text: Apollo deploys technical safeguards that are designed to protect its information systems from cybersecurity threats, including firewalls, intrusion prevention and detection systems, anti-malware functionality and access controls, which are evaluated and improved on an ongoing basis using vulnerability assessments and cybersecurity threat intelligence. Incident Response and Recovery Planning.


text: Apollo has established and maintains incident response and recovery plans that address its response to a cybersecurity incident, and such plans are tested and evaluated on a regular basis. Third-Party Risk Management.

companyName: Apollo Infrastructure Co LLC

secItem: Item 1C


text: Apollo maintains a risk-based approach to identifying and overseeing cybersecurity risks presented by third parties, including vendors, service providers and other external users of its systems, as well as the systems of third parties that could adversely impact its business and the business of its externally managed entities such as our company, in the event of a cybersecurity incident affecting those third-party systems. Education and Awareness.


text: Apollo provides regular, mandatory training for personnel regarding cybersecurity threats to equip its personnel with effective tools to help mitigate cybersecurity threats, and to communicate its evolving information security policies, standards, processes and practices.


text: Apollo engages in the periodic assessment and testing of its policies and practices that are designed to address cybersecurity threats and incidents. These efforts include a wide range of activities, including audits, assessments, tabletop exercises, threat modeling, vulnerability testing and other exercises focused on evaluating the effectiveness of its cybersecurity measures. Apollo regularly third parties, including auditors and consultants, to perform assessments on its cybersecurity measures, including information security maturity assessments, audits and independent reviews of its information security control environment and operating effectiveness. The results of such assessments, audits and reviews are reported to Apollo's risk management function, and Apollo adjusts its cybersecurity policies and practices as necessary based on the information provided by these assessments, audits and reviews. For further discussion of the risks we face from cybersecurity threats, including those that could materially affect us, see "Item 1A. Risk Factors— Risks Related to our Company and an Investment in our Shares—We may face a breach of our cyber security, which could result in exposure of confidential information and adverse consequences to our operations."


text: To our knowledge, cybersecurity threat risks have not materially affected our company, including our business strategy, results of operations or financial condition.


text: Cybersecurity Governance The AGM Board of Directors' oversight of Apollo's cybersecurity risk management is supported by the audit committee of the AGM Board of Directors (the " AGM audit committee "), the AAM Global Risk Committee (" AGRC "), the Operational Risk Forum (the " ORF "), the Cybersecurity Working Group and management. The AGM Board of Directors, the AGM audit committee, the AGRC, the ORF and the Cyber Security Working Group receive regular updates on Apollo's information technology, cybersecurity risk profile and strategy, and risk mitigation plans from Apollo's risk management professionals, AGM's Chief Security Officer (" CSO "), its CISO, and other members of Apollo's management and relevant management committees and working groups. The Cyber Security Working Group is chaired by the CISO and has representation from Apollo's Technology, Legal, Compliance, and ERM teams. The group meets at least once a quarter to discuss cybersecurity and risk mitigation activities, among other topics. The CISO regularly reports to the ORF regarding cyber risk, and the ORF in turn reports to the AGRC on a quarterly basis, noting any cyber updates when necessary or appropriate. In turn, AGM's board of directors and/or the AGM audit committee receive quarterly risk updates from risk management professionals, as well as at least annual updates on cyber risk specifically. The full AGM Board of Directors or the AGM audit committee receives presentations and reports on cybersecurity risks from AGM's CSO or CISO, as well as from Athene's CISO, at least annually.


text: The AGM CISO, in coordination with the Apollo Technology and ERM teams, works collaboratively across Apollo to implement a program designed to protect its information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents in accordance with its incident response and recovery plans. To facilitate the success of Apollo's cybersecurity risk management program, multidisciplinary teams throughout Apollo are deployed to address cybersecurity threats and to respond to cybersecurity incidents. Through ongoing communications with these teams, the CISO monitors the prevention, detection, mitigation and remediation of cybersecurity threats and incidents in real time and reports such threats and incidents to the AGM audit committee or AGM Board of Directors, as appropriate.


text: AGM's CSO holds an undergraduate degree in Management Information Systems and Business Administration, which he received magna cum laude. He has over 25 years of cyber-related experience, having served in various roles in technology and cybersecurity, including as Head of IT Risk Management, Executive Director of IT & Risk Compliance, and Global IT Risk Evaluation Lead at large financial institutions and consulting firms. He was also previously AGM's CISO for nearly eight years. AGM's CISO holds a master's degree in Business Information Systems and has served in various roles in information technology and information security for over 25 years across a number of large financial institutions, including as Director, Cybersecurity and Risk.


text: As part of the risk management oversight (including oversight of cyber risks) of the Company's Board, the Board will regularly interact with, and receive reports from, management of the Company, the Operating Manager, Apollo, and other service providers. The Company's Board is expected to receive presentations and reports on cybersecurity risks from AGM's CSO or CISO, at least annually, addressing a wide range of topics including recent developments, vulnerability assessments, third-party and independent reviews, the threat environment, technological trends and information security considerations arising with respect to Apollo's peers and third parties. Additionally, Apollo and other service providers are expected to periodically report to management as it relates to the Company's cybersecurity practices.


text: Apollo's cybersecurity incident response plan provides for proper escalation of identified cybersecurity threats and incidents, including, as appropriate, to the Company's management. These discussions provide a mechanism for the identification of cybersecurity threats and incidents, assessment of cybersecurity risk profile or certain newly identified risks relevant to the Company, the Operating Manager, and evaluation of the adequacy of the Company's cybersecurity program (as coordinated through the Operating Manager and Apollo), including risk mitigation, compliance and controls.


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: Strategy and Oversight We have implemented and maintain various information security processes 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, confidential information that is proprietary, strategic or competitive in nature, and data related to our clinical studies and employees, or our information systems and the data contained therein.

companyName: Eledon Pharmaceuticals, Inc.

ticker: ELDN


text: We retain a Chief Information Consultant to collaborate with the company, including the Chief Financial Officer, and Executive Leadership Team, to help identify, assess and manage the company's cybersecurity threats and risks. This group identifies and assesses risks from cybersecurity threats by monitoring and evaluating our threat environment using various methods including, for example, automated tools, subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and actors, and evaluating threats reported to us. We also use a third-party security management vendor to assist us from time to time to identify, assess, and manage material risks from cybersecurity threats.


text: Depending on the environment, we implement and maintain various technical, physical, and organizational measures, processes, standards and policies designed to manage and mitigate material risks from cybersecurity threats to our information systems, including, for example, incident detection and response policy, route risk assessments, data encryption, network security controls, data segregation, access controls, physical security, asset management, tracking and disposal, systems monitoring, penetration testing, and cybersecurity insurance. As part of our information security program, we provide mandatory periodic training for all employees on how to identify potential cybersecurity risks and protect our resources and information. This training is supplemented by firmwide testing initiatives, including periodic phishing tests.


text: Our assessment and management of material risks from cybersecurity threats are integrated into our overall risk management processes. For example, the Chief Information Consultant works with management to prioritize our risk management processes and mitigate cybersecurity threats that are more likely to lead to a material impact to our business. In addition, our Chief Financial Officer evaluates material risks from cybersecurity threats and, as appropriate, reports to the Audit Committee of the Board of Directors, which evaluates our overall enterprise risk.


text: To date, we do not believe that known risks from cybersecurity threats, including as a result of any previous cybersecurity incidents that we are aware of, have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition. However, we can give no assurance that we have detected or protected against all such cybersecurity incidents or threats. For a description of the risks from cybersecurity threats that may materially affect us and how they may do so, see our risk factors under Part I. Item 1A. Risk Factors in this Annual Report on Form 10-K, including the risk factor titled " We depend on our information systems and those of our third-party collaborators, service providers, contractors or consultants, which may fail or suffer cybersecurity incidents that could result in a material disruption of our development programs or loss of data and have a material adverse effect on our reputation, business, financial condition or results of operations."


text: Our Board addresses our cybersecurity risk management as part of its general oversight function. The Audit Committee is responsible for overseeing our cybersecurity risk management processes, including oversight and mitigation of risks from cybersecurity threats. Our cybersecurity risk assessment and management processes are implemented and maintained by our Chief Financial Officer who oversees the work performed by our Chief Information Consultant.


