text: Processes for Monitoring Cybersecurity Our cybersecurity oversight committee maintains rigorous processes to remain informed and responsive to the ever-changing landscape of cybersecurity. These processes include: The creation and management of secure user accounts within our Monogram email Google Workspace, ensuring controlled email communication. The establishment of access controls to Google Drive and Bitbucket, safeguarding our product-related documents and software development repositories. Subscription to Amazon Web Services for secure storage of our mechanical drawings and electrical schematics. Utilization of Green Light Guru for maintaining a repository of all released and quality documents. Oversight of bill.com and NetSuite for financial operations and inventory management, ensuring secure financial transactions and data integrity.


text: These processes are under continuous review and adjustment, with the committee meeting quarterly to evaluate and refine our cybersecurity practices.

companyName: Monogram Technologies Inc.

ticker: MGRM

secItem: Item 1C


text: Reporting Cybersecurity Information In terms of reporting, the structure of our cybersecurity information flow is designed to ensure that significant risks and incidents are communicated efficiently to senior management and the board of directors:


text: The Software Director, Platform Tech Manager, and dedicated admin for Green Light Guru report directly to Kamran Shamaei, the CTO.


text: The committee convenes on a quarterly basis to discuss the current state of cybersecurity affairs, subsequently reporting their findings to the CEO and CFO.


text: In the event of any concerns or breaches, these are immediately escalated to Paul Riss, ensuring prompt and effective response and mitigation strategies.


text: Through this tiered reporting structure, we ensure that critical cybersecurity information reaches the appropriate levels of management and that the board of directors is kept fully informed on material risks and incidents. Our approach ensures that we maintain a vigilant and responsive posture towards cybersecurity, embodying a culture of continuous improvement and accountability at all levels of our organization.


text: Our corporate information technology, communication networks, enterprise applications, accounting and financial reporting platforms, and related systems, and those that we offer to our customers are necessary for the operation of our business. We use these systems, among others, to manage our customer and vendor relationships, for internal communications, for accounting to operate record-keeping functions, and for many other key aspects of our business. Our business operations rely on the secure collection, storage, transmission, and other processing of proprietary, confidential, and sensitive data.

companyName: HUDSON TECHNOLOGIES INC /NY

ticker: HDSN


text: We have implemented and maintain various information security processes designed to identify, assess and manage material risks from cybersecurity threats to our critical computer networks, third-party hosted services, communications systems, hardware and software, and our critical data, including intellectual property, confidential information that is proprietary, strategic or competitive in nature, and tenant data ("Information Systems and Data").


text: We rely on a multidisciplinary team, including our information security function, legal department, management, and third-party service providers, as described further below, to identify, assess, and manage cybersecurity threats and risks. We identify and assess risks from cybersecurity threats by monitoring and evaluating our threat environment and our risk profile using various methods including, for example, using manual and automated tools, subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and threat actors, conducting scans of the threat environment, evaluating our industry's risk profile, utilizing internal and external audits, and conducting threat and vulnerability assessments.


text: Depending on the environment, we implement and maintain various technical, physical, and organizational measures, processes, standards, and/or policies designed to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data, including risk assessments, incident detection and response, vulnerability management, disaster recovery and business continuity plans, internal controls within our accounting and financial reporting functions, encryption of data, network security controls, access controls, physical security, asset management, systems monitoring, vendor risk management program, employee training, and penetration testing.


text: We work with third parties from time to time that assist us to identify, assess, and manage cybersecurity risks, including professional services firms, consulting firms, threat intelligence service providers, and penetration testing firms.


text: To operate our business, we utilize certain third-party service providers to perform a variety of functions. We seek to engage reliable, reputable service providers that maintain cybersecurity programs. Depending on the nature of the services provided, the sensitivity and quantity of information processed, and the identity of the service provider, our vendor management process may include reviewing the cybersecurity practices of such provider, contractually imposing obligations on the provider, conducting security assessments, and conducting periodic reassessments during their engagement.


text: We are not aware of any risks from cybersecurity threats, including as a result of any cybersecurity incidents, which have materially affected or are reasonably likely to materially affect our Company, including our business strategy, results of operations, or financial condition.


text: Our full Board oversees the Company's enterprise risk management process, including the management of risks arising from cybersecurity threats. The Board receives regular presentations and reports from management who are responsible for managing and assessing cybersecurity risks, which address a wide range of topics including recent developments, evolving standards, vulnerability assessments, third-party and independent reviews, the threat environment, technological trends and information security considerations. The Board also receives prompt and timely information regarding any cybersecurity incident that meets established reporting thresholds, as well as ongoing updates regarding any such incident until it has been addressed.


text: Management plays a crucial role in assessing and managing material risks from cybersecurity threats. At the management level, the Company's cybersecurity risk management and strategy is led by its Director of IT, who reports to the CFO. The qualifications of the Director of IT include over 25 years of IT management, cybersecurity, and information governance experience. The Director of IT is regularly informed about the latest developments in cybersecurity, including emerging threats and technologies to adapt security measures accordingly. This ongoing knowledge acquisition is crucial for the effective prevention, detection, mitigation, and remediation of cybersecurity incidents. Management's role includes:


text: Risk Assessment: Management conducts annual cybersecurity risk assessments to identify and evaluate potential threats and vulnerabilities. Management considers the likelihood and potential impact of various cybersecurity risks, considering the Company's assets, systems, and operations, to prioritize mitigation efforts.


text: Management reviews and approves the Company's cybersecurity policies and procedures and communicates these policies and procedures to all employees to ensure adherence to established security protocols. Compliance with Regulations: Management implements and maintains compliance with relevant cybersecurity regulations and standards applicable to the Company.


text: Management reviews budgets for cybersecurity initiatives and ensures that adequate resources are allocated to address cybersecurity risks and that investments in cybersecurity align with the Company's risk tolerance and strategic objectives.


text: The Director of IT is promptly informed of potential cybersecurity risks, threats, and vulnerabilities by the Company's IT Helpdesk. Once an incident has been identified, the Director of IT and the IT network security team assess the criticality and impact of the incident on the Company's business operations. The Director of IT then formulates and oversees a response to contain, eradicate and resolve incidents in accordance with the Company's incident response plan. Management is responsible for reporting incidents to the appropriate authorities as necessary and engaging senior leadership on all material incidents.


text: We have implemented processes designed to identify, review and manage risks from potential cybersecurity-related data breaches, unauthorized intrusions of our information technology systems, and other information security losses on or through our information technology systems that could result in adverse effects on the confidentiality, integrity, and availability of our systems and electronic information. These processes are managed and monitored by our third-party information technology service providers, as supervised by our Chief Financial Officer (CFO). Our CFO has experience in overseeing our cybersecurity and information technology programs. We rely heavily on information technology consultants for advice and expertise on monitoring evolving industry standards and to monitor our compliance with applicable policies. Our processes include mechanisms, controls, technologies, and systems designed to prevent or mitigate data loss, theft, misuse, or other security incidents or vulnerabilities affecting the data and maintain a stable information technology environment. With the assistance of our third-party vendors, we conduct regular information technology risk evaluations and security audits. Our information technology team conducts due diligence on key technology vendors, contractors and suppliers. We also provide ongoing education communications on cyber and information security, among other topics, and monitor phishing campaigns or other misrepresented system access requests to identify any employees that might need additional training.

companyName: Cellectar Biosciences, Inc.

ticker: CLRB


text: The Board of Directors, with the assistance of the Audit Committee, has oversight for the most significant risks facing us and for our processes to identify, prioritize, assess, manage, and mitigate those risks. As part of its oversight responsibilities, the Audit Committee receives periodic updates on cybersecurity and information technology matters and related risk exposures from our CFO.


text: As of the date of this report, we have not identified any cybersecurity threats or intrusions that have materially affected our strategy, results of operations or financial condition. We and our third-party service providers have, however, been the target of cybersecurity threats and we expect these threats to continue. For additional information regarding risks from cybersecurity threats, please refer to Item 1A, "Risk Factors," in this annual report on Form 10-K.


