CISO Tribune

Disclosure · Form 10-K · fiscal 2025

Universal Token 10-K cybersecurity disclosure (Item 1C), fiscal 2025

Filed March 31, 2026· period ended December 31, 2025· UTKN· CIK 1919182· Updated · filing on sec.gov ↗

Universal Token's Form 10-K for fiscal 2025, filed March 31, 2026, carries an Item 1C cybersecurity section; a top security role title is not identified.

What Universal Token's Item 1C says

Universal Token's Form 10-K for fiscal 2025 refers to the board of directors as involved in cybersecurity governance.

Board and management oversight

The company states that all employees of the company have a duty to manage cybersecurity.

How the company manages cyber risk

The company identifies security threats through internal audits of its systems. The company conducts regular searches for threats and suspicious activities, and it monitors passwords and changes passwords within industry expectations.

Third parties and incidents

The company requires any service providers to provide System and Organizational Control type reports to ensure that data is secure. As of the date of the report, the company has not experienced or become aware of any cybersecurity incidents resulting in a material impact to it.

What the section does not state

The section does not name the person who holds the top security role. The section does not say who the top security role reports to. The section does not name a board committee as responsible for cybersecurity oversight. The section does not say how often the board or its committee is briefed on cybersecurity.

Read from the Form 10-K filed March 31, 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

not identified

CISO or other person named

not identified

Frameworks and standards named

not identified

Outside assessors, consultants or testers

not identified

Experience of the security leadership, as stated

not identified

Material incident

The filing states none

“As of the date of this report we have not experienced or aware of any cybersecurity incidents resulting, or reasonably likely to result in, a material impact to us, including to our business, financial condition, and results of operations.”

The section

473 words, Form 10-K filed March 31, 2026 for the period ended December 31, 2025

Read by claude-sonnet-5-5 on November 5, 2026; every quote verified in the stored text by code; 1 proposed field not found in the text and left empty.

How peers in the same industry describe the seat

The SEC assigns Universal Token standard industrial classification 6199, Finance services (SEC SIC list). 8 other filers in our library have the same code.

FilerTop security roleReports toBoard oversight
IREN LimitedFY 2026, filed August 27, 2026Chief Information Security Officernot identifiedAudit and Risk Committee
BeneficientFY 2026, filed June 30, 2026Chief Technology Officerour Boardfull board
HIVE Digital Technologies Ltd.FY 2026, filed June 2, 2026Chief Information Officernot identifiedaudit committee of the Board
FORUM MARKETS IncFY 2025, filed April 1, 2026Chief Financial Officernot identifiedAudit Committee
Bitfarms LtdFY 2025, filed March 31, 2026Vice President, Global Corporate ITexecutive managementaudit committee of the Board
Greenidge Generation Holdings Inc.FY 2025, filed March 31, 2026not identifiednot identifiedAudit Committee
Mawson Infrastructure Group Inc.FY 2025, filed March 31, 2026not identifiednot identifiedAudit Committee
Bit Digital, IncFY 2025, filed March 27, 2026Head of ITnot identifiedfull board

Item 1C, verbatim from the filing

The text below is the Cybersecurity item of Universal Token's Form 10-K as filed with the SEC on March 31, 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

Risks

Material Effects from

Cybersecurity Incidents

Our business is subject

to risk from cybersecurity threats and incidents, including attempts to gain unauthorized access to our systems or networks, or those

of our managers, employees, and third-party vendors and service providers, to disrupt operations, corrupt data or steal confidential

or personal information and other cybersecurity breaches. We consider cybersecurity risk a serious threat to our assets and our people

and have put processes in place designed to mitigate the risk and impact of any such cybersecurity threat or incident.

Our operations rely on

the secure, accurate and timely receipt, storage, transmission, use, disclosure, and other processing of confidential and other information

(including personal information) in our systems and networks. We also rely on the secure, accurate and timely receipt, storage, transmission,

use, disclosure, and other processing of confidential and other information in the systems and networks of our customers and third parties,

including suppliers, sellers and servicers, financial market utilities, and other third parties. Cybersecurity risks for companies like

ours continue to increase. Like many companies and government entities, from time to time we have been, and expect to continue to be,

the target of attempted cybersecurity incidents and other information security threats, including those from nation-state and nation-state

supported actors.