text: Our Chief Financial Officer is responsible for hiring appropriate consultants, helping to integrate cybersecurity risk considerations into our overall risk management strategy and communicating key priorities to relevant personnel. Our Chief Financial Officer, with support from our Chief Information Consultant, is responsible for approving budgets, helping prepare for cybersecurity incidents, approving cybersecurity processes, and reviewing security assessments and other security-related reports.


text: The Audit Committee receives periodic reports from our Chief Financial Officer concerning our significant cybersecurity threats and risks and the processes we have implemented to address them. The Audit Committee also receives various reports, summaries or presentations related to cybersecurity threats, risk and mitigation. The Chief Financial Officer also promptly informs and updates the Board about any information security incidents that may pose significant risk to our Company.


text: The Chief Financial Officer has over 20 years of operations and leadership experience, including experience in information technology strategy and execution. The Chief Information Consultant has over 20 years of experience managing and securing technology infrastructure.


text: Cybersecurity Risk Management and Strategy The Company recognizes the critical importance of developing, implementing, and maintaining robust cybersecurity measures to safeguard our information systems and to protect the confidentiality, integrity, and availability of our and our client's data and information assets. As such, we have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information. Our cybersecurity risk management program includes a cybersecurity incident response plan.

companyName: Intapp, Inc.

ticker: INTA


text: We design our program based on industry standard cybersecurity frameworks, such as the National Institute of Standards and Technology Cybersecurity Framework (NIST CSF). This does not imply that we meet any particular technical standards, specifications, or requirements, only that we use the NIST CSF as a guide to help us identify, assess, and manage cybersecurity risks relevant to our business. Also, our cloud services comply with numerous internationally recognized standards, such as ISO 27001, ISO 27017, ISO 27108, SOC 2 and CSA STAR.


text: Our 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 legal, compliance, strategic, operational, and financial risk areas. Our cybersecurity incident response plan is also designed to integrate with or complement other enterprise plans, such as our business continuity plan and crisis management plan.


text: Our cybersecurity risk management program includes: • Risk assessments designed to help identify material cybersecurity risks to our critical systems, information, products, services, and our broader enterprise IT environment; • A security team principally responsible for managing (1) our cybersecurity governance and risk assessment processes, (2) our security controls, and (3) our response to cybersecurity incidents; • The use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security controls; • Cybersecurity awareness training of our employees, incident response personnel, and senior management, including through the use of third-party providers for regular mandatory trainings; • A cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents; and • A third-party risk management process for service providers, suppliers, and vendors.


text: When we experience cybersecurity incidents, we promptly activate incident response protocols and commence investigation of the incident. We may notify law enforcement and engage third-party professionals, as appropriate, as part of our incident response and/or investigation. Based on our assessments, during the last fiscal year, we have not identified any cybersecurity threat that has had a material impact on, or that we expect will have a material impact on our operations, business strategy, results of operations, or financial condition. However, we face ongoing cybersecurity risks, including threats that might become more sophisticated and effective over time. If realized, these risks are reasonably likely to materially affect us. Additional information on the cybersecurity risks we face is discussed in Part I, Item 1A, "Risk Factors."


text: Cybersecurity Governance Our Board of Directors considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit Committee ("Committee") oversight of our enterprise risks, including cybersecurity and other information security risks. The Committee oversees management's implementation of our cybersecurity risk management program. Also, we created a Risk Management Working Group which meets no less than quarterly and which receives updates on our cybersecurity risk management program and cybersecurity risks from the Chief Information Security Officer ("CISO"). The Risk Management Working Group includes two Audit Committee members, certain members of senior management and the CISO.


text: The Committee receives quarterly reports on our cybersecurity risks from the Risk Management Working Group. In addition, management updates the Committee, as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential.


text: The Committee reports quarterly to the full Board of Directors regarding its activities, including those related to cybersecurity. The full Board of Directors also receives briefings on our cyber risk management program.


text: Our team of experienced cybersecurity professionals has primary responsibility for our overall cybersecurity risk management program, including assessing and managing material risks from cybersecurity threats. Our CISO, Mark Schertler, supervises both our internal cybersecurity personnel and our retained external cybersecurity consultants. Mr. Schertler has over 40 years of experience in the field of cybersecurity. Mr. Schertler leads a team of experienced cybersecurity professionals who have extensive experience in the field of cybersecurity, including experience in cybersecurity consulting, cloud security, security architecture, application security and serving as a chief technology officer.


text: Our management team supervises efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel; threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us; and alerts and reports produced by security tools deployed in the IT environment.


text: Risk Management and Strategy We recognize the importance of cybersecurity in safeguarding sensitive information, maintaining operational integrity, and working to ensure the safety and efficacy of our products. We evaluate and monitor cybersecurity risk as part of our overall enterprise risk management program, which considers cybersecurity risks alongside other company risks as part of our overall risk assessment process. In addition, the risk oversight responsibility of our Board of Directors and its committees is supported by our cybersecurity risk assessment program, which includes policies and processes that are designed to provide visibility and information about the identification, assessment, and management of critical risks and management's risk mitigation strategies to our Board of Directors and personnel that are responsible for risk assessment. These policies also govern the security of our products and the protection of customer and patient data and provide for vulnerability remediation, regular system updates and patches, employee training on cybersecurity and HIPAA best practices, incident reporting, and the use of encryption to secure sensitive information. To identify, assess, and manage material cybersecurity risks, our team uses a cybersecurity risk assessment process aligned with leading frameworks such as the National Institute of Standards and Technology's Cyber Security Framework and HIPAA. Our cybersecurity risk assessment program provides the underlying basis for the activities of our team to identify and mitigate risks from, as well as develop risk management and response strategies for, evolving and emerging cybersecurity threats.

companyName: ACCURAY INC

ticker: ARAY


text: Our cybersecurity program includes a variety of processes to assess, identify and manage risks from cybersecurity threats arising from our own and third-party provided systems, including annual training requirements, simulation exercises, threat monitoring and detection tools (including those using artificial intelligence and machine learning), threat containment methods, risk assessments, third-party penetration testing and security requirements for our suppliers and other third parties. We have established processes providing for review of identified cybersecurity incidents by a cross-functional cybersecurity incident response team who monitors and manages the detection, assessment, mitigation and remediation of cybersecurity incidents and escalates incidents to the Chief Information and Security Officer and to our disclosure review board, which evaluates such incidents for materiality and potential disclosure, and works to ensure that members of management responsible for overseeing the operation of our disclosure controls and procedures are informed of such cybersecurity risks and incidents. Our cybersecurity incident response team and disclosure review board are comprised of subject matter experts, including employees in cybersecurity, information technology and other areas, to evaluate potential security, financial, operational, reputational and other risks, and to address our process. We also engage third parties to enhance and strengthen our cybersecurity program, to provide additional capabilities and support and to provide periodic independent assessments and evaluations of our cybersecurity program. Third parties also provide managed services for security operations, incident response, and security remediation services.


text: We monitor and periodically enhance our cybersecurity program, processes, techniques and procedures to combat evolving and adaptive cybersecurity threats. To this end, we engage in the periodic assessment of our policies, standards, processes, and practices that are designed to address cybersecurity threats and incidents, internally and through assessments by external providers. The results of such assessments, audits, and reviews are reported to the Audit Committee and the Board of Directors, and we adjust our cybersecurity policies, standards, processes, and practices as necessary based on the information provided by these assessments, audits, and reviews.


text: We also monitor and test our safeguards and train all our employees on cybersecurity safeguards related to our information technology systems. Personnel at all levels and departments are made aware of our cybersecurity policies through periodic cybersecurity trainings and tests. Further, we are focused on building and maintaining a positive cybersecurity culture through a combination of trainings, educational tools, videos, and other cybersecurity awareness initiatives. Our security training incorporates awareness of cyber threats (including malware, ransomware, and social engineering attacks), password hygiene, the importance of multifactor authentication and our incident reporting process. In addition to the assessment of internal cybersecurity risks, we have implemented processes to oversee, identify and monitor material risks from cybersecurity threats relating to potential compromises of sensitive information at our third-party business partners where relevant and we reevaluate these risks periodically. These processes include vetting of certain service providers for security, reliability, and availability; execution of a Business Associate Agreement with relevant providers for compliant management, storage, or processing of PHI if necessary; and confirmation by each service provider that its SOC-2 reports, or equivalent reports, are current and available, where applicable. In the event a service provider does not have a current and available SOC-2 or equivalent report, we review the service provider's cybersecurity risk management and advise relevant business stakeholders of any significant identified risks.


