heading: Cybersecurity Governance

body_start: As described above, ACRES has engaged a third-party IT firm


heading: Cybersecurity Risk Management and Strategy

body_start: Our cybersecurity risk management strategy focuses on severa


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy


heading: Cybersecurity Governance

body_start: The Board of Directors maintains overall oversight of cybers


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: We have processes in place for assessing, identifying, and m


heading: Governance

body_start: Related to Cybersecurity Risks The Audit Committee of our Bo


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Risk Management and Strategy

body_start: Our risk management program is designed to identify, assess,


heading: Board of Directors Oversight

body_start: The Risk Committee of our board of directors is responsible


heading: Risk Management and Strategy

body_start: We regularly assess risks from information security threats,


heading: Risk Management and Strategy

body_start: We have established a cybersecurity committee to oversee the


body_start: We have developed and implemented a cybersecurity risk manag


heading: Risk Management and Strategy

body_start: We have certain processes and policies in place to assess, i


heading: Risk Management and Strategy

body_start: Our cybersecurity strategy prioritizes detection, analysis a


heading: Risk Management and Strategy

body_start: As one of the critical elements of the Company's overall ERM


heading: Management's Role in Assessing and Managing

body_start: Risks from Cybersecurity Threats The CISO, in coordination w


heading: Risk Management and Strategy

body_start: We have implemented and maintain a comprehensive information


body_start: Effect of Risk We face risks related to cybersecurity such a


body_start: We recognize the importance of maintaining the safety and se


heading: Cybersecurity Governance

body_start: Our Board is responsible for overseeing our enterprise risk


heading: Governance

body_start: Related to Cybersecurity Risks Our cyber risk management pro


heading: Governance

body_start: Related to Cybersecurity Risks Our board has final oversight


heading: Cybersecurity Program

body_start: Given the importance of cybersecurity to our business, we ma


body_start: The Company has implemented information security programs to


heading: Governance

body_start: Related to Cybersecurity Risks Our board of directors is inv


body_start: Our processes to identify, assess, and manage risks presente


heading: Risk Management and Strategy

body_start: The goal of our cybersecurity risk management strategy is to


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Cybersecurity Governance

body_start: One of the key functions of our Board of Directors is inform


heading: Risk management and strategy

body_start: We have established and maintain various information securit


body_start: As an externally managed REIT, the Company's risk management


heading: Cybersecurity Governance

body_start: The AGM board of directors' oversight of cybersecurity risk


heading: Cybersecurity Governance

body_start: Our Head of Information Technology ("Head of IT") is respons


heading: Cybersecurity Risk Management

body_start: We operate in a highly regulated industry that requires the


heading: Cybersecurity Governance

body_start: Our board of directors oversees our biennial enterprise risk


heading: Risk Management and Strategy

body_start: We support a risk-based cybersecurity program with control a


heading: Risk Management and Strategy

body_start: The Company maintains robust processes for assessing, identi


heading: Risk Management and Strategy

body_start: Our policies for Cybersecurity and the Safeguarding of Data,


heading: Third-Party Risk Management

body_start: Any new organization or party that we show interest in estab


body_start: We utilize third party cybersecurity consultancy firms to ma


heading: Management's Role

body_start: Our CTO and Chief Compliance Officer have primary responsibi


heading: Risk Management and Strategy

body_start: Management of cybersecurity risks is an integral part of our


heading: Risk Management and Strategy

body_start: Based on the complex and continuously evolving cybersecurity


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Cybersecurity risk management and strategy

body_start: As one of the elements of the Company's overall risk managem


body_start: Effect of Risk We face risks related to cybersecurity such a


heading: Risk Management and Strategy

body_start: Talkspace recognizes the importance of assessing, identifyin


heading: Cybersecurity Governance

body_start: Cybersecurity is an important part of our risk management pr


heading: Risk Management and Strategy

body_start: We continue to make significant investments in our informati


heading: Risk Management and Strategy

body_start: As one of the critical elements of the Company's overall ris


body_start: We have implemented a cybersecurity risk management program,


heading: Risk management and strategy

body_start: We recognize the critical importance of developing, implemen


heading: Board of Directors Oversight

body_start: The Audit Committee of the Board (the "Audit Committee") is


heading: Risk Management Personnel

body_start: Primary responsibility for assessing, monitoring and managin


heading: Board of Directors Oversight

body_start: The Audit Committee of the Board of Directors is tasked with


heading: Risk Management and Strategy

body_start: Our cybersecurity management process is based on an internal


heading: Risk management and strategy

body_start: The Company has implemented and maintain various information


body_start: Our cybersecurity and data protection strategy is part of ou


heading: Cybersecurity Governance

body_start: The Audit Committee of our Board of Directors reviews risks


body_start: As an externally managed BDC, our risk management function,


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Risk management and strategy


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Cybersecurity Governance

body_start: Cybersecurity is an important part of our enterprise risk ma


heading: Risk Management and Strategy

body_start: Enterprise risk management is the responsibility of our exec


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Audit Committee of the Board of Directors has oversight


body_start: Our enterprise risk management program is designed to identi


heading: Board of Directors Oversight

body_start: The Board of Directors is charged with overseeing the establ


heading: Management's Role

body_start: The Information Security department is responsible for imple


heading: Risk Management and Strategy

body_start: As one of the critical elements of our overall risk manageme


heading: Governance

body_start: As discussed in more detail under the heading "Governance" b


heading: Incident Response and Recovery Planning

body_start: We have established and maintained comprehensive incident re


heading: Third-Party Risk Management

body_start: We maintain a comprehensive, risk-based approach to identify


heading: Cybersecurity Threats

body_start: As of the date of this Annual Report on Form 10-K, we do not


heading: Cybersecurity Governance

body_start: One of the key functions of our board of directors is inform


heading: Governance

body_start: Related to Cybersecurity Risks Our Vice President, Head of I


heading: Risk Management and Strategy

body_start: The Company recognizes the importance of developing, impleme


heading: Risk Management Personnel

body_start: Primary responsibility for assessing, monitoring, and managi


heading: Risk Management and Strategy

body_start: We employ a defense-in-depth approach with systems and proce


heading: Incident Response

body_start: We have adopted a Cybersecurity Incident Response Plan (the


heading: Risk management and strategy

body_start: We have implemented and maintain policies and processes desi


body_start: The Company has processes in place for assessing, identifyin


body_start: Information about cybersecurity risks and our risk managemen


heading: Cybersecurity Governance

body_start: Cybersecurity risk is part of management's risk oversight, a


heading: Governance

body_start: Related to Cybersecurity Risks Our board of directors holds


body_start: Our cybersecurity program is informed by industry standards


body_start: To help protect the Company from a major cybersecurity incid


heading: Risk management and strategy

body_start: We recognize the importance of developing, implementing and


heading: Board of Directors Oversight

body_start: Our Board of Directors is aware of the critical nature of ma


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy

body_start: As part of the ongoing maintenance and development of our IS


heading: Risk Management and Strategy

body_start: The Company's Information Technology team has established an


heading: Governance

body_start: Related to Cybersecurity Risks Management is responsible for


body_start: In an effort to protect our business from cybersecurity thre


heading: Cybersecurity Governance

body_start: Our Board of Directors has delegated responsibility for over


heading: Governance and Oversight

body_start: The governance structure for the Global Cybersecurity and Te


heading: Risk Management and Strategy

body_start: Our policies, standards, processes and practices for assessi


heading: Incident Response and Recovery Planning

body_start: We have established comprehensive incident response and reco


heading: Third-Party Risk Management

body_start: We have implemented processes designed to identify and mitig


heading: Risk Management and Strategy


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


body_start: Effect of Risk We face risks related to cybersecurity such a


body_start: We have certain processes for assessing, identifying and man


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk as part


heading: Governance

body_start: Related to Cybersecurity Risks Our Senior Director of Inform


heading: Risk management and strategy


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


body_start: As part of our enterprise risk management process, we have a


heading: Cybersecurity Governance

body_start: The Board of Directors has delegated oversight of the Compan


heading: Risk Management

body_start: Strategy and Governance The Fund is externally managed by th


heading: Governance

body_start: Related to Cybersecurity Risks Our board of directors, as a


heading: Governance

body_start: Related to Cybersecurity Risks Our Head of Information Techn


heading: Risk Management and Strategy

body_start: We regularly utilize information technology and data to oper


heading: Risk Management and Strategy

body_start: As a company externally managed by the Advisor, we rely on S


heading: Cybersecurity Governance

body_start: Our Audit Committee of the Board of Directors has oversight


body_start: We recognize the importance of assessing, identifying, and m


heading: Cybersecurity Governance

body_start: Cybersecurity is an important part of our risk management pr


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy

body_start: We continuously monitor our information systems to assess, i


heading: Risk Management and Strategy

body_start: We recognize the critical importance of maintaining the trus


body_start: The Company's cybersecurity framework encompasses a proactiv


heading: Governance and Oversight

body_start: Cybersecurity governance at the Company involves executive a


heading: Risk Management and Strategy

body_start: We take a risk-based approach in implementing and maintainin


heading: Cybersecurity Governance

body_start: Cybersecurity is an important part of our overall risk manag


heading: Risk management and strategy


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: Our policies, standards, processes and practices for assessi


