CISO Tribune

Disclosure · Form 10-K · fiscal 2025

Chord Energy Corp 10-K cybersecurity disclosure (Item 1C), fiscal 2025

Filed February 26, 2026· period ended December 31, 2025· CHRD· CIK 1486159· Updated · filing on sec.gov ↗

Chord Energy Corp's Form 10-K for fiscal 2025, filed February 26, 2026, names the Vice President, Information Technology as its top security role, with oversight by the Audit and Reserves Committee.

What Chord Energy's Item 1C says

Chord Energy's Form 10-K for fiscal 2025 places primary oversight of cybersecurity risk with the Board of Directors, which delegates oversight to the Audit and Reserves Committee. The Vice President, Information Technology, is responsible for overseeing the prevention, mitigation, detection and remediation of cybersecurity incidents.

Board and management oversight

The Vice President, Information Technology, provides updates to the Audit and Reserves Committee on data protection and cybersecurity matters on at least a semi-annual basis, or as requested or deemed necessary. On an annual basis, the Vice President, Information Technology, reviews with the Audit and Reserves Committee the results from tests of key cybersecurity risks and the subsequent steps taken to mitigate them. The Cybersecurity Council reports directly to the Chief Strategy Officer & Chief Commercial Officer. The Cybersecurity Council meets monthly to review current cybersecurity threats as well as the company's potential exposure.

Who leads security

The Cybersecurity Council is led by the Vice President, Information Technology. The Vice President, Information Technology, has over 20 years of experience, including prior industry experience consulting on various IT matters and developing and testing IT general controls and cybersecurity risk management programs.

How the company manages cyber risk

The company's cybersecurity program uses a combination of automated tools, manual processes and third-party assessments to identify and assess potential cybersecurity risks. The company has implemented policies, standards and technical controls based on the National Institute of Standards and Technology framework. The company requires all employees and contractors to participate in information security training at least quarterly. The company's cybersecurity team periodically tests its controls through penetration tests, vulnerability scans and attack simulations. The company has integrated these cybersecurity risk management processes into its overall ERM program.

Third parties and incidents

The company conducts due diligence before engaging any third-party service provider to evaluate the provider's cybersecurity capabilities. The company requires third-party service providers with access to personally identifiable information to enter into data processing services agreements and adhere to its policies and standards. The company is not aware of any previous cybersecurity threats or incidents that have materially affected or are reasonably likely to materially affect it.

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 February 26, 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)

Vice President, Information Technology

Reports to

not identified

Board oversight

Audit and Reserves Committee

“The Board of Directors delegates oversight of risk, including reviews of cybersecurity and data protection and compliance with cybersecurity policies, to the Audit and Reserves Committee.”

CISO or other person named

not identified

Frameworks and standards named

NIST (publication not named)

Where the filing names it
  • NIST (publication not named): “We have endeavored to implement policies, standards and technical controls based on the National Institute of Standards and Technology framework with the aim of protecting our networks, applications and data.”

Outside assessors, consultants or testers

Described

“We engage third-party vendors and consultants throughout our business as needed.”

Experience of the security leadership, as stated

Stated

“Our Vice President, Information Technology, has over 20 years of experience, including prior industry experience consulting on various IT matters and developing and testing IT general controls and cybersecurity risk management programs.”

Material incident

The filing states none

“As of the date of this report, we are not aware of any previous cybersecurity threats or incidents that have materially affected or are reasonably likely to materially affect us.”

The section

1,408 words, Form 10-K filed February 26, 2026 for the period ended December 31, 2025

Read by claude-sonnet-5-5 on October 22, 2026; every quote verified in the stored text by code.

How peers in the same industry describe the seat

The SEC assigns Chord Energy Corp standard industrial classification 1311, Crude petroleum & natural gas (SEC SIC list). 8 other filers in our library have the same code.

