text: As a blank check company, we have no operations and therefore do not have any operations of our own that face material cybersecurity threats. However, we do depend on the digital technologies of third parties, including information systems, infrastructure and cloud applications and services, any sophisticated and deliberate attacks on, or security breaches in, systems or infrastructure or the cloud that we utilize, including those of third parties, could lead to corruption or misappropriation of our assets, proprietary information and sensitive or confidential data. Because of our reliance on the technologies of third parties, we also depend upon the personnel and the processes of third parties to protect against cybersecurity threats, and we have no personnel or processes of our own for this purpose. In the event of a cybersecurity incident impacting us, the management team will report to the board of directors and provide updates on the management team's incident response plan for addressing and mitigating any risks associated with such an incident. As an early-stage company without significant investments in data security protection, we may not be sufficiently protected against such occurrences. We also lack sufficient resources to adequately protect against, or to investigate and remediate any vulnerability to, cyber incidents. It is possible that any of these occurrences, or a combination of them, could have material adverse consequences on our business and lead to financial loss.

companyName: Direct Selling Acquisition Corp.


text: We are a special purpose acquisition company with no business operations. Since our Initial Public Offering, our sole business activity has been identifying and evaluating suitable acquisition transaction candidates. Therefore, we do not consider that we face significant cybersecurity risk and have not adopted any cybersecurity risk management program or formal processes for assessing cybersecurity risk. Our board of directors is generally responsible for the oversight of risks from cybersecurity threats, if there is any.

companyName: Four Leaf Acquisition Corp

ticker: FORL

secItem: Item 1C


text: On April 28, 2023, we identified a payment of $54,300 was incorrectly made to an unauthorized payee as a result of a phishing attack. Our management team, at the direction of the board of directors, investigated the matter and concluded that the phishing attack was an isolated incident perpetrated by an external source. With the assistance of our bank, we were ultimately able to recover all of these funds on June 29, 2023. As a result of this phishing attack, we have implemented additional controls related to vendor verification and additional review procedures of each payment made by several authorized individuals.


text: We are a special purpose acquisition company with no business operations. Since our IPO, our sole business activity has been identifying and evaluating prospective acquisition candidates. Therefore, we do not consider that we face significant cybersecurity risk and have not adopted any cybersecurity risk management program or formal processes for assessing cybersecurity risk. Our board of directors is generally responsible for the oversight of risks from cybersecurity threats, if any. We have not encountered any cybersecurity incidents since our IPO.

companyName: Target Global Acquisition I Corp.

ticker: TGAAF


text: We are a SPAC with no business operations. Since our IPO, our sole business activity has been identifying and evaluating suitable acquisition transaction candidates. Therefore, we do not consider that we face significant cybersecurity risk and have not adopted any cybersecurity risk management program or formal processes for assessing cybersecurity risk. Our board of directors is generally responsible for the oversight of risks from cybersecurity threats, if there is any. We have not encountered any cybersecurity incidents since our IPO.

companyName: Invest Acquisition Corp


text: We are a SPAC with no business operations. Since our IPO, our sole business activity has been identifying, evaluating suitable acquisition transaction candidates and completing the merger with our target acquisition companies. Therefore, we do not consider that we face significant cybersecurity risk and have not adopted any cybersecurity risk management program or formal processes for assessing cybersecurity risk. Our board of directors is generally responsible for the oversight of risks from cybersecurity threats, if there is any. We have not encountered any cybersecurity incidents since our IPO.

companyName: AltEnergy Acquisition Corp

ticker: AEAE


text: We are a SPAC with no business operations. Since our IPO, our sole business activity has been identifying and evaluating suitable acquisition transaction candidates. Therefore, we do not consider that we face significant cybersecurity risk and have not adopted any cybersecurity risk management program or formal processes for assessing cybersecurity risk. However, because we have investments in our Trust Account and bank deposits and we depend on the digital technologies of third parties, we and third parties may be subject to attacks on or security breaches in our or their systems. Because of our reliance on the technologies of third parties, we also depend upon the personnel and the processes of third parties to protect against cybersecurity threats, and we have no personnel or processes of our own for this purpose. Our board of directors is generally responsible for the oversight of risks from cybersecurity threats, if there is any. We have not encountered any cybersecurity incidents since our IPO.

companyName: Investcorp AI Acquisition Corp.

ticker: IVCAF


text: We are a special purpose acquisition company with no business operations. Since the IPO, our sole business activity has been identifying and evaluating suitable acquisition transaction candidates. Therefore, we do not believe that we currently face significant cybersecurity risk and have not adopted any cybersecurity risk management program or formal processes for assessing cybersecurity risk. Our board of directors is generally responsible for the oversight of risks from cybersecurity threats, if any. We have not encountered any cybersecurity incidents since the IPO.

companyName: INTEGRATED RAIL & RESOURCES ACQUISITION CORP


text: Cybersecurity Risk Management and Strategy We are dedicated to protecting the integrity, confidentiality, and availability of our data, infrastructure and operating systems. As part of our commitment to safeguarding our operations against cybersecurity threats, we employ a comprehensive strategy for the assessment, identification, and management of cybersecurity risks. We engage a third-party CIO consulting firm and a managed services provider, which work together to provide wide-ranging services including risk assessments, threat detection, monitoring and response strategies, security audits and cybersecurity services, tools and training. An enterprise firewall; Implementation of Multi-Factor Authentication (MFA); Adherence to the Zero Trust model; Utilization of Managed Detection and Response (MDR); Endpoint Detection and Response (EDR) technologies;

companyName: ODYSSEY MARINE EXPLORATION INC

ticker: OMEX


text: 24x7 Security Operations Center (SOC); and Employment of Security Information and Event Management (SIEM) systems to continuously monitor our network and respond to threats in real time.


text: Risk Assessment Procedures: We conduct periodic risk assessments to identify potential cybersecurity threats and vulnerabilities within our IT infrastructure. These assessments are conducted using various software tools and methodologies that enable us to evaluate our systems critically and comprehensively. Our risk assessment process includes the analysis of: Hardware and software configurations; Network and data access protocols; Encryption standards; and Compliance with relevant industry and regulatory standards.


text: Threat Identification: We utilize advanced threat detection tools and services that continuously monitor our network for signs of unauthorized access, anomalies, and potential breaches. Our third-party cybersecurity provider is equipped with sophisticated detection technologies that help to swiftly identify even the most subtle signs of compromise. We focus on: Real-time monitoring of our networks; Regularly updated intrusion detection systems (IDS);


text: Deployment of endpoint detection and response (EDR) solutions; and Utilization of threat intelligence platforms to stay abreast of emerging threats.


text: Threat Management: Upon identification of a potential threat, our managed service provider's dedicated incident response team takes immediate action to mitigate any adverse impacts. Our threat management procedures include: Immediate isolation of affected systems to prevent the spread of threats; Application of appropriate remediation measures, such as patches and software updates; Conducting a thorough investigation to understand the breach's nature and scope; and Implementing enhancements to prevent future occurrences.


text: Our incident response plan provides a concise strategy of how we will respond to an incident, including who will respond and their roles and responsibilities, the facilities that are in place to help with the management of the incident, how decisions will be taken with regard to our response to an incident, how communication will be handled both internally and externally, and defining what will happen once the incident is resolved and how we can learn and improve from the situation.


text: Integration into Overall Risk Management: Our cybersecurity risk assessment processes are fully integrated into the broader risk management framework. Cybersecurity is positioned as a core component of our risk management strategy, with direct reporting to our President and COO, who is guided by our third-party CIO firm. The CIO firm provides strategic direction on policy, procedures and best practice. The synergy between cybersecurity and risk management ensures a resilient posture against emerging cyber threats.


text: Engagement of Third Parties: These providers are selected based on stringent criteria for cybersecurity expertise, particularly their capability to implement and manage NIST and CMMC protocols.


text: Third-Party Service Provider Oversight: Our oversight processes include comprehensive due diligence checks for any new third-party service provider and continuous monitoring of our existing managed service provider and CIO firms' activities. We have established protocols for communication and incident response that align with our managed service provider's operations, and industry best practice, ensuring swift action in the face of cybersecurity threats. Furthermore, a scheduled series of meetings has been established to procure updates and deliberate upon cybersecurity strategy with our contracted third-party providers.


text: Impact of Cybersecurity Risks Material Effects from Cyber Threats: To date, our operations and financial condition have not been materially affected by cybersecurity threats, due in part to our proactive measures such as employee security training programs and advanced threat detection and response capabilities. Our defensive strategies have successfully mitigated the risks of cyber incidents.


text: Potential Risk Exposure: While we have not experienced significant disruptions from cyber threats, we recognize the evolving nature of cyber risks. We continually evaluate the likelihood of potential cybersecurity incidents that could materially impact our strategic direction, operational efficacy, and financial stability. Our investment in training, alongside our sophisticated SOC, SIEM, and Zero Trust architecture, positions us to identify and address potential cybersecurity challenges promptly.