text: While we regularly experience cybersecurity incidents, and we expect to continue to be subject to such incidents, as of the date of this report, we are not aware of any cybersecurity incidents that have had or are reasonably likely to have a material impact on our business or operations. However, we are subject to ongoing risks from cybersecurity threats that could materially affect us, including our business strategy, results of operations, or financial condition, as further described in Item 1A. Risk Factors in the risk factor entitled "Disruption of critical information technology systems, infrastructure and data or cyberattacks or other security breaches or incidents could harm our business and financial condition."


text: Our Board of Directors, both directly and through the delegation of responsibilities to the Audit Committee, oversees the functioning of our cybersecurity risk management program and ensures strategic alignment and governance of our cybersecurity efforts at the highest level. Our Board of Directors receives periodic briefings on the outcome of our cybersecurity risk management program, including steps that we are taking to mitigate risks that the program identifies, and each quarter, the Audit Committee reviews cybersecurity incidents, metrics, and the state of the program.


text: Our cybersecurity risk management program is principally managed by our Global Information Systems team, which is led by our Chief Information and Security Officer, who reports directly to our Chief Executive Officer, as well as our Deputy Chief Information Security Officer (Deputy CISO). Our Chief Information and Security Officer and Deputy CISO combined have more than 40 years of experience in cybersecurity and/or information technology risk management, have relevant certification, and are active in a variety of cybersecurity related boards and organizations. Our Chief Information and Security Officer also serves as the officer who reports directly to senior management and makes regular reports to the Audit Committee and Board of Directors as described in this Item 1C. Under the direction of our Chief Information and Security Officer and Deputy CISO, we monitor developments that could affect our long-term organizational cybersecurity strategy based on threats globally and work to enhance our cybersecurity program as needed in response to such developments.


text: Cybersecurity Processes and Risk Assessment We rely on the cybersecurity program implemented by GECM. In order to assess, identify and manage material risks from cybersecurity threats, GECM has implemented a cybersecurity program for GEG and its subsidiaries, which is focused on (i) protecting the confidentiality of business, client, fund investor and employee information; (ii) maintaining the security and availability of its systems and data; (iii) supporting compliance with applicable laws and regulations; (iv) documenting cybersecurity incidents and its responses; and (v) notification of cybersecurity incidents to, and communications with, appropriate internal and external parties.

companyName: Great Elm Group, Inc.

ticker: GEG


text: GECM has implemented an information security policy governing cybersecurity risk, which is designed to facilitate the protection of sensitive or confidential business, client, investor and employee information that it stores or processes and the maintenance of critical services and systems. This program is based on recognized industry standards that we use to help us identify, assess and manage cybersecurity risks and is supported by both management and our Board. These processes and systems are designed to protect against unauthorized access of information, including by cyber-attacks. GECM's policies and processes include, as appropriate, encryption, data loss prevention technology, authentication technology, entitlement management, access control, anti-virus and anti-malware software, spam and phishing email filtering, and transmission of data over private networks. GECM's processes and systems aim to prevent or mitigate two main types of cybersecurity risk: (1) cybersecurity risks associated with its physical and digital devices and infrastructure, and (2) cybersecurity risks associated with third parties, such as people and organizations who have access to its devices, infrastructure or confidential or sensitive information.


text: As a part of its cybersecurity program, GECM's cybersecurity processes and systems are reviewed and assessed by third parties. These third parties provide external expertise in all aspects of our cybersecurity program and assess and report on GECM's compliance with applicable laws and regulations and its internal incident response preparedness, including benchmarking to best practices and industry frameworks. These third parties also help identify areas for continued focus and improvement. Annual penetration testing of its network, including critical systems and systems that store confidential or sensitive information, is conducted with third-party consultants and vulnerabilities are reviewed by Great Elm's Information Technology & Security Committee (IT Committee), comprised of GECM's Chief Operating Officer and other members of Company management as well as its third-party IT consultant. In order to oversee and identify risks from cybersecurity threats associated with its use of large vendors and material third parties who will have access to sensitive data or client systems and facilities, GECM requires these parties to adhere to GECM's cybersecurity requirements prior to accessing such data. In addition, GECM performs periodic reviews of its critical vendors with the assistance of a third-party consultant to identify and assess the vendors' security posture to reduce risk to the Company.


text: In May 2024, the SEC adopted amendments to Regulation S-P, which, beginning in December 2025, requiring investment companies and SEC-registered investment advisers to adopt written policies and procedures for incident response programs to address unauthorized access to, or use of, customer information, including providing notice to certain individuals affected by any such incident. GECM will need to comply with this amended rule beginning December 2025. With the SEC particularly focused on cybersecurity, we expect increased scrutiny of our policies and systems designed to manage cybersecurity risks and related disclosures.


text: GECM also provides its employees with cybersecurity awareness training at onboarding and semiannually, as well as interim security reminders and alerts. GECM's third-party consultants conduct regular phishing tests and provide additional training as appropriate.


text: Governance and Oversight of Cybersecurity Risks GECM's cybersecurity program is managed by the IT Committee. The members of the IT Committee collectively have over fifty years of experience helping to oversee the information technology infrastructure and processes at GECM and other asset managers in both operations and IT infrastructure leadership roles. Third-party consultants with specific education and over 25 years' experience in IT Infrastructure and Cybersecurity are utilized to provide additional technical insight and recommendations. The IT Committee is responsible for supervising and interfacing with providers to implement GECM's monitoring and alert response processes, vulnerability management, changes made to its critical systems, including software and network changes, and various other technological and administrative safeguards.


text: GECM has also developed an incident response framework to monitor the prevention, detection, mitigation and remediation of cybersecurity events. This framework is managed and implemented by the IT Committee, with support from their third-party consultants. The IT Committee alongside the General Counsel and Chief Compliance Officer of GECM are responsible for gathering information with respect to cybersecurity incidents, assessing their severity and determining potential responses, as well as communicating with business leaders and senior management, and the Board of Directors, as appropriate.


text: Our Board monitors cybersecurity risk as part of Great Elm's overall risk management program. Our Board has delegated the primary responsibility for oversight and review of guidelines and policies with respect to risk assessment and risk management to the Audit Committee, which includes oversight of risks related to cybersecurity threats. The Audit Committee and the Board, as appropriate, are informed about risks related to cybersecurity threats through periodic reports from GECM's Chief Operating Officer. Such reporting includes updates on GECM's cybersecurity program, the external threat environment, and GECM's programs to address and mitigate the risks associated with the evolving cybersecurity threat environment. These reports also include updates on GECM's preparedness, prevention, detection, responsiveness and recovery with respect to cyber incidents, where applicable.


text: Impact of Cybersecurity Risks As of the filing of this Form 10-K, we are not aware of any cyber-attacks that have occurred that have materially affected, or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition. We acknowledge that we cannot eliminate all security risks within our organization, and we cannot guarantee that any undetected cybersecurity incidents have occurred. For additional information about these risks, see "Item 1A. Risk Factors" in this Annual Report on Form 10-K.


text: Cybersecurity Risk Management and Strategy We recognize the importance of information security practices designed to protect the confidentiality, integrity, and availability of company information and the personal information that we process. Cybersecurity risk management is an integral part of our overall enterprise risk management efforts. We manage cybersecurity risks using a framework based on applicable regulations, industry standards, and recognized best practices. Through this framework, we devote significant resources to identifying, monitoring, assessing, and responding to cybersecurity threats and incidents, including those associated with our use of third-party software, applications, services, and cloud infrastructure.

companyName: Gold.com, Inc.

ticker: GOLD


text: Our Cybersecurity Program includes multiple policies, procedures, and other components designed to identify, analyze, and respond to cybersecurity risks, including reliance on a layered system of preventative and detective technologies and controls designed to detect, mitigate, and contain cybersecurity threats. As part of our Cybersecurity Program, we maintain a Written Information Security Plan that outlines internal controls and procedures designed to protect our information systems. Our Cybersecurity Program contains a comprehensive suite of cybersecurity policies that are commensurate with companies in our industry of similar size and sophistication, and these policies are also informed by the sensitivity of our data processing activities. Our Cybersecurity Program also includes policies and procedures designed to ensure adequate business continuity, disaster recovery, and incident response. We also have access through our insurer to computer forensics firms and specialized legal counsel in case of a cybersecurity incident. While we maintain cybersecurity insurance to assist in the cost of recovery from a cybersecurity incident, such coverage may not be sufficient to cover all costs resulting from such incidents.