heading: Incident Response and Recovery Planning

body_start: We have established comprehensive incident response and reco


heading: Third-Party Risk Management

body_start: We have implemented processes designed to identify and mitig


heading: Cybersecurity Governance

body_start: The Company has established an Information Technology Steeri


body_start: Effect of Risk We face risks related to cybersecurity such a


body_start: We rely on information systems and the data stored on them t


heading: Risk Management and Strategy

body_start: The General Partner has written plans, procedures and polici


heading: Risk Management and Strategy

body_start: We have developed and implemented cybersecurity risk managem


heading: Risk Management and Strategy

body_start: We rely on the cybersecurity policies and procedures impleme


heading: Risk Management

body_start: The Company established an Enterprise Risk Management (ERM)


heading: Cybersecurity

body_start: The Company employs a "defense in depth" approach to providi


heading: Risk Management and Strategy

body_start: The Company's cybersecurity program is designed to identify,


heading: Incident Response and Recovery Planning

body_start: We have established and maintain comprehensive incident resp


heading: Third-Party Risk Management

body_start: We maintain a risk-based approach to identifying cybersecuri


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Risk management and strategy

body_start: Due to the size of our company, we have not yet developed ro


heading: Risk Management and Strategy

body_start: As one of the critical elements of our overall ERM approach,


heading: Board of Directors Oversight

body_start: The Audit Committee of the Board of Directors (the "Audit Co


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


body_start: The Company, under the oversight of the audit committee of t


heading: Cybersecurity Program

body_start: Oversight and Governance Our Head of Information Technology


heading: Risk Management and Strategy

body_start: Information Technology and the Digital Transformation of the


body_start: We have developed and implemented a cybersecurity risk manag


heading: Risk Management and Strategy

body_start: The Company recognizes the importance of assessing, identify


heading: Risk Management and Strategy

body_start: The Company utilizes information systems to support a variet


body_start: We recognize the importance of assessing, identifying, and m


heading: Governance

body_start: Related to Cybersecurity Risks Our Vice President, Informati


heading: Risk management and strategy

body_start: We have implemented a risk-based approach designed to identi


heading: Governance

body_start: Related to Cybersecurity Risks Our cybersecurity risk manage


heading: Governance

body_start: Related to Cybersecurity Risks Our cyber risk management pro


heading: Risk Management and Strategy

body_start: We have certain processes for assessing, identifying and man


heading: Risk Management and Strategy

body_start: As part of the critical elements of our overall risk managem


heading: Third-Party Risk Management

body_start: We also maintain procedures designed to identify and mitigat


heading: Incident Response and Recovery Planning

body_start: We have an information security incident response process to


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


body_start: We have implemented cybersecurity risk management procedures


heading: Cybersecurity Governance

body_start: Our cybersecurity program is managed and directed by our Hea


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk part of


body_start: We have implemented a cybersecurity program in accordance wi


heading: Governance

body_start: Related to Cybersecurity Risks Our Head of Information Techn


heading: Risk Management and Strategy

body_start: The Company has processes in place to assess, identify, and


heading: Risk Management and Strategy

body_start: We recognize the importance of developing, implementing and


heading: Management's Role in Assessing and Managing Cybersecurity Risks

body_start: Our CEO in conjunction with our external IT team are respons


body_start: The Adviser's cybersecurity risk management strategy focuses


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: The Trust's cybersecurity risk management is established and


heading: Governance

body_start: The REIS Policy has been drafted in collaboration with one o


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Risk Management and Strategy


body_start: We recognize the importance of assessing, identifying, and m


heading: Cybersecurity Governance

body_start: Our Head of Information Technology, who reports directly to


body_start: Candel has implemented cybersecurity risk management process


heading: Cybersecurity Governance

body_start: The board of directors has delegated oversight of the Compan


heading: Risk Management and Strategy

body_start: We have established policies and processes designed to asses


body_start: The Company maintains a cybersecurity program designed to de


heading: Cybersecurity Governance

body_start: Our Board of Directors is focused on cyber security. Specifi


body_start: As a corporation committed to maintaining the integrity, con


heading: Risk Management and Strategy

body_start: Our information security program is still in its early devel


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy

body_start: We regularly assess risks from cybersecurity threats; monito


body_start: Our process for managing cybersecurity risk is comprised of


heading: Cybersecurity Governance

body_start: Cybersecurity is an important part of our risk management pr


heading: Risk Management and Strategy

body_start: We recognize the critical importance of developing, implemen


body_start: We have policies, procedures, and processes for assessing, i


heading: Risk management and strategy

body_start: We have implemented and maintain information security proces


heading: Risk Management and Strategy

body_start: As of December 31, 2023, we have implemented thorough cybers


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Cybersecurity Risk Management

body_start: The Company has processes for identifying, assessing, and ma


heading: Risk management and strategy


heading: Board of Directors Oversight

body_start: The Audit Committee is central to the Board's oversight of c


heading: Risk Management Personnel

body_start: Primary responsibility for assessing, monitoring and managin


body_start: The Adviser has implemented policies and associated controls


heading: Risk Management and Strategy

body_start: Cantor's global cybersecurity processes form the comprehensi


heading: Incident Response and Recovery Planning

body_start: The Company has implemented and maintains detailed incident


heading: Risk Management and Strategy

body_start: Our risk management program is designed to identify, assess,


body_start: The Company maintains an enterprise-wide and Board-approved


heading: Cybersecurity Governance

body_start: The Company has established an Information Security Committe


body_start: As an externally managed closed-end management investment co


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Risk Management and Strategy

body_start: Our policies, standards, processes and practices for assessi


heading: Incident Response and Recovery Planning

body_start: We have established comprehensive incident response and reco


heading: Third-Party Risk Management

body_start: We have implemented processes designed to identify and mitig


body_start: In recognition of the evolving cybersecurity threat landscap


heading: Cybersecurity Governance

body_start: Senior management, including the Chief Executive Officer and


heading: Cybersecurity Risk Management Program

body_start: Our Cybersecurity Risk Management Program is informed by the


heading: Cybersecurity

body_start: Incidents and Responses We have not experienced cybersecurit


body_start: We have developed and implemented cybersecurity risk managem


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: We have an enterprise-wide information security program desi


heading: Risk Management and Strategy

body_start: Cybersecurity risks are constantly evolving and becoming inc


heading: Governance and Oversight

body_start: The Board of Directors, including its Risk Subcommittee prov


heading: Risk Management and Strategy

body_start: We continue to assess and improve the capabilities of our pe


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Program

body_start: We have implemented a cybersecurity program to support both


body_start: We recognize the importance of assessing, identifying and ma


heading: Cybersecurity Governance

body_start: Our Board of Directors considers cybersecurity risk and othe


body_start: The Adviser's cybersecurity risk management strategy focuses


heading: Risk management and strategy

body_start: We rely on our information technology to operate our busines


heading: Risk Management and Strategy

body_start: We are committed to safeguarding the personal information of


body_start: Our cybersecurity risk management strategy and processes, wh


heading: Risk management and Strategy

body_start: We have implemented several cybersecurity processes and cont


heading: Cybersecurity Governance

body_start: As described above, we have engaged a third-party IT and cyb


heading: Risk Management and Strategy

body_start: We have developed and implemented cybersecurity risk managem


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Cybersecurity Governance

body_start: It is management's responsibility to manage cybersecurity ri


heading: Risk Management and Strategy

body_start: We recognize the importance of assessing, identifying, and m


heading: Risk Management and Strategy

body_start: We have developed a cybersecurity program intended to protec


heading: Risk Management and Strategy

body_start: As one of the critical elements of the Company's overall ERM


heading: Risk Management and Strategy

body_start: The Company relies on information systems and the data store


heading: Risk Management and Strategy

body_start: Our company is guided by a comprehensive cybersecurity frame


heading: Risk Management

body_start: Governance and Strategy We recognize the importance of asses


body_start: Our executive team and board of directors recognize that eff


heading: Cybersecurity Governance

body_start: Our board of directors has ultimate oversight of our risk ma


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management

body_start: Approach and Strategy Our corporate information technology,


heading: Risk Management and Strategy


heading: Risk Management and Strategy

body_start: The Company recognizes the critical importance of developing


heading: Management's Role in Assessing and Managing Cybersecurity Risk

body_start: The Chief Operating Officer of ExchangeRight (the "COO") ove


body_start: We have made substantial investments in cybersecurity risk m


heading: Cybersecurity Governance

body_start: Our management, including our Chief Executive Officer ("CEO"