FilerTop security roleReports toBoard oversight
EON Resources Inc.FY 2025, filed October 13, 2026not identifiednot identifiedfull board
Royale Energy, Inc.FY 2025, filed July 13, 2026not identifiednot identifiedaudit committee
Norris Industries, Inc.FY 2026, filed May 29, 2026Chief Executive Officernot identifiednot identified
Blue Dolphin Energy CoFY 2025, filed March 31, 2026chief executive officernot identifiedfull board
W&T Offshore IncFY 2025, filed March 16, 2026CIO & CISOnot identifiedAudit Committee of the board of directors
Empire Petroleum CorpFY 2025, filed March 13, 2026Vice President of ITChief Executive OfficerAudit Committee
Us Energy CorpFY 2025, filed March 13, 2026Director of ITnot identifiedAudit Committee
APA CorpFY 2025, filed February 26, 2026Executive Vice President, AdministrationChief Executive OfficerCybersecurity Committee

Item 1C, verbatim from the filing

The text below is the Cybersecurity item of Chord Energy Corp's Form 10-K as filed with the SEC on February 26, 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

We maintain a cybersecurity program overseen by the Vice President, Information Technology that uses a risk-based methodology to support the security, confidentiality, integrity and availability of our information. The security of our field infrastructure and corporate network is a priority for our business. We recognize the importance of assessing, identifying and managing material risks associated with cybersecurity threats. Our cybersecurity program utilizes a combination of automated tools, manual processes and third-party assessments with the goal of identifying and assessing potential cybersecurity risks. These risks may include, among other things, operational risks, unauthorized access to systems and data stored on them, intellectual property theft, fraud, extortion, harm to employees, customers or business partners, violation of privacy or security laws and other litigation and legal risk and reputational risks.

We have endeavored to implement policies, standards and technical controls based on the National Institute of Standards and Technology framework with the aim of protecting our networks, applications and data. We seek to assess, identify and manage cybersecurity risks through the processes described below:

• Risk Assessment: We have implemented a multi-layered system designed to protect and monitor data and cybersecurity risk. Periodic assessments of our cybersecurity safeguards are conducted both internally and by independent third-party cybersecurity vendors. Additionally, our internal audit department conducts regular audits designed to identify, assess and manage cybersecurity risks, and we endeavor to update cybersecurity infrastructure, procedures, policies and education programs in response to audit findings.

• Incident Identification and Response: We have implemented a monitoring and detection system that is designed to help promptly detect cybersecurity incidents. While processes are in place to minimize the chance of a successful cyberattack, we have established incident response procedures designed to address a cybersecurity threat that may occur despite these safeguards. The response procedures are designed to identify, analyze, contain and remediate any such cybersecurity incidents that occur. In the event of any breach or cybersecurity incident, we have a cross-functional enterprise-wide incident response plan, which includes the involvement of our executive management team, established incident levels, and associated notification procedures, including escalation procedures upon discovery of cybersecurity risks to our Board of Directors, outside counsel and law enforcement, if deemed material or appropriate. Further, we conduct periodic incident response tabletop exercises and planned incident response drills with various members of our management team that are designed to refine and update our incident response processes.

• Cybersecurity Training and Awareness: We maintain a formal information security training program for all employees and contractors that includes training on matters such as phishing, social engineering techniques, and email security best practices. We have implemented a requirement that all employees and contractors participate in information security training at least quarterly and have deployed internal phishing campaigns to measure the effectiveness of the training program.

• Access Controls: Our access controls are designed to provide users with access consistent with the principle of least privilege, which requires that users be given no more access than necessary to complete their job functions. We have also implemented a multi-factor authentication process for employees accessing company information.

• Systems and Processes: We use a combination of tools designed to detect cybersecurity incidents. We use firewalls and protection software in addition to working with a third-party cybersecurity vendor to scan internal and external networks for threat and intrusion detection. Our cybersecurity team periodically tests our controls through penetration tests, vulnerability scans and attack simulations.

• Encryption and Data Protection: We have encryption methods in place that are designed to protect certain sensitive data. This includes the encryption of customer data, financial information and other confidential data. We also have multiple programs in place that are designed to monitor our retained data and take actions to secure the data.

Table of Content s

We engage third-party vendors and consultants throughout our business as needed. We recognize that third-party service providers introduce cybersecurity risks. In an effort to mitigate these risks, we conduct due diligence prior to engaging with any third-party service provider to evaluate the third-party provider's cybersecurity capabilities, and maintain an ongoing monitoring process throughout the relationship to encourage continued compliance with our requirements and standards . For new cloud-based third-party providers, we review their cybersecurity practices in an effort to attempt to verify compliance with our cybersecurity standards. This process is documented through our Cloud Services Assessment. Additionally, we endeavor to include cybersecurity requirements in our contracts with third-party providers and endeavor to require them to adhere to our cybersecurity standards and protocols. Further, we require any third-party service providers with access to personally identifiable information to enter into data processing services agreements and adhere to our policies and standards. However, we are subject to the risk that our third-party providers and vendors may not fully comply with all of our policies and standards.