text: We leverage qualified third-party consultants, advisors, counsel, and other experts to inform, audit, and update our Cybersecurity Program throughout each year. We engage security assessors to identify vulnerabilities through both internal and external penetration tests and to perform cybersecurity maturity assessments. We perform risk assessments annually, or more frequently if circumstances require, using both internal and external resources. We may also be subject to examinations or disclosures by applicable regulators. We conduct annual cybersecurity training for employees to enhance awareness of how to detect and respond to cybersecurity threats, as well as periodic phishing training and testing campaigns. We also conduct periodic table-top exercises to simulate a response to a cybersecurity incident.


text: Our designated IT team members monitor cybersecurity threats in real time for the Company at the enterprise level, with the assistance of third-party threat detection and monitoring software. Cybersecurity threats at the subsidiary level are also monitored in real time by experienced IT professionals at those subsidiaries, including our IT leadership at JM Bullion, AMS, Pinehurst, LPM, and SGI. These individuals report cybersecurity incidents immediately to our Chief Information Officer ("CIO") and Chief Privacy Officer ("CPO"), who in turn follow approved incident response and reporting protocols, as more fully described below.


text: Our Cybersecurity Compliance and Disclosure Committee ("CCDC"), which is further described below, is chaired by our CIO and includes the General Counsel and the CPO of A-Mark and other representatives from the Company and our subsidiaries, including top-level management, to ensure enterprise-wide implementation and consistent application of the Company's data security, privacy, and artificial intelligence policies and procedures. The CCDC regularly enlists internal and external subject matter experts to assist where necessary.


text: We also maintain a formal Vendor Management Program that provides oversight of cybersecurity risks related to our vendor and supplier relationships. During vendor onboarding, we perform risk-based due diligence on these third-parties, with heightened requirements for vendors that have access to confidential enterprise information, personal data, or that require access to our information systems. This Vendor Management Program includes specific cybersecurity requirements for our vendors, as well as ongoing monitoring, assessment, and contract review. Members of the CCDC are involved in and review the Vendor Management Program annually.


text: We also maintain a formal Generative Artificial Intelligence ("GAI") Policy and Program that provides oversight of cybersecurity, privacy, and contractual risks related to enterprise use of GAI. All GAI tools and use cases must be submitted for review and approval by a subcommittee of CCDC members based on specific cybersecurity, privacy, and contractual requirements.


text: To date, we have not identified any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially affected us or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition. However, the sophistication of and risks from cybersecurity threats and incidents continue to increase, and the preventative actions that we have taken and continue to take to reduce the risk of cybersecurity threats and incidents may not successfully protect against all cybersecurity threats and incidents. For more information on the risks that we face from cybersecurity threats, see "Risk Factors – Risk Factors of General Applicability—Legislatures and regulators continue to scrutinize cybersecurity management and incident reporting." in Part 1, Item 1A of this report.


text: Cybersecurity Governance The Board has overall responsibility for risk oversight and has delegated oversight of our Cybersecurity Program, including enterprise-wide risk assessment and management, to the CCDC. The CCDC's charter requires it to monitor Company efforts to prevent, detect, mitigate, and remediate cybersecurity incidents, and to comply with cybersecurity laws and regulations. The CCDC oversees and approves all Company policies and procedures related to cybersecurity. The CCDC also ensures that significant cybersecurity issues or concerns are reported to the Board and A-Mark's CEO, and disclosed to the public, individuals, or regulators where required by law.


text: The CCDC directly oversees information technology and information security risks through regular meetings, reports from management on information technology, cybersecurity, and related risk assessments, and incidents disclosed by third-party service providers as applicable. If a cybersecurity threat is identified, our Vice President of IT or other reporting individuals will immediately inform our IT service desk and notify our CIO and CPO. Once the threat has been analyzed, our CIO and CPO will inform our General Counsel of any security incidents. The General Counsel or her delegate will report on the incident, as appropriate, to the CCDC, our CEO, President, CFO, and to the Board, either at the next scheduled meeting or on a current basis, depending on the severity of the incident. Each quarter, the enterprise CPO presents legal and regulatory updates concerning cybersecurity, security incident response and notification, privacy, and artificial intelligence. A-Mark's CPO is certified by the International Association of Privacy Professionals as an EU, US, and management privacy professional, as well as an artificial intelligence governance professional. Our CPO has over a decade of privacy, data protection, and information management experience.


text: The CCDC reports at least quarterly to the Board and A-Mark's CEO on the following topics, among possible others: our current risk posture and threat landscape; new material cybersecurity threats and high-risk exposures; risk mitigations and controls; incident response readiness; and updates to cybersecurity policies and procedures. The CCDC is also authorized and directed to report to the Board and A-Mark's CEO promptly in the event of a significant cybersecurity incident, as appropriate.


text: A-Mark's CIO chairs the CCDC. Our CIO brings over 15 years of IT experience to A-Mark. Since joining A-Mark in 2019, he has been pivotal in enhancing our data privacy compliance program, significantly strengthening our data protection and privacy measures, particularly ensuring protection of sensitive data. The co-vice chairs of the CCDC are A-Mark's Vice President of IT and JM Bullion's Vice President of Digital and Technology. Our Vice President of IT has over 25 years of experience in IT working in various industries including ecommerce, health care, and financial industries focusing on IT operations, cybersecurity and compliance. Since joining the company in 2014, he has been instrumental in the creation and growth of our cybersecurity program. Our Vice President of Digital and Technology at JM Bullion has comprehensive experience in the cybersecurity field. He successfully established a 24/7 security operation center (SOC) to continuously detect and respond to security incidents, as well as implemented various advanced services to proactively detect vulnerabilities on potential attack surfaces with high accuracy spanning across assets, applications, data, endpoints and network. He also centralized the workforce identity and access management (IAM) of the various systems for improved administration and control at the subsidiary level. He joined JM Bullion in 2015 and has served in his current role as Vice President of Digital and Technology since 2021.


text: Other members of the CCDC include top executives and management from the Company and its subsidiaries, including A-Mark's General Counsel and Assistant General Counsel, CPO, President, Chief Financial Officer, Chief Operating Officer, Senior Director of Financial Reporting, Senior Director of Internal Audit, and Director of Enterprise Development and Administration, as well as JM Bullion's President and Chief Executive Officer and its Chief Financial Officer. Finally, the CCDC is assisted by an external compliance consultant with over twenty years of IT experience, and A-Mark's outside legal counsel for privacy and data security.


text: Cybersecurity Risk Management and Strategy Our enterprise risk management framework considers cybersecurity risk alongside other applicable risks as part of our overall risk assessment process. Within our comprehensive enterprise risk management framework, our cybersecurity risk management program is focused on assessing, identifying, and managing risks arising out of our use of information technology ("IT") including the risk of cybersecurity incidents and threats. The program is informed by recognized frameworks such as the National Institute of Standards and Technology Cybersecurity Framework ("NIST CSF"). Our cybersecurity team utilizes a variety of tools, processes and outside resources to continue to raise and maintain its maturity across the elements of NIST CSF.

companyName: HAIN CELESTIAL GROUP INC

ticker: HAIN


text: Our cybersecurity risk management program includes a Cyber Security Incident Response Plan ("CSIRP"). Our CSIRP supports the Company in identifying, containing, and tracking cybersecurity incidents experienced by us or our third-party service providers or suppliers. The CSIRP was established to minimize the impact of cybersecurity incidents on our networks, IT systems, users and business processes, and to ensure the timely and accurate reporting of material cybersecurity incidents, should they occur. The execution of our CSIRP is led by our Chief Information Officer and Head of Business Services ("CIO"), with support from a designated IT Incident Response Manager leading an Incident Response Team consisting of subject matter experts, as well as our Executive Response Team when appropriate. In the event of an incident, these individuals work together to assess its severity, notify and brief the appropriate team members, escalate to our Board of Directors as needed, and implement containment procedures. The Company also conducts tabletop exercises to enhance incident response preparedness and engage s third parties, including consultants and other professionals, on an as-needed basis to assess and support our cybersecurity practices and procedures.


text: Our cybersecurity risk management program is integrated into our operations and is widely communicated to employees through periodic (not less than annual) employee and contractor cybersecurity awareness training, which includes information about how to identify and report cybersecurity concerns and incidents. Our information technology organization also conducts phishing simulations and testing scenarios to help ensure compliance with our cybersecurity policies and procedures. These awareness measures are coupled with ongoing implementation of technology aimed to reduce vulnerabilities (including external testing and validation) and to monitor and assess threats. Our program includes monitoring on a continuous basis through automated tools and 24x7 managed services that detect threats and trigger alerts for assessment, investigation, and remediation by our information technology organization.


