CISO Tribune

Disclosure · Form 10-K · fiscal 2026

Kentucky First Federal Bancorp 10-K cybersecurity disclosure (Item 1C), fiscal 2026

Filed September 28, 2026· period ended June 30, 2026· KFFB· CIK 1297341· Updated · filing on sec.gov ↗

Kentucky First Federal Bancorp's Form 10-K for fiscal 2026, filed September 28, 2026, names the Information Security Officer as its top security role, reporting to the CEO, with oversight by the Audit Committee.

What Kentucky First Federal Bancorp's Item 1C says

Kentucky First Federal Bancorp's Form 10-K for fiscal 2026 places oversight of cybersecurity risk management with the Board. The filing says primary responsibility for assessing and directing the cybersecurity program resides with the company's ISO.

Board and management oversight

The Technology Steering Committee consists of the ISO, other information security staff, and members of senior management, who meet regularly. Reports of these meetings are shared with the boards of the company's subsidiary banks. The ISO plays a role in informing the Board of Directors on cybersecurity risks. The Board takes part in strategic decisions related to cybersecurity, offering guidance and approval for major initiatives.

Who leads security

The ISO reports directly to the CEO. The ISO meets regularly with the CEO to update and discuss cybersecurity risks and incidents affecting the company. The ISO's experience includes prior leadership roles within the company, where the ISO developed an expert level of understanding of the intersection between financial regulations and cloud-based technologies.

How the company manages cyber risk

The company has developed an Incident Response Plan to guide its actions in responding to real and suspected information security incidents. Material cybersecurity threats are escalated and communicated directly to the Incident Response Team. Tabletop exercises are held regularly at the senior and executive management levels to validate roles and responsibilities. The process involves regular examinations of emerging threats, penetration tests and vulnerability scanning. The ISO and the Tech Steering Committee oversee governance programs and have developed the company's employee security awareness training program.

Third parties and incidents

The company has a third-party risk management program to identify, assess, monitor and mitigate risks associated with third-party relationships, including cybersecurity risks. Under the program, risk ratings are assigned to each of the vendors based on an assessment of the vendor and its access to networks, systems, and confidential information. Third parties with access to the company's systems or customer data must have appropriate technical and organizational security measures based on commercially acceptable security standards. The company has not experienced any material losses relating to cybersecurity threats or incidents for the year ended June 30, 2026.

What the section does not state

The section does not name the person who holds the top security role.

Read from the Form 10-K filed September 28, 2026, on . Every sentence rests on a passage of the section reproduced below.

The filing's fields, each with its sentence

Who leads security (the top role, as the filing names it)

Information Security Officer

Reports to

CEO

“The ISO directly reports to the CEO.”

Board oversight

Audit Committee

“Committee reports provide comprehensive briefings to both the Board and the Audit Committee as part of management's reporting.”

CISO or other person named

not identified

Frameworks and standards named

not identified

Outside assessors, consultants or testers

not identified

Experience of the security leadership, as stated

Stated

“The ISO's experience includes prior leadership roles within the Company, where they developed an expert level of understanding of the intersection between financial regulations and cloud-based technologies.”

Material incident

The filing states none

“We are not aware of 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 our business strategy, results of operations or financial condition.”

The section

1,222 words, Form 10-K filed September 28, 2026 for the period ended June 30, 2026

Read by claude-sonnet-5-5 on November 8, 2026; every quote verified in the stored text by code.

How peers in the same industry describe the seat

The SEC assigns Kentucky First Federal Bancorp standard industrial classification 6035, Savings institution, federally chartered (SEC SIC list). 3 other filers in our library have the same code. Also shown: filers whose codes the SEC assigns to the same review office (Office of Finance).

FilerTop security roleReports toBoard oversight
Broadway Financial Corp \DE\FY 2025, filed March 31, 2026Director of Information TechnologyChief Financial OfficerRisk and Compliance Committee
BankUnited, Inc.FY 2025, filed February 26, 2026CISOCRORisk Committee of the Board of Directors
Magyar Bancorp, Inc.FY 2025, filed December 19, 2025Information Security Officernot identifiedfull board
FilerTop security roleReports toBoard oversight
QDM International Inc.FY 2026, filed June 29, 2026responsible offerChief Executive Officernot identified
Roadzen Inc.FY 2026, filed June 29, 2026not identifiednot identifiedcorporate governance committee
StepStone Group Inc.FY 2026, filed May 27, 2026Partner, Chief Information Security Officer & Head of Information TechnologyPresident and Co-Chief Operating Officeraudit committee
Hamilton Lane IncFY 2026, filed May 21, 2026head of end user technology and information securitynot identifiedaudit committee
Triller Group Inc.FY 2025, filed April 14, 2026Group Chief Information Officernot identifiedaudit committee

Item 1C, verbatim from the filing

The text below is the Cybersecurity item of Kentucky First Federal Bancorp's Form 10-K as filed with the SEC on September 28, 2026, reproduced word for word from the filing on sec.gov. Page numbers and navigation lines have been removed; nothing has been added. It describes governance as of that date.

