CISO Tribune

Disclosure · Form 10-K · fiscal 2026

StepStone Group Inc. 10-K cybersecurity disclosure (Item 1C), fiscal 2026

Filed May 27, 2026· period ended March 31, 2026· STEP· CIK 1796022· Updated · filing on sec.gov ↗

StepStone Group Inc.'s Form 10-K for fiscal 2026, filed May 27, 2026, names the Partner, Chief Information Security Officer & Head of Information Technology as its top security role, reporting to the President and Co-Chief Operating Officer, with oversight by the audit committee.

What StepStone's Item 1C says

StepStone's Form 10-K for fiscal 2026 makes the audit committee responsible for reviewing and discussing practices on risk assessment and risk management, including information technology and cybersecurity risks. At the management level, the CISO heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices.

Board and management oversight

The board of directors oversees the company's processes for assessing and managing risk. The board of directors and audit committee periodically review the measures the company has implemented to identify and mitigate risks from cybersecurity threats. The CISO also periodically presents to the board of directors and audit committee, including to describe the information security infrastructure and improvements made, and to report on any significant developments. The company has a framework under which certain cybersecurity incidents are escalated and, where appropriate, reported to the board of directors or audit committee in a timely manner. The Enterprise Risk Management Committee was established to oversee and promote the efficient and effective management of the company's enterprise risks. The working group meets regularly to identify and mitigate data protection and cybersecurity risks and to discuss and respond to any significant cyber incidents.

Who leads security

The CISO reports directly to the President and Co-Chief Operating Officer and has over 25 years of work experience at the company and elsewhere. The CISO works closely with the Legal and Compliance departments to oversee compliance with legal, regulatory and contractual security requirements. The CISO is responsible for providing training to employees in respect of information security.

How the company manages cyber risk

The company has adopted an Incident Response Plan that provides a standardized framework for responding to security incidents. The company's incident response process focuses on four phases and uses the NIST framework. The company undergoes annual SOC 1 Type 2 testing of its financial processes and supporting technical controls. The company conducts regular employee trainings on cybersecurity and performs phishing exercises to test employees' understanding of how to identify social engineering attacks. The internal audit team facilitates periodic cybersecurity risk assessments and conducts audits relating to cybersecurity.

Third parties and incidents

The company conducts annual penetration testing performed by a rotating group of third-party security firms. The company performs diligence on vendors and third parties with significant access to confidential information and personal data, and periodically monitors such vendors. The company, at times, engages consultants or other third parties to assist with assessing, identifying, and managing cybersecurity risks. Based on information available as of the date of the annual report, the company has not identified any risks from cybersecurity threats that it believes have materially affected 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 May 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)

Partner, Chief Information Security Officer & Head of Information Technology

Reports to

President and Co-Chief Operating Officer

“At the management level, the CISO, who has extensive cybersecurity knowledge and skills gained from over 25 years of work experience at the Company and elsewhere, heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices and reports directly to the President and Co-Chief Operating Officer.”

Board oversight

audit committee

“Our audit committee is responsible for reviewing and discussing our practices with respect to risk assessment and risk management, including risks related to information technology and cybersecurity.”

CISO or other person named

not identified

Frameworks and standards named

NIST (publication not named)

Where the filing names it
  • NIST (publication not named): “In general, our incident response process leverages the NIST framework and focuses on four phases: preparation; detection and analysis; containment, eradication and recovery; and post-incident remediation.”

Outside assessors, consultants or testers

Described

“We conduct annual penetration testing performed by a rotating group of third-party security firms to test our technical controls and security response.”

Experience of the security leadership, as stated

Stated

“At the management level, the CISO, who has extensive cybersecurity knowledge and skills gained from over 25 years of work experience at the Company and elsewhere, heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices and reports directly to the President and Co-Chief Operating Officer.”

Material incident

The filing states none

“Based on information available as of the date of this annual report, we have not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that we believe have materially affected, or are reasonably likely to materially affect, us, including our business strategy, results of operations, or financial condition, but we face certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to have such an effect, and there can be no assurance that we will not be subject to future cybersecurity attacks, threats or incidents that may materially affect our business strategy, results of operations or financial condition.”

