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The Company also leverages the services and tools of a third-party cybersecurity firm to identify, prioritize, assess, mitigate and remediate reasonably foreseeable cybersecurity risks and threats.
−Removed: To identify, detect and respond to a cybersecurity incident, we conduct proactive privacy and cybersecurity reviews of systems and applications, audit applicable data policies, perform penetration testing, perform incident response capability reviews and exercises, conduct employee training, monitor emerging laws and regulations related to data protection and information security (including intellectual property) and implement appropriate changes.
+Added: To identify, detect and respond to a cybersecurity incident, we conduct proactive cybersecurity reviews of systems and applications, audit applicable data policies, perform penetration testing, perform incident response capability reviews and exercises, conduct annual employee training, monitor emerging laws and regulations related to data protection and information security (including intellectual property) and implement appropriate changes.
The Company has implemented a cybersecurity incident response plan that outlines the Company’s process for preparing for a cybersecurity incident, detecting, analyzing, containing, eradicating and recovering from such incident, and provides guidance for post-incident analysis.
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In such instance, the Cyber Incident Committee monitors the incident through resolution and post-incident analysis.
−Removed: For a discussion of cybersecurity risks or the impact of previous cybersecurity incidents and how they have materially affected us or are reasonably likely to materially affect the Company, including its business strategy, results of
−Removed: operations or financial condition, see Item 1A.
−Removed: Risk Factors “ Risks Related to Our Business” , which are incorporated by reference into this Item 1C.
+Added: To date, we have not identified any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, which have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition .
+Added: For additional discussion of cybersecurity risks or the impact of previous cybersecurity incidents, see Item 1A.
+Added: Risk Factors “ Risks Related to Our Business” in this Annual Report on Form 10-K.
The Company’s board of directors is responsible for overseeing the Company’s risk management program and has designated its Audit & Finance Committee with specific responsibility for overseeing cybersecurity risks, among other risks.
The Company’s cybersecurity organization is led by our Director of Information Security (“DOIS”), who is responsible for assessing and managing material risks that result from cybersecurity threats, and reports to the Senior Vice President and Chief Information Officer (“CIO”) .
−Removed: The CIO and the Audit & Finance Committee monitor the prevention, detection, mitigation and remediation of cybersecurity incidents through their management of, and participation in, the cybersecurity risk management and strategy processes described above, including regular communication with our DOIS and regular communication with and reporting from an outsourced third party cybersecurity firm and operation of the Company’s cybersecurity incident response plan, which includes escalation to the Cyber Incident Committee.
+Added: The CIO and the Audit & Finance Committee monitor the prevention, detection, mitigation and remediation of cybersecurity incidents through their management of, and participation in, the cybersecurity risk management and strategy processes.
Our DOIS has nearly a decade of experience within cybersecurity functions and his skillset includes security architecture and engineering, incident response and penetration testing.
−Removed: Our CIO joined the Company in 2023 and most recently served as CIO and VP at another large organization where he built a high-performing, global, collaborative IT team to focus on digitization, M&A, analytics and cybersecurity and has held other vital IT positions over the course of his career.
+Added: Our CIO joined the Company in 2023 and most recently served as CIO and VP at another large, publicly-traded organization and has held other vital IT positions over the course of his over 25 year career.
The Audit & Finance Committee regularly reviews our cybersecurity program with our CIO and management and reports to the Board of Directors.
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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.