4 unchanged sentences
We maintain a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical information technology systems and information.
−Removed: Our cybersecurity risk management program is integrated into our overall enterprise risk management program, and shares common methodologies, incident reporting channels and governance processes as those used in our enterprise risk management.
+Added: Our cybersecurity risk management program is integrated into our overall enterprise risk management program, and shares common methodologies, incident reporting channels and governance processes, as those used in our enterprise risk management program.
We designed and continue to assess our cybersecurity program based on the National Institute of Standards and Technology Cybersecurity Framework (“NIST CSF”), which we use as a guide to help us identify, prioritize and manage the cybersecurity risks that could materially affect our business, financial condition or results of operations.
5 unchanged sentences
Our cybersecurity risk management program also includes:
−Removed: • a multi-layered approach to cybersecurity in order to protect our assets;
+Added: • a multi-layered approach to cybersecurity designed to protect our assets;
• identification of key risk areas through internal reviews and researching trends;
−Removed: • continuous mitigation in the areas of human behavior, data breaches, remote work, third party vendors, removable media and emerging threats;
−Removed: • performance of multiple assessments both internal and external;
+Added: • ongoing mitigation in the areas of human behavior, data breaches, remote work, third party vendors, removable media and emerging threats;
+Added: • performance of multiple assessments both internally and externally;
• quarterly mandatory security training for employees as well as monthly phishing tests;
• multi-factor authentication.
−Removed: For the fiscal year ended December 31, 2023, we did not experience any cybersecurity incidents that have materially affected or are reasonably likely to materially affect our business strategy, results of operations or financial condition.
+Added: For the fiscal year ended December 29, 2024, we are not aware of any cybersecurity incidents or risks from cybersecurity incidents that have materially affected or were reasonably likely to materially affect our business strategy, results of operations or financial condition.
+Added: We cannot guarantee that we may not experience any cybersecurity incidents or risks related to cybersecurity incidents in the future.
Cybersecurity Governance
2 unchanged sentences
Our Company Board plays a role in overseeing risks associated with cybersecurity threats.
−Removed: The Audit Committee of the Board has been provided specific responsibility for overseeing the Company’s risk management of cybersecurity.
+Added: The Audit Committee of the Board has been delegated specific responsibility for overseeing the Company’s risk management of cybersecurity.
The Audit Committee has appointed a member of the Audit Committee to receive certified cybersecurity training so he can provide specialized guidance to the Board and Company.
9 unchanged sentences
The management team’s efforts to prevent, detect, mitigate and remediate cybersecurity risks and incidents are enhanced by monthly and quarterly briefings from internal security personnel, by receipt of threat intelligence and other information obtained from governmental, public or private sources, including external consultants, periodic assessments against the NIST CSF and through alerts and reports produced by security tools deployed in our IT environment.
−Removed: In the event a cybersecurity incident rise to the level of a corporate crisis, the management team along with the Security Incident Response Team would engage the Company Board.
+Added: In the event a cybersecurity incident meets certain predetermined criteria, the management team along with the Security Incident Response Team would engage the Company Board.
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.