The section

1,222 words, Form 10-K filed May 27, 2026 for the period ended March 31, 2026

Read by claude-sonnet-5-5 on October 23, 2026; every quote verified in the stored text by code.

How peers in the same industry describe the seat

The SEC assigns StepStone Group Inc. standard industrial classification 6282, Investment advice (SEC SIC list). 8 other filers in our library have the same code.

FilerTop security roleReports toBoard oversight
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
BRC Group Holdings, Inc.FY 2025, filed April 1, 2026Chief Information Security OfficerCo-Chief Executive OfficerAudit Committee of our Board of Directors
Westwood Holdings Group IncFY 2025, filed March 4, 2026Information Security Officernot identifiedfull board
KKRFY 2025, filed February 27, 2026Chief Information Security Officernot identifiedAudit Committee and the Risk Committee of our Board of Directors
Victory Capital Holdings, Inc.FY 2025, filed February 26, 2026Chief Information Security Officernot identifiedAudit Committee of the Board of Directors
Invesco Ltd.FY 2025, filed February 24, 2026Global Chief Security Officernot identifiedfull board
Price T Rowe Group IncFY 2025, filed February 13, 2026Chief Information Security Officernot identifiedAudit Committee

Item 1C, verbatim from the filing

The text below is the Cybersecurity item of StepStone Group Inc.'s Form 10-K as filed with the SEC on May 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.

We maintain a cybersecurity program that is reasonably designed to protect our information, and that of our clients, portfolio companies and investment managers with which we conduct business, against cybersecurity threats that may result in significant adverse effects on the confidentiality, integrity, and availability of our information systems.

Governance

Board of Directors

The board of directors oversees our processes for assessing and managing risk. Our audit committee is responsible for reviewing and discussing our practices with respect to risk assessment and risk management, including risks related to information technology and cybersecurity. The board of directors and audit committee periodically review the measures implemented by us to identify and mitigate risks from cybersecurity threats. As part of such reviews, the board of directors and audit committee receive reports and presentations from those responsible for overseeing our cybersecurity risk management, including the Partner, Chief Information Security Officer & Head of Information Technology ("CISO") and our Legal team, which may address a wide range of topics including recent developments, evolving standards, vulnerability assessments, third-party and independent reviews, the threat environment, technological trends and information security considerations arising with respect to our peers, industry participants, service providers and other third parties. The CISO also periodically presents to the board of directors and audit committee, including to describe our information security infrastructure and improvements made, and to report on any significant developments. From time to time, external legal advisers provide education to the board of directors and/or audit committee in respect of information security related developments and to provide training in respect of directors' responsibilities. We have a framework under which certain cybersecurity incidents are escalated and, where appropriate, reported to the board of directors or audit committee in a timely manner.

Management

We have a cybersecurity working group composed of members of the Information Technology (including Information Security), Legal and Compliance departments, including the CISO, Chief Technology Officer, Chief Legal Officer, Chief Compliance Officer, and a number of their respective team members . The working group meets regularly to identify and mitigate data protection and cybersecurity risks, implement information security governance mechanisms, discuss developments in information security, and discuss and respond to any significant cyber incidents. The working group is expected to escalate matters of significance to our Incident Response Team, ERMC (defined below) and/or the disclosure committee, as appropriate.

We have adopted an Incident Response Plan ("IRP") that applies in the event of a cybersecurity threat or incident to provide a standardized framework for responding to security incidents. The IRP sets out a coordinated approach to investigating, containing, documenting and mitigating incidents, including reporting findings and keeping senior management and other key stakeholders informed and involved as appropriate. In general, our incident response process leverages the NIST framework and focuses on four phases: preparation; detection and analysis; containment, eradication and recovery; and post-incident remediation. The IRP applies to all personnel, networks and systems, third-party systems and end-user devices.

In addition, we have an Enterprise Risk Management Committee ("ERMC") composed of a number of members of senior management from operations across our businesses, legal, compliance, information technology, finance, human resources and internal audit and risk. The ERMC was established to oversee and promote the efficient and effective management of our enterprise risks. Cybersecurity and significant information security matters are to be brought before the ERMC or certain of its members, and matters of primary significance are to be further escalated and reported to our Global Executive Committee and the audit committee of our board of directors, as appropriate.

