CISO Tribune

Disclosure · Form 10-K · fiscal 2025

RLJ Lodging Trust 10-K cybersecurity disclosure (Item 1C), fiscal 2025

Filed February 27, 2026· period ended December 31, 2025· RLJ· CIK 1511337· Updated · filing on sec.gov ↗

RLJ Lodging Trust's Form 10-K for fiscal 2025, filed February 27, 2026, places oversight of cybersecurity risk with the Audit Committee; a top security role title is not identified.

What RLJ Lodging Trust's Item 1C says

RLJ Lodging Trust's Form 10-K for fiscal 2025 places primary oversight of cybersecurity risk with the Audit Committee. The IT Committee comprises senior company leaders as well as the company's outsourced IT services provider.

Board and management oversight

The board of trustees is responsible for overseeing the assessment and management of enterprise-level risks that may impact the company, including cybersecurity. Management, including members of the IT Committee, reports at least annually to the Audit Committee on enterprise risk management, cybersecurity risks and mitigation strategies. The Audit Committee will inform the full board of trustees about significant cybersecurity incidents, as appropriate. Two board members have information security expertise from their professional experience.

Who leads security

The cybersecurity threat risk action plan is managed by a dedicated information technology committee, which oversees the cybersecurity program.

How the company manages cyber risk

The risk of cybersecurity threats is integrated into the overall risk management program, which includes an annual risk prioritization process to identify key enterprise-level risks. The company maintains a security operations center with round-the-clock monitoring to oversee and identify cybersecurity threat risks on a day-to-day basis. The company's information security policies are informed by the National Institute of Standards and Technology's Cybersecurity Standards. The company conducts an annual information security compliance training for employees to help them detect and report malware, ransomware, and social engineering attempts. The company has a cybersecurity incident response plan that includes an escalation framework, including processes for informing the board of trustees of material cybersecurity incidents.

Third parties and incidents

The company engages cybersecurity experts, as necessary, to analyze its IT policies, procedures, and infrastructure to assess their effectiveness. The company assesses the cybersecurity proficiency of potential third-party cloud suppliers before utilizing their services. The company has experienced phishing and similar attempts, but during the past three years management has not identified cybersecurity threats 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 27, 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)

not identified

Reports to

not identified

Board oversight

Audit Committee

“Our Audit Committee has primary responsibility for the oversight of risks from cybersecurity threats.”

How often the board or committee hears about it

At least annually

“Management, including members of the IT Committee, reports at least annually to the Audit Committee regarding the Company's enterprise risk management, cybersecurity risks and mitigation strategies and will report cybersecurity incidents to the Audit Committee as they occur, if material.”

CISO or other person named

not identified

Frameworks and standards named

NIST (publication not named)

Where the filing names it
  • NIST (publication not named): “Our information security policies are informed by the National Institute of Standards and Technology's Cybersecurity Standards.”

Outside assessors, consultants or testers

not identified

Experience of the security leadership, as stated

not identified

Material incident

The filing states none

“However, evolving cybersecurity threats make it increasingly challenging to anticipate, detect and defend against cybersecurity threats and incidents.”

The section

698 words, Form 10-K filed February 27, 2026 for the period ended December 31, 2025

Read by claude-sonnet-5-5 on October 27, 2026; every quote verified in the stored text by code.

How peers in the same industry describe the seat

The SEC assigns RLJ Lodging Trust standard industrial classification 6798, Real estate investment trusts (SEC SIC list). 8 other filers in our library have the same code.

FilerTop security roleReports toBoard oversight
Ashford Hospitality Trust IncFY 2025, filed March 23, 2026Executive Vice President of TechnologyExecutive Vice President of Asset ManagementAudit Committee
Strawberry Fields REIT, Inc.FY 2025, filed March 19, 2026Information Security Officernot identifiedfull board
Sunrise Realty Trust, Inc.FY 2025, filed March 12, 2026not identifiednot identifiedAudit and Valuation Committee
ACRES Commercial Realty Corp.FY 2025, filed March 10, 2026not identifiednot identifiedaudit committee
Franklin Street Properties CorpFY 2025, filed March 9, 2026Vice President and Director of Information Technologynot identifiedAudit Committee
Medical Properties Trust IncFY 2025, filed February 26, 2026Head of Technologynot identifiedRisk Committee
NexPoint Residential Trust, Inc.FY 2025, filed February 26, 2026Director of Information Technologynot identifiedAudit Committee
FrontView REIT, Inc.FY 2025, filed February 25, 2026IT ManagerChief Operating Officeraudit committee