text: Cybersecurity Governance Our executive team is actively involved in overseeing our cybersecurity operations to ensure that they meet industry standards. The executive team provides regular updates to the board of directors – specifically the audit committee – on the status of our cybersecurity efforts, including any potential risks, threats or incidents.


text: The President and COO, with guidance from our third-party managed services provider and CIO consulting firm, manages our cybersecurity risk management and strategy process. Collectively, our consultants have 50+ years' experience in the cybersecurity industry in various roles.


text: Processes for Informing the Board: The audit committee is regularly informed about cybersecurity risks through quarterly briefings from the President and COO. These briefings include risk assessment reports, incident response updates, changes to the cybersecurity landscape, and other relevant information. In the case of a cybersecurity incident that meets reporting thresholds, the audit committee will be promptly notified and will receive continual updates until the situation is remedied.


text: We are a special purpose acquisition company with no business operations. Since our IPO, our sole business activity has been identifying and evaluating suitable acquisition transaction candidates. Therefore, we do not consider that we face significant cybersecurity risk and have not adopted any cybersecurity risk management program or formal processes for assessing cybersecurity risk. Our board of directors is generally responsible for the oversight of risks from cybersecurity threats, if any.

companyName: Berenson Acquisition Corp. I


text: Cybersecurity Risk Management Strategy and Governance Overview The Trust and the Fund do not have any officers, directors or employees. The Sponsor is responsible for the oversight and overall management of the Trust and the Fund. The Sponsor is a wholly owned subsidiary of Franklin Resources, Inc. ("FRI"). FRI maintains global, firm-wide policies and procedures governing matters relating to crisis management, corporate continuity, business continuity planning and disaster recovery, enterprise business resilience, and corresponding risk mitigation processes and systems in these areas (collectively referred to as the "Global Corporate Continuity Program").

companyName: Franklin Templeton Holdings Trust

ticker: FGDL


text: The Global Corporate Continuity Program is generally overseen by the Business Recovery Governance Committee ("BRGC"). BRGC has developed certain policies and principles in implementing the program. The executive officers of the Sponsor perform certain functions with respect to the Trust and the Fund that, if the Trust or the Fund had directors or executive officers, would typically be performed by them, including receiving reports regarding the Global Corporate Continuity Program. In line with the Global Corporate Continuity Program, the Sponsor or its delegate: (1) regularly conducts a business impact analysis; (2) develops, exercises and maintains a viable and actionable Business Continuity Plan specifically tailored to the Sponsor in light of the nature and scope of its business; and (3) completes annual testing of the Business Continuity Plan. Material exceptions to this policy and risk events and related mitigation/corrective measures are reported to the Sponsor's Governance Oversight Committee. As appropriate, the Sponsor or its delegate will coordinate with FRI's relevant risk management and disaster recovery-related committees to review risk monitoring and mitigation strategies as contemplated under the Global Corporate Continuity Program at least annually, and more often if there are significant internal or external changes affecting these risks as pertains to the Sponsor's business and its Business Continuity Plan.


text: FRI has adopted the National Institute of Standards and Technology's ("NIST") cybersecurity framework as its security outline. The program is reviewed annually. Using the NIST framework as a guide, FRI's cybersecurity program is organized around the following program domains:


text: Identify critical assets, data, systems and capabilities, cybersecurity strategy and governing elements, threats and cybersecurity risks Protect assets (data, systems, networks, personnel, etc.) from external or internal malicious actors and failed practices Detect anomalies and security events through environments monitoring, analysis, remediation, and reporting. Engage outside vendors to periodically test the network infrastructure and software applications against known vulnerabilities and to ensure the use of a best practice security program Respond to incidents regardless of source or causality Recover through planning, improvements and communications (external and internal)


text: Conduct after-action evaluation to identify what went well, what did not go well and improve FRI's systems after an issue FRI employs third-party firms to assess its cybersecurity posture, conduct penetration testing, and forensic analysis. FRI maintains a risk-based approach to identifying and overseeing cybersecurity risks presented by third parties, including vendors, service providers, counterparties and clients, as well as the systems of third parties that could significantly and adversely impact FRI's business in the event of a cybersecurity incident affecting those third-party systems. Third-party risks are included within FRI's NIST framework, and risk identification and mitigation are supported by FRI's Global Corporate Continuity Program. FRI also performs diligence on certain third parties and monitors cybersecurity threats and risks identified through such diligence.


text: Assessment of Cybersecurity Risks As of March 31, 2024, cybersecurity risks have not materially affected the Trust or the Fund's ability to achieve its investment objective, results of operations or financial condition. However, future incidents could have a material impact on our ability to achieve the investment objective, results of operations, or financial condition.


text: With the guidance of the Audit & Risk Management Committee, our Board is responsible for our risk management framework, including our strategy, policies, procedures and systems with respect to cybersecurity and information technology risks associated with us and our supply chain, suppliers and service providers. Our management team has developed and implemented a risk management program that includes cybersecurity risks as a risk category. Management has primary responsibility for supervising internal staff and external consultants assisting with cybersecurity matters, including those that assist management in staying informed about cybersecurity risks and incidents. Management updates the Committee on our cyber risk management program, and the Committee reports to the full Board regarding its activities, including those related to cybersecurity.

companyName: Tamboran Resources Corp

ticker: TBN


text: Key elements of our risk management program relating to cybersecurity include: implementing risk assessments designed to help identify material risks, including risks arising from cybersecurity threats to our critical systems and information; engaging external cybersecurity consultants to assess and assist with aspects of our security processes; and maintaining insurance coverage related to cybersecurity matters. Currently, our management team's experience includes over 50 years combined experience in leadership roles at public companies. We are investing in additional resourcing and cybersecurity measures as we grow.


text: We have not experienced any material risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, which have materially affected us, including our operations, business strategy, results of operations, or financial condition. However, there can be no assurance that our cybersecurity risk management program and processes, including controls, systems and processes that we have or will in the future implement, will be fully implemented, complied with or effective in protecting our systems and information. We face risks from cybersecurity threats that, if realized, are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition. See our risk factor titled "Our business could be negatively affected by security threats and disruptions, including electronic, cybersecurity or physical security threats, incidents and other disruptions."


text: Risk Management and Strategy We have implemented and maintain an information security program 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 participant and patient-related data, and confidential information that is proprietary, strategic or competitive in nature. We believe our information security program is appropriate for a company of our size and stage of development, taking into account our operations and risks.

companyName: Benitec Biopharma Inc.

ticker: BNTC


text: Mechanisms, controls, and technologies designed to prevent or mitigate system intrusion or data loss, theft, misuse, or other security incidents or vulnerabilities and maintain a stable and secure information technology environment.


text: Information security policies, network and device security, encryption standards, risk management, as well as security tools such as malware protection and secure authentication tools.


text: We conduct ongoing monitoring of critical systems for any compromised or potentially compromised accounts, and conduct regular trainings for our employees and senior management on cyber and information security.


text: The Audit Committee of our Board of Directors oversees and reviews the Company's cybersecurity risks and the steps management has taken to protect against threats to the Company's information systems and security. The senior leadership team, including our Executive Director and Chief Executive Officer, provides periodic reports to our Board and the Audit Committee, as applicable.


text: To date, we have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us, including our operations, business strategy, results of operations, or financial condition.


text: Cybersecurity Risk Management Program Overview As cybersecurity threats rapidly evolve in sophistication and become more prevalent, especially with the increasing use of artificial intelligence ("AI") technology, we have implemented a cybersecurity risk management program as part of our oversight, evaluation and mitigation of enterprise-level risks. Our cybersecurity risk management program leverages a combination of processes, technologies and personnel with expertise in cybersecurity to comply with applicable regulations and detect and respond to cyber-attacks, data breaches, security incidents, and compromises of personal information, as well as to regularly and promptly inform management and our Board of Directors of any significant cybersecurity risks and developments.

companyName: TEVA PHARMACEUTICAL INDUSTRIES LTD

ticker: TEVA


text: Our cybersecurity risk management program is led by our global Chief Information Security Officer ("CISO"), who is directly responsible for establishing cybersecurity strategies and structures and managing ongoing cybersecurity risk management activities through our information security office, which is responsible for the day-to-day identification, monitoring and management of cybersecurity risks. Our CISO reports directly to our global Chief Information Officer ("CIO"). Our CISO has significant experience in managing cybersecurity risks at major global companies in the pharmaceutical and defense industries. Our CISO regularly meets with the CIO to provide updates on cybersecurity matters. Our CIO updates our executive management on a regular basis to share cybersecurity related matters and discuss strategies to proactively manage cybersecurity threats. Our CISO and CIO brief our Audit Committee on our cybersecurity and risk management programs.


text: Our information security office is supported by a team consisting of personnel with experience and expertise in cybersecurity risk management strategies, execution and operations, with domain expertise in cloud services security, infrastructure and operational technology security, cybersecurity incident response, and tactical governance risk compliance.