We have integrated the above cybersecurity risk management processes into our overall ERM program. Cybersecurity risks are understood to be significant business risks, and as such, are considered an important component of our enterprise-wide risk management approach.

As of the date of this report, we are not aware of any previous cybersecurity threats or incidents that have materially affected or are reasonably likely to materially affect us. 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 IT systems could have significant consequences for the business and our financial performance. While we devote resources to security measures that are designed to protect our systems and information, these measures cannot provide absolute security. No security measure is infallible. See "Item 1A. Risk Factors" for additional information about the risks to our business associated with a breach or compromise to our IT systems.

Cybersecurity Governance and Oversight

The Board of Directors has primary oversight of risks from cybersecurity threats. The Board of Directors delegates oversight of risk, including reviews of cybersecurity and data protection and compliance with cybersecurity policies, to the Audit and Reserves Committee.

The Vice President, Information Technology , provides updates to the Audit and Reserves Committee on data protection and cybersecurity matters on at least a semi-annual basis, or as requested or deemed necessary. The topics covered in such reports may include an overview of our current cybersecurity risk assessment, key risk areas, any significant cyber incidents that have occurred or are reasonably likely to occur, as well as recent updates on cybersecurity trends and emerging threats. Additionally, on an annual basis, the Vice President, Information Technology, reviews with the Audit and Reserves Committee the results from tests of key cybersecurity risks and the subsequent steps taken that are designed to mitigate such risks.

Management is responsible for assessing and managing cybersecurity risk. Specifically, the Vice President, Information Technology, is responsible for overseeing the prevention, mitigation, detection and remediation of cybersecurity incidents. Our Vice President, Information Technology, has over 20 years of experience, including prior industry experience consulting on various IT matters and developing and testing IT general controls and cybersecurity risk management programs. We maintain an internal staff of IT professionals who support our cybersecurity program and engage with third-party service providers to support specific areas of our cybersecurity risk mitigation and response.

The Vice President, Information Technology, works closely with other management positions, including our Chief Financial Officer, our Chief Strategy Officer & Chief Commercial Officer and our General Counsel, to help us maintain an effective incident response communication plan and understanding of our cybersecurity risk management processes. Our cybersecurity incident response plan provides processes for escalation if there is an emerging cybersecurity incident, including timely notice to our Board of Directors if the incident is deemed material or as otherwise appropriate.

We have developed a Cybersecurity Council that reports directly to our Chief Strategy Officer & Chief Commercial Officer. The Cybersecurity Council is led by the Vice President, Information Technology, and is comprised of select members of the IT team with an average of approximately 20 years of cybersecurity experience. The Cybersecurity Council meets monthly to review current cybersecurity threats as well as our potential exposure. The Cybersecurity Council also engages periodically with external and internal auditors, as well as the Cybersecurity and Infrastructure Security Agency, the American Exploration and Production Council and the Federal Bureau of Investigation in an effort to stay informed on cybersecurity risk management.

Earlier filings on record

Fiscal 2024 Form 10-K, filed February 27, 2025 sec.gov ↗

Top security role, as the filing names it

Vice President, Information Technology

Reports to, as the filing names it

Chief Strategy Officer & Chief Commercial Officer

“We have developed a Cybersecurity Council that reports directly to our Chief Strategy Officer & Chief Commercial Officer.”

Board oversight

Audit and Reserves Committee

“The Board of Directors delegates oversight of risk, including reviews of cybersecurity and data protection and compliance with cybersecurity policies, to the Audit and Reserves Committee.”

Person named in the filing

not identified

Experience, as stated

Stated

“Our Vice President, Information Technology, has over 17 years of experience, including prior industry experience consulting on various IT matters and developing and testing IT general controls and cybersecurity risk management programs.”

Material incident

The filing states none

“As of the date of this report, we are not aware of any previous cybersecurity threats that have materially affected or are reasonably likely to materially affect us.”

Read by claude-sonnet-5-5 on October 22, 2026; every quote verified in the stored text by code.

Item 1C. Cybersecurity

Cybersecurity Risk Management and Strategy

We maintain a cybersecurity program overseen by the Vice President, Information Technology that uses a risk-based methodology to support the security, confidentiality, integrity and availability of our information. The security of our field infrastructure and corporate network is a priority for our business. We recognize the importance of assessing, identifying and managing material risks associated with cybersecurity threats. Our cybersecurity program utilizes a combination of automated tools, manual processes and third-party assessments with the goal of identifying and assessing potential cybersecurity risks.