text: As a blank check company, we have no operations and therefore do not have any operations of our own that face cybersecurity threats. However, we do depend on the digital technologies of third parties, and as noted in Item 1A. Risk Factors of this report, any sophisticated and deliberate attacks on, or security breaches in, systems or infrastructure or the cloud that we utilize, including those of third parties, could lead to corruption or misappropriation of our assets, proprietary information and sensitive or confidential data. Because of our reliance on the technologies of third parties, we also depend upon the personnel and the processes of third parties to protect against cybersecurity threats, and we have no personnel or processes of our own for this purpose. Our board of directors oversees risk for our Company, and prior to filings with the SEC, our board of directors reviews our risk factors, including the descriptions of the risks we face from cybersecurity threats, as described in Item 1A. Risk Factors of this report.

companyName: SilverBox Corp IV

ticker: SBXD


text: We depend on a variety of information systems and technologies (including cloud technologies) to manage our business. We maintain a cyber risk management program designed to identify, assess, manage, mitigate, and respond to cybersecurity threats.

companyName: Quoin Pharmaceuticals, Ltd.

ticker: QNRX


text: The underlying processes and controls of our cyber risk management program incorporate recognized best practices and standards for cybersecurity and information technology, including the National Institute of Standards and Technology ("NIST") Cybersecurity Framework ("CSF"). We have undertaken, to conduct an annual assessment of our cyber risk management program and controls to identify, quantify, and categorize material cyber risks. In addition, we have developed a risk mitigation plan to address such risks, and where necessary, remediate potential vulnerabilities identified through the annual assessment process.


text: In addition, we maintain policies over areas such as information security, access on/offboarding, and access and account management, to help govern the processes put in place by management designed to protect our IT assets, data, and services from threats and vulnerabilities. Our cybersecurity risk management strategy and infrastructure includes maintenance of an IT assets inventory, periodic vulnerability scanning, identity access management controls including restricted access of privileged accounts, network integrity safeguarded by employing web-based software, industry-standard encryption protocols, critical data backups, infrastructure maintenance, incident response, cybersecurity strategy, and cyber risk advisory, assessment and remediation.


text: Our management team is responsible for oversight and administration of our cyber risk management program, and for informing our Board and other relevant stakeholders regarding the prevention, detection, mitigation, and remediation of cybersecurity incidents. Our management team relies on threat intelligence as well as other information obtained from governmental, public, or private sources, including external consultants who may be engaged by us for strategic cyber risk management, advisory and decision making. To the extent we utilize third-party vendors to provide information technology services for various areas, including human resources functions (e.g., payroll), we generally require these vendors to monitor and protect their information technology systems against cyber-attacks and other breaches. The Audit Committee of the Board of Directors oversees our cybersecurity risk exposures and the steps taken by management to monitor and mitigate cybersecurity risks. Member(s) of management brief the Audit Committee on cyber vulnerabilities identified through the risk management process, the effectiveness of our cyber risk management program, and the emerging threat landscape and new cyber risks on at least an annual basis. This includes updates on our processes to prevent, detect, and mitigate cybersecurity incidents.


text: We face risks from cybersecurity threats that could have a material adverse effect on our business, financial condition, results of operations, cash flows or reputation. We acknowledge that the risk of cyber incident is prevalent in the current threat landscape and that a future cyber incident may occur in the normal course of our business. To date, we have not had a cybersecurity incident. We proactively seek to detect and investigate unauthorized attempts and attacks against our IT assets, data, and services, and to prevent their occurrence and recurrence where practicable through changes or updates to internal processes and tools and changes or updates to service delivery; however, potential vulnerabilities to known or unknown threats will remain. Further, there is increasing regulation regarding responses to cybersecurity incidents, including reporting to regulators, investors, and additional stakeholders, which could subject us to additional liability and reputational harm. See Item 1A. "Risk Factors" for more information on cybersecurity risks.


text: As a blank check company, we have no operations and therefore do not have any operations of our own that face cybersecurity threats. However, we do depend on the digital technologies of third parties, and as noted in " Item 1A. Risk Factors " of this Form 10-K, any sophisticated and deliberate attacks on, or security breaches in, systems or infrastructure or the cloud that we utilize, including those of third parties, could lead to corruption or misappropriation of our assets, proprietary information and sensitive or confidential data. Because of our reliance on the technologies of third parties, we also depend upon the personnel and the processes of third parties to protect against cybersecurity threats, and we have no personnel or processes of our own for this purpose. Our board of directors oversees risk for our Company, and prior to filings with the SEC, our board of directors reviews our risk factors, including the descriptions of the risks we face from cybersecurity threats, as described in " Item 1A. Risk Factors " of this Form 10-K.

companyName: Graf Global Corp.

ticker: GRAF


text: We have established an Information Security department within our Risk Management department that is independent of the Information Technology department. Furthermore, we have a documented Information Security Strategy that guides the Information Security teams and business departments across the Company. The Information Security Strategy incorporates the external landscape, risk assessments, Company's strategy, information technology strategy and other inputs.

companyName: Sterling Bancorp, Inc.


text: Our appetite for cybersecurity risk is established within our enterprise risk appetite. We undertake an information technology risk assessment annually. This assessment considers our information assets, the potential threats/risks to those assets and the effectiveness of existing controls to identify and assess inherent and residual levels of information security risks. This assessment also identifies any control gaps that may exist and informs appropriate mitigation strategies to conform to our appetite for cybersecurity risk. Remediation plans for any identified gaps are monitored by management quarterly. Results from this risk assessment may affect changes in the Information Security Strategy and information security budget. Annually, we engage a third-party audit firm specializing in information technology audits to review the risk assessment and our Information Security Program overall as part of our information technology general controls audit.


text: We have previously experienced cybersecurity incidents, from time to time. These incidents have not materially affected our business strategy, results of operations or financial condition. We are not currently aware of any cybersecurity incidents that would have a material effect on our business strategy, results of operations or financial condition.


text: We use a security framework to guide our overall security posture, which has helped us develop and enhance our Information Security Policy, Incident Response Policy and Business Continuity Policy. These policies guide us in our effort to manage and control information technology risk and to define and communicate information security responsibilities and accountability throughout the Company. These policies also set the requirements to help ensure that we safeguard our data and information systems to reduce risk and minimize the effect of potential incidents. These policies are supported by written standards and procedures that ensure conformity with the policies that the board of directors has set forth. Pursuant to our Incident Response Policy, we have adopted a written Incident Response Plan that documents employee and management responsibilities, incident classifications and the procedures to be followed during a cybersecurity incident. The Incident Response Plan is tested annually through a tabletop exercise led by a third-party vendor who assists in developing and executing the exercise.


text: We have a documented Third-Party Risk Management Policy and Program to ensure that our vendor relationships are assessed, monitored and documented appropriately. It is our policy to exercise appropriate oversight and risk management of the activities conducted through significant third-party relationships, taking into consideration the nature, magnitude, complexity and risk potential of the arrangement. Vendors are monitored for cybersecurity issues during the initial onboarding processes and on an ongoing basis. We may review or require a SOC 2 Type 2 report, cybersecurity controls, cyber insurance and monitoring frequency depending on our assessment of the risk of any vendor.


text: Management performs ongoing monitoring of the Information Security Program with a range of reports and tools that are commensurate with our risk profile. These reports and tools ensure the program continues to comply with all policies related to information technology risk and information security.


text: We have engaged a third-party provider that manages and monitors our Security Operations Center, including our firewall and intrusion detection and prevention system. Additionally, management has engaged a separate vendor to monitor and manage endpoint detection and response applications on all Company devices, including workstations, laptops and servers.


text: Additional controls include vulnerability scanning, identity and access management, mobile device management and other various security controls. We also conduct periodic phishing tests and social awareness training for all employees, which include how to report and escalate suspected incidents.


text: Information security metrics are reported quarterly to the Information Technology Steering Committee, the Enterprise Risk Management Committee and the Board Risk Committee to provide evidence of the effectiveness of these controls and tools. Any identified specific gaps in the controls are sent to management quarterly until resolved.


