What Rubrik, Inc. tells the SEC about who runs cybersecurity

Item 1C. Cybersecurity

Risk management and strategy

We have implemented and maintain various information security processes designed to identify, assess and manage material risks from cybersecurity threats to our critical computer networks, third party hosted services, communications systems, hardware and software, and our critical data, including intellectual property, confidential information that is proprietary, strategic or competitive in nature, and sensitive data and applications of our customers ("Information Systems and Data").

Our Chief Information Security Officer ("CISO") and the direct reports to the CISO (including the Senior Director of Information Security and the Senior Director for Governance, Risk and Compliance, collectively, the "CISO Team") help identify, assess and manage the Company's cybersecurity threats and risks, including through the use of a risk register. The CISO Team identifies and assesses risks from cybersecurity threats by monitoring and evaluating our threat environment using various methods including, for example, manual and automated tools, subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and actors, conducting scans of the threat environment, evaluating our and our industry's risk profile, evaluating threats reported to us, internal and/or external audits, conducting vulnerability assessments to identify vulnerabilities, use of external intelligence feeds, and third-party-conducted red/blue team testing and tabletop incident response exercises.

Depending on the environment, we implement and maintain various technical, physical, and organizational measures, processes, standards and policies designed to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data, including, for example: an incident response plan and/or incident response policy, incident detection and response, a vulnerability management policy, disaster recovery/business continuity plans, risk assessments, implementation of security standards/certifications, encryption of data, network security controls, access controls, physical security, vendor risk management program, employee training, penetration testing, cybersecurity insurance, dedicated cybersecurity staff/officer, and systems monitoring.

Rubrik, Inc.

2026 Form 10-K

Our assessment and management of material risks from cybersecurity threats are integrated into the Company's overall risk management processes. For example, (1) cybersecurity risk is identified in and a component of the Company's risk register; (2) the CISO Team works with management to prioritize our risk management processes and mitigate cybersecurity threats that are more likely to lead to a material impact to our business; and (3) our information security team evaluates material risks from cybersecurity threats against our overall business objectives and reports to the board of directors, which evaluates our overall enterprise risk.

We use third-party service providers to assist us from time to time to identify, assess, and manage material risks from cybersecurity threats, including for example professional services firms (including legal counsel), threat intelligence service providers, cybersecurity consultants, cybersecurity software providers, penetration testing firms, dark web monitoring services, and forensic investigators.

We also use third-party service providers to perform a variety of functions throughout our business, such as application providers, hosting companies, and supply chain resources. We have a vendor management program to manage cybersecurity risks associated with our use of these providers. The program includes risk assessment for each vendor, security questionnaires, review of the vendor's written security program, review of security assessments and reports, audits, calls with vendors security personnel, and contractual obligations regarding cybersecurity imposed on each vendor. Depending on the nature of the services provided, the sensitivity of the Information Systems and Data at issue, and the identity of the provider, our vendor management process may involve different levels of assessment designed to help identify cybersecurity risks associated with a provider and impose contractual obligations related to cybersecurity on the provider.

For a description of the risks from cybersecurity threats that may materially affect the Company and how they may do so, see our risk factors under Part I. Item 1A. Risk Factors in this Annual Report on Form 10-K.

Governance

Our board of directors addresses the Company's cybersecurity risk management as part of its general oversight function. The board of directors has established a Cybersecurity committee to assist it in fulfilling its oversight responsibilities with respect to the management of cybersecurity risks related to the Company's products and services as well as its information technology and network systems, including overseeing the Company's implementation and maintenance of cybersecurity measures, data governance, and compliance with security laws.

Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management, including the CISO Team, along with other members of management.

Our CISO Team is responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into the Company's overall risk management strategy, and communicating key priorities to relevant personnel. The CISO Team is also responsible for approving budgets, helping prepare for cybersecurity incidents, approving cybersecurity processes, and reviewing security assessments and other security-related reports.

Our cybersecurity incident response processes are designed to escalate certain cybersecurity incidents to members of management depending on the circumstances, including our crisis management team. The CISO Team works with our crisis management team to help the Company mitigate and remediate cybersecurity incidents of which they are notified. In addition, the Company's incident response processes include reporting to the board of directors for certain cybersecurity incidents.

The Cybersecurity Committee and the board of directors receive periodic reports from the CISO team concerning the Company's significant cybersecurity threats and risk and the processes the Company has implemented to address them. The Cybersecurity Committee and the board of directors also receive various reports, summaries or presentations related to cybersecurity threats, risk and mitigation.

Rubrik, Inc.

2026 Form 10-K