As of the date of this

report we have not experienced or aware of any cybersecurity incidents resulting, or reasonably likely to result in, a material impact

to us, including to our business, financial condition, and results of operations. There is no assurance that our cybersecurity risk management

program will prevent cybersecurity incidents from having such impacts in the future.

Additionally, insider

threats also remain a risk given our workforce diversification to include contractors, remote workers, part-time employees, and full-time

employees. As referenced above, our third-party vendors and service providers and their supply chain connections remain a potential source

of risk.

Cybersecurity Risk

Management and Strategy

Our cybersecurity program

is built upon industry standards and we have deployed sophisticated software both from internal and external sources to mitigate cybersecurity

threats. We identify security threats through internal audits of our systems. We also require any service providers to provide System

and Organizational Control ("SOC") type reports to ensure that data is secure and our duty to protect information is fulfilled.

Cybersecurity Governance

We believe that all employees

of the company have a duty to manage cybersecurity. We have implemented industry standard guidelines that help ensure that cybersecurity

governance is a priority. Our BOD is also very involved in the cybersecurity governance. We conduct regular searches for threats and

suspicious activities, and we monitor passwords and change passwords within industry expectations. Due to the technical aspects, we have

a lot of individuals that are very capable and are able to quickly act if we are to find any issues with our cybersecurity.

Earlier filings on record

Fiscal 2024 Form 10-K, filed April 9, 2025 sec.gov ↗

Top security role, as the filing names it

not identified

Reports to, as the filing names it

not identified

Board oversight

not identified

Person named in the filing

not identified

Experience, as stated

not identified

Material incident

The filing states none

“As of the date of this report we have not experienced or aware of any cybersecurity incidents resulting, or reasonably likely to result in, a material impact to us, including to our business, financial condition, and results of operations.”

Read by claude-sonnet-5-5 on November 5, 2026; every quote verified in the stored text by code; 1 proposed field not found in the text and left empty.

Item 1C. Cybersecurity Risks

Material Effects from Cybersecurity Incidents

Our business is subject to risk from cybersecurity threats

and incidents, including attempts to gain unauthorized access to our systems or networks, or those of our managers, employees, and third-party

vendors and service providers, to disrupt operations, corrupt data or steal confidential or personal information and other cybersecurity

breaches. We consider cybersecurity risk a serious threat to our assets and our people and have put processes in place designed to mitigate

the risk and impact of any such cybersecurity threat or incident.

Our operations rely on the secure, accurate and timely receipt,

storage, transmission, use, disclosure, and other processing of confidential and other information (including personal information) in

our systems and networks. We also rely on the secure, accurate and timely receipt, storage, transmission, use, disclosure, and other processing

of confidential and other information in the systems and networks of our customers and third parties, including suppliers, sellers and

servicers, financial market utilities, and other third parties. Cybersecurity risks for companies like ours continue to increase. Like

many companies and government entities, from time to time we have been, and expect to continue to be, the target of attempted cybersecurity

incidents and other information security threats, including those from nation-state and nation-state supported actors.

As of the date of this report we have not experienced or aware

of any cybersecurity incidents resulting, or reasonably likely to result in, a material impact to us, including to our business, financial

condition, and results of operations. There is no assurance that our cybersecurity risk management program will prevent cybersecurity

incidents from having such impacts in the future.

Additionally, insider threats also remain a risk given our

workforce diversification to include contractors, remote workers, part-time employees, and full-time employees. As referenced above, our

third-party vendors and service providers and their supply chain connections remain a potential source of risk.

Cybersecurity Risk Management and Strategy

Our cybersecurity program is built upon industry standards

and we have deployed sophisticated software both from internal and external sources to mitigate cybersecurity threats. We identify security

threats through internal audits of our systems. We also require any service providers to provide System and Organizational Control ("SOC")

type reports to ensure that data is secure and our duty to protect information is fulfilled.

Cybersecurity Governance

We believe that all employees of the company have a duty to

manage cybersecurity. We have implemented industry standard guidelines that help ensure that cybersecurity governance is a priority. Our

BOD is also very involved in the cybersecurity governance. We conduct regular searches for threats and suspicious activities, and we monitor

passwords and change passwords within industry expectations. Due to the technical aspects, we have a lot of individuals that are very

capable and are able to quickly act if we are to find any issues with our cybersecurity.

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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