text: Cybersecurity risks and activities are reported quarterly to the Information Technology Steering Committee and the Enterprise Risk Management Committee. The Bank's chief risk officer and interim chief information officer are part of the Information Technology Steering and Enterprise Risk Management Committees. The Bank's interim chief information officer has over 30 years of experience managing technology.


text: We have also employed a chief information security officer who reports to the chief executive officer. The chief information security officer is responsible for information security, information technology risk management, vendor management and business continuity programs. The chief information security officer holds a graduate degree in cybersecurity and numerous information security certifications, including certified information systems security professional, certified information security manager, certified cloud security professional and qualified technology expert. Additionally, the chief information security officer has worked in the information security field for over 20 years within several financial institutions, implementing cybersecurity strategies, programs, policies and procedures.


text: Our Board Risk Committee generally meets quarterly and is responsible for overseeing cybersecurity risk and our information security program, including cybersecurity, and ensuring the continued development of the program as the Company grows and cyber and information risk exposures change. At each Board Risk Committee meeting, the chief information security officer presents information security metrics and any updates to the Information Security Program. New and changing cybersecurity risks are discussed when needed. The chair of the Board Risk Committee also serves as a board member and previously served as the chair and interim chief executive officer of the Information Systems Audit and Control Association. As a board member of the Information Systems Audit and Control Association, she is a member of their Audit and Risk Committee, Compensation and Human Capital Committee and Governance and Nominating Committee. All cybersecurity-related policies are reviewed and approved annually by the chief information security officer, Enterprise Risk Management Committee, Board Risk Committee and the board of directors.


text: All companies utilizing technology are subject to threats of breaches of their cybersecurity programs. To mitigate the threat to our business and address regulatory requirements, we take a comprehensive approach to cybersecurity risk management and have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information. As described in more detail below, we have established policies, standards, processes, and practices for assessing, identifying, and managing material risks from cybersecurity threats. We devote significant financial and personnel resources to implement and maintain security measures to meet regulatory requirements and customer expectations, and we intend to continue to make significant investments to maintain the security of our data and cybersecurity infrastructure.

companyName: UNITED BANCORP INC /OH/

ticker: UBCP


text: Legal Overview Pursuant to the requirements of section 39 of the Federal Deposit Insurance Act (12 U.S.C. 1831p–1) and sections 501 and 505(b) of the Gramm-Leach-Bliley Act (15 U.S.C. 6801, 6805(b)), the federal bank regulatory agencies adopted the Interagency Guidelines Establishing Information Security Standards (the "Guidelines"). The requirements of the Guidelines apply to all FDIC-insured depository institutions, most subsidiaries of such entities, and to state savings associations. Federal law also mandates that information security procedures and controls be routinely evaluated by the Bank's state and federal regulators as part of the standard safety and soundness examination process.


text: Bank Security Policy To comply with all applicable federal requirements, the Bank's Board of Directors has adopted the Unified Bank Information Security Policy (the "ISP"), which establishes a program that the Bank's management and board can use to: Ensure the security and confidentiality of customer information;


text: Protect against any anticipated threats or hazards to the security or integrity of such information; and Protect against unauthorized access to or use of customer information that could result in substantial harm or inconvenience to any customer.


text: Under the ISP, the Board of Directors or an appropriate committee thereof is required to oversee all efforts with respect to the development, implementation and maintenance of an effective information security program. In addition, the ISP charges management with responsibility for identifying all reasonably foreseeable internal and external threats that could result in unauthorized disclosure, misuse, alteration or destruction of Bank information, and directs management to develop and implement procedures and other controls designed to reduce or eliminate identified risks.


text: The Bank has also implemented controls designed to identify and mitigate cybersecurity threats associated with our use of the Bank's critical third-party service providers. Such providers are subject to security risk assessments at the time of onboarding, contract renewal, and based on risk profile. A variety of inputs are used in such assessments, including information supplied by providers and third parties. In addition, we require our providers to meet appropriate security requirements, controls and responsibilities and investigate security incidents that have impacted our third-party providers, as appropriate. In addition to being subject to routine examination by the Bank's state and federal regulators, the efficacy of the Bank's information security program is also audited annually by an independent third-party auditing firm.


text: Managerial and Board Oversight To facilitate oversight, the Bank has established a front line committee, the Compliance Risk Assessment Committee, which is comprised of all members of senior management, the head of information security and certain other operationally significant employees. This Committee, which meets quarterly, is responsible for monitoring all key operational risks applicable to the Bank. Cyber risk assessments are routinely conducted and reported to the Audit Committee of the Board of Directors In addition, key members of senior management also meet annually with a cyber risk consultant who apprises management on emerging cyber threats and evaluates the Company's adequacy of cyber risk insurance coverage. The findings of this meeting are also reported to the Executive Committee. All significant matters are reported by the Executive Committee to the full Board of Directors.


text: As a company with no ongoing business operations, the Company currently has limited exposure to cybersecurity risks. However, we recognize the importance of maintaining secure information systems and protecting sensitive data, including corporate records and investor-related information.

companyName: RIDGEFIELD ACQUISITION CORP

ticker: RDGA


text: We have implemented basic cybersecurity measures, including access controls, secure data storage, and third-party monitoring of our IT infrastructure. Given our lack of operations, we do not anticipate that cybersecurity threats will have a material impact on our financial condition or business strategy. If we pursue an acquisition or commence business operations in the future, we intend to reassess and enhance our cybersecurity risk management framework as necessary.


text: Our board of directors oversees cybersecurity risk as part of its general risk management responsibilities. Given our limited operations, the board does not currently have a dedicated cybersecurity committee or officer. However, cybersecurity matters are discussed as needed, particularly in the context of potential business combinations or transactions that may introduce new risks.


text: Material Cybersecurity Incidents During the fiscal year ended December 31, 2024, we did not experience any material cybersecurity incidents. Given our current operational status, we do not believe cybersecurity risks have materially affected, or are reasonably likely to materially affect, our financial condition or results of operations.


text: Although, as a blank check company, we do not have any operations, we are nonetheless subject to the risk of cybersecurity incidents. Among other things, the investments in our Trust Account and bank deposits may be vulnerable to such incidents, and we may depend on the digital technologies of third parties. We and third parties may be subject to cybersecurity attacks or security breaches. To the extent that we rely on the technologies of third parties, we depend upon the personnel and the processes of such third parties to protect against cybersecurity incidents, and we have no personnel or processes of our own for this purpose. In the event of a cybersecurity incident impacting us, our Management Team will report to the Board of Directors and provide updates on the Management Team's incident response plan for addressing and mitigating any risks associated with such an incident. As an early stage company without significant investments in data security protection, we may not be sufficiently protected against such occurrences. We also lack sufficient resources to adequately protect against, or to investigate and remediate any vulnerability to, cyber incidents. It is possible that any of these occurrences, or a combination of them, could have material adverse consequences on our business and lead to financial loss. We have not encountered any cybersecurity incidents since our Initial Public Offering. In addition to our own cybersecurity risks, any proposed Business Combination target may have been subject to, or may in the future be subject to, cybersecurity incidents.

companyName: Haymaker Acquisition Corp. 4

ticker: HYAC


text: We rely on Prudential, of which both the Manager and Subadviser are subsidiaries, for assessing, identifying and managing material risks to our business from cybersecurity threats. Below are details Prudential has provided to us regarding its cybersecurity program that are relevant to us.

companyName: PGIM Private Credit Fund

ticker: PGIM


text: Because of the size and scope of Prudential's business, Prudential, the Manager, their affiliates and the Company are subject to numerous and evolving cybersecurity risks, any of which, if it materializes, could affect our business strategy, results of operations, or financial condition. See "Item 1A. Risk Factors—Risks Related to Market Events and Regulatory Developments— Cybersecurity and data protection risks could result in the loss of data, exposure of confidential information, interruptions in our business, and damage to our reputation, and subject us to regulatory actions, increased costs and financial losses, each of which could have a material adverse effect on our business and results of operations." for a discussion of such risks.


text: Cybersecurity risk management is integrated within Prudential's risk management framework. Prudential conducts risk identification through several processes at the business unit, corporate, senior management, and board levels. This framework includes escalation points to Prudential's risk committees, allowing cyber risk and control matters to be elevated to Prudential's board of directors or its audit committee for oversight.