Item 1C. Cybersecurity .

Cybersecurity Risk Management and Strategy

The Company regards information and data as valuable assets. As a result, we have implemented safeguards to protect corporate information and data assets. Associated and established technology resources maintain the integrity, availability, and privacy of confidential information of the respective assets. Additionally, we maintain a similar risk-based approach to our third-party vendors including identifying and overseeing cybersecurity risks they present.

Integration into Overall Risk Management System

The Company employs comprehensive methodologies for risk assessment and diligently identifies and evaluates potential cybersecurity threats and vulnerabilities across our systems, networks and data assets. This process involves regular examinations of emerging threats, conducting penetration tests, vulnerability scanning and thorough analysis of industry-specific risks.

The Company continues to expand investments in information technology security, including continuous end-user training, layered defenses, identifying and protecting critical assets, strengthening monitoring and alerting.

The Company's Information Security Officer ("ISO") is responsible for completing additional mandatory training to understand the processes, procedures, and technical requirements for securing information assets across the Company.

The Company has developed an Incident Response Plan to guide its actions in responding to real and suspected information security incidents. This includes unlawful, unauthorized, or unacceptable actions that involve a computer system or a computer network such as Distributed Denial of Service attacks, Corporate Account Takeover schemes, or ransomware. Cybersecurity threats that are identified and deemed material are escalated and communicated directly to the Incident Response Team, in collaboration with relevant information technology personnel, insurance providers, legal counsels and when necessary, external cybersecurity firms specializing in forensic investigations.

The Company sets forth enterprise-wide coordinated responses to identified threats, ensuring timely mitigation and remediation, and facilitating awareness and communication. Tabletop exercises are held regularly at the senior and executive management levels to validate roles and responsibilities, and response protocols respective to cybersecurity threats.

Third-party Access

The Company has a fully integrated third-party risk management program to identify, assess, monitor and mitigate risks associated with third-party relationships, including cybersecurity risks. Under the program, risk ratings are assigned to each of the vendors based on an assessment of the vendor and its access to networks, systems, and confidential information. An assessment is conducted on each vendor to identify and measure the risks from cybersecurity threats that could impact our customer's data and our environment. Third parties that have access to our systems or customer data must have appropriate technical and organizational security measures and security control principles based on commercially acceptable security standards, and we require third parties in this class to agree by contract to manage their cybersecurity risks.

Material Cybersecurity Threat Risks

The Company has not experienced any material losses relating to cybersecurity threats or incidents for the year ended June 30, 2026. We are not aware of 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 our business strategy, results of operations or financial condition. Although we have a robust cybersecurity program that is designed to assess, identify, and manage material risks from cybersecurity threats, we cannot provide absolute surety that we have properly identified or mitigated all vulnerabilities or risks of incidents. The Company, and the third parties that the Company engages, are subject to constant and evolving threats of attack and cybersecurity incidents may be more difficult to detect for periods of time. A cybersecurity incident could harm our business strategy, results of operations, financial condition, reputation, and/or subject us to regulatory actions or litigation which may result in fines, judgments or indictments.

Cybersecurity Governance

The Board of Directors is acutely aware of the critical nature of managing risks associated with cybersecurity threats. The Board has oversight responsibilities to ensure effective governance in managing these risks because it recognizes the significance of these threats to our operational integrity, shareholder and customer confidence and reputation.

Board of Directors Oversight

The Board is responsible for the oversight of cybersecurity risk management and is composed of members with expertise in risk management, technology, and finance, thereby equipping them to manage and prevent cybersecurity risks effectively.