At the management level, the CISO, who has extensive cybersecurity knowledge and skills gained from over 25 years of work experience at the Company and elsewhere, heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices and reports directly to the President and Co-Chief Operating Officer. The CISO receives reports on cybersecurity threats from his team and external service providers on an ongoing basis and, in conjunction with management, reviews risk management measures implemented by us to identify and mitigate data protection and cybersecurity risks. The CISO works closely with our Legal and Compliance departments to oversee compliance with legal, regulatory and contractual security requirements and to develop reports and presentations to the board of directors and its audit committee. The CISO is responsible for providing training to employees in respect of information security.

Risk Management and Strategy

We take a multifaceted approach to managing risk from cybersecurity threats. Our cybersecurity program leverages people, processes, and technology to identify and respond to cybersecurity threats in a timely manner. Our information security program and supporting policies apply to all employees, contractors and certain vendors servicing the firm. The program outlines the development, maintenance, and distribution of information security policies and procedures that detail the implementation and maintenance of the information security program and its safeguards, and cover various areas such as information handling, user access management, encryption, data retention and backups, computer and network security and monitoring, physical security, incident reporting and response, service provider oversight, and employee and contractor use of technology. We also undergo annual SOC 1 Type 2 testing of our financial processes and supporting technical controls.

In addition to the foregoing, we conduct regular employee trainings on cybersecurity and perform phishing exercises to test employees' understanding of how to identify social engineering attacks. We perform diligence, including in respect of information security, of vendors and third parties with significant access to confidential information and personal data, and periodically monitor such vendors. We also employ systems and processes designed to oversee, identify, and reduce the potential impact of a security incident at a third-party vendor, service provider or customer or otherwise implicating the third-party technology and systems. We conduct annual penetration testing performed by a rotating group of third-party security firms to test our technical controls and security response. Our internal audit team also facilitates periodic cybersecurity risk assessments and conducts audits relating to cybersecurity to review our processes and controls designed to mitigate cybersecurity risks. In addition to our internal cybersecurity capabilities and third-party penetration testing, we also, at times, engage consultants or other third parties to assist with assessing, identifying, and managing cybersecurity risks.

Material Cybersecurity Risks, Threats & Incidents

Due to evolving cybersecurity threats, it has and will continue to be difficult to prevent, detect, mitigate, and remediate cybersecurity incidents. Based on information available as of the date of this annual report, we have not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that we believe have materially affected, or are reasonably likely to materially affect, us, including our business strategy, results of operations, or financial condition, but we face certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to have such an effect, and there can be no assurance that we will not be subject to future cybersecurity attacks, threats or incidents that may materially affect our business strategy, results of operations or financial condition. Additional information on cybersecurity risks we face can be found in Part I, Item 1A "Risk Factors" of this Report under the heading "Cybersecurity risks and cybersecurity incidents could adversely affect our business by causing a disruption to our operations, which could adversely affect our financial condition and results of operations.", which should be read in conjunction with the foregoing information.

Earlier filings on record

Fiscal 2025 Form 10-K, filed May 23, 2025 sec.gov ↗

Top security role, as the filing names it

Partner, Chief Information Security Officer & Head of Information Technology

Reports to, as the filing names it

President and Co-Chief Operating Officer

“At the management level, the CISO, who has extensive cybersecurity knowledge and skills gained from over 20 years of work experience at the Company and elsewhere, heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices and reports directly to the President and Co-Chief Operating Officer.”

Board oversight

audit committee

“Our audit committee is responsible for reviewing and discussing our practices with respect to risk assessment and risk management, including risks related to information technology and cybersecurity.”

Person named in the filing

not identified

Experience, as stated

Stated

“At the management level, the CISO, who has extensive cybersecurity knowledge and skills gained from over 20 years of work experience at the Company and elsewhere, heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices and reports directly to the President and Co-Chief Operating Officer.”

Material incident

The filing states none

“To date, based on information available as of the date of this annual report, we have not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that we believe have materially affected, or are reasonably likely to materially affect, us, including our business strategy, results of operations, or financial condition, but we face certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to have such an effect and there can be no assurance that we will not be subject to future cybersecurity attacks, threats or incidents that may materially affect our business strategy, results of operations or financial conditi”

Read by claude-sonnet-5-5 on October 23, 2026; every quote verified in the stored text by code.