text: In order to respond to the threat of security breaches and cyber-attacks, Prudential has developed an information security program designed to protect and preserve the confidentiality, integrity, and continued availability of information owned by, or in the care of, Prudential, including information related to the Company's operations and investments. This information security program provides for the coordination of various corporate functions and governance groups, including global technology, risk, legal, compliance and corporate audit, and serves as a framework for the execution of responsibilities across businesses and operational roles. Among other things, the information security program establishes security standards for Prudential's, the Manager's, their affiliates' and the Company's technological resources and includes training for employees, contractors and third parties. Employees of Prudential, as well as employees of the Manager and Subadviser, with access to Prudential's or its affiliates' systems are subject to comprehensive annual training on responsible information security, data security, and cybersecurity practices and how to protect data against cyber threats.


text: As part of the information security program, Prudential conducts periodic exercises with independent outside advisers to assess the effectiveness of its program and its internal response preparedness. Prudential regularly engages with the broader security community and monitors cyber threat information.


text: To address risks associated with third-parties, Prudential has established an enterprise-wide Third-Party Risk Management Program. This program's features include, among other things, identifying, assessing and managing cybersecurity risks throughout the life of our third-party relationships.


text: Prudential also maintains an incident response plan, which specifies escalation and evaluation processes for cyber events. This plan is executed in close coordination with Prudential's corporate functions, including a dedicated cyber and privacy law function, external affairs, and risk management, and is designed to ensure, among other things, appropriate and timely reporting and disclosure.


text: During the period covered by this Annual Report, we did not identify any cybersecurity threats that have materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial condition. See "Item 1A. Risk Factors—Risks Related to Market Events and Regulatory Developments— Cybersecurity and data protection risks could result in the loss of data, exposure of confidential information, interruptions in our business, and damage to our reputation, and subject us to regulatory actions, increased costs and financial losses, each of which could have a material adverse effect on our business and results of operations." for a discussion of risks related to cybersecurity.


text: Prudential's information security program is overseen by its Chief Information Security Officer ("CISO") and Information Security Office, as well as the Chief Information Officer ("CIO"), Stacey Goodman. Each of Prudential, the Manager, their affiliates and the Company believes that Prudential's employees and the employees of the Manager, Subadviser and their affiliates who provide services to the Company, respectively, responsible for managing cybersecurity risk have the skills and knowledge to assess and manage material risks from cybersecurity threats, and their qualifications include degrees and certifications typical for cybersecurity professionals. Prudential expects these employees to, among other things, understand computer systems, networks, and security technologies and be proficient in a variety of security tools and techniques, including intrusion detection, malware analysis and penetration testing. Prudential's CISO has served in various roles in information technology and information security for over 25 years, including serving as the head of information technology risk at two large public companies. Prudential's CISO holds a graduate degree in technology management and has attained the professional certifications of Certified Information Systems Security Professional and Certified Information Privacy Professional. Ms. Goodman, our CIO, was elected Executive Vice President and Chief Information Officer of Prudential and PICA in July 2019. Previously, she served as the Chief Information Officer at Freddie Mac, where she was responsible for the technology division, and served as a member of the Senior Operating Committee. Prior to Freddie Mac, Ms. Goodman was Executive Vice President and Chief Information and Operations Officer for CIT Group, Inc., where she was a member of the Executive Management Committee. Previously, Ms. Goodman was the Divisional Chief Information Officer of Global Technology and Operations at Bank of America. She also held global leadership positions at UBS and PaineWebber. Ms. Goodman began her career at Salomon Brothers.


text: The Board is responsible for understanding the primary risks to our business. The Board is responsible for reviewing periodically our and the Manager's and the Subadviser's information technology security controls and related compliance matters, with the Company's management. The Board receives periodic updates from Prudential's CISO, CIO and/or Operational Risk Management, or their designees, throughout the year. At least annually, the Board, or a committee thereof, also receives updates on cybersecurity matters, including risks facing the Company, the Manager and the Subadviser and, as applicable, certain incidents. In addition to such periodic updates, the Board or a committee thereof may receive updates from management as to our and the Manager's cybersecurity risks and Prudential cybersecurity program developments.


text: The Company has processes in place to assess, identify, and manage material risks from cybersecurity threats. The Company's business is dependent on the communications and information systems of the Adviser and other third-party service providers. The Adviser manages the Company's day-to-day operations and has implemented a cybersecurity program that applies to the Company and its operations.

companyName: Andalusian Credit Company, LLC


text: Cybersecurity Program Overview The Adviser has instituted a cybersecurity program designed to identify, assess, and manage cyber risks applicable to the Company and assists as necessary with the oversight of other third-party service providers and their cybersecurity programs as discussed further below. The Adviser's cyber risk management program involves risk assessments, implementation of security measures, and ongoing monitoring of systems and networks, including networks on which the Company relies. The Adviser actively monitors the current threat landscape in an effort to identify material risks arising from new and evolving cybersecurity threats, including material risks faced by the Company.


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


text: The Company depends on and engages various third parties, including suppliers, vendors, and service providers, to operate its business. The Company relies on the expertise of risk management, legal, information technology, and compliance personnel of the Adviser when identifying and overseeing risks from cybersecurity threats associated with its use of such entities. The Company's Chief Compliance Officer (" CCO ") also plays an oversight role in the area of cybersecurity preparedness with respect to these entities.


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


text: Management's Role in Cybersecurity Risk Management The Company's management, including the Company's CCO and the Adviser oversee the establishment of and adherence to the cybersecurity program and plays an oversight role regarding cybersecurity preparedness. Management of the Company is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents impacting the Company, including through the receipt of notifications from service providers and reliance on communications with risk management, legal, information technology, and/or compliance personnel of the Adviser.


text: The Company's CCO also plays a vital oversight role in the area of cybersecurity preparedness and the effective implementation of the cybersecurity program. The CCO has worked in the financial services industry for more than 30 years, during which time the CCO has gained expertise in assessing and managing regulatory compliance risk applicable to the Company.


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


text: Information systems and other technologies, including those related to the Corporation's information and operational technology systems, and its technical and environmental data, are an important part of the Corporation's business activities. We must comply with certain elevated contractual requirements, including those related to adequately safeguarding controlled unclassified information and reporting cybersecurity incidents to the DOD. We continue to implement cybersecurity processes designed to align with DOD requirements, instructions and guidance and work with the DOD as needed to assess cybersecurity risk and on policies and practices aimed at mitigating these risks. Accordingly, the Company maintains processes for assessing, identifying, and managing material risks from cybersecurity threats.

companyName: PERPETUA RESOURCES CORP.

ticker: PPTA


text: Such processes include the use of traffic monitoring tools, as well as training users to detect, report, and prevent unusual behavior. We also employ monitoring mechanisms to help us detect and respond to cybersecurity threats. We conduct regular assessments and testing of the effectiveness of these controls, including security audits, incident response planning, and regulatory compliance assessments. We seek to foster cybersecurity awareness and responsibility throughout the organization by regularly providing our employees with training on cybersecurity practices.


text: We use user access controls to limit unauthorized access to sensitive information and critical systems. In addition, we use multi-factor authentication for remote access, use of privileged accounts and access to critical systems. Encryption methods are used to protect sensitive data. This includes the encryption of customer data, financial information, and other confidential data. The implementation and management of these cybersecurity processes are integrated with the Company's overall operational risk management processes, which seeks to limit our exposure to unnecessary risks across our operations.


text: We maintain an incident response plan that outlines the steps to be taken in the event of a cybersecurity incident. Pursuant to the incident response plan, the identifying party is required to notify the Company's Chief Financial Officer ("CFO") and Board of Directors of certain cybersecurity incidents deemed to have a moderate or higher business impact, even if immaterial to us. The incident response plan also includes procedures for: Gathering information about the cybersecurity incident. Consulting with cybersecurity consultants and other parties to assess the cybersecurity incident.


text: Evaluating the materiality of the cybersecurity incident, determining whether there are disclosure obligations under applicable securities laws, and external reporting, as required.


