1 unchanged sentence
Cybersecurity
−Removed: Risk management and strategy
−Removed: We recognize the critical
−Removed: importance of developing, implementing, and maintaining robust cybersecurity measures to safeguard our information systems and protect
−Removed: the confidentiality, integrity, and availability of our data.
−Removed: Managing Material Risks & Integrated Overall
−Removed: Risk Management
−Removed: We have strategically integrated cybersecurity
−Removed: risk management into our broader risk management framework to promote a company-wide culture of cybersecurity risk management.
−Removed: Our Chief Technology Officer (CTO) evaluates and addresses cybersecurity risks in alignment with our business objectives and
−Removed: operational needs.
−Removed: Engage Third parties on Risk Management
−Removed: Recognizing the complexity
−Removed: and evolving nature of cybersecurity threats, we have engaged with a range of external experts, including cybersecurity assessors,
−Removed: consultants, and auditors in evaluating and testing our risk management systems in an ongoing and as needed basis.
−Removed: These partnerships
−Removed: enable us to leverage specialized knowledge and insights, ensuring our cybersecurity strategies and processes remain at the
−Removed: forefront of industry best practices.
−Removed: Our collaboration with these third parties includes regular audits, threat assessments, and consultation
−Removed: on security enhancements.
−Removed: Oversee Third-party Risk
−Removed: Because we are aware of the
−Removed: risks associated with third-party service providers, we implement stringent processes to oversee and manage these risks.
+Added: management and strategy
+Added: recognize the critical importance of developing, implementing, and maintaining robust cybersecurity measures to safeguard our information
+Added: systems and protect the confidentiality, integrity, and availability of our data.
+Added: Material Risks & Integrated Overall Risk Management
+Added: have strategically integrated cybersecurity risk management into our broader risk management framework to promote a company-wide
+Added: culture of cybersecurity risk management.
+Added: Our Chief Technology Officer (CTO) evaluates and addresses cybersecurity risks
+Added: in alignment with our business objectives and operational needs.
+Added: The Company’s cybersecurity
+Added: risk management strategy focus on:
+Added: ● Technical Safeguards:
+Added: The Company implements
+Added: technical safeguards that are designed to protect the Company’s information systems from cybersecurity threats.
+Added: The company uses
+Added: a managed antivirus platform to scan for viruses, manage patching and updates, and provide remote support and monitoring tools.
+Added: accounts have strong passwords and two factor authentication, where available.
+Added: ● Third-Party Risk Management:
We conduct thorough
security assessments of all third-party providers before engagement and maintain ongoing monitoring to ensure compliance with our cybersecurity
−Removed: The monitoring includes quarterly assessments by our CTO.
−Removed: This approach is designed to mitigate risks related to data breaches
−Removed: or other security incidents originating from third parties.
+Added: This approach is designed to mitigate risks related to data breaches or other security incidents originating from third parties
+Added: ● Incident Response and Recovery Planning:
+Added: Company has established and maintains comprehensive incident response, business continuity, and disaster recovery plans designed to address
+Added: the Company’s response to a cybersecurity incident.
+Added: Recognizing the complexity
+Added: and evolving nature of cybersecurity threats, we have engaged with a range of external experts, including cybersecurity assessors,
+Added: and consultants in evaluating and testing our risk management systems in an ongoing and as needed basis.
+Added: These partnerships enable us
+Added: to leverage specialized knowledge and insights, ensuring our cybersecurity strategies and processes remain at the forefront
+Added: of industry best practices.
+Added: Our collaboration with these third parties includes threat assessments and consultation on security enhancements.
Risks from Cybersecurity Threats
−Removed: We have not encountered cybersecurity challenges
−Removed: that have materially impaired our operations or financial standing.
−Removed: The Board of Directors is
−Removed: acutely aware of the critical nature of managing risks associated with cybersecurity threats.
−Removed: The Board has established oversight
−Removed: mechanisms to ensure effective governance in managing risks associated with cybersecurity threats because we recognize the
−Removed: significance of these threats to our operational integrity and stakeholder confidence,
−Removed: Board of Directors Oversight
−Removed: The Audit Committee is central
−Removed: to the Board’s oversight of cybersecurity risks and bears the primary responsibility for this domain.
−Removed: The Audit Committee
−Removed: is composed of board members with diverse expertise including, risk management, technology, and finance, equipping them to oversee cybersecurity risks
−Removed: Management’s Role Managing Risk
−Removed: The CTO and the Chief Executive
−Removed: Officer (“CEO”) play a pivotal role in informing the Audit Committee on cybersecurity risks.
−Removed: The CTO keeps the CEO apprised
−Removed: of any noteworthy activity on an ongoing basis.
−Removed: The CEO in turn provides comprehensive briefings to the Audit Committee on a regular
−Removed: basis, with a minimum frequency of once per year.
+Added: As of the date of this report,
+Added: we are not aware of any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, that have
+Added: materially affected our business strategy, results of operations, or financial condition, nor in our view, are such threats currently
+Added: or reasonably likely to materially affect the Company.
+Added: Acknowledging
+Added: the critical importance of cybersecurity, our management and Board are dedicated to maintaining the trust and confidence of our business
+Added: partners and employees.
+Added: Our executive officers manage the day-to-day material risks we face, adopting a cross-functional approach to
+Added: address cybersecurity risks by identifying, preventing, and mitigating cybersecurity threats and effectively responding to incidents
+Added: when they occur.
+Added: CTO and the Chief Executive Officer (“CEO”) play a pivotal role in informing the Audit Committee on cybersecurity risks.
+Added: The CTO keeps the CEO apprised of any noteworthy activity on an ongoing basis.
+Added: The CEO in turn provides comprehensive briefings to the
+Added: Audit Committee on a regular basis, with a minimum frequency of once per year.
These briefings encompass a broad range of topics, including:
7 unchanged sentences
requirements and industry standards.
−Removed: In addition to our scheduled
−Removed: meetings, the Audit Committee and CEO maintain an ongoing dialogue regarding emerging or potential cybersecurity risks.
−Removed: they receive updates on any significant developments in the cybersecurity domain, ensuring the Board’s oversight is proactive
−Removed: and responsive.
+Added: addition to our scheduled meetings, the Audit Committee and CEO maintain an ongoing dialogue regarding emerging or potential cybersecurity risks.
+Added: Together, they receive updates on any significant developments in the cybersecurity domain, ensuring the Board’s oversight
+Added: is proactive and responsive.
+Added: We are a distributed organization
+Added: and do not maintain a central location at which our employees work.
+Added: Our employees primarily work from home or from coworking spaces.
+Added: We believe our current arrangements are adequate for our needs and do not anticipate any difficulty in continuing to support our operations
+Added: as the business evolves.
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.