text: We maintain business continuity and disaster recovery plans to prepare for potential information technology disruptions. We also maintain insurance coverage that, subject to its terms and conditions, is intended to address costs associated with certain aspects of cyber incidents and information systems failures. Based on the information we have as of the date of this Form 10-K, we do not believe any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition. See "Item 1A. Risk Factors – Risks Related to Cybersecurity and Technology" for further information about these risks.


text: Cybersecurity Governance Our Board of Directors has risk oversight responsibility for the Company, which it administers directly and with assistance from its committees. The Audit Committee assists the Board in its oversight of the cybersecurity risk management program. The Audit Committee is tasked with reviewing and receiving periodic reports from management regarding the Company's information technology system controls and security and, at least annually, evaluating the adequacy of the Company's information technology security program, compliance, governance processes, training and controls. The Audit Committee specifically oversees: • management's evaluation of the potential impact of cybersecurity risk exposures on the Company's business, financial results, operations and reputation, • the steps management has taken to monitor and mitigate such exposures, • major legislative and regulatory developments that could materially impact such exposure, and • the Company's incident response planning (including escalation protocols), including with respect to the prompt reporting of material cybersecurity threats or incidents to management, the Audit Committee and the Board of Directors.


text: Our CIO periodically provides the Executive Leadership Team, which consists of the Company's executive officers and other senior leaders, with cybersecurity briefings, information and trainings, and updates the Audit Committee on cybersecurity biannually or more frequently as appropriate. At any time, Board members may raise concerns regarding the Company's cybersecurity posture and recommend changes regarding controls or procedures to management. Our CSIRP includes a process for incidents to be evaluated for material impact, with an escalation protocol requiring reporting of material incidents to the Executive Response Team and to the Board of Directors.


text: The CIO is the management position with primary responsibility for the development, operation, and maintenance of our cybersecurity risk management program. The CIO has deep experience in information systems and technology, including developing information and cybersecurity programs, roll-outs of new technology, information security audit and assessments, and cybersecurity operations focused on identification, mitigation and response to cybersecurity threats. The CIO has experience overseeing and executing technology strategies in complex, global, and matrixed environments. The CIO joined the Company in 2020, bringing over 15 years of experience leading IT strategy and change initiatives in the consumer packaged goods industry, and reports directly to our interim CEO.


text: Cybersecurity, data privacy, and data protection are critical to our business. In the ordinary course of our business, we collect and store certain confidential information such as information about our employees, contractors, vendors, suppliers, partners and customers. We understand the increasing reliance of our customers, suppliers, and partners on our digital platforms. Our goal is to strengthen our digital infrastructure, ensuring the highest levels of customer service while effectively managing risks and adhering to global compliance standards. We have processes in place for assessing, identifying, and managing material risks from cybersecurity threats, and we continually monitor our overall security to assess performance and identify areas for improvement.

companyName: RADIANT LOGISTICS, INC

ticker: RLGT


text: Risk Management and Strategy Our processes for assessing, identifying, and managing cybersecurity threats have been integrated into our overall risk management processes. Our cybersecurity and risk management program is structured around strategy, execution, management, oversight, and user training, with ongoing evaluations to ensure its effectiveness.


text: Identifying and assessing cybersecurity risks and threats are integral components of our broader enterprise risk management strategy. Our information technology leadership, with input from senior management, is responsible for defining our cybersecurity strategy, setting priorities, and driving the execution of our cybersecurity initiatives. We maintain a cybersecurity program that is designed to identify, protect from, detect, respond to, and recover from cybersecurity threats and risks, and protect the confidentiality, integrity, and availability of our information systems, including the information residing on our systems. We utilize the National Institute of Standards and Technology Cybersecurity Framework ("NIST CSF") to guide our efforts, aligning with industry standards.


text: We take a risk-based approach to cybersecurity, which begins with the identification and evaluation of cybersecurity risks or threats that could affect our operations, finances, legal or regulatory compliance, or reputation. The scope of our evaluation encompasses risks that may be associated with both our internally managed IT systems and key business functions and sensitive data operated or managed by third-party service providers. Risk mitigation strategies are developed and implemented based on the specific nature of each cybersecurity risk. Our cybersecurity and risk management program is developed based on: • Continuous Development: Ongoing refinement of our risk management processes. • Partners and Tools: Leveraging global access control and activity monitoring solutions. • Education and Training: Implementing company-wide policies and proactive user training. • Continuous Monitoring: Regular surveillance of our environment. • Access Management: Ensuring only authorized users have access to our Zero Trust approach network implementation.


text: 24x7 Endpoint Monitoring by NOSC As part of our commitment to safeguarding our network, we operate a Network Operations and Security Center ("NOSC") that provides 24x7 monitoring of all endpoints across our network. This continuous surveillance allows us to detect and respond to potential threats in real time, helping our systems remain secure and operational. The NOSC is a critical component of our cybersecurity infrastructure, enabling proactive risk management and the ongoing protection of our digital assets.


text: Use of Consultants and Advisors In addition to our in-house capabilities, we engage various third-party cybersecurity service providers to assess and enhance our cybersecurity practices and assist with protection and monitoring of our systems and information. We partner with a third-party provider specializing in endpoint security and monitoring. This partnership enhances our overall security posture by providing advanced incident response capabilities. This collaboration ensures that any potential threats are quickly identified and managed, adding an extra layer of security to our existing infrastructure.


text: The execution and measurement of our cybersecurity program are managed by our Information Technology department. This program is integrated into our broader governance and internal controls framework. We regularly engage with third-party consultants, auditors, and specialists to enhance our program, employing advanced cybersecurity technologies and services to prevent, detect, respond to, and recover from cyber threats and incidents. Additionally, our third-party security partner actively monitors and mitigates risks from external sources as part of our overall cybersecurity strategy.


text: We have processes to evaluate third-party service providers and vendors that have access to sensitive systems and customer data, which may include due diligence procedures such as assessments of that service provider's cybersecurity posture or a recommendation of specific mitigation controls. Following an assessment, we determine and prioritize service provider risk based on potential threat impact and likelihood, and such risk determinations drive the level of due diligence and ongoing compliance monitoring required for each service provider.


text: Role of Management Management has implemented risk management structures, policies and procedures, and is responsible for day-to-day cybersecurity risk management. Our Information Technology department that is led by our Chief Technology Officer ("CTO") is responsible for the day-to-day assessment and management of cybersecurity risks. Our CTO has led IT departments, including cybersecurity teams, for the past 15 years in worldwide leading logistics companies. We have implemented several processes which allow the management team to be informed about and monitor the prevention, detection, mitigation, and remediation of cybersecurity incidents. These processes include, among other things, system alerts of potential malicious cyber activity, access to real-time dashboards that monitor and assess our systems, status reports provided on a daily, weekly and monthly basis, and regular ongoing communications with service providers regarding potential new attack vectors and vulnerabilities. Our CTO and his team share such information with our management team and reports information about such risks to our Audit and Executive Oversight Committee ("AEOC").


text: The Board of Directors, both directly and through the delegation of responsibilities to the AEOC, has risk management oversight, which includes the proper functioning of our cybersecurity risk management program. In particular, the AEOC assists the Board in its oversight of management's responsibility to assess, manage and mitigate risks associated with our business and operational activities, to administer our various compliance programs, in each case including cybersecurity concerns, and to oversee our information technology systems, processes and data.


text: The AEOC, which is comprised entirely of independent directors, is responsible for periodically reviewing and assessing with management (i) the adequacy of controls and security for our information technology systems, processes and data, and (ii) our contingency plans in the event of a breakdown or security breach affecting our information technology systems, it being understood that it is not possible to eliminate all such risks and that we will necessarily face a variety of risks with respect to information technology in the conduct of our business. The AEOC is additionally responsible for reviewing the cybersecurity disclosures required to be included in our filings with the SEC.


text: The AEOC regularly discusses with management, including our CTO, our enterprise risk management process, including our cybersecurity exposures, the steps management has taken to monitor and control such exposures and guidelines and policies to govern our risk assessment and risk management processes. The AEOC periodically reports to the Board regarding significant matters identified with respect to the foregoing, including, among others, our risk assessment and risk management approach to cybersecurity.