text: We engage third party service providers including consultants and auditors in connection with the above processes. We recognize that third-party service providers introduce cybersecurity risks.


text: Impacts from Cybersecurity Threats As of the date of this Report, though the Company and our service providers have been subject to certain cybersecurity incidents, we are not aware of any previous cybersecurity threats that have materially affected or are reasonably likely to materially affect the Company. However, we acknowledge that cybersecurity threats are continually evolving, and the possibility of future cybersecurity incidents remains. Despite the implementation of our cybersecurity processes, our security measures cannot guarantee that a significant cyberattack will not occur. A successful attack on our information technology systems could have significant consequences to the business. For additional information about the risks to our business associated with a breach or compromise to our information technology systems, see Item 1A, Risk Factors – System security vulnerabilities, data breaches, and cyber-attacks could compromise proprietary or otherwise sensitive information or disrupt operations, which could adversely affect Perpetua Resources' business, reputation, operations, and stock price.


text: Our IT Systems Administrator is responsible for assessing and managing our risks from cybersecurity threats and oversees our cybersecurity program. The IT Systems Administrator reports directly to our CFO. Our IT Systems Administrator holds an associate degree in computer application and support and has served in various roles in information systems administration for over eight years, including roles involving managing information technology and systems and implementing cybersecurity programs.


text: Our full Board and our Audit Committee oversee risks from cybersecurity threats and our cybersecurity practices and policies. Accordingly, our CFO periodically updates the Board and Audit Committee on cybersecurity matters, including cybersecurity risks. Additionally, our Board and Audit Committee, as well as senior management, receive reports on an as-needed basis regarding our cybersecurity posture, cybersecurity incidents, and remediation efforts.


text: We recognize the importance of assessing, identifying, and managing material risks associated with cybersecurity threats, as such term is defined in Item 106(a) of Regulation S-K. These risks include, among other things: operational risks, intellectual property theft, fraud, extortion, harm to employees or customers and violation of data privacy or security laws.

companyName: Bluerock Homes Trust, Inc.

ticker: BHM


text: Identifying and assessing cybersecurity risk is integrated into our overall risk management systems and processes. We have an enterprise-wide information security program designed to identify, protect, detect, and respond to and manage reasonably foreseeable cybersecurity risks and threats. To protect our information systems from cybersecurity threats, we use various security tools that help prevent, identify, escalate, investigate, resolve, and recover from identified vulnerabilities and security incidents in a timely manner. These include, but are not limited to, incoming (external) physical infrastructure with enhanced firmware, continuous employee training, internal reporting, and monitoring and detection tools. We also engage top third-party security providers for applications and infrastructure to identify, prioritize, assess, mitigate, and remediate risks.


text: Our information technology ("IT") department regularly assess risks from cybersecurity and technology threats and monitors our information systems for potential vulnerabilities. We use a widely adopted risk quantification model to identify, measure and prioritize cybersecurity and technology risks and develop related security controls and safeguards. We conduct regular reviews and tests of our information security program, including but not limited to tabletop exercises, penetration and vulnerability testing, red team exercises, simulations, and other exercises to evaluate the effectiveness of our information security program and improve our security measures and planning.


text: We have implemented incident response and breach management processes which have four overarching and interconnected stages: (i) preparation for a cybersecurity incident, (ii) detection and analysis of a security incident, (iii) containment, eradication, and recovery, and (iv) post-incident analysis. Such incident responses are overseen by our Leadership Committee comprised of our Chief Operating Officer, Chief Financial Officer, General Counsel and Senior Vice President of FP&A.


text: Security events and data incidents are evaluated, ranked by severity, and prioritized for response and remediation. Incidents are evaluated to determine materiality as well as operational and business impact and reviewed for privacy impact.


text: As part of the above processes, we regularly engage external resources and consultants to assess our internal cybersecurity programs and compliance with applicable practices and standards.


text: Our risk management program also assesses third party risks, and we perform third-party risk management to identify and mitigate risks from key third parties such as vendors, suppliers, and other business partners. Cybersecurity risks are evaluated when determining the selection and oversight of applicable third-party service providers when handling and/or processing our employee, business, or customer data. In addition, we perform risk management during third-party cybersecurity compromise incidents to identify and mitigate risks to us from third-party incidents.


text: Management has not identified any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially affected or are reasonably likely to materially affect the Company, including its business strategy, results of operations or financial condition. See Item 1A. Risk Factors, " We are highly dependent on information systems and therefore systems failures, cybersecurity incidents or other technology disruptions could negatively impact our business" and "Security breaches and other disruptions could compromise our information and expose us to liability, which would cause our business and reputation to suffer." above for more information. While we continually work to safeguard the information systems we use, and the proprietary, confidential and personal information residing therein, and mitigate potential risks, there can be no assurance that such actions will be sufficient to prevent cybersecurity incidents or mitigate all potential risks to such systems, networks and data or those of our third-party providers.


text: Our Board holds oversight responsibility over our strategy and risk management, including material risks related to cybersecurity threats. This oversight is executed directly by the Board and through its committees. The Audit Committee meets annually to review enterprise security, technology risks and cybersecurity threats, risk assessments and areas of emerging risks, incidents and mitigation strategies, and industry trends.


text: Our IT department maintains internal and external resources and is led by our IT Manager and assisted by our Risk Assessment/IT Compliance & Enterprise Manager. These two individuals have a combined 40+ years of industry experience, including serving in similar roles leading and overseeing cybersecurity programs at other public companies. The IT department is responsible for the information security of the organization and for the oversight of all cybersecurity infrastructure and programs. The department provides regular reports to senior management and other relevant teams on various cybersecurity threats, assessments, and findings.


text: Our Leadership Committee is responsible for the oversight of risks from cybersecurity threats. The Leadership Committee receive updates on a quarterly basis from leaders of our IT department and compliance and legal teams regarding matters of cybersecurity. This includes existing and new cybersecurity risks, status on how management is addressing and/or mitigating those risks, cybersecurity, and data privacy incidents (if any) and status on key information security initiatives. Our Leadership Committee and IT department discuss cybersecurity-related current events and any updates to our cybersecurity risk management and strategy programs.


text: Management, in coordination with our IT department, is responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into our overall risk management strategy, and communicating key priorities to relevant personnel. Management is responsible for approving budgets, approving cybersecurity processes, and reviewing cybersecurity assessments and other cybersecurity-related matters.


text: As a shell company with no current business or operations, we do not have an established process to oversee and identify material risks from cybersecurity threats nor any board committee or subcommittee responsible for the oversight of risks from cybersecurity threats.

companyName: THEGLOBE COM INC

ticker: TGLO


text: The Bank is subject to ongoing cybersecurity incident and threat risk. A cybersecurity incident is an unauthorized occurrence, or a series of related unauthorized occurrences, through the Bank's information systems that jeopardizes the confidentiality, integrity, or availability of the Bank's information systems or any information residing therein. Cybersecurity threats are potential unauthorized occurrences on or conducted through the Bank's information systems that may result in adverse effects on the confidentiality, integrity, or availability of information systems or any information residing therein. Information systems are any electronic information resources, owned or used by the Bank, including physical or virtual infrastructure controlled by such information resources, or their components, organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of the Bank's information to maintain or support the Bank's operations. Please refer to "Risk Factors — Failure, breach, or cyberattack of the information systems of the FHLBNY could disrupt the FHLBNY's business or result in significant losses or reputational damage" in Part I, Section 1A of this Form 10-K for a description of cybersecurity incident and threat risk. The Bank has implemented processes for assessing, identifying, and managing material risks from cybersecurity threats or incidents that may directly or indirectly impact the Bank's business strategy, results of operations, or financial condition.

companyName: Federal Home Loan Bank of New York


text: The Bank's cybersecurity risk management framework for assessing, identifying, and managing material risks from cybersecurity threats is designed to protect the confidentiality, integrity, and availability of the Bank's information technology assets and data under the Bank's control.