text: Our CISO and CIO are also members of our information and security governance group, led by our CIO, which is comprised of executive and senior leadership from a variety of functions, including information security, corporate security, legal, finance, human resources, internal audit and compliance, as well as members of Teva's global situation room ("GSR"). Additionally, our CISO, CIO and other members of our information security office may, from time to time, consult and coordinate with other Teva departments and members of management to manage cybersecurity risks, promote cybersecurity awareness and implement cybersecurity incident responses.


text: In addition, management has worked, and expects to continue to work, with third-party service providers, as appropriate, to assess, identify and manage cybersecurity risks. Management also conducts periodic and on-demand assessments of our cybersecurity risk management program with expert service providers to ensure it complies with and meets current ISO 27001 standards. As part of its cybersecurity program, Teva conducts periodic tabletop exercises to assess its cybersecurity incident response process.


text: As part of its overall risk oversight function, our Audit Committee, which is comprised entirely of independent directors, oversees cybersecurity risks in connection with overseeing our overall enterprise risk management system. Management, including our CISO and CIO, provide updates on our cybersecurity risk management program and cybersecurity matters to the Audit Committee, and also reports to the Board of Directors as necessary. These updates and reports include updates on Teva's cybersecurity risks and threats, the status of projects intended to strengthen its information security systems, assessments of the information security program (including remediation, mitigation, and management of identified vulnerabilities), and the emerging threat landscape.


text: As part of our cybersecurity risk management program, we maintain industry standard procedures and policies, which are reviewed and revised periodically, and certified to comply with ISO 27001 standards, to both proactively assess, identify and manage potential cybersecurity risks and respond to any actual cybersecurity threats and incidents. Such procedures and policies include: actively monitoring our information technology systems to ensure compliance with applicable legal and regulatory requirements; engaging third-party consultants and other service providers to monitor and, as appropriate, respond to cybersecurity risks; requiring our service providers and our business partners who connect directly to our information technology systems to comply with our cybersecurity standards and due diligence processes and be subject to our non-disclosure and other confidentiality agreements that include cybersecurity-related terms; providing and analyzing specialized industry sector intelligence on cybersecurity threats; regularly testing our cybersecurity systems and disaster preparedness, including our back-up information technology systems; developing and updating incident response plans to address potential cybersecurity threats; and maintaining and training our personnel on cybersecurity incident reporting procedures. Teva engages with key vendors, industry participants, and intelligence and law enforcement communities as part of its continuing efforts to obtain current threat intelligence, collaborate on security enhancements, and evaluate and improve the effectiveness of its information security program.


text: Cyber Threats and Incident Response In the ordinary course of our business, we collect and store confidential data, including intellectual property, proprietary business information and personally identifiable information (including of our employees, customers, suppliers and business partners). We rely extensively on information technology systems, including some systems that are managed by third-party service providers, to securely process, store and transmit such confidential data in order to conduct our business. These systems include programs and processes relating to internal and external communications, ordering and managing materials from suppliers, collecting, processing and storing data produced by our clinical trials and other research and development initiatives, converting materials to finished products, shipping products to customers, processing transactions, processing payments to employees and vendors, calculating sales receivables, generating our financial results for each reporting period, summarizing and reporting results of operations, and complying with information technology security compliance and other regulatory, legal or tax requirements. In addition, as cybersecurity attacks may become increasingly complex as they are enhanced or facilitated by the emergence of new technologies such as AI used to identify and target new vulnerabilities in our information technology systems or those of our customers, third-party vendors and other business partners, we are taking measures to manage these risks by utilizing new tools and capabilities, including AI.


text: We have not been materially impacted by risks from cybersecurity threats and as of the date of this Annual Report on Form 10-K, we are not aware of any cybersecurity risks that are reasonably likely to materially affect our business. However, there can be no assurance that Teva will not be materially affected by such risks in the future. Our systems and networks have been, and are expected to continue to be, the target of increasingly advanced and evolving cyber-attacks and cybersecurity incidents in the future may adversely impact our business, financial condition and results of operations, and we are continuing to actively monitor such threats. For more information, see "Item 1A, Risk Factors—Risks related to our general business and operations—Significant disruptions of our information technology systems could adversely affect our business" and "Item 1A, Risk Factors—Risks related to our general business and operations—A data security breach could adversely affect our business and reputation."


text: In the event that we experience a cybersecurity incident, we have a cybersecurity incident response playbook that sets forth the applicable processes, roles, engagements, escalations and notifications to be executed in order to promptly respond to such threats. Depending on its nature and scale, a cybersecurity threat may be managed within our information security office, escalated to our CISO and CIO, or escalated to our management, and Audit Committee and Board of Directors, as appropriate. In certain instances, our GSR may be initiated and will collectively manage Teva's response to a crisis on a corporate level. The GSR is comprised of members from our various business units and regions, including senior leadership from a variety of functions, such as information security, legal, finance, human resources, communications and compliance.


text: We carry insurance that provides protection against the potential losses arising from a cybersecurity incident. However, there is no assurance that our insurance coverage will cover or be sufficient to cover all losses or claims that may result from a cybersecurity incident.


text: Risk Management and Strategy We have established security practices and safeguards designed to help identify and protect against intentional and unintentional misappropriation or corruption of our information technology systems, data, and operational continuity. We regularly conduct risk assessments to identify potential cybersecurity threats, which include evaluating the likelihood and potential impact of these threats, identifying system and network vulnerabilities, and assessing the effectiveness of our existing controls. As part of our overall cybersecurity program, we engage specialized third-party vendors for certain cybersecurity functions including, but not limited to, incident response, penetration testing, and security operations center monitoring of our information technology environment. Identified risks are documented and communicated to the relevant stakeholders. Upon identification and assessment of risks, we develop and implement what we believe are appropriate measures to manage these risks, which may involve enhancing security controls, implementing new technologies, training employees, or changing business processes. We maintain change management processes, monitoring practices, and data protection measures to mitigate cybersecurity risks and continuously test our systems for potential threats. Such processes and practices to assess, identify, and manage cybersecurity incidents are integrated into our overall enterprise risk assessment process.

companyName: WATSCO INC

ticker: WSO


text: A dedicated team at our corporate headquarters, which is led by our Director of Data Security ("DDS") and composed of the Chief Technology Officer ("CTO") and representatives from risk management, legal, internal audit, and finance departments, is responsible for assessing and managing our cybersecurity risks and data protection practices. The Audit Committee oversees the measures taken by this team to monitor material risks associated with cybersecurity threats, a role crucial to maintaining a robust and effective cybersecurity risk management approach. The DDS and CTO provide formal briefings to the Audit Committee on various cybersecurity matters, including risk assessments, mitigation strategies, areas of emerging risks, and other areas of importance at least once a year, with the Board of Directors receiving updates periodically. Regular discussions on enterprise risks are held between the Audit Committee, Board of Directors, and senior management.


text: Our DDS has more than 20 years of expertise in the information technology sector, with 11 years specifically dedicated to cybersecurity. This experience has fostered a thorough comprehension of cyber threat landscapes, defense strategies, and security technologies.


text: We have identified information technology and cybersecurity risk as some of the most significant risk types to our business. Related to these identified risk types, we have classified our top risks and report them to both senior management and the risk committee of Genworth Financial's Board of Directors, which in turn reports to the Board of Directors. For additional information regarding the risks associated with these matters, see "Item 1A—Risk Factors."

companyName: GENWORTH FINANCIAL INC

ticker: GNW


text: Risk Management and Strategy Genworth's risk management framework recognizes the significant operational risk, including risk of losses, from cybersecurity incidents and the importance of a strong cybersecurity program for effective risk management.


text: As part of our overall risk management, we have implemented a Data Security and Cybersecurity Program (the "DSCP") which sets policy expectations, ensures broad coverage over information technology risks, integrates the Information Security and Information Technology Risk Management Framework into our broader risk management systems, establishes clear roles and governance, and aligns control expectations to the National Institute of Standards and Technology ("NIST"). Under the DSCP, we have processes for identifying, assessing, escalating and managing technology and cybersecurity risk. The DSCP employs various controls and policies to secure our operations and information, which include monitoring, reporting, managing and remediating cybersecurity threats and incidents.


text: Key features of the DSCP include access controls, security training, system security testing, dedicated security personnel, security event monitoring, and when necessary, consultation with third-party data security experts.


text: Through a cross-functional team, we assess and mitigate risks associated with our third-party providers and have processes in place to regularly monitor and evaluate cybersecurity risks, threats and incidents associated with the use of third-party providers, as well as monitoring rights, as appropriate. Our information security team, overseen by our Chief Information Security Officer ("CISO"), conducts annual information security awareness training for employees involved in our systems and processes that handle customer data. We also conduct periodic cybersecurity awareness training with management and the Board of Directors, including cybersecurity preparedness exercises. In addition, the DSCP includes an incident response plan, which coordinates the activities we take to prepare for, detect, respond to and recover from cybersecurity incidents, which include processes to assess the materiality of the incident, escalate, contain, investigate and remediate the incident, as well as to comply with potentially applicable legal reporting and other obligations and mitigate reputational damage. We also carry insurance that provides protection against certain losses arising from a cybersecurity incident.