Table of Conten ts

These risks may include, among other things, operational risks, intellectual property theft, fraud, extortion, harm to employees, customers or business partners, violation of privacy or security laws and other litigation and legal risk and reputational risks.

We have endeavored to implement policies, standards and technical controls based on the National Institute of Standards and Technology framework with the aim of protecting our networks and applications. We seek to assess, identify and manage cybersecurity risks through the processes described below:

• Risk Assessment: We have implemented a multi-layered system designed to protect and monitor data and cybersecurity risk. Regular assessments of our cybersecurity safeguards are conducted both internally and by independent third-party cybersecurity vendors. Additionally, our internal audit department conducts regular audits to identify, assess and manage material cybersecurity risks, and we endeavor to update cybersecurity infrastructure, procedures, policies and education programs in response to audit findings.

• Incident Identification and Response: We have implemented a monitoring and detection system to help promptly identify cybersecurity incidents. While processes are in place to minimize the chance of a successful cyberattack, we have established incident response procedures to address a cybersecurity threat that may occur despite these safeguards. The response procedures are designed to identify, analyze, contain and remediate any such cybersecurity incidents that occur. In the event of any breach or cybersecurity incident, we have a cross-functional incident response plan, which includes the involvement of our executive management team, established incident levels, and associated notification procedures, including escalation procedures upon discovery of cybersecurity risks to our Board of Directors, outside counsel and law enforcement, if deemed material or appropriate. Further, we conduct periodic incident response tabletop exercises and planned incident response drills with various members of our management team to continuously refine and update our incident response processes.

• Cybersecurity Training and Awareness: We maintain a formal information security training program for all employees and contractors that includes training on matters such as phishing and email security best practices. We have implemented a requirement that all employees and contractors participate in information security training at least quarterly and have deployed internal phishing campaigns to measure the effectiveness of the training program.

• Access Controls: We provide users with access consistent with the principle of least privilege, which requires that users be given no more access than necessary to complete their job functions. We have also implemented a multi-factor authentication process for employees accessing company information.

• Systems and Processes: We use a combination of tools to identify cybersecurity incidents. We use firewalls and protection software in addition to working with a third-party cybersecurity vendor to scan internal and external networks for threat and intrusion detection. Our cybersecurity team regularly tests our controls through penetration tests, vulnerability scans and attack simulations.

• Encryption and Data Protection: We have encryption methods in place to protect certain sensitive data. This includes the encryption of customer data, financial information and other confidential data. We also have multiple programs in place to monitor our retained data and take actions to secure the data.

We engage third-party vendors and consultants throughout our business as needed. We recognize that third-party service providers introduce cybersecurity risks. In an effort to mitigate these risks, before engaging with any third-party service provider, we conduct due diligence to evaluate the third-party provider's cybersecurity capabilities . For new cloud-based third-party providers, we aim to review their cybersecurity practices to verify compliance with our cybersecurity standards. This process is documented through our Cloud Services Assessment. Additionally, we endeavor to include cybersecurity requirements in our contracts with third-party providers and endeavor to require them to adhere to our cybersecurity standards and protocols. Further, we require any third-party service providers with access to personally identifiable information to enter into data processing services agreements and adhere to our policies and standards.

We have integrated the above cybersecurity risk management processes into our overall ERM program. Cybersecurity risks are understood to be significant business risks, and as such, are considered an important component of our enterprise-wide risk management approach.

Table of Conten ts

As of the date of this report, we are not aware of any previous cybersecurity threats that have materially affected or are reasonably likely to materially affect us. 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 IT systems could have significant consequences for the business. While we devote resources to our security measures to protect our systems and information, these measures cannot provide absolute security. No security measure is infallible. See "Item 1A. Risk Factors" for additional information about the risks to our business associated with a breach or compromise to our IT systems.

Cybersecurity Governance and Oversight

The Board of Directors has primary oversight of risks from cybersecurity threats. The Board of Directors delegates oversight of risk, including reviews of cybersecurity and data protection and compliance with cybersecurity policies, to the Audit and Reserves Committee.

The Vice President, Information Technology , provides updates to the Audit and Reserves Committee on data protection and cybersecurity matters on at least a semi-annual basis, or as requested or deemed necessary. The topics covered in such reports may include an overview of our current cybersecurity risk assessment, key risk areas, any significant cyber incidents that have occurred or are reasonably likely to occur, as well as recent updates on cybersecurity trends and emerging threats. Additionally, on an annual basis, the Vice President, Information Technology, reviews with the Audit and Reserves Committee the results from tests of key cybersecurity risks and the subsequent steps taken to mitigate such risks.

