5 unchanged sentences
Managing Material Risks & Integrated Overall Risk Management
−Removed: We attempt to integrate cybersecurity risk management into our broader risk management framework to promote a company-wide culture of cyber risk awareness.
+Added: We have integrated cybersecurity risk management into our broader risk management framework to promote a company-wide culture of cyber risk awareness.
We depend on various controls, policies, procedures and programs (“Risk Controls”) to manage our risks, including risks associated with our information systems.
−Removed: Risks and Risk Controls are included as part of our annual enterprise risk management (“ERM”) program.
+Added: Risks Assessment and Risk Controls are included as part of our annual enterprise risk management (“ERM”) program.
Our risk controls include our administrative, physical, and technical controls (“Cyber Risk Controls”).
12 unchanged sentences
Risk Management Personnel
−Removed: Our Director of IT Infrastructure and Cybersecurity has direct responsibility for assessing, monitoring and managing risks related to cybersecurity threats in conjunction with the Vice President of Information Technology.
+Added: Our Director of Cybersecurity and Networking has direct responsibility for assessing, monitoring and managing risks related to cybersecurity threats in conjunction with the Vice President of Information Technology.
Third party experts and/or consultants are retained to help identify, assess and monitor cybersecurity incidents and related risks.
−Removed: Our Director of IT Infrastructure and Cybersecurity has been in that position with the Company since 2019 and, including prior experience, has over 12 years’ experience in managing IT infrastructure, architecture and security.
+Added: Our Director of Cybersecurity and Networking has been in that position with the Company since 2019 and, including prior experience, has over 13 years’ experience in managing IT infrastructure, architecture and security.
Our Vice President of Information Technology has been with the Company in his current position and similar roles since its inception in 2011.
1 unchanged sentence
Monitoring Cybersecurity Risks and Incidents
−Removed: Our Director of IT Infrastructure and Cybersecurity meets regularly with members of our executive team to discuss and review risks related to cybersecurity.
+Added: Our Director of IT Cybersecurity and Networking meets regularly with members of our executive team to discuss and review risks related to cybersecurity.
The reviews may include evaluations of risks and incidents identified by third-party providers retained to review our cyber risk as well as cybersecurity threat scenario planning.
5 unchanged sentences
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.