text: Additionally, we have procedures set forth in the DSCP for reporting and responding to potential cybersecurity incidents as well as determining applicable disclosure requirements, including timely incident reporting. For example, as disclosed in our Form 8-K filed on February 29, 2024, after being notified of the MOVEit Cybersecurity Incident, we, together with PBI, promptly launched an investigation to determine whether and to what extent personal information had been unlawfully accessed as a result of that incident. We determined that approximately 2.5 million to 2.7 million of our policyholders' or other customers' personal information, including social security numbers, was exposed to and obtained by the threat actor as a result of the MOVEit Cybersecurity Incident. We do not believe the MOVEit Cybersecurity Incident has had any impact on any of our information systems, including our financial systems, and there has not been any material interruption of our business operations. While we are continuing to measure the impact of remediation expenses and other potential liabilities, neither this incident, nor other known cybersecurity threats, has had or is reasonably likely to have a material adverse effect on our business strategy, results of operations or financial condition.


text: See "Item 1A—Risk Factors—Our computer systems and those of our third-party service providers have in the past failed or been compromised and may in the future fail or be compromised, including through cybersecurity breaches; we may experience issues from new and complex information technology methodologies such as artificial intelligence; and unanticipated problems could materially adversely impact our disaster recovery systems and business continuity plans, any of which could expose confidential information such as personal information of our customers or employees, damage our reputation, impair our ability to conduct business effectively, result in enforcement action or litigation, and materially adversely affect our business, financial condition and results of operations."


text: Our Board of Directors recognizes the importance of maintaining the privacy and security of customer information, as well as the availability and integrity of our systems, and consequently dedicates meaningful time and attention to the oversight of cybersecurity risk. In light of these risks, our Board of Directors is actively engaged in the oversight of the Company's information technology, which includes periodic briefings on cybersecurity threats and participation in cybersecurity preparedness exercises. Furthermore, under its charter, the Board's risk committee has primary responsibility for information technology risk oversight, including as it relates to cybersecurity and data security matters. In this capacity, the risk committee oversees the Company's processes for identifying, assessing and managing technology and cybersecurity risk, including a risk-based escalation process, which requires that the risk committee be notified by management and, as necessary, receive regular briefings on the matter, and work with management, including Genworth's CISO and Chief Risk Officer ("CRO"), to assess and manage the risk and implement the Company's response to the incident, as appropriate.


text: Genworth's CISO and CRO, both members of management, support the cybersecurity risk oversight responsibilities of the Board and the risk committee and involve applicable management personnel in cybersecurity risk management. The risk committee receives periodic reports from the CISO and CRO on the Company's technology and cybersecurity risk profiles, information security program and key cybersecurity initiatives. Additionally, the CISO and CRO follow a risk-based escalation process to notify the risk committee outside of the regular reporting cycle when they identify actual or potential substantive cybersecurity risks or issues.


text: Genworth's CISO is an information technology and security professional with 24 years of experience and 12 years of service at Genworth. In his 24 years of experience, he has held roles in information technology infrastructure administration, information technology infrastructure, security consulting and security administration. He received a Bachelor of Science Degree in Business Administration from Regent University and is a Certified Information Systems Security Professional (CISSP).


text: Genworth's CRO has served in information technology and risk management leadership roles for over twenty years, including oversight of enterprise risk management and operational risk, as well as oversight for financial reporting systems, operational and technology platforms, and testing and quality assurance programs. He received a Bachelor of Science Degree in Decision Support Systems from Virginia Polytechnic Institute (Virginia Tech) and graduated from the Tuck Global Executive Leadership Program through Dartmouth in 2020. For more information about our CRO, see "Part III—Item 10—Directors, Executive Officers and Corporate Governance."


text: Management Committee ("RMC"), which is responsible for the oversight of the Corporation's overall risk framework, and assists the Board in the monitoring, review and approval of the policies that measure, limit and manage the Corporation's risks, including cybersecurity risk. The RMC holds periodic meetings in which management provides overview of Popular's cybersecurity threat risk management incident status.

companyName: POPULAR, INC.

ticker: BPOP


text: Cybersecurity Risk Management and Strategy operations are managed by Blackstone Infrastructure Strategies Associates L.P. (the "General Partner") subject to certain oversight rights held by the Board of Directors. The General Partner has delegated BXINFRA's portfolio management function to Blackstone Infrastructure Advisors L.L.C. (the "Investment Manager"). The General Partner and the Investment Manager are individually and collectively referred to as the "Sponsor." Our executive officers are senior Blackstone professionals and our General Partner and Investment Manager are both subsidiaries of Blackstone. As such, we are reliant on Blackstone for assessing, identifying and managing material risks to our business from cybersecurity threats. Below are details Blackstone has provided to us regarding its cybersecurity program that are relevant to us.

companyName: Blackstone Infrastructure Strategies L.P.


text: Blackstone maintains a comprehensive cybersecurity program, including policies and procedures designed to protect its systems, operations, and the data utilized and entrusted to it, including by BXINFRA, from anticipated threats or hazards. Blackstone utilizes a variety of protective measures as a part of its cybersecurity program. These measures include, where appropriate, physical and digital access controls, patch management, identity verification and mobile device management software, new hire and annual employee cybersecurity awareness and best practices training programs, security baselines and tools to report anomalous activity, and monitoring of data usage, hardware and software.


text: Blackstone tests its cybersecurity defenses regularly through automated and manual vulnerability scanning, to identify and remediate critical vulnerabilities. In addition, it conducts annual "white hat" penetration tests to validate its security posture. Blackstone examines its cybersecurity program every two to three years with third parties, evaluating its effectiveness in part by considering industry standards and established frameworks, such as those established by the National Institute of Standards and Technology and Center for Internet Security, as guidelines. Further, Blackstone engages in cybersecurity incident tabletop exercises and scenario planning exercises involving hypothetical cybersecurity incidents to test its cybersecurity incident response processes. Blackstone's Chief Security Officer (the "CSO") and members of Blackstone's senior management, Legal and Compliance, Technology and Innovations ("BXTI") and Global Corporate Affairs participate in these exercises. Learnings from these tabletop exercises and any cybersecurity events Blackstone experiences are reviewed, discussed, and incorporated into its incident response processes as appropriate. In addition to Blackstone's internal exercises to test aspects of its cybersecurity program, Blackstone periodically engages independent third parties to analyze data on the interactions of users of Blackstone information technology resources, including Blackstone employees, and conduct penetration tests and scanning exercises to assess the performance of Blackstone's cybersecurity systems and processes.


text: Blackstone has a comprehensive Security Incident Response Plan (the "IRP"), designed to inform the proper escalation (including, as appropriate, to our senior management) of non-routine suspected or confirmed information security or cybersecurity events based on the expected risk an event presents. As appropriate, a Security Incident Response Team composed of individuals from several internal technical and managerial functions may be formed to investigate and remediate the event and determine the extent of external advisor support required, including from external counsel, forensic investigators, and/or law enforcement. The IRP sets out ongoing monitoring or remediating actions to be taken after resolution of an incident. The IRP is reviewed at least annually by members of BXTI and Blackstone's Legal and Compliance.


text: Blackstone maintains a formal cybersecurity risk management process and cybersecurity risk register, designed to identify, track and treat cybersecurity risks at the firm, and integrates these processes into the firm's overall risk management practices described above. Blackstone's CSO periodically discusses and reviews cybersecurity risks and related mitigants with its enterprise risk committee and incorporates relevant cybersecurity risk updates and metrics in the semi-annual enterprise-wide risk management report.


text: Blackstone has a process designed to assess the cybersecurity risks associated with the engagement of third-party vendors, including those of companies sponsored by Blackstone such as BXINFRA. This assessment is conducted on the basis of, among other factors, the types of services provided and the extent and type of Blackstone data accessed or processed by a third-party vendor. On the basis of its preliminary risk assessment of a third-party vendor, Blackstone may conduct further cybersecurity reviews or request remediation of, or contractual protections related to, any actual or potential identified cybersecurity risks. In addition, where appropriate, Blackstone seeks to include in its contractual arrangements with certain of its third-party vendors provisions addressing its requirements and industry best practices with respect to data and cybersecurity, as well as the right to assess, monitor, audit and test such vendors' cybersecurity programs and practices. Blackstone also utilizes a number of digital controls, which are reviewed at least annually, to monitor and manage third-party access to its internal systems and data.