Management is responsible for assessing and managing cybersecurity risk. Specifically, the Vice President, Information Technology, is responsible for overseeing the prevention, mitigation, detection and remediation of cybersecurity incidents. Our Vice President, Information Technology, has over 17 years of experience, including prior industry experience consulting on various IT matters and developing and testing IT general controls and cybersecurity risk management programs. We maintain an internal staff of IT professionals who support our cybersecurity program and engage with third-party service providers to support specific areas of our cybersecurity risk mitigation and response.

The Vice President, Information Technology, works closely with other management positions, including our Chief Financial Officer and our General Counsel, to help us maintain an effective incident response communication plan and understanding of our cybersecurity risk management processes. Our cybersecurity incident response plan provides processes for escalation if there is an emerging cybersecurity incident, including timely notice to our Board of Directors if the incident is deemed material or as otherwise appropriate.

We have developed a Cybersecurity Council that reports directly to our Chief Strategy Officer & Chief Commercial Officer. The Cybersecurity Council is led by the Vice President, Information Technology, and is comprised of select members of the IT team with an average of nearly 20 years of cybersecurity experience. The Cybersecurity Council meets monthly to review current cybersecurity threats as well as our potential exposure. The Cybersecurity Council also engages periodically with external and internal auditors, as well as the Cybersecurity and Infrastructure Security Agency, the American Exploration and Production Council and the Federal Bureau of Investigation to stay informed on cybersecurity risk management.

Fiscal 2023 Form 10-K, filed February 26, 2024 sec.gov ↗

Top security role, as the filing names it

Managing Director, Information Technology

Reports to, as the filing names it

not identified

Board oversight

Audit and Reserves Committee

“The Board of Directors delegates oversight of risk, including reviews of cybersecurity and data protection and compliance with cybersecurity policies, to the Audit and Reserves Committee.”

Person named in the filing

not identified

Experience, as stated

Stated

“Our Managing Director, Information Technology, has over 16 years of experience, including prior industry experience consulting on various IT matters and developing and testing IT general controls and cybersecurity risk management programs.”

Material incident

The filing states none

“As of the date of this report, we are not aware of any previous cybersecurity threats that have materially affected or are reasonably likely to materially affect us.”

Read by claude-sonnet-5-5 on October 22, 2026; every quote verified in the stored text by code.

Item 1C. Cybersecurity

Cybersecurity Risk Management and Strategy

We maintain a cybersecurity program overseen by the Managing Director, Information Technology that uses a risk-based methodology to support the security, confidentiality, integrity and availability of our information. The security of our field infrastructure and corporate network is a priority for our business. We recognize the importance of assessing, identifying and managing material risks associated with cybersecurity threats. Our cybersecurity program utilizes a combination of automated tools, manual processes and third-party assessments with the goal of identifying and assessing potential cybersecurity risks. These risks may include, among other things, operational risks, intellectual property theft, fraud, extortion, harm to employees, customers or business partners, violation of privacy or security laws and other litigation and legal risk and reputational risks.

We have endeavored to implement policies, standards and technical controls based on the National Institute of Standards and Technology (NIST) framework with the aim of protecting our networks and applications. We seek to assess, identify and manage cybersecurity risks through the processes described below:

• Risk Assessment: We have implemented a multi-layered system designed to protect and monitor data and cybersecurity risk. Regular assessments of our cybersecurity safeguards are conducted both internally and by independent third-party cybersecurity vendors. Additionally, our internal audit department conducts regular audits to identify, assess and manage material cybersecurity risks, and we endeavor to update cybersecurity infrastructure, procedures, policies and education programs in response to audit findings.

• Incident Identification and Response: We have implemented a monitoring and detection system to help promptly identify cybersecurity incidents. While processes are in place to minimize the chance of a successful cyberattack, we have established incident response procedures to address a cybersecurity threat that may occur despite these safeguards. The response procedures are designed to identify, analyze, contain and remediate any such cybersecurity incidents that occur. In the event of any breach or cybersecurity incident, we have a cross-functional incident response plan, which includes the involvement of our executive management team, established incident levels, and associated notification procedures, including escalation procedures upon discovery of cybersecurity risks to our Board of Directors, outside counsel and law enforcement, if deemed material or appropriate. Further, we conduct periodic incident response tabletop exercises and planned incident response drills with various members of our management team to continuously refine and update our incident response processes.