heading: Risk Management and Strategy

body_start: The Company employs an IT Security Team that is responsible


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Cybersecurity Governance

body_start: Our Board of Directors and management prioritize cybersecuri


heading: Risk Management and Strategy

body_start: At a high level, the key objectives for the Company's cybers


heading: Incident Response and Recovery Planning

body_start: We have established comprehensive incident response and reco


heading: Risk Management and Strategy

body_start: We are a clinical stage biopharmaceutical company, with no c


heading: Management's Role

body_start: Our VP IT leads our information technology and cybersecurity


heading: Board of Directors Oversight

body_start: Our board of directors has delegated oversight of our Cyber


heading: Risk Management and Strategy

body_start: Overview of Processes for Assessing, Identifying, and Managi


body_start: The Company is committed to, and recognizes the importance o


heading: Cybersecurity Governance

body_start: Our Board of Directors and Audit Committee are actively enga


heading: Risk Management and Strategy

body_start: Managing cybersecurity risks and securing our sensitive data


heading: Cybersecurity Governance

body_start: Our Board of Directors is responsible for oversight of risk


heading: RISK MANAGEMENT AND STRATEGY

body_start: The Company continues to make cybersecurity a priority as th


heading: Risk Management Personnel

body_start: The Company's cybersecurity risk management program is overs


heading: Board of Directors Oversight

body_start: The Audit Committee of the Company's Board is responsible fo


body_start: We recognize the importance of developing, implementing, and


heading: Cybersecurity Governance

body_start: As stated above, the Board of Directors and the Audit Commit


heading: Governance

body_start: As discussed in more detail under the heading "Governance" b


heading: Third-Party Risk Management

body_start: We review and evaluate material cybersecurity risks related


body_start: The Company's cybersecurity risk management strategy focuses


heading: Risk management and strategy

body_start: Our cybersecurity program is designed to safeguard our infor


heading: Cybersecurity Governance

body_start: The Board of Directors (the "Board") has risk oversight resp


heading: Risk Management and Strategy

body_start: We have developed and implemented cybersecurity risk managem


heading: Risk Management and Strategy

body_start: The Company regularly assesses risks from cybersecurity thre


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Risk management and Strategy

body_start: We have processes for assessing, identifying, and managing m


heading: Risk management and strategy

body_start: We depend on information systems and technology in substanti


heading: Risk Management and Strategy

body_start: We are committed to protecting the confidentiality, integrit


heading: Risk Management and Strategy

body_start: We manage cybersecurity risks as part of our broader enterpr


heading: Cybersecurity Governance

body_start: The FedEx Board of Directors has delegated to the Cyber and


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risks as part of its risk


heading: Risk Management and Strategy

body_start: The Company recognizes the critical importance of cybersecur


heading: Risk Management and Strategy

body_start: We utilize a combination of manual processes, specialized so


heading: Risk Management and Strategy

body_start: We have a comprehensive cybersecurity risk assessment progra


heading: Board of Directors Oversight

body_start: The Governance and Sustainability Committee of our Board of


heading: Management's Role

body_start: Our management team is primarily responsible for assessing a


heading: RISK MANAGEMENT AND STRATEGY

body_start: Microsoft plays a central role in the world's digital ecosys


heading: Risk Management and Strategy

body_start: We are focused on the growing threat of cybersecurity risks


body_start: We recognize the importance of establishing governance and o


heading: Cybersecurity Governance

body_start: This risk management approach informs decision-making proces


heading: Risk Management and Strategy

body_start: We rely upon information technology networks and systems to


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: The Company's cybersecurity program is part of its overall r


heading: Cybersecurity Governance

body_start: Pursuant to the Audit Committee Charter, the Audit Committee


heading: Risk Management and Strategy

body_start: As a part of the Company's overall risk management and compl


heading: Risk Management and Strategy

body_start: Our cybersecurity risk management program is part of our ove


body_start: The Company recognizes the critical importance of developing


heading: Cybersecurity Governance

body_start: Our Board of Directors considers cybersecurity risk as part


body_start: Our enterprise risk management framework considers cybersecu


heading: Cybersecurity Governance

body_start: Our Board of Directors has risk oversight responsibility for


heading: Cybersecurity

body_start: Processes and Risk Assessment We rely on the cybersecurity p


body_start: We have developed and implemented a cybersecurity risk manag


heading: Risk Management and Strategy

body_start: The Company's cybersecurity risk management program is integ


heading: Incident Detection and Response

body_start: We have established a cybersecurity incident response plan t


heading: Cybersecurity

body_start: Training and Awareness All new hires receive cybersecurity a


heading: Third-Party Risk Management

body_start: We have implemented a third-party risk management process fo


heading: Cybersecurity Governance

body_start: The Board of Directors is responsible for overseeing cyberse


heading: Risk Management and Strategy

body_start: Our processes for assessing, identifying, and managing cyber


body_start: We recognize the importance of information security practice


heading: Cybersecurity Governance

body_start: The Board has overall responsibility for risk oversight and


heading: Risk Management and Strategy

body_start: We recognize the importance of cybersecurity in safeguarding


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: We have developed and implemented cybersecurity risk managem


heading: Risk management and strategy

body_start: Our cybersecurity program has been designed to protect our o


heading: Risk Management and Strategy

body_start: Our cybersecurity program focuses on the following areas: •


heading: Risk Management and Strategy

body_start: Our cybersecurity program is designed to monitor and control


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk as part


heading: Risk Management and Strategy

body_start: We recognize the critical importance of effective cyber risk


body_start: Our cybersecurity risk management strategy is designed to de


heading: Cybersecurity Governance

body_start: Our CITO, who reports to our Chief Financial Officer, is res


body_start: Our Risks from Cybersecurity Threats Our Cybersecurity Progr


heading: Risk Management and Strategy

body_start: Ashland recognizes the importance of cybersecurity in safegu


heading: Risk Management and Strategy

body_start: Surmodics has adopted the National Institute of Standards an


heading: Risk Management and Strategy

body_start: As noted in Part I, Item IA, Risk Factors, Cabot recognizes


heading: Governance

body_start: Related to Cybersecurity Risks Our cybersecurity risk manage


body_start: We maintain a cybersecurity risk management program based up


heading: Cybersecurity Governance

body_start: Our cybersecurity program is ultimately overseen by the Boar


heading: Risk Management and Strategy

body_start: We have dedicated to advance our cybersecurity risk manageme


heading: Cybersecurity Governance and Oversight

body_start: The Board of Directors has assigned the Audit Committee to b


body_start: Our cybersecurity strategy prioritizes detection, analysis a


heading: Cybersecurity Governance

body_start: Our Board of Supervisors is responsible for overseeing our e


heading: Risk Management and Strategy

body_start: We have implemented a comprehensive information security pro


heading: Risk Management and Strategy

body_start: The Company maintains a cybersecurity risk management progra


heading: Risk Management and Strategy

body_start: The protection of our clients' data, our brand, and our syst


heading: Cybersecurity Governance

body_start: Board and Committee Oversight. Our Board of Directors is res


heading: Management's Role

body_start: Our Internal security team in conjunction with the Chief Tec


heading: Risk Management and Strategy

body_start: As one of the critical elements of enterprise-wide approach


heading: Governance

body_start: As discussed in more detail under the heading "Governance" b


heading: Incident Response and Recovery Planning

body_start: We have established and maintained comprehensive incident re


heading: Third-Party Risk Management

body_start: We maintain a comprehensive, risk-based approach to identify


heading: Cybersecurity Threats

body_start: As of the date of this Annual Report on Form 10-K, we do not


body_start: At Genasys, cybersecurity risk management is integrated into


body_start: We have implemented cybersecurity risk management procedures


heading: Cybersecurity Governance

body_start: Our cybersecurity program is managed and directed by our Vic


heading: Third-Party Risk Management

body_start: The Company maintains a risk-based approach to identifying a


heading: Cybersecurity Risk Management Program

body_start: We recognize the importance of maintaining the integrity of


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Cybersecurity Governance

body_start: One of the key functions of our board of directors is inform


body_start: As an externally managed REIT, our risk management function,


heading: Cybersecurity Governance

body_start: The AGM board of directors ' oversight of cybersecurity risk


heading: Risk management and strategy

body_start: The Company has a Cybersecurity Plan for assessing, identify


heading: Cybersecurity Risk Management

body_start: In the ordinary course of our business, we use, store and pr


heading: Risk Management and Strategy

body_start: As is the case for similar companies of our size and industr


heading: Risk Management and Strategy

body_start: Our enterprise risk management program, which includes cyber


heading: Incident response

body_start: We employ a formal process to identify, track, prioritize an


heading: Governance

body_start: Related to Cybersecurity Risks Board oversight: Our board of


heading: Management's role in assessing and managing cybersecurity risk

body_start: Our risk management program for cybersecurity is led by the


heading: Risk Management and Strategy

body_start: In the ordinary course of our business, we collect and store


heading: Governance and Oversight

body_start: We have a multi-layered information security governance fram


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: We understand the importance of identifying, assessing, and