Item 1C. Cybersecurity.

We maintain a cybersecurity program that is reasonably designed to protect our information, and that of our clients, portfolio companies and investment managers with which we conduct business, against cybersecurity threats that may result in significant adverse effects on the confidentiality, integrity, and availability of our information systems.

Governance

Board of Directors

The board of directors oversees our processes for assessing and managing risk. Our audit committee is responsible for reviewing and discussing our practices with respect to risk assessment and risk management, including risks related to information technology and cybersecurity. The board of directors and audit committee periodically review the measures implemented by us to identify and mitigate risks from cybersecurity threats. As part of such reviews, the board of directors and audit committee receive reports and presentations from those responsible for overseeing our cybersecurity risk management, including the Partner, Chief Information Security Officer & Head of Information Technology ("CISO") and our Legal team, which may address a wide range of topics including recent developments, evolving standards, vulnerability assessments, third-party and independent reviews, the threat environment, technological trends and information security considerations arising with respect to

our peers, industry participants, service providers and other third parties. The CISO also periodically presents to the board of directors and audit committee, including to describe our information security infrastructure and improvements made, and to report on any significant developments. From time to time, external legal advisers provide education to the board of directors and/or audit committee in respect of information security related developments and to provide training in respect of directors' responsibilities. We have a framework under which certain cybersecurity incidents are escalated and, where appropriate, reported to the board of directors or audit committee in a timely manner.

Management

We have a cybersecurity working group composed of members of the Information Technology (including Information Security), Legal and Compliance departments, including the CISO, Chief Technology Officer, Chief Legal Officer, Chief Compliance Officer, and a number of their respective team members . The working group meets regularly to identify and mitigate data protection and cybersecurity risks, implement information security governance mechanisms, discuss developments in information security, and discuss and respond to any significant cyber incidents. The working group is expected to escalate matters of significance to our Incident Response Team, ERMC (defined below) and/or the disclosure committee, as appropriate.

We have adopted an Incident Response Plan ("IRP") that applies in the event of a cybersecurity threat or incident to provide a standardized framework for responding to security incidents. The IRP sets out a coordinated approach to investigating, containing, documenting and mitigating incidents, including reporting findings and keeping senior management and other key stakeholders informed and involved as appropriate. In general, our incident response process leverages the NIST framework and focuses on four phases: preparation; detection and analysis; containment, eradication and recovery; and post-incident remediation. The IRP applies to all personnel, networks and systems, third-party systems and end-user devices.

In addition, we have an Enterprise Risk Management Committee ("ERMC") composed of a number of members of senior management from operations across our businesses, legal, compliance, information technology, finance, human resources and internal audit and risk. The ERMC was established to oversee and promote the efficient and effective management of our enterprise risks. Cybersecurity and significant information security matters are to be brought before the ERMC or certain of its members, and matters of primary significance are to be further escalated and reported to our Global Executive Committee and the audit committee of our board of directors, as appropriate.

At the management level, the CISO, who has extensive cybersecurity knowledge and skills gained from over 20 years of work experience at the Company and elsewhere, heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices and reports directly to the President and Co-Chief Operating Officer. The CISO receives reports on cybersecurity threats from his team and external service providers on an ongoing basis and, in conjunction with management, reviews risk management measures implemented by us to identify and mitigate data protection and cybersecurity risks. The CISO works closely with our Legal and Compliance departments to oversee compliance with legal, regulatory and contractual security requirements and to develop reports and presentations to the board of directors and its audit committee. The CISO is responsible for providing training to employees in respect of information security.

Risk Management and Strategy

We take a multifaceted approach to managing risk from cybersecurity threats. Our cybersecurity program leverages people, processes, and technology to identify and respond to cybersecurity threats in a timely manner. Our information security program and supporting policies apply to all employees, contractors and certain vendors servicing the firm. The program outlines the development, maintenance, and distribution of information security policies and procedures that detail the implementation and maintenance of the information security program and its safeguards, and cover various areas such as information handling, user access management, encryption, data retention and backups, computer and network security and monitoring, physical security, incident reporting and response, service provider oversight, and employee and contractor use of technology. We also undergo annual SOC 1 Type 2 testing of our financial processes and supporting technical controls.