Management's Role in Managing Risk

The ISO plays a pivotal role in informing the Board of Directors on cybersecurity risks. The ISO, other information security staff, and members of senior management meet regularly as the Technology Steering Committee. Reports of their meetings are shared with the boards of our subsidiary banks. Committee reports provide comprehensive briefings to both the Board and the Audit Committee as part of management's reporting. These briefings encompass a broad range of topics, including:

● Current cybersecurity landscape and emerging threats;

● Status of ongoing cybersecurity initiatives and strategies;

● Incident reports and issues identified from any cybersecurity events; and

● Compliance with regulatory requirements and industry standards.

In addition to our regularly scheduled Board meetings, the ISO regularly communicates with senior staff regarding emerging or potential cybersecurity risks. They discuss any significant developments in the cybersecurity domain, which when reported to the Board, ensures the Board's oversight is proactive and responsive. The Board actively participates in strategic decisions related to cybersecurity, offering guidance and approval for major initiatives. This involvement ensures that cybersecurity considerations are integrated into the broader strategic objectives of the Company. The Board closely reviews these reports of the Bank's cybersecurity posture and the effectiveness of its risk management strategies prior to approval. This review helps in identifying areas for improvement and ensuring the alignment of cybersecurity efforts with the overall risk management framework.

Cyber Risk Management Personnel

The ISO directly reports to the CEO. The ISO regularly meets with the CEO to update and discuss any cybersecurity risks and incidents affecting the Company. This ensures that the highest levels of management are kept abreast of the cybersecurity posture and potential risks facing the Company. Furthermore, all significant cybersecurity matters and strategic risk management decisions are promptly escalated to the Board of Directors, ensuring that they have an up-to-date, comprehensive understanding of and can provide guidance on critical cybersecurity issues.

Primary responsibility for assessing and providing strategic direction to our cybersecurity program resides with our ISO. The ISO's experience includes prior leadership roles within the Company, where they developed an expert level of understanding of the intersection between financial regulations and cloud-based technologies. The ISO and other information systems staff possess in-depth knowledge and experience which are instrumental in developing and executing our cybersecurity strategies. The ISO and the Tech Steering Committee oversee our governance programs, work with our technology-focused leaders and partners to align security and compliance, and have developed our employee security awareness training program.

Monitoring Cybersecurity Incidents

The ISO and other information security staff utilizes vendor relationships and various other internet based daily updates for the latest developments in cybersecurity, including potential threats and innovative risk management techniques. This knowledge is crucial for the effective prevention, detection, mitigation, and remediation of cybersecurity incidents. The ISO provides structure for clear processes to ensure the regular monitoring of our information systems. This includes the deployment of advanced security measures and regular system audits to identify potential vulnerabilities. In the event of a cybersecurity incident, we believe we are equipped with a well-defined Incident Response Plan that is adequately resourced. This plan includes immediate actions to mitigate the impact and long-term strategies for remediation and prevent future incidents.

Earlier filings on record

Fiscal 2025 Form 10-K, filed September 30, 2025 sec.gov ↗

Top security role, as the filing names it

Information Security Officer

Reports to, as the filing names it

CEO

“The ISO directly reports to the CEO.”

Board oversight

Audit Committee

“Committee reports provide comprehensive briefings to both the Board and the Audit Committee as part of managements reporting.”

Person named in the filing

not identified

Experience, as stated

Stated

“The ISO's experience includes prior leadership roles within the Company, where they developed an expert level of understanding of the intersection between financial regulations and cloud-based technologies.”

Material incident

The filing states none

“We are not aware of 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 our business strategy, results of operations or financial condition.”

Read by claude-sonnet-5-5 on November 8, 2026; every quote verified in the stored text by code.

Item 1C. Cybersecurity .

Cybersecurity Risk Management and Strategy

The Company regards information and data as valuable

assets. As a result, we have implemented safeguards to protect corporate informational and data assets. Associated and established technology

resources maintain the integrity, availability, and privacy of confidential information of the respective assets. Additionally, we maintain

a similar risk-based approach to our third-party vendors including identifying and overseeing cybersecurity risks they present.

Integration into Overall Risk Management System

The Company employs comprehensive methodologies

for risk assessment and diligently identifies and evaluates potential cybersecurity threats and vulnerabilities across our systems, networks

and data assets. This process involves regular examinations of emerging threats, conducting penetration tests, vulnerability scanning

and thorough analysis of industry-specific risks.

The Company continues to expand investments in

information technology security, including continuous end-user training, layered defenses, identifying and protecting critical assets,

strengthening monitoring and alerting.