text: Cybersecurity risk management is part of the Bank's Enterprise Risk Management program, which includes specific controls for the mitigation, monitoring and reporting associated with those risks. The program is supported by a robust set of policies and procedures, skilled staff, layered technical defenses, employee training, and oversight of third parties.


text: The Bank's Information Security Policy establishes administrative, technical, and physical safeguards designed to protect the security, confidentiality, and integrity of Bank information in accordance with the Gramm-Leach-Bliley Act, the interagency guidelines issued thereunder, and other applicable laws and regulations. The Technology Committee of the Board of Directors ("Board") also annually reviews and approves the Bank's Information Security Policy.


text: The Bank's cyber incident response plan determines how cybersecurity threats and incidents are identified, classified, and escalated, including for the purposes of reporting, and providing relevant information to the Board. The cyber incident response plan also stipulates management assessment of the materiality of each identified threat or incident for the purposes of such reporting.


text: The Bank's business continuity program is designed to ensure that necessary resources are in place to protect the Bank from potential loss during a disruption, which includes the unavailability of information technology assets due to unintentional occurrences like weather-related events, fire, power loss, and technical incidents such as hardware failures. The business continuity program is overseen by the Technology Committee of the Board and includes, among other items, business impact analysis for developing effective plans, including disaster recovery plans, to respond, recover, resume, and restore technology assets critical to the Bank's operations. Elements of this plan may be leveraged in support of recovery from a cyber incident that disables critical infrastructure.


text: The Bank leverages audits and external reviews to strengthen its program. Those reviews include internal audits and reviews by the Bank's Risk Management function, SOX audits, penetration tests, and external benchmarking reviews based on the National Institute of Standards and Technology ("NIST") and the International Organization for Standardization ("ISO") standards. Those reviews assist the Bank in assessing, identifying, and managing cybersecurity incident and threat risk.


text: The Bank's cyber incident response plan includes third-party cybersecurity incidents and threats. The Bank undertakes due diligence of third-party systems with which the Bank will interact, in addition to requiring data protection covenants in its vendor agreements. The Bank's vendor risk management program includes regular reviews and oversight of these service providers, including performance and technological reviews and escalation of any unsatisfactory reviews.


text: During the period covered by this report, risks from cybersecurity threats did not have a material impact on the Bank's strategy, results of operations, or financial condition. The Bank has experienced minor cybersecurity incidents in the past, though none that have had a material effect on the Bank's financial condition or results of operations.


text: It is inevitable that additional cybersecurity incidents will occur in the future and any such cybersecurity incident could result in significantly harmful consequences to the Bank, the Bank's members, and their customers. We assess the materiality of any such cybersecurity incident from several perspectives including, but not limited to, the Bank's ability to continue to service the Bank's members and protect the privacy of the data their customers have entrusted to us, lost revenue, disruption of business operation, increased operating costs, litigation, and reputational harm.


text: The Bank's Board devotes significant time and attention to data and systems protection, including protection from cybersecurity and information security risk. The Board oversees the Bank's information security program through setting of policies and principles including the Bank's Information Security Policy and Enterprise Risk Management program. The Board also oversees management's approach to staffing, policies, processes, and practices to gauge and address cybersecurity and information security risk.


text: The Risk Committee of the Board has oversight of the Bank's Risk Management Program, which includes risks from cybersecurity threats within cybersecurity risk management. The Technology Committee of the Board has responsibility for the strategic design, direction and oversight of the Bank's information and cybersecurity program.


text: The Bank's Information Security Department is led by the Bank's Chief Information Security Officer ("CISO"). The CISO reports to the Chief Information Officer ("CIO"), with an open line of communication to the Bank President. The Bank also has an internal cross-functional committee – the internal Technology and Operations Committee –which is responsible for, among other activities, overseeing information and cybersecurity risks and the steps taken by management to understand and mitigate such risk. This Committee reports to the Bank's Management Committee.


text: The Bank's Technology and Operations Committee is responsible for approving the Bank's cyber incident response plan and other technical processes and standards to implement the policies and procedures defined in the cybersecurity risk management program. The Risk Management function is responsible for management of operational risk and implementation of the cybersecurity risk management framework within the Risk Management Program as approved by the Board.


text: The Bank's Technology and Operations Committee is made up of members of the Bank's leadership, including the Bank's CIO, CISO, other information technology and information security leadership, and leadership representatives from the Bank's operational risk, information security, information technology, operations, and other departments throughout the Bank.


text: The Bank has an Information Security Department comprised of specialized professionals that is responsible for the day-to-day, hands-on management of cybersecurity risk and that handles the processes and procedures to mitigate and implement protective, proactive and reactive measures to protect the Bank against those risks. The Bank's Information Security Department is responsible for developing, documenting, and approving the Bank's technical information security control standards, guidelines, and procedures designed to preserve the confidentiality, integrity, and availability of the Bank's information technology assets and data under the Bank's control.


text: The Bank's CIO has over 35 years of experience in Financial IT and has overseen Information Security programs in large financial institutions since 2003.


text: The Bank's CISO has held that position at the Bank since 2020 and has 30 years of experience in IT, including 18 years of experience in building and overseeing Information Security and Cybersecurity programs.


text: The Technology and Operations Committee receives regular and prompt information from the Information Security Department as reported by the CISO, who in turn provides periodic, regular and prompt reporting to the Management Committee on topics such as threat intelligence, major cybersecurity risk areas, technologies and best practices, and any cybersecurity incidents that may have impacted the Bank.


text: The Board receives prompt and timely information from the Bank's CISO on any cybersecurity or information security incident that may pose significant risk to the Bank and continues to receive regular reports on each such incident until its conclusion. The Bank's Board also receives regular presentations and reports throughout the year on cybersecurity and information security risk. These presentations and reports address a broad range of topics, including updates on technology trends, regulatory developments, legal issues, policies and practices, information security resources and organization, the threat environment and vulnerability assessments, and specific and ongoing efforts to prevent, detect, and respond to internal and external incidents and critical threats. At least quarterly, the Board discusses cybersecurity and information security risks with the Bank's CIO and CISO.


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

companyName: Spark I Acquisition Corp

ticker: SPKL


text: Although, as a blank check company, we do not have any operations, we are nonetheless subject to the risk of cybersecurity incidents. Among other things, the investments in our Trust Account and bank deposits may be vulnerable to such incidents, and we may depend on the digital technologies of third parties. We and third parties may be subject to cybersecurity attacks or security breaches. To the extent that we rely on the technologies of third parties, we depend upon the personnel and the processes of such third parties to protect against cybersecurity incidents, and we have no personnel or processes of our own for this purpose. In the event of a cybersecurity incident impacting us, our Management Team will report to the Board of Directors and provide updates on the Management Team's incident response plan for addressing and mitigating any risks associated with such an incident. As an early-stage company without significant investments in data security protection, we may not be sufficiently protected against such occurrences. We also lack sufficient resources to adequately protect against, or to investigate and remediate any vulnerability to, cyber incidents. It is possible that any of these occurrences, or a combination of them, could have material adverse consequences on our business and lead to financial loss. We have not encountered any cybersecurity incidents since our Initial Public Offering. In addition to our own cybersecurity risks, any proposed Business Combination target may have been subject to, or may in the future be subject to, cybersecurity incidents.

companyName: Melar Acquisition Corp. I/Cayman

ticker: MACI


text: As an externally managed company, our day-to-day operations are managed by BFIM, under the supervision and with the participation of the Principal Executive Officer and Principal Accounting and Financial Officer. Our business is highly dependent on the communications and information systems of BFIM, its affiliates and third-party service providers. BFIM is an affiliate of ORIX Corporation USA ("ORIX USA"), a diversified financial company and a subsidiary of ORIX Corporation ("ORIX") and participates in and is subject to ORIX USA's cybersecurity program. Accordingly, we rely and BFIM relies on ORIX USA and its cybersecurity risk management program to identify, assess and manage material risks to our business from cybersecurity threats.

companyName: BCTC IV ASSIGNOR CORP


text: To date, Cybersecurity threats, including any previous Cybersecurity incidents, have not had a material impact nor, are they anticipated to significantly affect the Assignor Limited Partner, including our business strategy, results of operations or financial condition.