In addition to the foregoing, we conduct regular employee trainings on cybersecurity and perform phishing exercises to test employees' understanding of how to identify social engineering attacks. We perform diligence, including in respect of information security, of vendors and third parties with significant access to confidential information and personal data, and periodically monitor such vendors. We also employ systems and processes designed to oversee, identify, and reduce the potential impact of a security incident at a third-party vendor, service provider or customer or otherwise implicating the third-party technology and systems. We conduct annual penetration testing performed by a rotating group of third-party security firms to test our technical controls and security response. Our internal audit team has also conducted a cybersecurity assessment to test our preparedness. In addition to our internal cybersecurity capabilities and third-party penetration testing, we also, at times, engage consultants or other third parties to assist with assessing, identifying, and managing cybersecurity risks.

Material Cybersecurity Risks, Threats & Incidents

Due to evolving cybersecurity threats, it has and will continue to be difficult to prevent, detect, mitigate, and remediate cybersecurity incidents. To date, based on information available as of the date of this annual report, we have not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that we believe have materially affected, or are reasonably likely to materially affect, us, including our business strategy, results of operations, or financial condition, but we face certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to have such an effect and there can be no assurance that we will not be subject to future cybersecurity attacks, threats or incidents that may materially affect our business strategy, results of operations or financial condition. Additional information on cybersecurity risks we face can be found in Part I, Item 1A "Risk Factors" of this Report under the heading "Cybersecurity risks and cybersecurity incidents could adversely affect our business by causing a disruption to our operations, which could adversely affect our financial condition and results of operations.", which should be read in conjunction with the foregoing information.

Fiscal 2024 Form 10-K, filed May 24, 2024 sec.gov ↗

Top security role, as the filing names it

Head of IT

Reports to, as the filing names it

President and Co-Chief Operating Officer

“At the management level, the Head of IT, who has extensive cybersecurity knowledge and skills gained from over 20 years of work experience at the Company and elsewhere, heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices and reports directly to the President and Co-Chief Operating Officer.”

Board oversight

audit committee

“Our audit committee is responsible for reviewing and discussing our practices with respect to risk assessment and risk management, including risks related to information technology and cybersecurity.”

Person named in the filing

not identified

Experience, as stated

Stated

“At the management level, the Head of IT, who has extensive cybersecurity knowledge and skills gained from over 20 years of work experience at the Company and elsewhere, heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices and reports directly to the President and Co-Chief Operating Officer.”

Material incident

The filing states none

“To date, we have not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that we believe have materially affected, or are reasonably likely to materially affect, us, including our business strategy, results of operations, or financial condition, but we face certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to have such an effect.”

Read by claude-sonnet-5-5 on October 23, 2026; every quote verified in the stored text by code.

Item 1C. Cybersecurity.

We maintain a cybersecurity program that is reasonably designed to protect our information, and that of our clients, portfolio companies and investment managers with which we conduct business, against cybersecurity threats that may result in significant adverse effects on the confidentiality, integrity, and availability of our information systems.

Governance

Board of Directors

The board of directors oversees our processes for assessing and managing risk. Our audit committee is responsible for reviewing and discussing our practices with respect to risk assessment and risk management, including risks related to information technology and cybersecurity. The board of directors and audit committee periodically review the measures implemented by us to identify and mitigate risks from cybersecurity threats. As part of such reviews, the board of directors and audit committee receive reports and presentations from those responsible for overseeing our cybersecurity risk management, including the Managing Director, Head of Information Technology ("Head of IT") and our Legal team, which may address a wide range of topics including recent developments, evolving standards, vulnerability assessments, third-party and independent reviews, the threat environment, technological trends and information security considerations arising with respect to our peers, industry

participants, service providers and other third parties. The Head of IT also periodically presents to the board of directors and audit committee, including to describe our information security infrastructure and improvements made, and to report on any significant developments. From time to time, external legal advisers provide education to the board of directors and/or audit committee in respect of information security related developments and to provide training in respect of directors' responsibilities. We have a framework under which certain cybersecurity incidents are escalated and, where appropriate, reported to the board of directors or audit committee in a timely manner.