body_start: We collect, use and store personal information of our employ


body_start: As an externally managed closed-end management investment co


heading: Risk management and strategy

body_start: We have an enterprise-wide information security program desi


heading: Risk Management and Strategy

body_start: We have developed and implemented a cybersecurity risk manag


heading: Management and Board Oversight

body_start: Our Board of Directors actively considers cybersecurity risk


body_start: The Company's cybersecurity risk management strategy focuses


heading: Risk Management and Strategy

body_start: Cybersecurity is a critical component of the Company's ERM p


heading: Governance

body_start: The Board provides oversight of the ERM process and reviews


heading: Risk Management and Strategy

body_start: We maintain an Enterprise Risk Management ("ERM") program to


heading: Cybersecurity

body_start: Governance and Risk Management Information security is a sig


heading: Risk Management and Strategy

body_start: We have developed an information security program intended t


body_start: The Company employs a tiered structure of management and ove


heading: Cybersecurity Governance

body_start: The Audit Committee of the Board is charged with overseeing


heading: Risk Management and Strategy

body_start: The Company has a robust cybersecurity program that has dire


heading: Risk management and strategy

body_start: We implement and maintain various information security proce


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk as part


heading: Risk Management and Strategy

body_start: We have processes in place for assessing, identifying and ma


heading: Governance

body_start: The company's board of directors (the "Board" or "Board of D


heading: Risk Management and Strategy

body_start: Our cybersecurity risk management program is focused on the


heading: Management's Role

body_start: Our Head of IT Risk, with the CTO's oversight, is primarily


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Cybersecurity

body_start: Governance and Responsibilities The Board recognizes that cy


heading: Third-Party Risk Management

body_start: The Company maintains a risk-based approach to identifying a


heading: Risk Management and Strategy

body_start: In the regular course of business, the Registrants handle a


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as critical to the en


heading: Risk Management and Strategy

body_start: The Company has developed an information security program to


heading: Governance

body_start: The Chief Technology Officer (CTO) is the management positio


heading: Risk Management and Strategy

body_start: Garmin has a cybersecurity risk management program, generall


heading: Board of Directors Oversight

body_start: Garmin's entire Board of Directors performs the risk oversig


body_start: As is the case for most companies, we are regularly subject


heading: Cybersecurity Governance and Oversight

body_start: The Audit Committee of our Board of Directors provides direc


heading: Risk Management and Strategy

body_start: The Company's cybersecurity program focuses on the following


body_start: Our cybersecurity risk management is integrated in our overa


heading: Cybersecurity

body_start: Governance and Risk Management Systems Our risk management s


body_start: Our Manager has developed and implemented a cybersecurity ri


heading: Cybersecurity Governance

body_start: Our Board has generally delegated the cybersecurity risk ove


heading: Risk Management and Strategy

body_start: As of December 31, 2024, we have implemented a set of compre


heading: Risk Management and Strategy

body_start: We recognize the importance of assessing, identifying, and m


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board of Directors considers cybersecurity risk as part


heading: Risk Management

body_start: Oversight and Governance The Board of Directors is responsib


body_start: Cybersecurity risk management for the Company is undertaken


heading: Management's Role

body_start: The Chief Information Security Officer (CISO) is responsible


heading: Board of Directors Oversight

body_start: Our Board, in coordination with the Audit and Risk Committee


heading: Risk Management and Strategy

body_start: The Company maintains robust and comprehensive processes, pr


heading: Risk Management and Strategy

body_start: Our cybersecurity risk management process is aligned with ou


heading: Cybersecurity Risk Management

body_start: We have implemented an information security program that is


heading: Cybersecurity Program

body_start: Our and our Manager's cybersecurity and related controls, po


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Incident Response

body_start: We maintain plans to address any cybersecurity incidents, in


heading: Risk Management and Strategy

body_start: The Company's processes for assessing, identifying, and mana


heading: Risk Management and Strategy

body_start: We have instituted policies and processes dedicated to asses


heading: Risk Management and Strategy

body_start: The Company maintains a cybersecurity risk management progra


heading: Governance

body_start: The Board of Directors is responsible for general oversight


heading: Risk Management and Strategy

body_start: We employ information systems to support our business. As is


heading: Risk Management and Strategy

body_start: The Trust's cybersecurity risk management is established and


body_start: As a component of our overall risk management system and pro


heading: Risk Management and Strategy

body_start: The Company's Information Security Program ("Program") uses


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance and Oversight

body_start: Our Board of Directors ("Board") considers cybersecurity ris


body_start: We recognize the importance of developing, implementing and


heading: Risk Management and Strategy

body_start: We and our customers and suppliers have an increasing relian


heading: Risk Management and Strategy

body_start: Our cybersecurity risk management processes have been integr


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Risk Management

body_start: Strategy and Governance The Company is externally managed by


body_start: We assess and identify security risk to the organization by:


heading: Risk Management and Strategy

body_start: The Company recognizes the importance of maintaining cyberse


heading: Cybersecurity

body_start: Roadmap and Risk Assessment We have a cybersecurity roadmap


heading: Incident Response and Recovery Planning

body_start: We have an established incident response and recovery plan b


heading: Third-Party Risk Management

body_start: We use a risk-based approach to identify and oversee cyberse


heading: Risk Management and Strategy

body_start: Our business operations and strategy are highly dependent on


heading: Cybersecurity Governance

body_start: The Company's entire Board of Directors is engaged in risk m


body_start: Cybersecurity is a key component of the Company's overall ri


heading: Governance

body_start: Related to Cybersecurity Risks Our audit committee of the bo


heading: Risk Management and Strategy

body_start: Our business depends on our continued ability to collect and


heading: Risk Management and Strategy

body_start: The Company has adopted an Enterprise Risk and Resilience Fr


heading: Management and Board Oversight

body_start: The Company's Board of Directors administers cybersecurity r


body_start: Saia maintains cybersecurity processes, technologies and con


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as critical to the en


heading: Cybersecurity Risk Management

body_start: The Company has systems and processes for identification, as


heading: Cybersecurity Governance

body_start: Our cybersecurity programs, including the cross-functional m


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


body_start: The Company actively maintains an enterprise risk management


heading: Governance

body_start: Our Board of Directors has responsibility for oversight of m


heading: Risk Management and Strategy

body_start: We have implemented cybersecurity programs designed to maint


heading: Governance

body_start: Related to Cybersecurity Risks Our Executive Director, IT &


heading: Governance

body_start: Related to Cybersecurity Risks The Board of Directors, as a


heading: Cybersecurity Governance

body_start: The Board of Directors (the "Board") recognizes the need for


body_start: Increased global cybersecurity vulnerabilities, threats and


heading: Risk Management and Strategy

body_start: Processes for Assessing, Identifying and Managing Material R


heading: Risk Management and Strategy

body_start: The Company engages in the periodic assessment and testing o


heading: Risk Management and Strategy

body_start: We have established a cybersecurity program intended to prot


heading: Risk Management and Strategy

body_start: We recognize the importance of assessing, identifying, and m


heading: Risk Management and Strategy

body_start: As one of the critical elements of the Company's overall ris


heading: Governance

body_start: As discussed in more detail under the heading "Governance,"


heading: Incident Response and Recovery Planning

body_start: The Company has established and maintains comprehensive inci


heading: Third-Party Risk Management

body_start: The Company maintains a comprehensive, risk-based approach t


heading: Risk Management and Strategy


heading: Risk Management and Strategy

body_start: Key elements of our cybersecurity program include the follow


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


body_start: As an externally managed BDC, our risk management function,


heading: Risk Management and Strategy

body_start: We assess, identify and manage material risks from cybersecu


body_start: We rely heavily on information technology (IT) systems in al


heading: Cybersecurity Governance

body_start: The Company's Board of Directors has oversight of informatio


heading: Risk Management and Strategy

body_start: We recognize the critical importance of developing, implemen


heading: Risk Management and Strategy

body_start: We recognize that cybersecurity threats pose a risk to our b


heading: Risk Management and Strategy

body_start: We have implemented policies and processes to evaluate and m


heading: Risk management and strategy

body_start: We rely on IT networks and systems to process, transmit and


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board of Directors considers cybersecurity risk as part