text: The Assignor Limited Partner, under the supervision and with the participation of the Principal Executive Officer and Principal Accounting and Financial Officer, is responsible for directing and overseeing our risk management. The Principal Executive Officer and Principal Accounting and Financial Officer administers this oversight function directly. In particular, the Principal Executive Officer and Principal Accounting and Financial Officer has the responsibility to consider and discuss our major financial risk exposures and the steps BFIM takes, or is required to take, to monitor and control these exposures, including guidelines and policies to govern the process by which risk assessment and management is undertaken. The Principal Executive Officer and Principal Accounting and Financial Officer also monitors compliance with legal and regulatory requirements.


text: BFIM is responsible for identifying, assessing, and managing the Assignor Limited Partner's material risks from cybersecurity threats. BFIM relies on ORIX USA and the ORIX USA information and security team, including the ORIX USA CIO, to provide us with a comprehensive cybersecurity risk management program.


text: Periodically, at least annually, ORIX USA's CIO and/or other members of the ORIX USA information and cybersecurity team will present to BFIM on various topics relating to ORIX USA's technology risks, including ORIX USA's cybersecurity program (including the results of cybersecurity tabletop exercises), cybersecurity issues (including those relating to data protection, insider threats, regulatory changes and geopolitical cyber threat management) and risk management (including the results of periodic technology audits).


text: Cybersecurity Risk Management and Strategy ORIX USA has a Chief Information Officer (the "ORIX USA CIO"), who leads an information and cybersecurity team (the "ORIX USA information and cybersecurity team") responsible for managing information security at ORIX USA's asset management business, including its Cybersecurity strategy and program, which encompasses annual employee training about Cybersecurity risks and new employee onboarding about ORIX USA's security policies. The ORIX USA information and cybersecurity team's responsibilities cover three main areas: (i) operations and engineering, (ii) threat detection and response, and (iii) governance. The team comprises members with diverse and relevant skill sets and expertise. The ORIX USA CIO leads the cybersecurity team with over twenty years of experience at ORIX USA and prior experience as a principal with a large management consulting firm. This team has developed a program aligned with the NIST CSF framework, emphasizing training and development, with team members holding industry-recognized certifications complemented by industry-recognized third-party providers for threat and incident management.


text: ORIX USA employs a 'defense in depth' cybersecurity strategy and program based on the NIST Cybersecurity Framework, which includes multiple layers of security policies, protections, and controls designed to safeguard the confidentiality, integrity, and availability of infrastructure, network and information assets from malware and threats. This includes the deployment of firewalls, email protection technologies and web gateway, antivirus, and endpoint detection and response ("EDR") systems.


text: Our firewalls (intrusion detection systems and intrusion prevention systems) are designed to secure the organization's perimeter complemented by an antivirus and EDR platform designed to detect malware and threats on systems. Web application firewalls are designed to protect external facing applications, while our email security gateway utilizes machine learning and multilayered detection techniques designed to filter malicious emails.


text: Mobile device management software monitors security events via a Security Information and Event Management platform, managed by a detection and response provider. Mobile device management software is employed with the objective of protecting corporate email and data on mobile devices and is designed to prevent unauthorized data transfer.


text: ORIX USA maintains a Cybersecurity incident response capability that includes detailed policies, plans and modular run books and maps designed around different types of Cyber Incidents. The plan and run books are tested annually through Cybersecurity tabletop simulations where incident response technical, and executive team members go through real-world scenarios focused on current Cyber threats. ORIX USA's Cybersecurity incident response plan provides for escalation of identified Cybersecurity threats and incidents, including, as appropriate, to our management. These discussions provide a mechanism for the identification of Cybersecurity threats and incidents, assessment of Cybersecurity risk profile or certain newly identified risks relevant to our company, and evaluation of the adequacy of our Cybersecurity program, including risk mitigation, compliance and controls. ORIX USA has established a notification decision framework to determine when the notifications regarding certain cybersecurity incidents, with different severity thresholds triggering notification to different recipient groups, including BFIM and the Principal Executive Officer and Principal Accounting and Financial Officer of the Assignor Limited Partner.


text: For information about risks from cybersecurity threats, see the Windstream Prospectus, under the caption "Risk Factors—Risks Related to the Merger—Cybersecurity incidents could have a material adverse effect on New Uniti's business, results of operations and financial condition."

companyName: Uniti Group Inc.

ticker: UNIT


text: The information required by Item 106 of Regulation S-K is included throughout the Prospectus and is incorporated by reference herein.


text: The Company has processes in place to assess, identify, and manage material risks from cybersecurity threats. The Company's business is dependent on the communications and information systems of the Investment Adviser and other third-party service providers. The Investment Adviser manages the Company's day-to-day operations and has implemented a cybersecurity program that applies to the Company and its operations.

companyName: Brightwood Capital Corp I


text: Cybersecurity Program Overview The Investment Adviser has engaged a managed service provider to provide comprehensive information technology services (the "IT MSP"), including services related to cybersecurity. The Investment Adviser, in conjunction with IT MSP, has instituted a cybersecurity program designed to identify, assess, and mitigate cyber risks applicable to the Company. The cyber risk management program involves risk assessments, implementation of security measures, and ongoing monitoring of systems and networks, including networks on which the Company relies. The Investment Adviser, in conjunction with IT MSP, actively monitors the current threat landscape in an effort to identify material risks arising from new and evolving cybersecurity threats, including material risks faced by the Company.


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


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


text: Board Oversight of Cybersecurity Risks The Board provides strategic oversight on cybersecurity matters, including risks associated with cybersecurity threats. The Board receives updates from the Company's Chief Compliance Officer ("CCO") regarding the overall state of the Investment Adviser 's cybersecurity program and cybersecurity incidents impacting the Company, if any.


text: Management's Role in Cybersecurity Risk Management The Company relies on the Investment Adviser and IT MSP to assess and manage material risks from cybersecurity threats. Management of the Company is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity risks and incidents, if any, impacting the Company, including through the receipt of notifications from service providers and reliance on communications with risk management, legal, information technology, and/or compliance personnel of the Investment Adviser.


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


text: The Company has processes in place to assess, identify, and manage material risks from cybersecurity threats. The Company's business is dependent on the communications and information systems of the Adviser and other third-party service providers. The Adviser manages the Company's day-to-day operations and has implemented a cybersecurity program that applies to the Company and its operations.

companyName: Stone Point Credit Corp


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


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


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


text: Board Oversight of Cybersecurity Risks The Board provides strategic oversight on cybersecurity matters, including risks associated with cybersecurity threats. The Board receives periodic updates from the Company's Chief Compliance Officer and Adviser's Director of IT regarding the overall state of the Adviser's cybersecurity program, information on the current threat landscape, and risks from cybersecurity threats and any cybersecurity incidents impacting the Company.


text: Management's Role in Cybersecurity Risk Management The Adviser's Director of IT and internal cybersecurity team are responsible for the cybersecurity program applicable to the Company (including enterprise-wide cybersecurity strategy, policies, standards, engineering, architecture, and processes), and along with the Company's CCO, are responsible for assessing and managing material risks from cybersecurity threats that impact the Company. The Adviser's Director of IT has more than 25 years of experience advising on and managing risks from cybersecurity. The Adviser's Director of IT works closely with Company management to administrator, assess, discuss, and prioritize the Company's cybersecurity efforts. The Company's Chief Compliance Officer oversees the Company's oversight function generally and relies on the Adviser's Director of IT to assist with assessing and managing material risks from cybersecurity threats. The Company's Chief Compliance Officer has been responsible for this oversight function as Chief Compliance Officer since his appointment and has worked in the financial services industry for more than 15 years, during which time the Chief Compliance Officer has gained expertise in assessing and managing risk applicable to the Company.


text: The Company's management is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents impacting the Company, including through the receipt of notifications from service providers and reliance on communications with information technology, legal and compliance personnel of the Adviser.