text: For a discussion of how risks from cybersecurity threats affect our business, and our reliance on Blackstone in managing these risks, see "—Item 1A. Risk Factors — Cyber Security and Operational Risk" in this Annual Report on Form 10-K.


text: Cybersecurity Governance Blackstone has a dedicated cybersecurity team, led by Blackstone's CSO, who works closely with Blackstone senior management, including Blackstone's Chief Technology Officer ("CTO"), to develop and advance the firm's cybersecurity program and strategy, which applies to BXINFRA.


text: Blackstone's CSO and CTO have extensive experience in cybersecurity and technology, respectively. Blackstone's CSO is a Senior Managing Director in BXTI and is responsible for all aspects of cyber and physical security across Blackstone. He has over 25 years of information security, technology and engineering experience, including having previously led the international security organization at a large credit bureau.


text: Blackstone's CTO is a Senior Managing Director and the head of BXTI. Blackstone's CTO has over 23 years of information security, technology and engineering experience, including having previously served as the Chief Technology and Chief Innovation Officer at a large financial institution. Blackstone's CTO is responsible for all aspects of technology across Blackstone, advises Blackstone's investment teams and acts as a resource to portfolio companies on technology-related matters.


text: BXTI conducts periodic cybersecurity risk assessments, including assessments or audits of third-party vendors, and assists with the management and mitigation of identified cybersecurity risks. The CSO and CTO are responsible for the review of Blackstone's cybersecurity framework annually as well as on an event-driven basis as necessary. The CSO and CTO also review the scope of Blackstone's cybersecurity measures periodically, including in the event of a change in business practices that may implicate the security or integrity of Blackstone's information and systems.


text: BXINFRA's Board of Directors and its Audit Committee are responsible for understanding the primary risks to our business. The Audit Committee is responsible for reviewing BXINFRA's and the Sponsor's IT security controls with management and evaluating the adequacy of BXINFRA's and the Sponsor's IT security program, compliance and controls with management.


text: Blackstone's CSO will report to BXINFRA's Board of Directors and/or Audit Committee periodically on cybersecurity matters, including risks facing BXINFRA and the Sponsor and, as applicable, certain incidents. In addition to such periodic reports, BXINFRA's Board of Directors and/or Audit Committee will receive periodic reports and/or updates from management on the primary cybersecurity risks facing BXINFRA and the Sponsor and the measures we and the Sponsor are taking to mitigate such risks. In addition to such reports, the Board of Directors and/or Audit Committee will receive updates from management regarding changes to BXINFRA's and the Sponsor's cybersecurity risk profile or certain newly identified risks.


text: Cybersecurity Risk Management and Strategy operations are managed by Blackstone Private Equity Strategies Associates L.P. (the "General Partner") subject to certain oversight rights held by the Board of Directors. The General Partner has delegated BXPE's portfolio management function to Blackstone Private Investments Advisors L.L.C. (the "Investment Manager"). The General Partner and the Investment Manager are individually and collectively referred to as the "Sponsor." The executive officers are senior Blackstone professionals and our General Partner and Investment Manager are both subsidiaries of Blackstone. As such, we are reliant on Blackstone for assessing, identifying and managing material risks to our business from cybersecurity threats. Below are details Blackstone has provided to us regarding its cybersecurity program that are relevant to us.

companyName: Blackstone Private Equity Strategies Fund L.P.


text: Blackstone maintains a comprehensive cybersecurity program, including policies and procedures designed to protect its systems, operations, and the data utilized and entrusted to it, including by BXPE, from anticipated threats or hazards. Blackstone utilizes a variety of protective measures as a part of its cybersecurity program. These measures include, where appropriate, physical and digital access controls, patch management, identity verification and mobile device management software, new hire and annual employee cybersecurity awareness and best practices training programs, security baselines and tools to report anomalous activity, and monitoring of data usage, hardware and software.


text: Blackstone tests its cybersecurity defenses regularly through automated and manual vulnerability scanning, to identify and remediate critical vulnerabilities. In addition, it conducts annual "white hat" penetration tests to validate its security posture. Blackstone examines its cybersecurity program every two to three years with third parties, evaluating its effectiveness in part by considering industry standards and established frameworks, such as those established by the National Institute of Standards and Technology and Center for Internet Security, as guidelines. Further, Blackstone engages in cybersecurity incident tabletop exercises and scenario planning exercises involving hypothetical cybersecurity incidents to test its cybersecurity incident response processes. Blackstone's Chief Security Officer (the "CSO") and members of Blackstone's senior management, Legal and Compliance, Technology and Innovations ("BXTI") and Global Corporate Affairs participate in these exercises. Learnings from these tabletop exercises and any cybersecurity events Blackstone experiences are reviewed, discussed, and incorporated into its incident response processes, as appropriate. In addition to Blackstone's internal exercises to test aspects of its cybersecurity program, Blackstone periodically engages independent third parties to analyze data on the interactions of users of Blackstone information technology resources, including Blackstone employees, and conduct penetration tests and scanning exercises to assess the performance of Blackstone's cybersecurity systems and processes.


text: Blackstone has a process designed to assess the cybersecurity risks associated with the engagement of third-party vendors, including those of companies sponsored by Blackstone such as BXPE. This assessment is conducted on the basis of, among other factors, the types of services provided and the extent and type of Blackstone data accessed or processed by a third-party vendor. On the basis of its preliminary risk assessment of a third-party vendor, Blackstone may conduct further cybersecurity reviews or request remediation of, or contractual protections related to, any actual or potential identified cybersecurity risks. In addition, where appropriate, Blackstone seeks to include in its contractual arrangements with certain of its third-party vendors provisions addressing its requirements and industry best practices with respect to data and cybersecurity, as well as the right to assess, monitor, audit and test such vendors' cybersecurity programs and practices. Blackstone also utilizes a number of digital controls, which are reviewed at least annually, to monitor and manage third-party access to its internal systems and data.


text: For a discussion of how risks from cybersecurity threats affect our business, and our reliance on Blackstone in managing these risks, see "— Item 1A. Risk Factors — Cyber Security and Operational Risk" in this Annual Report on Form 10-K.


text: Cybersecurity Governance Blackstone has a dedicated cybersecurity team, led by Blackstone's CSO, who works closely with Blackstone senior management, including Blackstone's Chief Technology Officer ("CTO"), to develop and advance the firm's cybersecurity program and strategy, which applies to BXPE.


text: The Board of Directors and the Audit Committee are responsible for understanding the primary risks to our business. The Audit Committee is responsible for reviewing BXPE's and the Sponsor's IT security controls with management and evaluating the adequacy of BXPE's and the Sponsor's IT security program, compliance and controls with management.


text: Blackstone's CSO will report to the Board of Directors and/or Audit Committee periodically on cybersecurity matters, including risks facing BXPE and the Sponsor and, as applicable, certain incidents. In addition to such periodic reports, the Board of Directors and/or Audit Committee will receive periodic reports and/or updates from management on the primary cybersecurity risks facing BXPE and the Sponsor and the measures we and the Sponsor are taking to mitigate such risks. In addition to such reports, the Board of Directors and/or Audit Committee will receive updates from management regarding changes to BXPE's and the Sponsor's cybersecurity risk profile or certain newly identified risks.


text: Cybersecurity Risk Management and Strategy Cybersecurity risks and data protection are key components of our long-term strategy and enterprise risk management program and are integrated into our overall risk management systems and processes. We maintain processes for assessing, identifying and managing material risks from cybersecurity threats, and we routinely invest in the development and implementation of essential cybersecurity systems, infrastructures and processes to protect the security and integrity of our systems, networks, databases and proprietary information. Key areas of our cybersecurity risk management processes and strategy currently include:

companyName: MAGNACHIP SEMICONDUCTOR Corp

ticker: MX


text: Compliance with industry standards and regulatory frameworks : Our information security management system is ISO 27001 certified. In addition, we align our standards to comply with South Korea's industrial technology protection law (Act on Prevention of Divulgence and Protection of Industrial Technology), which prevents technologies vital to South Korean national security or economic competitiveness from being divulged to or shared with foreign countries or corporations without the government's approval.


text: Ongoing Evaluation and Assessment of Systems and Procedure : We monitor compliance with regulatory, industry and evolving data privacy requirements and update our cybersecurity risk management program from time to time as appropriate. We also continuously monitor our information security systems and processes on an ongoing basis to identify and remediate cybersecurity threats and vulnerabilities that could be exploited to adversely impact our business operations. To better preemptively identify risks and vulnerabilities in our security systems, we perform penetration testing for security controls using external third-party tools and encourage vulnerability reporting within our organization.


text: Cross-Collaboration and Coordination : Cybersecurity risks related to our business, privacy and compliance issues are identified and managed through a multifaceted approach, including third-party monitoring, internal and external IT security audits and reviews by relevant committees.