• Cybersecurity Training and Awareness: We maintain a formal information security training program for all employees and contractors that includes training on matters such as phishing and email security best practices. We have implemented a requirement that all employees and contractors participate in information security training at least quarterly and have deployed internal phishing campaigns to measure the effectiveness of the training program.

• Access Controls: We provide users with access consistent with the principle of least privilege, which requires that users be given no more access than necessary to complete their job functions. We have also implemented a multi-factor authentication process for employees accessing company information.

• Systems and Processes: We use a combination of tools to identify cybersecurity incidents. We use firewalls and protection software in addition to working with a third-party cybersecurity vendor to scan internal and external networks for threat and intrusion detection. Our cybersecurity team regularly tests our controls through penetration tests, vulnerability scans and attack simulations.

• Encryption and Data Protection: We have encryption methods in place to protect certain sensitive data. This includes the encryption of customer data, financial information and other confidential data. We also have multiple programs in place to monitor our retained data and take actions to secure the data.

We engage third-party vendors and consultants throughout our business as needed. We recognize that third-party service providers introduce cybersecurity risks. In an effort to mitigate these risks, before engaging with any third-party service provider, we conduct due diligence to evaluate the third-party provider's cybersecurity capabilities. For new cloud-based third-party providers, we aim to review their cybersecurity practices to verify compliance with our cybersecurity standards. This process is documented through our Cloud Services Assessment. Additionally, we endeavor to include cybersecurity requirements in our contracts with third-party providers and endeavor to require them to adhere to our cybersecurity standards and protocols. Further, we require any third-party service providers with access to personally identifiable information to enter into data processing services agreements and adhere to our policies and standards.

We have integrated the above cybersecurity risk management processes into our overall ERM program. Cybersecurity risks are understood to be significant business risks, and as such, are considered an important component of our enterprise-wide risk management approach.

As of the date of this report, we are not aware of any previous cybersecurity threats that have materially affected or are reasonably likely to materially affect us. 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 ("IT") systems could have significant consequences for the business. While we devote resources to our security measures to protect our systems and information, these measures cannot provide absolute security. No security measure is infallible. See "Item 1A. Risk Factors" for additional information about the risks to our business associated with a breach or compromise to our IT systems.

Cybersecurity Governance and Oversight

The Board of Directors has primary oversight of risks from cybersecurity threats. The Board of Directors delegates oversight of risk, including reviews of cybersecurity and data protection and compliance with cybersecurity policies, to the Audit and Reserves Committee.

The Managing Director, Information Technology, provides updates to the Audit and Reserves Committee on data protection and cybersecurity matters on at least a semi-annual basis, or as requested or deemed necessary. The topics covered in such reports may include an overview of our current cybersecurity risk assessment, key risk areas, any significant cyber incidents that have occurred or are reasonably likely to occur, as well as recent updates on cybersecurity trends and emerging threats. Additionally, on an annual basis, the Managing Director, Information Technology, reviews with the Audit and Reserves Committee the results from tests of key cybersecurity risks and the subsequent steps taken to mitigate such risks.

Management is responsible for assessing and managing cybersecurity risk. Specifically, the Managing Director, Information Technology, is responsible for overseeing the prevention, mitigation, detection and remediation of cybersecurity incidents. Our Managing Director, Information Technology, has over 16 years of experience, including prior industry experience consulting on various IT matters and developing and testing IT general controls and cybersecurity risk management programs. We maintain an internal staff of IT professionals who support our cybersecurity program and engage with third-party service providers to support specific areas of our cybersecurity risk mitigation and response.

The Managing Director, Information Technology, works closely with other management positions, including our Chief Financial Officer and our General Counsel, to help us maintain an effective incident response communication plan and understanding of our cybersecurity risk management processes. Our cybersecurity incident response plan provides processes for escalation if there is an emerging cybersecurity incident, including timely notice to our Board of Directors if the incident is deemed material or as otherwise appropriate.

We have developed a Cybersecurity Council that reports directly to our Chief Financial Officer. The Cybersecurity Council is led by the Managing Director, Information Technology, and is comprised of select members of the IT team. The Cybersecurity Council meets monthly to review current cybersecurity threats as well as our potential exposure. The Cybersecurity Council also engages periodically with external and internal auditors, as well as the Cybersecurity and Infrastructure Security Agency,

the American Exploration and Production Council and the Federal Bureau of Investigation to stay informed on cybersecurity risk management.

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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