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


text: For purposes of Item 106 of Regulation S-K, "cybersecurity threat" means any potential unauthorized occurrence on or conducted through a company's information systems that may result in adverse effects on the confidentiality, integrity or availability of a company's information systems or any information residing therein.

companyName: Emeren Group Ltd


text: A "cybersecurity incident" means an unauthorized occurrence, or a series of related unauthorized occurrences, on or conducted through a company's information systems that jeopardizes the confidentiality, integrity or availability of a company's information systems or any information residing therein.


text: The term "information systems" means electronic information resources, owned or used by the company, including physical or virtual infrastructure controlled by such information resources, or components thereof, organized for the collection, processing, maintenance, use, sharing, dissemination or disposition of the company's information to maintain or support the company's operations.


text: The Company's Board of Directors (the "Board") recognizes the critical importance of maintaining the trust and confidence of our customers, clients, business partners and employees. The Board is actively involved in oversight of the Company's risk management program, and cybersecurity represents an important component of the Company's overall approach to enterprise risk management ("ERM"). The Company's cybersecurity policies, standards, processes, and practices are fully integrated into the Company's ERM program and are based on recognized frameworks established by the National Institute of Standards and Technology, the International Organization for Standardization and other applicable industry standards. In general, the Company seeks to address cybersecurity risks through a comprehensive, cross-functional approach that is focused on preserving the confidentiality, security and availability of the information that the Company collects and stores by identifying, preventing and mitigating cybersecurity threats and effectively responding to cybersecurity incidents when they occur.


text: As one of the critical elements of the Company's overall ERM approach, the Company's cybersecurity program is focused on the following key areas:


text: As discussed in more detail under the heading "Governance," The Board's oversight of cybersecurity risk management is supported by the Risk Management Committee of the Board (the "Risk Management Committee"), which regularly interacts with the Company's ERM function, other members of management and relevant management committees and councils, including management's Cybersecurity Council.


text: Collaborative Approach: The Company has implemented a comprehensive, cross-functional approach to identifying, preventing and mitigating cybersecurity threats and incidents, while also implementing controls and procedures that provide for the prompt escalation of certain cybersecurity incidents so that decisions regarding the public disclosure and reporting of such incidents can be made by management in a timely manner.


text: Technical Safeguards: The Company deploys technical safeguards that are designed to protect the Company's information systems from cybersecurity threats, including firewalls, intrusion prevention and detection systems, anti-malware functionality and access controls, which are evaluated and improved through vulnerability assessments and cybersecurity threat intelligence.


text: The Company has established and maintains comprehensive incident response and recovery plans that fully address the Company's response to a cybersecurity incident, and such plans are tested and evaluated on a regular basis.


text: The Company maintains a comprehensive, risk-based approach to identifying and overseeing cybersecurity risks presented by third parties, including vendors, service providers and other external users of the Company's systems, as well as the systems of third parties that could adversely impact our business in the event of a cybersecurity incident affecting those third-party systems.


text: The Company provides regular, mandatory training for personnel regarding cybersecurity threats as a means to equip the Company's personnel with effective tools to address cybersecurity threats, and to communicate the Company's evolving information security policies, standards, processes and practices.


text: The Company engages in the periodic assessment and testing of the Company's policies, standards, processes and practices that are designed to address cybersecurity threats and incidents. These efforts include a wide range of activities, including audits, assessments, tabletop exercises, threat modeling, vulnerability testing and other exercises focused on evaluating the effectiveness of our cybersecurity measures and planning. The Company regularly engages third parties to perform assessments on our cybersecurity measures, including information security maturity assessments, audits and independent reviews of our information security control environment and operating effectiveness. The results of such assessments, audits and reviews are reported to the Risk Management Committee and the Board, and the Company adjusts its cybersecurity policies, standards, processes and practices as necessary based on the information provided by these assessments, audits and reviews.


text: The Board, in coordination with the Risk Management Committee, oversees the Company's ERM process, including the management of risks arising from cybersecurity threats. The Board and the Risk Management Committee each receive regular presentations and reports on cybersecurity risks, which address a wide range of topics including recent developments, evolving standards, vulnerability assessments, third-party and independent reviews, the threat environment, technological trends and information security considerations arising with respect to the Company's peers and third parties. The Board and the Risk Management Committee also receive prompt and timely information regarding any cybersecurity incident that meets established reporting thresholds, as well as ongoing updates regarding any such incident until it has been addressed. On an annual basis, the Board and the Risk Management Committee discuss the Company's approach to cybersecurity risk management with the members of the Cybersecurity Council (Risk Management Team), which includes the Company's Information Technology Engineer ("IT Engineer"), Compliance Officer and Chief Financial Officer ("CFO"). The Risk Management Team continuously monitors cybersecurity risks and implements updates to enhance the Company's IT security framework. Additionally, the Compliance Officer issues quarterly reminders to all employees regarding cybersecurity practices and wire fraud prevention measures.


text: The IT Engineer, in coordination with the Cybersecurity Council, which includes our Chief Executive Officer ("CEO"), CFO and Compliance Director works collaboratively across the Company to implement a program designed to protect the Company's information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents in accordance with the Company's incident response and recovery plans. To facilitate the success of the Company's cybersecurity risk management program, multidisciplinary teams throughout the Company are deployed to address cybersecurity threats and to respond to cybersecurity incidents. Through ongoing communications with these teams, the IT Engineer and the Cybersecurity Council monitor the prevention, detection, mitigation and remediation of cybersecurity threats and incidents in real time and report such threats and incidents to the Risk Management Committee when appropriate.


text: The Company's IT Engineer, CEO, CFO and Compliance Director each hold undergraduate and graduate degrees in their respective fields, and each have over 25 years of experience managing risks at the Company and at similar companies, including risks arising from cybersecurity threats.


text: Previous cybersecurity incidents have not materially affected us, including our business strategy, results of operations or financial condition. However, risks from cybersecurity threats could harm our business and could have a material adverse effect on our business, prospects, liquidity, financial condition and results of operations. See "Information system failures, cyber incidents or breaches in security could adversely affect us" under Item 1A. Risk Factors for a discussion of cybersecurity risks.


text: We recognize the critical importance of developing, implementing, and maintaining robust cybersecurity measures to maintain the security, confidentiality, integrity, and availability of our business systems and confidential information, including personal information and intellectual property. Our cybersecurity program includes systems and processes for assessing, identifying and managing material risks from cybersecurity threats and include maintenance and monitoring of information security policies aligned with Information Technology controls; user and employee awareness of cyber policies and practices; information systems configuration management; infrastructure security systems; and cyber threat operations with continuous monitoring and threat hunting. This program includes processes to oversee and identify material risks from cybersecurity threats associated with our use of third party service providers. We also engage a range of third party experts in connection with various security implementation, and maintenance activities related to our cybersecurity program.

companyName: CYPHERPUNK TECHNOLOGIES INC.

ticker: CYPH


text: Our cybersecurity program is integrated into our overall risk management systems, business continuity and incident response plan. As part of our overall risk management program, we maintain an insurance portfolio with comprehensive cyber coverage. Our Director of Information Technology consults with third - party security advisors and provides input to each of these programs to ensure that material risks from cybersecurity threats are appropriately assessed, identified, and managed.


text: As of the date of this report, there have been no cybersecurity threats that have materially affected or are reasonably likely to materially affect our business, operations, or financial condition.


text: While our audit committee has oversight responsibility for risk management generally, the Director of Information Technology is specifically responsible for overseeing our cybersecurity program to ensure that cybersecurity risks are identified, assessed, managed, and monitored. Our Director of Information Technology provides periodic updates to senior management in this regard and covers the state of our cybersecurity program to information asset protection, core security and endpoint security, and cyber threat operations. These updates include descriptions of cybersecurity incidents of interest, including those associated with our third - party service providers. The board of directors will be informed promptly of material risks from cybersecurity threats.


text: We strive to create a culture of cybersecurity resilience and awareness and believe that cybersecurity is the responsibility of every employee and contractor. At the same time, primary responsibility for assessing, monitoring, and managing our cybersecurity risks lies with our Director of Information Technology.


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

companyName: Jaws Mustang Acquisition Corp

ticker: JWSMF


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

companyName: Summit Healthcare REIT, Inc


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


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


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