text: Third-Party Service Providers : We engage leading third-party product and service providers to assist us with our cybersecurity risk management. We use an Information Prevention and Data Loss Prevention System on networks and endpoints, which is designed to prevent unauthorized access to or transfer of sensitive data. We also use centrally managed antivirus systems for blocking illegal software to detect and remove malware and illegal software from devices in real time. In particular, we use a Managed Security Service provider for Security Information and Event Management services for matters such as firewall management, intrusion detection and prevention, vulnerability management and incident response.


text: Cyber Incident Response Plan : We maintain a comprehensive cyber incident response plan that sets forth the applicable processes, roles, engagements, escalations and notifications to promptly respond to a cybersecurity incident. This plan covers steps to be taken upon the detection of a cybersecurity incident detection, review by relevant committees, identification of damages, recovery process, post-incident analysis and the introduction of improvement measures. Such incident responses are managed in a timely manner by a dedicated team and overseen by relevant organizations, including IT, finance, legal and compliance.


text: Security Awareness Training for Personnel : We provide comprehensive employee training on cybersecurity awareness, confidential information protection and simulated phishing attacks.


text: Review of Third-Party Risks : We routinely conduct risk and compliance assessments of third-party service providers prior to exchanging any sensitive data or integrating with any key third-party provider.


text: As of December 31, 2024, we have not identified any risks from cybersecurity threats, including any previous cybersecurity incidents, that have materially affected or are reasonably likely to materially affect the Company, our business strategy, our results of operations or our financial condition. For a discussion of risks from cybersecurity threats (including any previous cybersecurity incidents) that could be reasonably likely to materially affect us, please refer to our Risk Factors discussion under the heading 'We may be subject to disruptions, breaches or cyber-attacks of our secured networks and information technology systems that could damage our reputation, harm our business, expose us to liability and materially adversely affect our results of operations' in Item 1A of this Annual Report on Form 10-K.


text: Cybersecurity Governance In line with our overall risk management governance structure, management is responsible for the day-to-day management of cybersecurity risks while the Company's Board of Directors and its Risk Committee actively and continuously provide oversight.


text: Our Risk Committee oversees the Company's management of key risks including those arising from cybersecurity threats. Our management team reports to the Risk Committee on a quarterly basis, presenting their assessment of key enterprise risks, including cybersecurity. The topics include trends in cyber threats and the initiatives designed to strengthen our security systems and enhance the cyber readiness of our organization. Additionally, at least annually, our management team and our Chief Information Security Officer ("CISO") update the members of the Risk Committee and the Board of Directors on existing and new cybersecurity risks, status of risk mitigation efforts, cybersecurity incidents, if any, and the progress of key information security initiatives.


text: In 2020, we established the Information Security Steering Committee (the "IS Steering Committee"), a management-level and cross-functional committee, led by our Chief Executive Officer, and comprised of our Chief Compliance Officer, Chief Financial Officer, CISO, Chief Privacy Officer and relevant teams including Information Security, HR, Compliance & Internal Audit and Legal. The IS Steering Committee holds quarterly meetings, during which they review and take action on a wide range of topics, including cybersecurity threat matters such as prevention monitoring, detection mitigation and remediation of cybersecurity incidents.


text: Our CISO leads a dedicated Information Security team in charge of cybersecurity matters. Collectively, the members of our Information Security team have over 35 years of relevant experience in various roles involving information technology, information security, compliance and systems. Also, our Information Security team oversees compliance with our cybersecurity framework, facilitates cybersecurity risk management activities, assists with the review and approval of policies, and oversees the security awareness program. At least annually, our Information Security team and CISO update the members of the Risk Committee and the Board of Directors on compliance and risk matters. The Information Security team also reports to the IS Steering Committee on a quarterly basis. We invest in ongoing cybersecurity training for our Information Security team.


text: We rely extensively on various information systems and other electronic resources to operate our business . In addition, nearly all our customers, service providers and other business partners on whom we depend, including the providers of our online banking, mobile banking, and accounting systems, use their own information systems and electronic resources. Any of these systems can be compromised, including through the employees, customers, and other individuals who are authorized to use them, and bad actors who use a sophisticated and constantly evolving set of software, tools, and strategies to do so. Moreover, the nature of our business as a financial services provider, and our relative size, make us and our business partners high-value targets for these bad actors to pursue. For additional information see "Item 1A. Risk Factors—Operational Risks."

companyName: Princeton Bancorp, Inc.

ticker: BPRN


text: Accordingly, we have long devoted significant resources to assessing, identifying, and managing risks associated with cybersecurity threats, including: in-house team dedicated to information and cybersecurity, responsible for conducting regular evaluations of our information systems, existing controls, vulnerabilities, and potential enhancements; tools for continuous monitoring capable of detecting and aiding in the response to cybersecurity threats in real-time;


text: conducting thorough due diligence on our third-party service providers, evaluating their cybersecurity practices, and requiring contractual commitments from them to implement specific cybersecurity measures;


text: collaboration with third-party cybersecurity experts who perform periodic penetration testing, vulnerability assessments, and other procedures to pinpoint potential weaknesses in our systems and processes; and regular cybersecurity training sessions for our staff.


text: This information security program is a key part of our overall risk management system, which is administered by our Information Security Officer . The program includes administrative, technical and physical safeguards to help ensure the security and confidentiality of customer records and information. These security and privacy policies and procedures are in effect across all of our bu sine sses and geographic locations.


text: We face a number of cybersecurity risks in connection with our business. From we have identified cybersecurity threats and cybersecurity incidents that require us to make changes to our processes and to implement additional safeguards. While none of these identified threats or incidents have materially affected us, it is possible that threats and incidents we identify in the future could have a material adverse effect on our business strategy, results of operations, and financial condition.


text: Our management team is responsible for the management of risks we face, including our CIO. Our CIO has been in the role since May 2021, and has 30 years of experience in technology risk management and cybersecurity, primarily within the financial services sector.


text: our board of directors is responsible for the oversight of risk management. In that role, our board of directors, with support from our cybersecurity advisors, are responsible for ensuring that the risk management processes designed and implemented by management are adequate and functioning as designed. To carry out those duties, our board of directors receives quarterly reports from our management team regarding cybersecurity risks, and our efforts to prevent, detect, mitigate, and remediate any cybersecurity incidents.


text: The Company's management, including the Company's Chief Compliance Officer and the investment manager's Global Chief Information Security Officer, are responsible for conducting a regulatory risk assessment which includes cybersecurity threats. Members of Company management possess relevant experience in various disciplines that are important to effectively managing cybersecurity related risks including Security Operations, Vulnerability Management, Network Security, Application and Cloud Security, and cybersecurity risk management. Management of the Company and the investment manager maintain compliance programs which include policies and procedures that are reasonably designed to address regulatory risks related to cybersecurity. The compliance programs include controls to monitor the prevention, detection, mitigation and remediation of cybersecurity incidents impacting the Company; in addition to the compliance programs, a vendor oversight program is leveraged to monitor risks associated with relevant service providers including cybersecurity.

companyName: PIMCO Capital Solutions BDC Corp.


text: Cybersecurity Program Overview The Adviser has instituted a cybersecurity program designed to identify, assess, and mitigate cyber risks applicable to the Company. The cyber risk management program involves risk assessments, implementation of security measures, and ongoing monitoring of systems and networks, including networks on which the Company relies. The Adviser actively monitors the current threat landscape in an effort to identify material risks arising from new and evolving cybersecurity threats, including material risks faced by the Company.


text: The Company relies on the Adviser to engage external experts, including cybersecurity assessors, consultants, and internal auditors to evaluate cybersecurity measures and risk management processes, including those applicable to the Company. The Company relies on the Adviser's risk management program and processes, which include cyber risk assessments.


text: The Company depends on and engages various third parties, including suppliers, vendors, and service providers, to operate its business. The Company relies on the expertise of risk management, legal, information technology, and compliance personnel of the Adviser when identifying and overseeing risks from cybersecurity threats associated with our use of such entities.


text: Board Oversight of Cybersecurity Risks The Board provides oversight on cybersecurity matters, including risks associated with cybersecurity threats. The Board receives periodic updates from the Company's Global Chief Information Security officer or their designee regarding the overall state of the Adviser's cybersecurity program, information on the current threat landscape, and risks from cybersecurity threats and cybersecurity incidents impacting the Company.


text: Management's Role in Cybersecurity Risk Management The Company's management, including the Company's Chief Compliance Officer ("CCO"), is responsible for assessing and managing material risks from cybersecurity threats. Members of Company management possess relevant expertise in various disciplines that are key to effectively managing such risks. Management of the Company is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents impacting the Company, including through the receipt of notifications from service providers and reliance on communications with risk management, legal, information technology, and/or compliance personnel of the Adviser.


text: Assessment of Cybersecurity Risk The potential impact of risks from cybersecurity threats on the Company are assessed on an ongoing basis, and how such risks could materially affect the Company's business strategy, operational results, and financial condition are regularly evaluated. During the reporting period, the Company has not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that the Company believes have materially affected, or are reasonably likely to materially affect, the Company, including its business strategy, operational results, and financial condition.