The Company's Information Security Officer

("ISO") is responsible for completing additional mandatory training to understand the processes, procedures, and technical

requirements for securing information assets across the Company.

The Company has developed an Incident Response

Plan to guide its actions in responding to real and suspected information security incidents. This includes unlawful, unauthorized, or

unacceptable actions that involve a computer system or a computer network such as Distributed Denial of Service attacks, Corporate Account

Takeover schemes, or ransomware. Cybersecurity threats that are identified and deemed material are escalated and communicated directly

to the Incident Response Team, in collaboration with relevant information technology personnel, insurance providers, legal counsels and

when necessary, external cybersecurity firms specializing in forensic investigations.

The Company sets forth enterprise-wide coordinated

responses to identified threats, ensuring timely mitigation and remediation, and facilitating awareness and communication. Tabletop exercises

are held regularly at the senior and executive management levels to validate roles and responsibilities, and response protocols respective

to cybersecurity threats.

Third-party Access

The Company has a fully integrated third-party

risk management program to identify, assess, monitor and mitigate risks associated with third-party relationships, including cybersecurity

risks. Under the program, risk ratings are assigned to each of the vendors based on an assessment of the vendor and its access to networks,

systems, and confidential information. An assessment is conducted on each vendor to identify and measure the risks from cybersecurity

threats that could impact our customer's data and our environment. Third parties that have access to our systems or customer data

must have appropriate technical and organizational security measures and security control principles based on commercially acceptable

security standards, and we require third parties in this class to agree by contract to manage their cybersecurity risks.

Material Cybersecurity Threat Risks

The Company has not experienced any material

losses relating to cybersecurity threats or incidents for the year ended June 30, 2025. We are not aware of 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 our business strategy, results of operations or financial condition. Although we have a robust cybersecurity

program that is designed to assess, identify, and manage material risks from cybersecurity threats, we cannot provide absolute surety

that we have properly identified or mitigated all vulnerabilities or risks of incidents. The Company, and the third parties that the

Company engages, are subject to constant and evolving threats of attack and cybersecurity incidents may be more difficult to detect for

periods of time. A cybersecurity incident could harm our business strategy, results of operations, financial condition, reputation, and/or

subject us to regulatory actions or litigation which may result in fines, judgments or indictments.

Cybersecurity Governance

The Board of Directors is acutely aware of the

critical nature of managing risks associated with cybersecurity threats. The Board has oversight responsibilities to ensure effective

governance in managing these risks because it recognizes the significance of these threats to our operational integrity, shareholder

and customer confidence and reputation.

Board of Directors Oversight

The Board is responsible for the oversight of

cybersecurity risk management and is composed of members with expertise in risk management, technology, and finance, thereby equipping

them to manage and prevent cybersecurity risks effectively.

Management's Role in Managing Risk

The ISO plays a pivotal role in informing the

Board of Directors on cybersecurity risks. The ISO, other information security staff, and members of senior management meet regularly

as the Technology Steering Committee. Reports of their meetings are shared with the boards of our subsidiary banks. Committee reports

provide comprehensive briefings to both the Board and the Audit Committee as part of managements reporting. These briefings encompass

a broad range of topics, including:

●

Current cybersecurity landscape

and emerging threats;

●

Status of ongoing cybersecurity

initiatives and strategies;

●

Incident reports and issues

identified from any cybersecurity events; and

●

Compliance with regulatory

requirements and industry standards.

In addition to our regularly scheduled Board

meetings, the ISO regularly communicates with senior staff regarding emerging or potential cybersecurity risks. They discuss any significant

developments in the cybersecurity domain, which when reported to the Board, ensures the Board's oversight is proactive and responsive.

The Board actively participates in strategic decisions related to cybersecurity, offering guidance and approval for major initiatives.

This involvement ensures that cybersecurity considerations are integrated into the broader strategic objectives of the Company. The Board

closely reviews these reports of the Bank's cybersecurity posture and the effectiveness of its risk management strategies prior

to approval. This review helps in identifying areas for improvement and ensuring the alignment of cybersecurity efforts with the overall

risk management framework.

Cyber Risk Management Personnel

The ISO directly reports to the CEO. The ISO

regularly meets with the CEO to update and discuss any cybersecurity risks and incidents affecting the Company. This ensures that the

highest levels of management are kept abreast of the cybersecurity posture and potential risks facing the Company. Furthermore, all significant

cybersecurity matters and strategic risk management decisions are promptly escalated to the Board of Directors, ensuring that they have

an up-to-date, comprehensive understanding of and can provide guidance on critical cybersecurity issues.