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk as part


heading: Risk Management and Strategy

body_start: Our processes for assessing, identifying, and managing mater


heading: Board of Directors Oversight

body_start: Our Audit Committee is central to the Board's oversight of c


heading: Risk Management Personnel

body_start: Primary responsibility for assessing, monitoring and managin


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


body_start: We define information security and cybersecurity risk as the


heading: Cybersecurity Governance

body_start: Under our information security framework, our Board and our


heading: Risk management and strategy


heading: Board of Directors Oversight

body_start: The Board of Directors as a group is responsible for oversig


body_start: We recognize the importance of identifying and managing cybe


heading: Cybersecurity Governance

body_start: The Company's Board of Directors oversees the overall risk m


heading: Risk Management and Strategy

body_start: Cybersecurity risk is a direct responsibility of management


heading: Management's Role

body_start: The Information Security function is led by the Company's Di


heading: Risk Management and Strategy

body_start: As a component of the Company's overall risk management proc


heading: Governance

body_start: The Board's oversight of cybersecurity risk management is su


heading: Incident Response and Recovery Planning

body_start: Our Adviser has established and maintains comprehensive busi


heading: Third-Party Risk Management

body_start: Our Adviser maintains a comprehensive, risk-based approach t


heading: Governance

body_start: Related to Cybersecurity Risks The IT Director oversees and


heading: Risk Management and Strategy

body_start: We recognize the critical importance of developing, implemen


heading: Board of Directors Oversight

body_start: The Audit Committee is central to the Board's oversight of c


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


body_start: Protecting our data, which includes information related to o


heading: Governance of Cybersecurity

body_start: Cybersecurity is an integral part of our risk management pro


body_start: Our cybersecurity risk management strategy focuses on severa


heading: Risk management and strategy


body_start: As cyber criminals continue to become more sophisticated thr


heading: Governance of Cybersecurity

body_start: The Audit Committee of our Board of Trustees is responsible


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


body_start: We recognize the need to maintain the security and confident


heading: Risk Management and Strategy

body_start: The Company's cybersecurity risk management strategy is comp


heading: Risk management and strategy

body_start: We operate in the biopharmaceutical sector, which is a highl


heading: Risk Management Personnel

body_start: Our Information Technology personnel responsible for cyberse


body_start: The Company's information security program is designed to pr


heading: Cybersecurity Governance

body_start: Our Board of Directors is responsible for overseeing the Com


body_start: The Company has processes for assessing, identifying, and ma


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk as part


heading: Risk Management and Strategy

body_start: As one of the critical elements of the Company's overall ris


body_start: In an effort to protect our business from cybersecurity thre


heading: Cybersecurity Governance

body_start: Our Board of Directors has delegated responsibility for over


heading: Governance

body_start: Related to Cybersecurity Risks Under the ultimate direction


heading: Risk Management and Strategy


heading: Risk Management and Strategy

body_start: In the ordinary course of our business, we collect, use, sto


heading: Management's Role in Assessing and Managing Material Risks

body_start: Our technology team, and particularly our information securi


heading: Risk Management Personnel

body_start: Among management, our Chief Information Security Officer ("C


heading: Risk Management and Strategy

body_start: In an effort to reduce the likelihood and severity of cyber


body_start: The Company is externally managed by the Advisor and has no


heading: Cybersecurity Governance

body_start: The Board of Directors of the Company periodically receives


heading: Governance

body_start: Related to Cybersecurity Risks Our Head of Information Techn


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board, including the Governing Body, considers cybersecu


heading: Board of Directors Oversight

body_start: The Audit Committee of the Board of Directors is responsible


heading: Risk Management and Strategy

body_start: The Company maintains a cyber risk management program to pre


heading: Risk Management and Strategy

body_start: The Company recognizes the critical importance of developing


heading: Risk Management and Strategy

body_start: We are committed to our goal to protect sensitive business-r


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: The cybersecurity program at Cars Commerce is part of our en


heading: Governance

body_start: The Board of Directors provides strategic guidance regarding


body_start: We have established policies and processes for identifying,


heading: Cybersecurity governance

body_start: One of the key functions of our board of directors is inform


body_start: We are committed to protecting the privacy and security of o


heading: Cybersecurity Governance

body_start: Our Board of Directors considers cybersecurity risk as part


heading: Risk Management and Strategy

body_start: As part of our overall approach to integrated risk managemen


heading: Risk Management and Strategy

body_start: Consistent with overall policies and practices, the Company'


heading: Risk Management and Strategy

body_start: We have processes in place for assessing, identifying, and m


body_start: Cybersecurity is an integral part of risk management at the


heading: Cybersecurity Governance

body_start: Our general partner's board of directors appreciates the rap


heading: Cybersecurity Risk Management

body_start: We assess, identify and manage material risks from cybersecu


heading: Cybersecurity Governance

body_start: The Audit Committee of the Company's Board of Directors (the


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Governance

body_start: Related to Cybersecurity Risks Our board of directors is res


heading: Risk management and strategy


heading: Cybersecurity Strategy and Risk Management

body_start: Our Cybersecurity and Technology Risk Program (the "Program"


heading: Risk Management and Strategy

body_start: We recognize the importance of developing, implementing, and


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Risk Management and Strategy

body_start: The Company has processes in place to assess, identify, and


heading: Risk Management and Strategy

body_start: We have implemented and maintain a comprehensive information


heading: Risk management and strategy

body_start: Cytokinetics recognizes the critical importance of developin


heading: Board of Directors Oversight

body_start: The Audit Committee is central to the Board's oversight of c


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board of Directors and Audit Committee jointly oversee m