text: We recognize the importance of assessing, identifying, and managing risk associated with cybersecurity threats. Our external advisor has implemented cybersecurity processes, technologies, and controls to aid in our efforts to assess, identify, and manage such risks. Our advisor has developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information.

companyName: LUB LIQUIDATING TRUST


text: This cybersecurity risk management program is integrated into our overall enterprise risk management program, and shares common methodologies, reporting channels and governance processes that apply across the enterprise risk management program to other legal, compliance, strategic, and financial risk areas.


text: As we are fully externally managed, we are reliant on our external manager's network and risk management program. Our external advisor has elected to engage third-party managed service providers to maintain its network and to manage the monitoring, detection, mitigation, and prevention of cybersecurity threats. These service providers are responsible for managing our advisor's hosted services, all of the computer and computer-related hardware and software they use, and for managing the backup process. Our manager's primary managed service provider supplies management with monthly updates and activity reports related to network alerts, connectivity issues and help desk tickets.


text: We are subject to risks from cybersecurity threats and incidents. As of December 31, 2024, we do not believe such risks have materially affected or are reasonably likely to materially affect the Company, including the Company's business strategy, results of operations or financial condition. However, there can be no assurance that the Company will not be materially affected in the future.


text: December 31, 2024 Our Trustees consider cybersecurity risk as part of its risk oversight function. Our Trustees oversee management's implementation of our cybersecurity risk management program. Our Trustees will receive periodic reports from management on our cybersecurity risks as well as updates, as necessary, regarding any significant cybersecurity incidents impacting our advisor's information systems.


text: Risk Management and Strategy We recognize the importance of identifying, assessing, and managing material risks associated with cybersecurity threats, which include, among other things, operational risks, intellectual property theft, fraud, extortion, harm to employees or patients, and violation of data privacy or security laws. We employ multiple levels of protection designed to minimize the risks associated with cybersecurity, ransomware and data breaches, including firewalls, data loss prevention, email filtering for ransomware, proactive threat-hunting, cloud-based backups, multifactor authentication, encryption software, intrusion testing and SIEM networking monitoring to ensure the integrity of our data and systems. In addition, we maintain recovery and other business continuity procedures.

companyName: Guardian Pharmacy Services, Inc.

ticker: GRDN


text: Our cybersecurity risk management program is informed by prevailing security standards and is designed to provide a framework for evaluating and responding to cybersecurity risks. This includes processes for assessing the severity of a cybersecurity threat, identifying the source of a cybersecurity threat, implementing cybersecurity countermeasures and mitigation strategies, and informing and updating management and, as needed, the audit committee and our board of directors of cybersecurity incidents that may pose a significant risk for the business. Security events and data incidents are evaluated, ranked by severity, and prioritized for response and remediation. Incidents are evaluated to determine materiality, as well as operational and business impact, and reviewed for privacy impact.


text: We deploy technical safeguards that are designed to protect our information systems, products, operations and sensitive information from cybersecurity threats. These include including firewalls, data loss prevention, email filtering for ransomware, proactive thread-hunting, cloud-based backups, multifactor authentication, encryption software, intrusion testing and SIEM networking monitoring to ensure the integrity of our data and systems. In addition, we maintain recovery and other business continuity procedures, including cloud-based backups, electrical generators, critical systems housed at hardened data centers and geographic redundancy, intended to minimize disruptions to our operations in the event of disaster or other interruptions to our information systems. Our security events are logged to a central source and monitored by a third party security operations management provider.


text: We provide periodic training for all personnel regarding cybersecurity threats, with such training appropriate to the roles, responsibilities and access of the relevant Company personnel.


text: Recognizing the complexity and evolving nature of cybersecurity threats, incidents and risks, we engage third-party experts, including cybersecurity consultants, to evaluate and support our risk management systems. We also rely on software support from third-party vendors to assist with evaluating, monitoring, and testing our information technology systems. These relationships enable us to leverage specialized knowledge and insights, to help ensure our cybersecurity strategies and processes remain effective. Our collaboration with these third parties includes regular audits, routine system monitoring, threat assessments, incident response, and consultation on potential security enhancements. We require third-party service providers with access to personal, confidential, or proprietary information to implement and maintain comprehensive cybersecurity practices consistent with applicable legal standards and industry best practices.


text: we are not aware of any cybersecurity incidents that have materially affected or are reasonably likely to materially affect the Company, including our business strategy, results of operations, or financial condition. For further discussion of the risks associated with cybersecurity incidents, see " Risk Factors—Risks Related to Our Business—Interruptions to our information systems may materially and adversely affect our operating results " as well as "— Cybersecurity attacks or other data security incidents could disrupt our operations and expose us to regulatory fines or penalties, liability or reputational harm.


text: Our board of directors has overall oversight responsibility for our risk management, and delegates data protection and cybersecurity risk oversight to the audit committee. The audit committee receives regular briefings on cybersecurity risks and risk management practices, including, for example, recent developments in the external cybersecurity threat landscape, evolving standards, vulnerability assessments, third-party and independent reviews, technological trends, as well as how management is addressing or mitigating those risks. The audit committee may also promptly receive information regarding any material cybersecurity incident that may occur, including any ongoing updates regarding the same. The audit committee periodically discusses our approach to cybersecurity risk management with our VP of Technology & Senior Security Officer.


text: Our VP of Technology & Senior Security Officer is responsible for overseeing our cybersecurity risk management program. Our VP of Technology & Senior Security Officer has over 20 years of extensive experience in information technology and security, and works in coordination with other members of the management team.


text: Our VP of Technology & Senior Security Officer, along with leaders from our privacy and corporate compliance functions, collaborate to implement a program designed to manage our exposure to cybersecurity risks and to promptly respond to cybersecurity incidents. Response to incidents is delivered by multi-disciplinary teams in accordance with our incident response plan. Through ongoing communications with these teams during incidents, the VP of Technology & Senior Security Officer monitors the triage, mitigation and remediation of cybersecurity incidents, and reports such incidents to executive management, the audit committee and other colleagues in accordance with our cybersecurity policies and procedures, as appropriate.


text: We are a special purpose acquisition company with no business operations and therefore, prior to the completion of a business combination, do not have any operations of our own that face cybersecurity threats. Since our initial public offering, our sole business activity has been identifying and evaluation suitable targets for a business combination. Therefore, the Company does not consider that it faces significant cybersecurity risk and has not adopted any cybersecurity risk management program or formal processes for assessing, identifying, and managing material risks from cybersecurity threats. Our board of directors is ultimately responsible for overseeing the Company's risk management activities in general and will be informed, promptly and as deemed necessary by our management team, of any cybersecurity threats or risks that may arise, cyber incidents and industry trends, including regarding the appropriate disclosure, mitigation, or other response or actions that our board deems appropriate to take. As of the date of this Report, the Company did not identify any risks from cybersecurity threats that have materially affected or are reasonably likely to materially affect the Company, including its business strategy and results of operations. However, any such attack could adversely affect our business. We depend on the digital technologies of third parties and any sophisticated and deliberate attacks on, or security breaches in, systems or infrastructure or the cloud that we utilize, including those of third parties, could lead to corruption or misappropriation of our assets, proprietary information and sensitive or confidential data. Because of our reliance on the technologies of third parties, we also depend upon the personnel and the processes of third parties to protect against cybersecurity threats, and we have no personnel or processes of our own for this purpose. A penetration of our systems or a third-party's systems or other misappropriation or misuse of personal information could subject us to business, regulatory, litigation and reputation risk, which could have a negative effect on our business, financial condition and results of operations. For more information about the cybersecurity risks we face, see the risk factor entitled " Cyber incidents or attacks directed at us could result in information theft, data corruption, operational disruption and/or financial loss. " in " Item 1A. Risk Factors—General Risk Factors. "

companyName: Oaktree Acquisition Corp. III Life Sciences

ticker: OACC


text: We are a SPAC with no business operations. Since our IPO, our sole business activity has been identifying, evaluating suitable acquisition transaction candidates and completing the merger with our target acquisition companies. Therefore, we do not consider that we face significant cybersecurity risk and have not adopted any cybersecurity risk management program or formal processes for assessing cybersecurity risk. Our board of directors is generally responsible for the oversight of risks from cybersecurity threats, if there is any. We have not encountered any cybersecurity incidents since our IPO.

companyName: AltEnergy Acquisition Corp


text: information technology and data to operate our business effectively and recognize the importance of implementing and maintaining cybersecurity systems and processes that allow us to protect the confidentiality, integrity and availability of our information systems and the data residing within them.

companyName: INFINITY NATURAL RESOURCES, INC.

ticker: INR


text: We maintain a comprehensive cybersecurity risk program to effectively identify, assess, manage, and respond to cybersecurity risks and incidents. Our program is implemented by in-house personnel with experience in cybersecurity fields and is further enhanced by external partners that specialize in cybersecurity services. Our program is built on recognized industry standards and frameworks that are regularly evaluated and updated to address emerging threats.