text: We believe each of the members of the AEOC has relevant work experience related to information security or cybersecurity to allow for the effective oversight of cybersecurity risks. In particular, Richard Palmieri has held numerous roles where he provided oversight of technology functions, Kristin Toth has significant experience managing e-commerce platforms and businesses, and Michael Gould has held senior roles in the technology consulting businesses at Oracle and Hewlett-Packard Company.


text: Risks from Material Cybersecurity Threats Although we have taken steps to prevent and mitigate data security threats, there can be no assurance that our protective measures and those of our third-party service providers will prevent or detect security breaches that could have a significant impact on our business, reputation, operating results and financial condition.


text: We have experienced two separate cyber events. First, in December 2021, we experienced a targeted cyber-attack, leading to a global shutdown of our connectivity, operational, and accounting systems to protect our infrastructure. Although our operations systems were eventually restored, this event caused significant disruption to our operations for approximately two weeks, temporarily impacting our ability to manage freight shipments, customs brokerage functions, and distribution activities. Next, in March 2024, our Canadian subsidiary experienced a targeted cybersecurity breach. This attack was identified by our end point protection software and our third-party monitoring partner. As per our response process, we initiated a shutdown of our Canadian infrastructure and engaged our incident response team. The operations systems were restored and approved to return to service within one week. While we continue to learn from these incidents, we do not anticipate further material adverse impacts from them on our business. Following the attacks, we enhanced our security program with additional tools and strengthened measures for improved system and network monitoring.


text: As of the date of this filing, we have not identified any cybersecurity threats that are reasonably anticipated to have a material effect on our business strategy, results of operations or financial condition. Maintaining a robust information security system is an ongoing priority for us and we plan to continue to identify and evaluate new, emerging risks to data protection and cybersecurity both internally and through our engagement of third-party service providers.


text: Cybersecurity is a significant and integrated component of Winchester Bancorp's risk management strategy, designed to protect the confidentiality, integrity and availability of sensitive information contained within the Company's information services. As a financial services company, cyber threats are present and growing, and the potential exists for a cybersecurity incident to disrupt business operations, compromise sensitive data or both. As a proactive measure, the Company maintains insurance coverage for cybersecurity incidents experienced by the Company, however, such insurance coverage may not be sufficient to cover all losses incurred. During the year ended June 30, 2025, we did not, to our knowledge, experience a cybersecurity incident materially affecting or reasonably likely to materially affect the Company. Risk Management & Strategy (Scope)

companyName: Winchester Bancorp, Inc./MD/

ticker: WSBK


text: On a periodic basis, but not less than annually, the Information Security Officer (ISO), in conjunction with the Information Technology department, identifies and documents internal and external vulnerabilities that could result in unauthorized disclosure, misuse, alteration or destruction of customer information or customer records. Based on the results of the risk assessment, the Company's Information Security Program may be revised to protect against any anticipated threats or hazards to the security or integrity of such information. The Information Security Officer, CIO and IT Department regularly meet to review, monitor and address technology related threats and emerging risks.


text: Additionally, the Company engages third parties to aid in the identification of risks and controls related to technology and technology driven product delivery channels, allowing for an independent opinion. The risk assessment process identifies data sources, threats and vulnerabilities, and ensures awareness, accountability and oversight for data protection throughout the Company and with trusted third parties to ensure that data is protected and able to be recovered in the event of a breach or failure (technical or other disaster). Risk Assessments (Detail)


text: On a periodic basis, but not less than annually, the Information Security Officer (ISO), in conjunction with the Information Technology department, identifies and documents internal and external vulnerabilities that could result in unauthorized disclosure, misuse, alteration or destruction of customer information or customer records. Risks are identified and mitigations are documented by the ISO, IT staff and business lines responsible for the assessed area. Risks related to the engagement of third-party providers are identified and reviewed by the Risk & Compliance Department, in coordination with Vendors and Business lines that engaged the vendor relationship.


text: Response to Security Vulnerabilities In response to identified risks, management may take certain steps to correct and respond to security vulnerabilities, which may include: • Eliminating unwarranted risks by applying vendor provided software fixes (patches); • Ensuring that changes to security configurations are documented, approved and tested; • Ensuring that exploitable files and services are assessed and removed or disabled based upon known vulnerabilities and business needs; • Updating and monitoring vulnerability scanning and intrusion detection tools to identify known vulnerabilities and related unauthorized activities; • Conducting penetration testing and vulnerability assessments as warranted; • Review performance with service providers to ensure that security maintenance and reporting responsibilities are operating according to contract provisions and that service providers provide notification of system security breaches that may affect the Company.


text: Internal Controls, Audit and Testing Regular internal monitoring is integral to the Company's risk assessment process, which includes regular testing of key controls, systems and procedures. In addition, independent third party penetration testing to test the effectiveness of security controls and preparedness measures is conducted at least annually. Management determines the scope and objectives of the penetration analysis.


text: Aspects of the Information Security program are audited by the Company's Internal Audit provider(s) to ensure aspects are aligned with regulatory expectations.


text: Employee Training Employees are an integral part in the line of defense against cybersecurity risks. Every employee is responsible for protecting Company and client information. Accordingly, employees complete formal training, including regular simulated phishing assessments designed to sharpen threat detection and reporting capabilities. Our employees are supported by solutions designed to identify, prevent, detect, respond to and recover from incidents. Technologies include firewalls, intrusion detection systems, managed endpoint security automation and response capabilities, encryption, data backups and multi-factor authentication when available. Notable services include 24/7 security monitoring and response, real time vulnerability scanning, third party monitoring and threat intelligence.


text: Service Providers The company relies on third party vendor services and solutions to support its operations. Many of these vendors have access to sensitive and proprietary information. Third party vendors continue to be a notable source of operational and informational risk. Accordingly, the Company has implemented a "Third Party" Management program, which includes a detailed onboarding process and periodic reviews of vendors with access to sensitive Company data. The program is audited as part of the Company's internal audit program.


text: Program Adjustments The ISO monitors, evaluates and adjusts the Information Security Program considering any relevant changes in technology, the sensitivity of its customer information, internal or external threats to information and changing business arrangements, such as mergers and acquisitions, alliances and joint ventures, outsourcing arrangements and changes to customer information systems.


text: Incident Response Plan The Company has implemented an Incident Response Plan (IRP) to provide structure and a systematic incident response process for information security incidents that may affect any of the information technology systems, network or data. The Company's business continuity program provides a coordinated response when responding to incidents. The IRP is implemented and maintained by the ISO and is subject to annual review and approval by the IT Steering Committee and the Board of Directors. Cybersecurity metrics are reported to the Audit Committee quarterly.


text: The IRP includes: • Identifying the Incident Response Team (IRT); • Coordinating IRT activities, including developing, maintaining and following appropriate procedures to respond to and document identified information security incidents; • Conducting post-incident reviews to gather feedback on information security incident response procedures and to address any identified gaps in security measures; • Provide training and conduct periodic exercises to promote employee and stakeholder preparedness and awareness of the IRP; • Reviewing the IRP at least annually, or whenever there is a material change in the Company's business practices that may reasonably affect its cyber incident response procedures.


text: Governance & Reporting The Board of Directors has designated the Vice President of Information Security as Information Security Officer (ISO). The ISO reports directly to the Senior Vice President of Risk & Compliance and works in tandem with the Chief Information Officer.


text: On a quarterly basis, the ISO presents risks and metrics related to cyber and information security efforts to the IT Steering Committee and then to the Board's Audit Committee.


text: At least annually, the ISO reports to the Board of Directors the overall status of the Information Security Program and the Company's compliance with the Interagency Guidelines for Safeguarding Customer Information. Any material findings related to risk assessment, risk management and control decisions, service provider arrangements, results of testing, security breaches or violations are discussed, as are management responses and any recommendations for program changes.


text: Cybersecurity is a significant and integrated component of CFSB Bancorp's risk management strategy, designed to protect the confidentiality, integrity, and availability of sensitive information contained within the Company's information services. As a financial services company, cyber threats are present and growing, and the potential exists for a cybersecurity incident to disrupt business operations, compromise sensitive data or both. To date, we have not, to our knowledge, experienced a cybersecurity incident materially affecting or reasonably likely to materially affect the Company.