heading: Risk Management and Strategy

body_start: The Company's risk management program is designed to identif


body_start: We use the CIS benchmarks as a guideline to strengthen our c


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk as part


heading: Risk Management and Strategy

body_start: We have implemented procedures for assessing, identifying an


body_start: Effect of Risk We face risks related to cybersecurity such a


heading: Risk Management and Strategy

body_start: As one of the elements of the Company's overall ERM program,


heading: Risk Management and Strategy


heading: Risk Management and Strategy

body_start: The Company relies on information systems and the data store


heading: Cybersecurity Risk Management

body_start: Process We have developed and continue to enhance our cybers


heading: Cybersecurity Threats

body_start: We are not aware of any risks from cybersecurity threats tha


body_start: Our cybersecurity risk management strategy focuses on severa


heading: Risk Management and Strategy

body_start: Our Information Security Committee (the "ISC") oversees and


heading: Cybersecurity Governance

body_start: Our Information Security Officer is accountable for managing


heading: Risk management and strategy

body_start: The Company's Information Security strategy prioritizes dete


heading: Risk Management and Strategy

body_start: Primerica has processes in place aimed at assessing, identif


heading: Cybersecurity Risk Management Program

body_start: We regularly assess and identify potential cybersecurity ris


heading: Cybersecurity Governance and Oversight

body_start: Our Board, directly or through its committees, is responsibl


heading: Risk Management and Strategy

body_start: Premier's risk management program is designed to identify, m


heading: Risk Management and Strategy

body_start: As one of the critical elements of the Company's overall ERM


heading: Risk management and strategy

body_start: We implement and maintain various information security proce


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy

body_start: We believe that effective cybersecurity depends upon the suc


heading: Risk Management and Strategy

body_start: Our policies, standards, processes and practices for assessi


heading: Third-Party Risk Management

body_start: We have implemented controls designed to identify and mitiga


heading: Risk Management and Strategy

body_start: We have processes for assessing, identifying, and managing c


heading: Risk Management and Strategy

body_start: The goal of our cybersecurity risk management strategy is to


heading: Risk Management and Strategy

body_start: We recognize the critical importance of cybersecurity and da


heading: CYBERSECURITY RISK MANAGEMENT AND STRATEGY

body_start: We recognize the critical importance of maintaining the safe


heading: Cybersecurity Governance

body_start: Our Board of Directors is responsible for overseeing our ent


heading: Risk Management and Strategy

body_start: Our cybersecurity risk management program is designed to ide


body_start: The Company is externally managed by the Advisor and has no


heading: Cybersecurity Governance

body_start: The Board of Directors of the Company periodically receives


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


body_start: We utilize third party cybersecurity consultancy firms to ma


heading: Management's Role

body_start: Our CIO, who has 15 years experience in technology, has prim


heading: Risk Management and Strategy

body_start: We have implemented a set of comprehensive cybersecurity and


heading: Risk management and strategy

body_start: Cybersecurity risk management is an important and rapidly ev


heading: Risk Management and Strategy

body_start: The Company continuously seeks to identify threats, vulnerab


heading: Incident Response and Recovery Planning

body_start: The Company has established comprehensive incident response


body_start: The Fund is externally managed by the Advisers and has no em


heading: Cybersecurity Governance

body_start: The Board of Trustees of the Fund periodically receives repo


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


body_start: We have an established process led by our Chief Information


heading: Cybersecurity Governance

body_start: We recognize the critical importance of maintaining the safe


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk as part


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


body_start: We have designed and implemented a comprehensive program int


body_start: Our cybersecurity risk management program is designed to ass


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk management and strategy

body_start: We have implemented a risk-based approach designed to identi


heading: Board of Directors Oversight

body_start: Our board of directors established a technology committee (t


heading: Management's Role

body_start: We have established a Security and Privacy Steering Committe


body_start: We recognize the importance of identifying, assessing, and m


body_start: We recognize the importance of developing, implementing, and


heading: Cybersecurity Governance

body_start: Our global cybersecurity and privacy program is managed by o


body_start: Our cybersecurity risk management strategy and processes, wh


heading: Risk Management and Strategy

body_start: We recognize that cybersecurity threats have been increasing


body_start: We may face risks related to cybersecurity, such as unauthor


heading: Cybersecurity Governance

body_start: Our Board is actively involved in oversight of our risk mana


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy

body_start: The Company takes a risk-based approach to cybersecurity and


heading: Risk Management and Strategy

body_start: We recognize the importance of safeguarding the security of


heading: Risk Management and Strategy

body_start: We employ a defense-in-depth approach with systems and proce


heading: Incident Response

body_start: We have adopted a Cybersecurity Incident Response Plan (the


heading: Risk Management and Strategy

body_start: Our risk management program is designed to identify, assess,


heading: Board of Directors Oversight

body_start: The Risk Committee of our board of directors is responsible


heading: Risk Management and Strategy

body_start: As one of the critical elements of our overall risk manageme


heading: Governance

body_start: As discussed in more detail under the heading "Governance" b


heading: Incident Response and Recovery Planning

body_start: We have established and maintained comprehensive incident re


heading: Third-Party Risk Management

body_start: We maintain a comprehensive, risk-based approach to identify


heading: Cybersecurity Threats

body_start: As of the date of this Annual Report on Form 10-K, we do not


heading: Risk Management and Strategy

body_start: Our business operations rely on the secure collection, stora


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk management and strategy


heading: Cybersecurity Governance

body_start: We leverage the support of third-party information technolog


heading: Risk Management and Strategy

body_start: We recognize the importance of identifying, assessing, and m


heading: Risk Management and Strategy

body_start: The Company recognizes the importance of a cybersecurity ris


heading: Risk Management Personnel

body_start: The IT Manager has the primary responsibility for managing t


heading: Risk Management and Strategy

body_start: In the ordinary course of its business, the Bank relies on e


body_start: We have developed and implemented a cybersecurity risk manag


heading: Governance

body_start: Related to Cybersecurity Risks Our Executive Director of Inf


heading: Cybersecurity Governance

body_start: The Board of Directors maintains overall oversight of cybers


heading: Risk management and strategy

body_start: The Company has implemented and maintain various information


heading: Cybersecurity Program

body_start: Given the importance of cybersecurity to our business, we ma


body_start: We recognize the critical role that cybersecurity plays in p


heading: Cybersecurity Governance

body_start: We have established a cybersecurity governance framework to


heading: Risk Management and Strategy

body_start: We maintain a cybersecurity management program designed to i


heading: Management's Role

body_start: The Company's Chief Information Officer is responsible for t


heading: Risk Management and Strategy

body_start: We regularly assess risks from information security threats,


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Risk management and strategy

body_start: We recognize the critical importance of developing, implemen


heading: Board of Directors Oversight

body_start: The Audit Committee of the Board (the "Audit Committee") is


heading: Risk Management Personnel

body_start: Primary responsibility for assessing, monitoring and managin


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


body_start: Effect of Risk We face risks related to cybersecurity such a


body_start: We recognize the importance of assessing, identifying, and m


heading: Cybersecurity Governance

body_start: Cybersecurity is an important part of our risk management pr


heading: Risk Management and Strategy

body_start: Our cybersecurity program includes technical safeguards, inc


heading: Governance

body_start: Related to Cybersecurity Risks Our Vice President, Head of I


heading: Governance

body_start: Related to Cybersecurity Risks Our board has final oversight


body_start: As an externally managed closed-end management investment co


heading: Risk Management and Strategy

body_start: We have established policies and processes designed to asses


body_start: We have developed and implemented a cybersecurity risk manag


heading: Risk Management and Strategy

body_start: As one of the critical elements of the Company's overall ERM


body_start: Risks from Cybersecurity Threats The CISO, in coordination w


heading: Third-Party Risk Management

body_start: We also maintain procedures designed to identify and mitigat


heading: Incident Response and Recovery Planning

body_start: We have an information security incident response process to


body_start: As one of the elements of our overall risk management progra


heading: Board of Directors Oversight

body_start: Our Board is aware of the critical nature of managing risks


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy

body_start: We are increasingly dependent upon information technology sy


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk management and strategy

body_start: Cybersecurity is a critical aspect of our operations, and ou


heading: Cybersecurity Governance

body_start: One of the key functions of our Board of Directors is inform


heading: Risk Management and Strategy

body_start: We have certain processes and policies in place to assess, i


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Governance

body_start: Related to Cybersecurity Risks Our cyber risk management pro


heading: Cybersecurity

body_start: Processes and Risk Assessment We rely on the cybersecurity p


heading: Risk Management and Strategy

body_start: Our cybersecurity risk assessment process helps identify our


heading: Incident Response and Recovery Planning

body_start: We have established incident response and recovery plans and


heading: Third-Party Risk Management

body_start: Our cybersecurity risk processes address risks associated wi


heading: Management's Role

body_start: Our cybersecurity program, which is discussed in greater det


body_start: We have developed and implemented a cybersecurity risk manag


heading: Governance

body_start: Related to Cybersecurity Risk Management is responsible for


body_start: Our process for managing cybersecurity risk is comprised of


heading: Cybersecurity Governance

body_start: Cybersecurity is an important part of our risk management pr


heading: Risk Management and Strategy

body_start: Our policies for Cybersecurity and the Safeguarding of Data,


heading: Third-Party Risk Management

body_start: Any new organization or party that we show interest in estab


heading: Risk Management and Strategy

body_start: We have certain processes for assessing, identifying and man


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: The Company recognizes the importance of developing, impleme


heading: Risk Management Personnel

body_start: Primary responsibility for assessing, monitoring, and managi


body_start: The Company has processes in place for assessing, identifyin


body_start: We recognize the importance of maintaining the safety and se


heading: Cybersecurity Governance

body_start: Our Board is responsible for overseeing our overall enterpri


heading: Governance

body_start: Related to Cybersecurity Risks Our audit committee of the bo


heading: Risk Management and Strategy

body_start: We support a risk-based cybersecurity program with control a


heading: Incident Response and Recovery Planning

body_start: We have established comprehensive incident response and reco


heading: Third-Party Risk Management

body_start: We have implemented processes designed to identify and mitig


heading: Risk Management and Strategy

body_start: Based on the complex and continuously evolving cybersecurity


body_start: We have developed and implemented a cybersecurity risk manag


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Risk Management and Strategy


heading: Risk Management and Strategy

body_start: Cybersecurity risk management is part of the Company's overa


body_start: The Company is externally managed by the Adviser and has no


heading: Risk Management and Strategy


heading: Risk Management and Strategy

body_start: Talkspace recognizes the importance of assessing, identifyin


heading: Cybersecurity Governance

body_start: Cybersecurity is an important part of our risk management pr


heading: Risk Management and Strategy

body_start: Management of cybersecurity risks is an integral part of our


body_start: The Company, under the oversight of the audit committee of t


heading: Cybersecurity Program

body_start: Oversight and Governance Our Head of Information Technology


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Board of Directors Oversight