Item 1C, verbatim from the filing

The text below is the Cybersecurity item of RLJ Lodging Trust's Form 10-K as filed with the SEC on February 27, 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

Risk Management and Strategy

We are committed to properly addressing the cybersecurity threats we face, and we have processes to assess, identify, and manage risks from cybersecurity threats. We apply a robust approach to the identification, mitigation and management of cybersecurity risks. The risk of cybersecurity threats is integrated into our overall risk management program, which includes an annual risk prioritization process to identify key enterprise-level risks. The cybersecurity threat risk action plan is managed by a dedicated information technology ("IT") committee (the "IT Committee"), which oversees our cybersecurity program. The IT Committee comprises senior company leaders as well as our outsourced IT services provider. To oversee and identify cybersecurity threat risks on a day-to-day basis, we maintain a security operations center with round-the-clock monitoring. We have established policies, including those related to privacy, information security and cybersecurity, and we employ a broad and diversified set of mitigation strategies and techniques to reduce cybersecurity risks, including continuous monitoring, early

detection tools, and proactive vulnerability management. Our information security policies are informed by the National Institute of Standards and Technology's Cybersecurity Standards.

Given the ever-changing cybersecurity landscape, our IT Committee regularly meets to identify opportunities for incremental improvements, assess additional layers of security, and evaluate new technologies for implementation. In addition, we engage, as necessary, cybersecurity experts to analyze our IT policies, procedures, and infrastructure to assess their effectiveness and to identify opportunities for improvement.

We conduct an annual information security compliance training for employees to better enable them to detect and report malware, ransomware, and other malicious software and social engineering attempts that may compromise our IT systems. Employees also are subject to spear-phishing training campaigns, which helps us to assess the effectiveness of our training programs.

Our management companies are ultimately responsible for our guests' information, and we monitor these companies, as well as other third-party service providers , to ensure that they are complying with our privacy, information security and cybersecurity policies. We also assess the cybersecurity proficiency of potential third-party cloud suppliers before utilizing their services.

We work closely with our internal and external auditors to assess, identify and manage cybersecurity risks. Our internal controls over financial reporting, which include certain of our IT internal controls, are audited by our external auditor as part of our Sarbanes-Oxley Act compliance activities, and this process includes assessing the design and operating effectiveness of those controls.

Although we have experienced phishing and similar attempts for unauthorized access to our information technology systems and data, during the past three years, m anagement has not identified cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition. However, evolving cybersecurity threats make it increasingly challenging to anticipate, detect and defend against cybersecurity threats and incidents. See "Item 1A. Risk Factors" above for more information.

Governance

Our board of trustees is responsible for overseeing the assessment and management of enterprise-level risks that may impact us, including cybersecurity. Two board members have information security expertise from their professional experience. Nathaniel A. Davis has expertise in information technology and experience reviewing and addressing cybersecurity risks. Patricia L. Gibson also has experience assessing and addressing cybersecurity risks through her past professional experience.

Our Audit Committee has primary responsibility for the oversight of risks from cybersecurity threats. Management, including members of the IT Committee, reports at least annually to the Audit Committee regarding the Company's enterprise risk management, cybersecurity risks and mitigation strategies and will report cybersecurity incidents to the Audit Committee as they occur, if material. The Audit Committee will inform the full board of trustees regarding significant cybersecurity incidents, as appropriate.

In addition to implementing and monitoring safeguards to minimize the chance and potential impact of a cybersecurity incident, we have established a cybersecurity incident response plan that is designed to effectively address cybersecurity threats that may occur despite these safeguards and help ensure timely and consistent responses to actual or attempted cybersecurity incidents impacting our company. The cybersecurity incident response plan includes an escalation framework, including processes for informing the board of trustees of material cybersecurity incidents.

