions of our business operations;
loss of revenue or profits;
−Removed: loss of customers or sales and expose us to liability or other adverse effects to our business.”
+Added: loss of customers or sales and legal liability or other adverse effects to our business.”
Our board of directors addresses our cybersecurity risk management as part of its general oversight function.
The audit committee of our board of directors is responsible for overseeing our cybersecurity risk management processes, including oversight of risks from cybersecurity threats.
−Removed: Our cybersecurity risk assessment and management processes are implemented and maintained by certain members of our management, including, among others, our Executive Vice President of Talent, Advocacy & Communications, Vice President of IT, and Associate Director of IT Operations.
−Removed: Our Vice President of IT is an IT security professional and members of our IT Department have certain credentialling in cybersecurity.
−Removed: We also rely on third-party security analysts who have certain certifications related to cybersecurity.
+Added: Our cybersecurity risk assessment and management processes are implemented and maintained by certain members of our management, including, among others, our Executive Vice President of Talent, Advocacy & Communications, Vice President of IT, and Director of IT Infrastructure & Operations.
+Added: Our Vice President of IT is an IT security professional with over 15 years heading IT and cybersecurity functions, and our Director of IT Infrastructure & Operations holds CCNA Security and CyberOps certifications, as well as ITIL Foundation v4 certification.
Our Executive Vice President of Talent, Advocacy & Communications and Vice President of IT, are responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into our overall risk management strategy, and communicating key priorities to relevant personnel.
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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.