companyName: CFSB Bancorp, Inc. /MA/

ticker: CFSB


text: To prepare and respond to incidents, the Company has implemented a multi-layered "defense-in-depth" cybersecurity strategy, integrating people, technology, and processes. This includes employee training, the use of innovative technologies, and the implementation of policies and procedures in the areas of Information Security, Data Governance, Business Continuity and Disaster Recovery, Privacy, Third-Party Risk Management, and Incident Response. Core activities supporting our strategy include cybersecurity training, technology optimization, threat intelligence, vulnerability and patch management and the testing of incident response, business continuity and disaster recovery capabilities. The Company engages third-party consultants and independent auditors to, among other things, conduct penetration tests and audits of the areas noted above, including cybersecurity-related vendors.


text: The Board of Directors designated the Chief Information Officer as the Information Security Officer (the "ISO") and for oversight, the full Board receives threat intelligence reports and a Cybersecurity Executive Dashboard from the ISO each month. The ISO has more than thirty years' experience with the Company and meets with full Board of Directors in person at least annually. The ISO works with the Company's third-party Security Operations Center and the Company's Compliance/Enterprise Risk Management ("ERM") Team to identify, assess, and manage material risks from cybersecurity threats. The ISO also oversees the Company's Information Security Program, which governs various information security and cybersecurity processes, systems development, change control, disaster recovery/business continuity, physical asset classification and control policies. The Information Security Program identifies data sources, threats, and vulnerabilities and ensures awareness, accountability, and oversight for data protection throughout the Company and with trusted third parties to ensure that data is protected and able to be recovered in the event of a breach or failure (technical or other disaster). The ISO is a member of various management committees, including the quarterly Management Control meetings which serve as the Company's IT Steering Committee.


text: On a periodic basis, but not less than annually, the ISO in conjunction with the Compliance/ERM Team, identifies and documents internal and external vulnerabilities that could result in unauthorized disclosure, misuse, alteration, or destruction of customer information or customer records. Based on the results of the risk assessment, the Company's Information Security Program may be revised to protect against any anticipated threats or hazards to the security or integrity of such information. The Compliance/ERM Team reviews changes to the program designed to monitor, measure, and respond to vulnerabilities identified.


text: Response to Security Vulnerabilities In response to identified risks, management may take certain steps to correct and respond to security vulnerabilities, which may include: • Eliminating unwarranted risks by applying vendor-provided software fixes, commonly called patches. • Ensuring that changes to security configurations are documented, approved, and tested. • Ensuring that exploitable files and services are assessed and removed or disabled based upon known vulnerabilities and business needs. • Updating vulnerability scanning and intrusion detection tools to identify known vulnerabilities and related unauthorized activities. • Conducting subsequent penetration testing and vulnerability assessments, as warranted. • Reviewing performance with service providers to ensure security maintenance and reporting responsibilities are operating according to contract provisions and that service providers provide notification of system security breaches that may affect the Company.


text: Employees and Training Employees are an integral part in the line of defense against cybersecurity risks. Every employee is responsible for protecting Company and client information. Accordingly, employees complete formal training including regular simulated phishing assessments designed to sharpen threat detection and reporting capabilities. Our employees are supported with solutions designed to identify, prevent, detect, respond to, and recover from incidents. Notable technologies include firewalls, intrusion detection systems, managed endpoint security automation and response capabilities, user behavior analytics, multi-factor authentication when available, encrypted data backups, and business continuity applications. Notable services include 24/7 security monitoring and response, real-time vulnerability scanning, third-party monitoring, and threat intelligence.


text: Service Providers The Company relies on third-party vendor services and solutions to support its operations. Many of these vendors have access to sensitive and proprietary information. Third-party vendors continue to be a notable source of operational and informational risk. Accordingly, the Company has implemented an Outsourcing Management Policy which includes a detailed onboarding process and periodic reviews of vendors with access to sensitive Company data. The Outsourcing Management program is audited as part of the Company's external audit program.


text: At least annually, the ISO reports to the Board the overall status of the Information Security Program and the Company's compliance with the Interagency Guidelines for Safeguarding Customer Information. Any material findings related to the risk assessment, risk management and control decisions, service provider arrangements, results of testing, security breaches or violations are discussed as are management's responses and any recommendations for program changes.


text: Program Adjustments The ISO monitors, evaluates, and adjusts the Information Security Program considering any relevant changes in technology, the sensitivity of its customer information, internal or external threats to information, and changing business arrangements, such as mergers and acquisitions, alliances and joint ventures, outsourcing arrangements, and changes to customer information systems.


text: Incident Response Plan The Company has implemented an Incident Response Plan (the "IRP") to provide a structured and systematic incident response process for information security incidents that affect any of the information technology systems, network, or data. The Company's business continuity and disaster recovery programs provide a coordinated response when responding to incidents. The IRP is implemented and maintained by the ISO and is subject to annual review and approval by the Board. Cybersecurity metrics are reported to the board monthly.


text: The IRP includes: • Identifying the incident response team (the "IRT") and any appropriate sub-teams to address specific information security incidents, or categories of information security incidents. • Coordinating IRT activities, including developing, maintaining, and following appropriate procedures to respond to and document identified information security incidents. • Conducting post-incident reviews to gather feedback on information security incident response procedures and address any identified gaps in security measures. • Providing training and conducting periodic exercises to promote employee and stakeholder preparedness and awareness of the IRP. • Reviewing the IRP at least annually, or whenever there is a material change in the Company's business practices that may reasonably affect its cyber incident response procedures.


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 Chief Financial Officer 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: We have implemented cybersecurity practices appropriate for the size and complexity of our operations. Our IT systems are professionally managed, and access to Company data is restricted to authorized personnel using secure access protocols.

companyName: Paramount Gold Nevada Corp.

ticker: PZG


text: We take a proactive approach to managing cybersecurity risks. This includes regular updates to our systems, access controls, and training programs to help employees recognize and avoid phishing, spam, and other common cyber threats.


text: To date, we have no t experienced any material cybersecurity incidents. We continue to monitor evolving threats and adjust our practices as necessary to help protect our systems, data, and operations.


text: We recognize the importance cybersecurity has to the success of our business, as well as recognize the need to continually assess cybersecurity risks and evolve our responses in the face of a rapidly and ever-changing environment. Accordingly, we aim to protect our business operations, records and information against known and evolving cybersecurity threats.

companyName: Lite Strategy, Inc.

ticker: LITS


text: Risk Management and Strategy We have established policies and processes for assessing, identifying and managing material risk from cybersecurity threats and have integrated these processes into our overall risk management systems and processes. We routinely assess material risks from cybersecurity threats, including any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality, integrity, or availability of our information systems or any information residing within these systems.


text: We conduct periodic risk assessments to identify cybersecurity threats, as well as assessments in the event of a material change in our business practices that may affect information systems that are vulnerable to such cybersecurity threats. These risk assessments include identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that could result from such risks and the sufficiency of existing policies, procedures, systems and safeguards in place to manage such risks.


text: Following these risk assessments, we re-design, implement and maintain reasonable safeguards to minimize identified risks, reasonably address any identified gaps in existing safeguards and regularly monitor the effectiveness of our safeguards. Primary responsibility for assessing, monitoring and managing our cybersecurity risks rests with the Senior Director, Information Security and Infrastructure who reports to our Acting Chief Executive Officer and Chief Financial Officer to manage the risk assessment and mitigation process.


text: As part of our overall risk management system, we monitor and test our safeguards and train our employees on these safeguards, in collaboration with our Information Technology department. Personnel at all levels and departments are made aware of our cybersecurity policies through trainings and internal communications.


text: If required, we engage consultants, or other third parties in connection with our risk assessment processes. These service providers, where appropriate, assist us in the assessment, testing or other aspects of our security controls to help identify material cybersecurity risks to our critical systems, information, products, services and our broader enterprise IT environment, as well as assist us in designing and implementing our cybersecurity policies and procedures.


text: We have not encountered cybersecurity challenges that have materially impaired our operations or financial standing. For additional information regarding risks from cybersecurity threats, please refer to Item 1A, "Risk Factors," in this annual report on Form 10-K.


text: Cybersecurity Governance Our Board considers cybersecurity risk as part of its risk oversight function and has delegated oversight of cybersecurity and other information technology risks to the Audit Committee. The Audit Committee oversees management's implementation of our cybersecurity risk management program and is responsible for monitoring and assessing strategic risk exposure, while our management team is responsible for the day-to-day operations over the material risks we face. Our management team, including our Acting Chief Executive Officer and Chief Financial Officer and Senior Director, Information Security and Infrastructure, provide periodic briefings to the Audit Committee regarding our cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, if applicable.


text: The Audit Committee receives annual reports from management on our cybersecurity risks. In addition, management updates the Audit Committee, as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential.