Earlier filings on record

Fiscal 2024 Form 10-K, filed February 26, 2025 sec.gov ↗

Top security role, as the filing names it

not identified

Reports to, as the filing names it

not identified

Board oversight

Audit Committee

“Our Audit Committee has primary responsibility for the oversight of risks from cybersecurity threats.”

Person named in the filing

not identified

Experience, as stated

not identified

Material incident

The filing states none

“Management has not identified cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition.”

Read by claude-sonnet-5-5 on October 27, 2026; every quote verified in the stored text by code.

Item 1C. Cybersecurity

Risk Management and Strategy

We are committed to properly addressing the cybersecurity threats we face, and we have processes to assess, identify, and manage material risks from cybersecurity threats. We apply a comprehensive approach to the mitigation of cybersecurity risks. The risk of cybersecurity threats is integrated into our overall risk management program, which includes an annual risk prioritization process to identify key enterprise-level risks. The cybersecurity threat risk action plan is managed by a dedicated information technology ("IT") committee (the "IT Committee"), which oversees our cybersecurity program. The IT Committee comprises senior company leaders as well as our outsourced IT services provider. To oversee and identify cybersecurity threat risks on a day-to-day basis, we maintain a security operations center with round-the-clock monitoring. We have established

policies, including those related to privacy, information security and cybersecurity, and we employ a broad and diversified set of mitigation strategies and techniques to reduce cybersecurity risks, including continuous monitoring, early detection tools, proactive vulnerability management, and remediation. Our information security policies are modeled against the National Institute of Standards and Technology's Cybersecurity Standards and incorporate concepts from the Zero Trust Framework.

Given the ever-changing cybersecurity landscape, our IT Committee regularly meets to identify opportunities for incremental improvements, assess additional layers of security, and evaluate new technologies for implementation. In addition, we engage, as necessary, cybersecurity experts to analyze our IT policies, procedures, and infrastructure to assess their effectiveness and to identify opportunities for improvement.

We conduct an annual information security compliance training for all employees to enable them to detect and report malware, ransomware, and other malicious software and social engineering attempts that may compromise our IT systems. Employees also are subject to spear-phishing training campaigns, which allow us to assess the effectiveness of our training programs.

Our management companies are ultimately responsible for our guests' information, and we monitor these companies, as well as other third-party service providers , to ensure that they are complying with our privacy, information security and cybersecurity policies. We also assess the cybersecurity proficiency of potential third-party cloud suppliers before utilizing their services.

We work closely with our internal and external auditors to assess, identify and manage cybersecurity risks. Our IT internal controls are audited by our external auditor as part of our Sarbanes-Oxley Act compliance activities, and this process includes assessing the design and operating effectiveness of those controls.

Any failure to maintain proper function, security and availability of our information technology networks and systems could interrupt our operations, our financial reporting and compliance, damage our reputation, and subject us to liability claims or regulatory penalties, which could have a material and adverse effect on our business, financial condition and results of operations. Management has not identified cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition. See "Item 1A. Risk Factors" above for more information.

Governance

Our board of trustees is responsible for overseeing the assessment and management of enterprise-level risks that may impact us, including cybersecurity. Two board members have information security expertise from their professional experience. Nathaniel A. Davis has expertise in information technology and experience reviewing and addressing cybersecurity risks. Patricia L. Gibson also has experience assessing and addressing cybersecurity risks through her past professional experience.

Our Audit Committee has primary responsibility for the oversight of risks from cybersecurity threats. Management, including members of the IT Committee, reports at least annually to the Audit Committee regarding cybersecurity risks and mitigation strategies. We consider each member of our Audit Committee to possess information security experience by way of their oversight responsibilities over this area.

In addition to ensuring adequate safeguards are in place to minimize the chance of a successful cyber attack, we have established a cybersecurity incident response plan to effectively address any cybersecurity threat that may occur despite these safeguards. We believe our cybersecurity incident response plan will help ensure timely, consistent and compliant responses to actual or attempted data incidents impacting our company. The cybersecurity incident response plan includes an escalation framework, including processes for informing the board of trustees of material cybersecurity incidents.