text: Key elements of our cybersecurity risk management program include regular and thorough risk assessments to identify potential cybersecurity threats across our operations, the implementation of appropriate multi-layered security controls and advanced monitoring systems, comprehensive employee cybersecurity awareness training and education programs delivered throughout the year. A key element of our cybersecurity response program is the regular and redundant point-in-time backup of critical configurations and files. The backup information is stored both locally and at off-site locations for additional security.


text: Our board of directors oversees our cybersecurity risk management program through the Audit Committee. Our management team, including our Senior Vice President of Operations, provides periodic updates on cybersecurity matters to the Audit Committee, which relays them to the board of directors as needed. Our Senior Vice President of Operations has primary responsibility for assessing and managing cybersecurity risks and leading our overall cybersecurity posture, including the engagement of external third parties to assist us. Our Senior Vice President of Operations has 10 years of experience in the field of information systems and cybersecurity.


text: from Cybersecurity Threats As of the date of this Annual Report, we are not aware of any previous cybersecurity incidents that have materially affected or are reasonably likely to materially affect the Company, including our business strategy, results of operations and financial condition. We acknowledge that cybersecurity threats are continually evolving, and the possibility of future cybersecurity incidents, material or otherwise, remains. Despite the implementation of our cybersecurity processes, our security measures cannot guarantee that a significant cybersecurity incident will not occur. While we devote resources to our security measures designed to protect our systems and information, no security measure is infallible. For more information about the cybersecurity risks we face, refer to "Item 1A. Risk Factors" in this Annual Report.


text: The Company, the Advisor and StepStone Group are affiliates of StepStone Group Inc., a Delaware corporation listed on the Nasdaq Stock Market LLC and whose securities are registered with the SEC pursuant to Section 12(b) of the Exchange Act. In general, the Company relies upon the information systems and other enterprise services provided by StepStone Group Inc. and its subsidiaries, including StepStone Group and the Advisor (together, "STEP").

companyName: Stepstone Private Credit Fund LLC


text: STEP maintains a cybersecurity program that is reasonably designed to protect the Company's information, and that of the Company's portfolio companies and investors, against cybersecurity threats that may result in significant adverse effects on the confidentiality, integrity, and availability of the information systems of STEP and its affiliates. Governance.


text: Board of Directors The Board of Directors of StepStone Group Inc. ("STEP Board") oversees STEP's processes for assessing and managing risk. The STEP Board's Audit Committee is responsible for reviewing and discussing STEP's practices with respect to risk assessment and risk management, and risks related to matters, including information technology and cybersecurity.


text: The STEP Board and Audit Committee regularly review the measures implemented by STEP to identify and mitigate risks from cybersecurity threats. As part of such reviews, the STEP Board and Audit Committee receive reports and presentations from those responsible for overseeing STEP's cybersecurity risk management, including the Partner, Head of Information Technology & CISO ("Head of IT") and STEP's Legal team, which may address a wide range of topics including recent developments, evolving standards, vulnerability assessments, third-party and independent reviews, the threat environment, technological trends and information security considerations arising with respect to STEP's peers, industry participants, service providers and other third parties. The Head of IT also periodically presents to the STEP Board and its Audit Committee, including to describe STEP's information security infrastructure and improvements made, and to report on any significant developments in respect to STEP. From time to time, external legal advisers provide education to the STEP Board and/or Audit Committee in respect of information security related developments and to provide training in respect of directors' responsibilities.


text: At the Company level, the Company's Board oversees and monitors enterprise risk management at the Company, including with respect to cybersecurity and information security risk. The Company's Board and disclosure review team are expected to receive periodic reports and updates from the Head of IT, as applicable in the context of risks from cybersecurity threats that may impact the Company. STEP has a framework under which certain cybersecurity incidents are escalated within the Company and STEP and, where appropriate, reported to the Company Board, STEP Board or Audit Committee in a timely manner.


text: STEP has a cybersecurity working group composed of members of the Information Technology (including Information Security), Legal and Compliance departments, including the Head of IT, the Chief Legal Officer of STEP, the Chief Compliance Officer of STEP, and a number of their respective team members. The working group meets regularly to identify and mitigate data protection and cybersecurity risks, implement information security governance mechanisms, discuss developments in information security, and discuss and action any significant cyber incidents relevant to STEP, and its affiliates, including the Company. The working group is expected to escalate matters of significance to STEP's Incident Response Team, ERMC (defined below) and/or the STEP Disclosure Committee, as well as to the Company's disclosure review team, as appropriate.


text: STEP has adopted an Incident Response Plan ("IRP") that applies in the event of a cybersecurity threat or incident, including those that impact the Company, to provide a standardized framework for responding to security incidents. The IRP sets out a coordinated approach to investigating, containing, documenting and mitigating incidents, including reporting findings and keeping senior management and other key stakeholders informed and involved as appropriate, including stakeholders at the Company, as relevant. In general, STEP's incident response process leverages the NIST framework and focuses on four phases: preparation; detection and analysis; containment, eradication and recovery; and post-incident remediation. The IRP applies to all STEP personnel and STEP networks and systems, third-party systems and end-user devices, including those of the Advisor and those relied upon by the Company.


text: In addition, STEP has an Enterprise Risk Management Committee ("ERMC") composed of a number of members of senior management from operations across STEP's businesses, legal, compliance, information technology, finance, human resources and internal audit and risk. The ERMC was established to oversee and ensure the efficient and effective management of STEP's enterprise risks. Cybersecurity and significant information security matters are to be brought before the ERMC or certain of its members, and matters of primary significance are to be further escalated and reported to the StepStone Global Executive Committee and the Audit Committee of the STEP Board and the Company's Board, as appropriate.


text: At the management level, the STEP Head of IT, who has extensive cybersecurity knowledge and skills gained from over 20 years of work experience at STEP and elsewhere, heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices and reports directly to the President and Co-Chief Operating Officer of STEP. The Head of IT receives reports on cybersecurity threats from his team and external service providers on an ongoing basis and, in conjunction with management, reviews risk management measures implemented by STEP to identify and mitigate data protection and cybersecurity risks, including those applicable to the Company and the Advisor. The Head of IT works closely with the STEP Legal and Compliance departments to oversee compliance with legal, regulatory and contractual security requirements and in developing reports and presentations to the STEP Board and its Audit Committee, as well as to the Company's Board. The Head of IT is responsible for providing regular training to STEP employees, including employees of the Advisor, in respect of information security. Risk Management and Strategy.


text: STEP takes a multifaceted approach to managing risk from cybersecurity threats. STEP's cybersecurity program leverages people, processes, and technology to identify and respond to cybersecurity threats in a timely manner. STEP's information security program, and supporting policies apply to all employees, contractors and vendors servicing the firm, including employees of the Advisor. The program outlines the development, maintenance, and distribution of information security policies and procedures that detail the implementation and maintenance of the information security program and its safeguards, and cover various areas such as information handling, user access management, encryption, data retention and backups, computer and network security and monitoring, physical security, incident reporting and response, service provider oversight, and employee and contractor use of technology. STEP also undergoes annual SOC 1 Type 2 testing of its financial processes and supporting technical controls. In addition to the foregoing, STEP conducts regular employee trainings on cybersecurity, which trainings apply to the Company's officers and employees of the Advisor, and performs phishing exercises to test employees' understanding of how to identify social engineering attacks. STEP performs diligence, including in respect of information security, of vendors and third parties with significant access to confidential information and personal data, and periodically monitors such vendors, including such vendors relied upon by the Company and the Advisor. STEP also employs systems and processes designed to oversee, identify, and reduce the potential impact of a security incident at a third-party vendor, service provider or customer or otherwise implicating the third-party technology and systems STEP and its affiliates use. STEP conducts annual penetration testing performed by a rotating group of third-party security firms to test STEP's technical controls and security response. STEP's internal audit team has also conducted a cybersecurity assessment to evaluate STEP's preparedness against potential cyber risks and threats. In addition to its internal cybersecurity capabilities and third-party penetration testing, STEP also, at times, engages consultants or other third parties to assist with assessing, identifying, and managing cybersecurity risks.


text: Material Cybersecurity Risks, Threats & Incidents Due to evolving cybersecurity threats, it has and will continue to be difficult to prevent, detect, mitigate, and remediate cybersecurity incidents. To date, the Company has not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that the Company believes have materially affected, or are reasonably likely to materially affect, the Company, including its business strategy, results of operations, or financial condition, but the Company faces certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to have such an effect. Additional information on cybersecurity risks the Company faces can be found in Part I, Item 1A "Risk Factors" of this Report under the heading "Cybersecurity risks and cyber incidents could adversely affect our business by causing a disruption to our operations, which could adversely affect our financial condition and results of operations.", which should be read in conjunction with the foregoing information.