Primary responsibility for assessing and providing

strategic direction to our cybersecurity program resides with our ISO. The ISO's experience includes prior leadership roles within

the Company, where they developed an expert level of understanding of the intersection between financial regulations and cloud-based

technologies. The ISO and other information systems staff possess in-depth knowledge and experience which are instrumental in developing

and executing our cybersecurity strategies. The ISO and the Tech Steering Committee oversee our governance programs, work with our technology-focused

leaders and partners to align security and compliance, and have developed our employee security awareness training program.

Monitoring Cybersecurity Incidents

The ISO and other information security staff

utilizes vendor relationships and various other internet based daily updates for the latest developments in cybersecurity, including

potential threats and innovative risk management techniques. This knowledge is crucial for the effective prevention, detection, mitigation,

and remediation of cybersecurity incidents. The ISO provides structure for clear processes to ensure the regular monitoring of our information

systems. This includes the deployment of advanced security measures and regular system audits to identify potential vulnerabilities.

In the event of a cybersecurity incident, we believe we are equipped with a well-defined Incident Response Plan that is adequately resourced.

This plan includes immediate actions to mitigate the impact and long-term strategies for remediation and prevent future incidents.

Fiscal 2024 Form 10-K, filed October 3, 2024 sec.gov ↗

Top security role, as the filing names it

Information Security Officer

Reports to, as the filing names it

CEO

“The ISO directly reports to the CEO.”

Board oversight

Audit Committee

“Committee reports provide comprehensive briefings to both the Board and the Audit Committee as part of managements reporting.”

Person named in the filing

not identified

Experience, as stated

Stated

“The ISO's experience includes prior leadership roles within the Company, where they developed an expert level of understanding of the intersection between financial regulations and cloud-based technologies.”

Material incident

The filing states none

“We are not aware of 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 our business strategy, results of operations or financial condition.”

Read by claude-sonnet-5-5 on November 8, 2026; every quote verified in the stored text by code.

Item 1C. Cybersecurity .

Cybersecurity Risk Management and Strategy

The Company regards information and data as valuable

assets. As a result, we have implemented safeguards to protect corporate informational and data assets. Associated and established technology

resources maintain the integrity, availability, and privacy of confidential information of the respective assets. Additionally, we maintain

a similar risk-based approach to our third-party vendors including identifying and overseeing cybersecurity risks they present.

Integration into Overall Risk Management System

The Company employs comprehensive methodologies

for risk assessment and diligently identifies and evaluates potential cybersecurity threats and vulnerabilities across our systems, networks

and data assets. This process involves regular examinations of emerging threats, conducting penetration tests, vulnerability scanning

and thorough analysis of industry-specific risks.

The Company continues to expand investments in

information technology security, including continuous end-user training, layered defenses, identifying and protecting critical assets,

strengthening monitoring and alerting.

The Company's Information Security Officer

("ISO") is responsible for completing additional mandatory training to understand the processes, procedures, and technical

requirements for securing information assets across the Company.

The Company has developed an Incident Response

Plan to guide its actions in responding to real and suspected information security incidents. This includes unlawful, unauthorized, or

unacceptable actions that involve a computer system or a computer network such as Distributed Denial of Service attacks, Corporate Account

Takeover schemes, or ransomware. Cybersecurity threats that are identified and deemed material are escalated and communicated directly

to the Incident Response Team, in collaboration with relevant information technology personnel, insurance providers, legal counsels and

when necessary, external cybersecurity firms specializing in forensic investigations.

The Company sets forth enterprise-wide coordinated

responses to identified threats, ensuring timely mitigation and remediation, and facilitating awareness and communication. Tabletop exercises

are held regularly at the senior and executive management levels to validate roles and responsibilities, and response protocols respective

to cybersecurity threats.

Third-party Access

The Company has a fully integrated third-party

risk management program to identify, assess, monitor and mitigate risks associated with third-party relationships, including cybersecurity

risks. Under the program, risk ratings are assigned to each of the vendors based on an assessment of the vendor and its access to networks,

systems, and confidential information. An assessment is conducted on each vendor to identify and measure the risks from cybersecurity

threats that could impact our customer's data and our environment. Third parties that have access to our systems or customer data

must have appropriate technical and organizational security measures and security control principles based on commercially acceptable

security standards, and we require third parties in this class to agree by contract to manage their cybersecurity risks.