Fiscal 2023 Form 10-K, filed February 27, 2024 sec.gov ↗

Top security role, as the filing names it

not identified

Reports to, as the filing names it

not identified

Board oversight

Audit Committee

“Our Audit Committee has primary responsibility for the oversight of risks from cybersecurity threats.”

Person named in the filing

not identified

Experience, as stated

not identified

Material incident

The filing states none

“Management has not identified cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition.”

Read by claude-sonnet-5-5 on October 27, 2026; every quote verified in the stored text by code.

Item 1C. Cybersecurity

Risk Management and Strategy

We are committed to properly addressing the cybersecurity threats we face, and we have processes to assess, identify, and manage material risks from cybersecurity threats. We apply a comprehensive approach to the mitigation of cybersecurity risks. The risk of cybersecurity threats is integrated into our overall risk management program, which includes an annual risk prioritization process to identify key enterprise-level risks. The cybersecurity threat risk action plan is managed by a dedicated information technology ("IT") committee (the "IT Committee"), which oversees our cybersecurity program. The IT Committee comprises senior company leaders as well as our outsourced IT services provider. To oversee and identify cybersecurity threat risks on a day-to-day basis, we maintain a security operations center with round-the-clock monitoring. We have established policies, including those related to privacy, information security and cybersecurity, and we employ a broad and diversified set of mitigation strategies and techniques to reduce cybersecurity risks, including continuous monitoring, early detection tools, proactive vulnerability management, and remediation. Our information security policies are modeled against the National Institute of Standards and Technology's Cybersecurity Standards and incorporate concepts from the Zero Trust Framework.

Given the ever-changing cybersecurity landscape, our IT Committee regularly meets to identify opportunities for incremental improvements, assess additional layers of security, and evaluate new technologies for implementation. In addition, we engage, as necessary, cybersecurity experts to analyze our IT policies, procedures, and infrastructure to assess their effectiveness and to identify opportunities for improvement.

We conduct an annual information security compliance training for all employees to enable them to detect and report malware, ransomware, and other malicious software and social engineering attempts that may compromise our IT systems. Employees also are subject to spear-phishing training campaigns, which allow us to assess the effectiveness of our training programs.

Our management companies are ultimately responsible for our guests' information, and we monitor these companies, as well as other third party service providers, to ensure that they are complying with our privacy, information security and cybersecurity policies. We also assess the cybersecurity proficiency of potential third party cloud suppliers before utilizing their services.

We work closely with our internal and external auditors to assess, identify and manage cybersecurity risks. Our IT internal controls are audited by our external auditor as part of our Sarbanes-Oxley Act compliance activities, and this process includes assessing the design and operating effectiveness of those controls.

Any failure to maintain proper function, security and availability of our information technology networks and systems could interrupt our operations, our financial reporting and compliance, damage our reputation, and subject us to liability claims or regulatory penalties, which could have a material and adverse effect on our business, financial condition and results of operations. Management has not identified cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition. See "Item 1A. Risk Factors" above for more information.

Governance

Our board of trustees is responsible for overseeing the assessment and management of enterprise-level risks that may impact us, including cybersecurity. Two board members have information security expertise from their professional experience. Nathaniel A. Davis has expertise in information technology and experience reviewing and addressing cybersecurity risks. Patricia L. Gibson also has experience assessing and addressing cybersecurity risks through her past professional experience.

Our Audit Committee has primary responsibility for the oversight of risks from cybersecurity threats. Management, including members of the IT Committee, reports at least annually to the Audit Committee regarding cybersecurity risks and mitigation strategies. We consider each member of our Audit Committee to possess information security experience by way of their oversight responsibilities over this area.

In addition to ensuring adequate safeguards are in place to minimize the chance of a successful cyber attack, we have established a cybersecurity incident response plan to effectively address any cybersecurity threat that may occur despite these safeguards. We believe our cybersecurity incident response plan will help ensure timely, consistent and compliant responses to actual or attempted data incidents impacting our company. The cybersecurity incident response plan includes an escalation framework, including processes for informing the board of trustees of material cybersecurity 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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