Management

We have a cybersecurity working group composed of members of the Information Technology (including Information Security), Legal and Compliance departments, including the Head of IT, Chief Legal Officer, Chief Compliance Officer, and a number of their respective team members. The working group meets regularly to identify and mitigate data protection and cybersecurity risks, implement information security governance mechanisms, discuss developments in information security, and discuss and respond to any significant cyber incidents. The working group is expected to escalate matters of significance to our Incident Response Team, ERMC (defined below) and/or the disclosure committee, as appropriate.

We have adopted an Incident Response Plan ("IRP") that applies in the event of a cybersecurity threat or incident to provide a standardized framework for responding to security incidents. The IRP sets out a coordinated approach to investigating, containing, documenting and mitigating incidents, including reporting findings and keeping senior management and other key stakeholders informed and involved as appropriate. In general, our incident response process leverages the NIST framework and focuses on four phases: preparation; detection and analysis; containment, eradication and recovery; and post-incident remediation. The IRP applies to all personnel, networks and systems, third-party systems and end-user devices.

In addition, we have an Enterprise Risk Management Committee ("ERMC") composed of a number of members of senior management from operations across our businesses, legal, compliance, information technology, finance, human resources and internal audit and risk. The ERMC was established to oversee and promote the efficient and effective management of our enterprise risks. Cybersecurity and significant information security matters are to be brought before the ERMC or certain of its members, and matters of primary significance are to be further escalated and reported to our Global Executive Committee and the audit committee of our board of directors, as appropriate.

At the management level, the Head of IT, who has extensive cybersecurity knowledge and skills gained from over 20 years of work experience at the Company and elsewhere, heads the team responsible for implementing, monitoring and maintaining cybersecurity and data protection practices and reports directly to the President and Co-Chief Operating Officer. The Head of IT receives reports on cybersecurity threats from his team and external service providers on an ongoing basis and, in conjunction with management, reviews risk management measures implemented by us to identify and mitigate data protection and cybersecurity risks. The Head of IT works closely with our Legal and Compliance departments to oversee compliance with legal, regulatory and contractual security requirements and to develop reports and presentations to the board of directors and its audit committee. The Head of IT is responsible for providing training to employees in respect of information security.

Risk Management and Strategy

We take a multifaceted approach to managing risk from cybersecurity threats. Our cybersecurity program leverages people, processes, and technology to identify and respond to cybersecurity threats in a timely manner. Our information security program and supporting policies apply to all employees, contractors and certain vendors servicing the firm. The program outlines the development, maintenance, and distribution of information security policies and procedures that detail the implementation and maintenance of the information security program and its safeguards, and cover various areas such as information handling, user access management, encryption, data retention and backups, computer and network security and monitoring, physical security, incident reporting and response, service provider oversight, and employee and contractor use of technology. We also undergo annual SOC 1 Type 2 testing of our financial processes and supporting technical controls.

In addition to the foregoing, we conduct regular employee trainings on cybersecurity and perform phishing exercises to test employees' understanding of how to identify social engineering attacks. We perform diligence, including in respect of information security, of vendors and third parties with significant access to confidential information and personal data, and periodically monitor such vendors. We also employ systems and processes designed to oversee, identify, and reduce the potential impact of a security incident at a third-party vendor, service provider or customer or otherwise implicating the third-party technology and systems. We conduct annual penetration testing performed by a rotating group of third-party security firms to test our technical controls and security response. Our internal audit team has also conducted a cybersecurity assessment to test our preparedness. In addition to our internal cybersecurity capabilities and third-party penetration testing, we also, at times, engage consultants or other third parties to assist with assessing, identifying, and managing cybersecurity risks.

Material Cybersecurity Risks, Threats & Incidents

Due to evolving cybersecurity threats, it has and will continue to be difficult to prevent, detect, mitigate, and remediate cybersecurity incidents. To date, we have not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that we believe have materially affected, or are reasonably likely to materially affect, us, including our business strategy, results of operations, or financial condition, but we face certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to have such an effect. Additional information on cybersecurity risks we face can be found in Part I, Item 1A "Risk Factors" of this Report under the heading "Cybersecurity risks and cybersecurity incidents could adversely affect our business by causing a disruption to our operations, which could adversely affect our financial condition and results of operations.", which should be read in conjunction with the foregoing information.

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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