Material Cybersecurity Threat Risks

The Company has not experienced any material losses

relating to cybersecurity threats or incidents for the year ended June 30, 2024. We are not aware of 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 our business strategy, results of operations or financial condition. Although we have a robust cybersecurity program

that is designed to assess, identify, and manage material risks from cybersecurity threats, we cannot provide absolute surety that we

have properly identified or mitigated all vulnerabilities or risks of incidents. The Company, and the third parties that the Company engages,

are subject to constant and evolving threats of attack and cybersecurity incidents may be more difficult to detect for periods of time.

A cybersecurity incident could harm our business strategy, results of operations, financial condition, reputation, and/or subject us to

regulatory actions or litigation which may result in fines, judgments or indictments.

Cybersecurity Governance

The Board of Directors is acutely aware of the

critical nature of managing risks associated with cybersecurity threats. The Board has oversight responsibilities to ensure effective

governance in managing these risks because it recognizes the significance of these threats to our operational integrity, shareholder and

customer confidence and reputation.

Board of Directors Oversight

The Board is responsible for the oversight of

cybersecurity risk management and is composed of members with expertise in risk management, technology, and finance, thereby equipping

them to manage and prevent cybersecurity risks effectively.

Management's Role in Managing Risk

The ISO plays a pivotal role in informing the

Board of Directors on cybersecurity risks. The ISO, other information security staff, and members of senior management meet regularly

as the Technology Steering Committee. Reports of their meetings are shared with the boards of our subsidiary banks. Committee reports

provide comprehensive briefings to both the Board and the Audit Committee as part of managements reporting. These briefings encompass

a broad range of topics, including:

● Current cybersecurity landscape and emerging

threats;

● Status of ongoing cybersecurity initiatives and

strategies;

● Incident reports and issues identified from any

cybersecurity events; and

● Compliance with regulatory requirements and industry

standards.

In addition to our regularly scheduled Board meetings,

the ISO regularly communicates with senior staff regarding emerging or potential cybersecurity risks. They discuss any significant developments

in the cybersecurity domain, which when reported to the Board, ensures the Board's oversight is proactive and responsive. The Board

actively participates in strategic decisions related to cybersecurity, offering guidance and approval for major initiatives. This involvement

ensures that cybersecurity considerations are integrated into the broader strategic objectives of the Company. The Board closely reviews

these reports of the Bank's cybersecurity posture and the effectiveness of its risk management strategies prior to approval. This

review helps in identifying areas for improvement and ensuring the alignment of cybersecurity efforts with the overall risk management

framework.

Cyber Risk Management Personnel

The ISO directly reports to the CEO. The ISO regularly

meets with the CEO to update and discuss any cybersecurity risks and incidents affecting the Company. This ensures that the highest levels

of management are kept abreast of the cybersecurity posture and potential risks facing the Company. Furthermore, all significant cybersecurity

matters and strategic risk management decisions are promptly escalated to the Board of Directors, ensuring that they have an up-to-date,

comprehensive understanding of and can provide guidance on critical cybersecurity issues.

Primary responsibility for assessing and providing

strategic direction to our cybersecurity program resides with our ISO. The ISO's experience includes prior leadership roles within

the Company, where they developed an expert level of understanding of the intersection between financial regulations and cloud-based technologies.

The ISO and other information systems staff possess in-depth knowledge and experience which are instrumental in developing and executing

our cybersecurity strategies. The ISO and the Tech Steering Committee oversee our governance programs, work with our technology-focused

leaders and partners to align security and compliance, and have developed our employee security awareness training program.

Monitoring Cybersecurity Incidents

The ISO and other information security staff utilizes

vendor relationships and various other internet based daily updates for the latest developments in cybersecurity, including potential

threats and innovative risk management techniques. This knowledge is crucial for the effective prevention, detection, mitigation, and

remediation of cybersecurity incidents. The ISO provides structure for clear processes to ensure the regular monitoring of our information

systems. This includes the deployment of advanced security measures and regular system audits to identify potential vulnerabilities. In

the event of a cybersecurity incident, we believe we are equipped with a well-defined Incident Response Plan that is adequately resourced.

This plan includes immediate actions to mitigate the impact and long-term strategies for remediation and prevent future incidents.

The fields above are exact quotes from the stored text. "Not identified" means no supporting sentence was found, not that the company has no such arrangement. A name in a filing is not a record of who holds the seat today: the Wire tracks that.

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