text: The Audit Committee reports to the full Board regarding its activities, including those related to cybersecurity. The full Board also receives briefings from management on our cyber risk management program, in the discretion of the Board and management. Board members may receive presentations on cybersecurity topics from external experts as part of the Board's continuing education on topics that impact public companies.


text: Our Acting Chief Executive Officer, CFO and Senior Director, Information Security and Infrastructure, are responsible for assessing and managing our material risks from cybersecurity threats and have decades of experience in overseeing operations, including information technology functions, in the public company environment. The team has primary responsibility for our overall cybersecurity risk management program and supervises our retained external cybersecurity consultants as needed.


text: Our management team supervises cybersecurity risk management efforts to prevent, detect, mitigate,and remediate cybersecurity risks and incidents through various means, which may include briefings from external consultants engaged by us; threat intelligence and other information obtained from governmental, public or private sources; and alerts and reports produced by security tools deployed in the IT environment. The cybersecurity risk management program also includes tools and activities to prevent, detect and analyze current and emerging cybersecurity threats and plans and strategies to address threats and incidents.


text: The Trust does not have a board of directors; therefore, the Trustee is responsible for oversight of the Trust’s risks from cybersecurity threats. The Trustee has dedicated personnel responsible for assessing and managing the Trust’s cyber risk management program, informing senior management of the Trustee regarding the prevention, detection, mitigation, and remediation of cybersecurity incidents and supervising such efforts. The Trustee’s information technology team has decades of experience selecting, deploying, and operating cybersecurity technologies, initiatives, and processes, and relies on threat intelligence as well as other information obtained from governmental, public or private sources, including external consultants engaged by the Trustee to monitor the prevention, detection, mitigation, and remediation of cybersecurity incidents. External partners are a key part of the Trustee’s cybersecurity protocols and policies. The Trustee works with leading firms in the cybersecurity industry, leveraging their technology and expertise to monitor and maintain the performance and effectiveness of products and services that are used by the Trustee.

companyName: MARINE PETROLEUM TRUST

ticker: MARPS


text: The Trustee maintains a cyber risk management program designed to identify, assess, manage, mitigate, and respond to cybersecurity threats, which processes are integrated into the Trustee’s overall risk management process. The Trustee maintains robust cybersecurity protocols including, but not limited to technological capabilities that prevent and detect disruptions; computer workstations and programs protected with passwords and passphrases, as well as employee training throughout the year on financial regulations and cybersecurity followed up by testing of that knowledge. The protocols are based on recognized best practices and standards for cybersecurity and information technology. The Trustee has an annual assessment, performed by a third party vendor, of the Trustee’s cyber risk management program.


text: Other non-technical protocols include securing of documents and work areas that could contain personal, non-public information and independent verification of information changes by outside vendors.


text: The Trust faces risks from cybersecurity threats that could have a material adverse effect on its business, financial condition, results of operations, cash flows or reputation. The Trustee has experienced, and will continue to experience, cyber incidents in the normal course of its business. However, prior cybersecurity incidents have not had a material adverse effect on the Trust’s business, financial condition, results of operations, or cash flows. See Item 1A “Risk Factors – Risks Related to Units – The Trustee may be subject to attempted cybersecurity disruptions from a variety of sources including state-sponsored actors.”


text: Our risk management program is designed to identify, assess and mitigate risks across various aspects of our company, including financial, operational, regulatory, reputational and legal. Cybersecurity is a critical component of this program as we rely extensively on various information systems and other electronic resources to operate our business. Additionally, we rely to a great extent on third-party service providers to perform critical functions to assist in maintaining customer accounts, providing electronic banking services and financial reporting. Our Information Security Officer, who is a member of our Executive Management Team, is primarily responsible for managing our cybersecurity program. Our Information Security Officer has direct access to our Board of Directors and is authorized to evaluate our cybersecurity posture throughout the Company to ensure the implementation of appropriate controls over our systems and applications to maintain an effective cybersecurity program. The information security officer consults, where appropriate, with both our staff of IT professionals and, at times, outside security professionals to ensure the implementation of appropriate controls.

companyName: SR Bancorp, Inc.

ticker: SRBK


text: We have implemented a cybersecurity risk management program to protect the confidentiality, integrity and availability of our information and information technology environment. Our cybersecurity risk management program consists of an extensive range of risk assessments to identify the cyber threats to our environment along with multiple policies and procedures to mitigate the risks identified, including, but not limited to, information technology and cybersecurity standards, incident response and disaster recovery/business continuity. Employees receive regular information and cybersecurity training and reminders throughout the year.


text: Daily operations are monitored by a dedicated team of information technology professionals complemented by management's monitoring of critical information security monitoring reports along with our third-party security vendor who provides for 24x7 monitoring of our external connections and email system. Defined incident response procedures are maintained, including a requirement that our security vendor notify designated members of management when unusual or suspicious activity is identified.


text: To test and evaluate the effectiveness of our cybersecurity program, we are subject to annual audits of our program by an outside audit firm who specializes in both information technology and cybersecurity assessments. These assessments include a review of general IT controls, external penetration assessments, internal penetration assessments and security awareness testing of our staff.


text: Our vendor management program is designed to identify the risks associated with using third-party service providers to run our business. Third-party service providers that present cyber risk to our operations must meet specific criteria, such as the maintenance of appropriate controls, processes and monitoring to ensure the confidentiality, integrity and availability of data and resources prior to being onboarded. In addition to initial assessments of our critical third-party service provides, we perform regular on-going monitoring of these critical third parties' infrastructure and performance, including data security and the effectiveness of their cybersecurity risk management programs.


text: Our Board of Directors, along with our Information Technology Committee, which is comprised of key members of senior management, are actively involved in providing oversight of our cybersecurity program. Monthly updates are provided to our Board regarding the status of our program, including key monitoring metrics and trends noted both internally and within our industry. Our Board reviews and approves all cybersecurity-related risk assessments, polices and formalized reviews performed throughout the year.


text: Description of Processes for Assessing, Identifying, and Managing Cybersecurity Risks Cybersecurity is integrated within the Company's Enterprise Risk Management process, which is the Company's systematic approach to identifying, managing and assessing major risk and safeguards, including cybersecurity. We have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information.

companyName: 5E Advanced Materials, Inc.

ticker: FEAM


text: Our cybersecurity risk management program is integrated into our overall risk management program, and shares common methodologies, reporting channels and governance processes that apply across the risk management program to other legal, compliance, strategic, operational, and financial risk areas. Despite our efforts we put into maintaining a high level of cybersecurity, there can be no assurance that our cybersecurity risk management program and processes, including our policies, controls or procedures, will be fully implemented, complied with or effective in protecting our systems and information.


text: We periodically conduct assessments of cybersecurity risks to identify potential vulnerabilities and threats to our systems and data. These risk assessments are designed to help identify material risks from cybersecurity threats to our critical systems and information.


text: We have established a security team which is principally responsible for managing (i) our cybersecurity risk assessment processes, (ii) our security controls, and (iii) our response to cybersecurity incidents.


text: Protection Measures We implement and maintain cybersecurity controls, including firewalls, access controls, and intrusion detection systems, to safeguard our systems and data from unauthorized access, use, or disclosure. Furthermore, we use external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security processes.


text: Incident Detection and Response We have established a cybersecurity incident response plan that includes procedures for responding to relevant cybersecurity incidents. These protocols include incident response plans and escalation procedures to minimize the impact of potential breaches.


text: Cybersecurity Training and Awareness All new hires receive cybersecurity awareness training. All employees, including incident response personnel and senior management, receive periodic training and are periodically subject to evaluations to confirm their cybersecurity knowledge and awareness.


text: Third-Party Risk Management We have implemented a third-party risk management process for key service providers based on our assessment of their criticality to our operations and respective risk profile.


text: Material Cybersecurity Incidents 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. 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 "Risk Factors" within this report when evaluating our business and related risk.


text: Cybersecurity Governance The Board of Directors is responsible for overseeing cybersecurity, information security, and information technology risks, as well as management's actions to identify, assess, mitigate, and remediate those risks. As part of its program of regular risk oversight, the Audit Committee assists the Board of Directors in exercising oversight of the Company's cybersecurity, information security, and information technology risks. Periodically, the Audit Committee reviews and discusses with the Chief Financial Officer, who leads our cybersecurity program, the Company's policies, procedures, and practices with respect to cybersecurity, information security and information and operational technology, including related risks.