body_start: The Audit Committee of the Board of Directors is tasked with


heading: Risk Management and Strategy

body_start: Our cybersecurity management process is based on an internal


body_start: To help protect the Company from a major cybersecurity incid


heading: Cybersecurity

body_start: Incidents and Material Impacts The Company has not experienc


body_start: As an externally managed BDC, our risk management function,


body_start: Candel has implemented cybersecurity risk management process


heading: Cybersecurity Governance

body_start: The board of directors has delegated oversight of the Compan


heading: Risk Management and Strategy

body_start: As one of the critical elements of our overall ERM approach,


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Governance

body_start: Related to Cybersecurity Risks Our Board of Directors ("Boar


body_start: We maintain a cybersecurity program, which is informed by in


body_start: Our enterprise risk management program is designed to identi


heading: Board of Directors Oversight

body_start: The Board of Directors is charged with overseeing the establ


heading: Management's Role

body_start: The Information Security department is responsible for imple


heading: Incident Response and Recovery

body_start: Our comprehensive incident response plan outlines detailed p


heading: Third-Party Risk Management

body_start: Vendors and service providers are rigorously vetted through


heading: Risk Management and Strategy

body_start: As part of the ongoing maintenance and development of our IS


heading: Cybersecurity Governance

body_start: Cybersecurity is an important part of our enterprise risk ma


heading: Risk Management

body_start: Strategy and Governance The Fund is externally managed by th


heading: Risk management and strategy

body_start: We prioritize the management of cybersecurity risk and the p


body_start: Cybersecurity is an important part of our overall risk manag


heading: Cybersecurity Governance

body_start: The Board oversees our annual enterprise risk assessment, wh


heading: Governance

body_start: Related to Cybersecurity Risks Our cyber risk management pro


heading: Risk management and strategy

body_start: We have implemented and maintain policies and processes desi


heading: Cybersecurity Risk Management Program

body_start: Our Cybersecurity Risk Management Program is designed around


heading: Cybersecurity

body_start: Incidents and Responses As of the date of this Annual Report


heading: Risk Management and Strategy

body_start: The Company has processes in place to assess, identify, and


heading: Risk Management and Strategy

body_start: Enterprise risk management is the responsibility of our exec


heading: Risk Management and Strategy

body_start: We continue to develop and implement a framework designed to


body_start: The Adviser has implemented policies and associated controls


body_start: As an externally managed REIT, our risk management function,


heading: Cybersecurity Governance

body_start: As described above, ACRES has engaged a third-party IT firm


heading: Risk Management and Strategy

body_start: We manage cybersecurity threats as part of our oversight, ev


body_start: We maintain a team, tools, policies, and processes for ident


heading: Cybersecurity Governance

body_start: Cybersecurity risk management is a part of our risk manageme


body_start: We have implemented a cybersecurity program in accordance wi


heading: Governance

body_start: Related to Cybersecurity Risks Our Head of Information Techn


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Risk Management and Strategy

body_start: Kodak has implemented various processes designed to help ass


heading: Board Oversight

body_start: The Board has delegated to its Audit and Finance Committee t


heading: Management's Role

body_start: The IT Security Team addresses and responds to cyber risk, i


heading: Board of Directors' Oversight

body_start: The Audit Committee of the Board of Directors (the "Audit Co


heading: Cybersecurity

body_start: Governance and Responsibilities Our Board of Directors recog


heading: Risk Management and Strategy

body_start: We periodically assess and test our cybersecurity procedures


heading: Third-Party Risk Management

body_start: We maintain a risk-based approach to identifying and oversee


body_start: Effect of Risk We face risks related to cybersecurity such a


heading: Cybersecurity Governance

body_start: Our Audit Committee of the Board of Directors has oversight


heading: Cybersecurity Governance

body_start: One of the key functions of our board of directors is inform


body_start: As an externally managed BDC, our risk management function,


heading: Cybersecurity Governance

body_start: Cybersecurity is an important part of our overall risk manag


heading: Risk Management and Strategy

body_start: The Trust's cybersecurity risk management is established and


body_start: We recognize the importance of assessing, identifying, and m


heading: Governance

body_start: Related to Cybersecurity Risks Our Vice President, Informati


heading: Risk Management and Strategy

body_start: We take a risk-based approach in implementing and maintainin


heading: Cybersecurity Risk Management

body_start: We operate in a highly regulated industry that requires the


heading: Cybersecurity Governance

body_start: Our board of directors oversees our biennial enterprise risk


heading: Incident Response and Recovery Planning

body_start: We have established and maintain comprehensive incident resp


heading: Third-Party Risk Management

body_start: We maintain a risk-based approach to identifying cybersecuri


heading: Governance and Oversight

body_start: The governance structure for the Global Cybersecurity and Te


heading: Risk management and strategy

body_start: We have established and maintain various information securit


body_start: We have developed and implemented a cybersecurity risk manag


heading: Risk Management

body_start: The Company established an Enterprise Risk Management (ERM)


body_start: We face risks related to cybersecurity such as unauthorized


heading: Governance

body_start: Related to Cybersecurity Risks Our board of directors is inv


body_start: Effect of Risk Like all companies w e face risks related to


heading: Risk Management and Strategy

body_start: We rely on the cybersecurity policies and procedures impleme


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk Management and Strategy

body_start: We maintain a comprehensive cybersecurity risk management pr


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


body_start: We have implemented a cybersecurity risk management program,


heading: Risk Management and Strategy

body_start: We regularly utilize information technology and data to oper


heading: Risk Management and Strategy

body_start: We have processes in place for assessing, identifying, and m


body_start: The Company's cybersecurity framework encompasses a proactiv


heading: Governance and Oversight

body_start: Cybersecurity governance at the Company involves executive a


heading: Risk Management and Strategy


heading: Risk Management and Strategy

body_start: We recognize the critical importance of developing, implemen


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk as part


heading: Risk Management and Strategy

body_start: We recognize the critical importance of maintaining the trus


heading: Risk management and strategy

body_start: We depend on the functioning, availability and security of o


heading: Cybersecurity Processes

body_start: We have implemented various information security processes d


heading: Risk Management and Strategy

body_start: The Company's Information Technology team has established an


heading: Risk Management and Strategy

body_start: Our risk management program is designed to identify, assess,


heading: Risk Management and Strategy

body_start: Our policies, standards, processes and practices for assessi


heading: Incident Response and Recovery Planning

body_start: We have established comprehensive incident response and reco


heading: Third-Party Risk Management

body_start: We have implemented processes designed to identify and mitig


heading: Risk Management and Strategy

body_start: As a company externally managed by the Advisor, we rely on S


heading: Risk management and strategy

body_start: In the ordinary course of our business, we and our third-par


heading: Risk management and strategy

body_start: Due to the size of our company, we have not yet developed ro


heading: Risk Management and Strategy

body_start: The Company's cybersecurity program is designed to identify,


heading: Risk Management and Strategy

body_start: The General Partner has written plans, procedures and polici


body_start: As an externally managed REIT, the Company's risk management


heading: Cybersecurity Governance

body_start: The AGM board of directors' oversight of cybersecurity risk


heading: Risk Management and Strategy

body_start: We have developed and implemented cybersecurity risk managem


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Risk Management and Strategy

body_start: Our cybersecurity risk management and strategy program consi


heading: Risk Management and Strategy

body_start: We are planning to establish an appropriate confidentiality


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Cybersecurity Risk Management

body_start: The Company has processes for identifying, assessing, and ma


heading: Cybersecurity Governance

body_start: Our Board of Directors and management prioritize cybersecuri


body_start: We have implemented cybersecurity risk management procedures


heading: Cybersecurity Governance

body_start: Our cybersecurity program is managed and directed by our Hea


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


body_start: As an externally managed closed-end management investment co


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk part of


body_start: We continuously monitor our information systems to assess, i


heading: Governance

body_start: Related to Cybersecurity Risks Management is responsible for


body_start: The Adviser's cybersecurity risk management strategy focuses


heading: Risk management and strategy


heading: Governance

body_start: Related to Cybersecurity Risks The Audit Committee of our Bo


heading: Risk Management and Strategy

body_start: Information technology and the digital transformation of our


body_start: We have implemented a cybersecurity risk management program


heading: Governance

body_start: Related to Cybersecurity Risks Our board of directors has de


heading: Cybersecurity Governance

body_start: The Company has established an Information Technology Steeri


heading: Risk management and strategy

body_start: We have implemented and maintain information security proces


body_start: We recognize the importance of assessing, identifying, and m


heading: Cybersecurity Governance

body_start: Our Head of Information Technology, who reports directly to


heading: Governance

body_start: Related to Cybersecurity Risks Our cybersecurity risk manage


heading: Governance

body_start: Related to Cybersecurity Risks Our cyber risk management pro


heading: Risk Management and Strategy

body_start: Our risk management program is designed to identify, assess,


heading: Governance

body_start: Our Chief Information Security Officer is accountable for ma


heading: Risk Management and Strategy

body_start: We recognize the importance of developing, implementing and


body_start: Our CEO in conjunction with our external IT team are respons


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our board of directors considers cybersecurity risk as part


heading: Risk management and strategy


heading: Risk Management and Strategy

body_start: We continue to assess and improve the capabilities of our pe


heading: Risk Management and Strategy

body_start: We have established policies and processes for assessing, id


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Cybersecurity

body_start: Processes and Risk Assessment Fortress's cybersecurity progr


heading: Risk Management and Strategy

body_start: At December 31, 2024, we have implemented thorough cybersecu


heading: Cybersecurity Program

body_start: Given the importance of cybersecurity to our business, we ma


body_start: The Company recognizes the risks posed by cybersecurity thre


heading: Board of Directors Oversight

body_start: The Company's Board of Directors is charged with overseeing


heading: Management's Role

body_start: The Company's ISO has many years of experience appropriate t


heading: Risk management and Strategy

body_start: We have implemented several cybersecurity processes and cont


heading: Cybersecurity Governance

body_start: As described above, we have engaged a third-party IT and cyb


heading: Governance

body_start: Related to Cybersecurity Risks Our board of directors holds


body_start: Our cybersecurity program is informed by industry standards


body_start: As a corporation committed to maintaining the integrity, con


heading: Risk Management

body_start: Approach and Strategy Our corporate information technology,


heading: Risk management and strategy

body_start: We recognize the critical importance of developing, implemen


heading: Board of Directors Oversight

body_start: The Audit Committee is central to the Board's oversight of c


heading: Risk Management Personnel

body_start: Primary responsibility for assessing, monitoring and managin


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Risk management and strategy

body_start: We have established policies and processes for assessing, id


heading: Governance

body_start: Related to Cybersecurity Risks Our board of directors, as a


body_start: In recognition of the evolving cybersecurity threat landscap


heading: Cybersecurity Governance

body_start: Senior management, including the Chief Executive Officer and


heading: Risk management and strategy

body_start: We recognize the importance of developing, implementing and


heading: Board of Directors Oversight

body_start: Our Board of Directors is aware of the critical nature of ma


heading: Cybersecurity

body_start: Policies and Standards We have a comprehensive collection of


heading: Incident Response

body_start: Our incident response plan provides consistent guidance for


body_start: The Company maintains an enterprise-wide and Board-approved


heading: Cybersecurity Governance

body_start: The Company has established an Information Security Committe


heading: Risk Management and Strategy

body_start: As part of our strategy to cease deploying capital into new


heading: Risk Management and Strategy

body_start: Our policies, standards, processes and practices for assessi


heading: Incident Response and Recovery Planning

body_start: We have established comprehensive incident response and reco


heading: Third-Party Risk Management

body_start: We have implemented processes designed to identify and mitig


body_start: As an externally managed company, our risk management functi


heading: Cybersecurity Governance

body_start: The AGM Board of Directors' oversight of Apollo's cybersecur


body_start: We have policies, procedures, and processes for assessing, i


heading: Risk Management and Strategy

body_start: We recognize the importance of assessing, identifying, and m


body_start: Our executive team and board of directors recognize that eff


heading: Cybersecurity Governance

body_start: Our board of directors has ultimate oversight of our risk ma


body_start: Due to the size of our company, we have not yet developed ro


heading: Cybersecurity Program

body_start: We have implemented a cybersecurity program to support both


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy

body_start: We have developed and implemented cybersecurity risk managem


heading: Risk Management and Strategy

body_start: We regularly assess risks from cybersecurity threats, monito


heading: Cybersecurity Threats

body_start: As of the date of this report, we have not identified cybers


heading: Risk Management and Strategy

body_start: As one of the critical elements of our overall risk manageme


heading: Governance

body_start: The Board's oversight of cybersecurity risk management is su


heading: Incident Response and Recovery Planning

body_start: We have established and maintain comprehensive incident resp


heading: Third-Party Risk Management

body_start: We maintain a comprehensive, risk-based approach to identify


heading: Risk Management and Strategy

body_start: We regularly assess risks from cybersecurity threats; monito


heading: Risk Management and Strategy

body_start: Cybersecurity risks are constantly evolving and becoming inc


heading: Governance and Oversight

body_start: The Board of Directors, including its Risk Subcommittee prov


heading: Risk Management and Strategy

body_start: We recognize the critical importance of securing our informa


heading: Risk Management and Strategy

body_start: The Company relies on information systems and the data store


heading: Risk Management and Strategy

body_start: Cantor's global cybersecurity processes form the comprehensi


heading: Risk Management and Strategy

body_start: We recognize the importance of assessing, identifying, and m


body_start: We recognize the importance of assessing, identifying and ma


heading: Cybersecurity Governance

body_start: Our Board of Directors considers cybersecurity risk and othe


body_start: We have developed and maintained a Cybersecurity risk manage


heading: Cybersecurity Governance

body_start: Our Board provides strategic oversight on Cybersecurity matt


body_start: The Adviser's cybersecurity risk management strategy focuses


body_start: We are dedicated to protecting the integrity, confidentialit


heading: Cybersecurity Processes

body_start: We conduct robust cybersecurity processes aligned with the N


heading: Cybersecurity Governance

body_start: Our executive team is actively involved in overseeing our cy


heading: Risk Management and Strategy

body_start: Cybersecurity risk management is a core tenet of our informa


body_start: Like many companies, we face significant and persistent cybe


heading: Risk Management and Strategy

body_start: We are committed to safeguarding the personal information of


heading: Risk management and strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management

body_start: Governance and Strategy We recognize the importance of asses


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


heading: Risk management and strategy

body_start: We implemented and maintain various information security pro


heading: Risk Management and Strategy

body_start: We recognize the importance of cybersecurity risk and the pr


body_start: We recognize the need to continually monitor and assess mate


heading: Cybersecurity Governance

body_start: Our cybersecurity program is overseen by the Company's CTO i


heading: Risk Management and Strategy

body_start: We are a clinical stage biopharmaceutical company with no co


heading: Risk Management and Strategy

body_start: We periodically assess risks from cybersecurity threats; mon


heading: Risk Management and Strategy

body_start: We have in place certain infrastructure, systems, policies,


heading: Risk Management and Strategy


body_start: We continue to invest substantially in cybersecurity risk ma


heading: Cybersecurity Governance

body_start: Our management, including our Chief Executive Officer, Chief


body_start: In recognition of the evolving cybersecurity threat landscap


heading: Cybersecurity Governance

body_start: Senior management, including the Chief Executive Officer and


heading: Risk Management and Strategy

body_start: Our company is guided by a comprehensive cybersecurity frame


heading: Risk Management and Strategy

body_start: The Company employs an IT Security Team that is responsible


heading: Risk Management and Strategy

body_start: The Company recognizes the importance of assessing, identify


heading: Board of Directors Oversight

body_start: The Risk Committee of our board of directors is responsible


heading: Risk Management and Strategy

body_start: Overview of Processes for Assessing, Identifying, and Managi


body_start: The Company is committed to, and recognizes the importance o


heading: Cybersecurity Governance

body_start: Our Board of Directors and Audit Committee are actively enga


heading: Risk Management and Strategy

body_start: As one of the critical elements of enterprise-wide approach


heading: Governance

body_start: As discussed in more detail under the heading "Governance" b


heading: Incident Response and Recovery Planning

body_start: We have established and maintained comprehensive incident re


heading: Third-Party Risk Management

body_start: We maintain a comprehensive, risk-based approach to identify


heading: Cybersecurity Threats

body_start: As of the date of this Annual Report on Form 10-K, we do not


heading: RISK MANAGEMENT AND STRATEGY

body_start: The Company continues to make cybersecurity a priority as th


heading: Risk Management Personnel

body_start: The Company's cybersecurity risk management program is overs


heading: Board of Directors Oversight

body_start: The Audit Committee of the Company's Board is responsible fo


heading: Risk Management and Strategy

body_start: We recognize the importance of establishing governance and o


body_start: We have developed and implemented a cybersecurity risk manag


heading: Cybersecurity Governance

body_start: Our Board considers cybersecurity risk as part of its risk o


body_start: We recognize the importance of developing, implementing, and


heading: Cybersecurity Governance

body_start: As stated above, the Board of Directors and the Audit Commit


heading: Third-Party Risk Management

body_start: We review and evaluate material cybersecurity risks related


heading: Risk management and strategy

body_start: Our cybersecurity program is designed to safeguard our infor


body_start: As is the case for all companies in our industry or with a s


heading: Cybersecurity Governance and Oversight

body_start: Our board of directors provides oversight over cybersecurity


heading: Governance

body_start: The REIS Policy has been drafted in collaboration with one o


body_start: The Company's cybersecurity risk management strategy focuses


heading: Cybersecurity Governance

body_start: The Board of Directors (the "Board") has risk oversight resp


heading: Risk Management and Strategy

body_start: We have developed and implemented cybersecurity risk managem


heading: Risk Management and Strategy

body_start: The Company regularly assesses risks from cybersecurity thre


heading: Risk Management and Strategy

body_start: As a publicly traded e-commerce outdoor company, we are acut


heading: Risk Management and Strategy

body_start: We have implemented and maintain various information securit


heading: Risk Management and Strategy

body_start: We have established processes, that seek to assess, identify


heading: Risk Management and Strategy

body_start: We are committed to maintaining the confidentiality, integri


heading: Risk management and strategy

body_start: We depend on information systems and technology in substanti


heading: Risk Management and Strategy

body_start: We manage cybersecurity risks as part of our broader enterpr


heading: Risk Management and Strategy

body_start: We are committed to protecting the confidentiality, integrit


body_start: The Company is committed to maintaining a robust cybersecuri