Regulus Therapeutics Inc. - (RGLS)
10-K Filing Date: March 21, 2024
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 (“Information Systems and Data”).
Our legal department, a management committee (composed of our Senior Vice President and General Counsel, our Chief Financial Officer, and our Vice President, Finance and Controller) and a third-party service provider (collectively, the “Cybersecurity Risk Management Team”) help identify, assess and manage the Company’s cybersecurity threats and risks. Our
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Cybersecurity Risk Management Team identify and assess risks from cybersecurity threats by monitoring and evaluating our threat environment using various methods including, for example, manual tools, automated tools, conducting scans of the threat environment, evaluating our and our industry’s risk profile, evaluating threats reported to us, conducting internal audits, conducting third party threat assessments, and conducting vulnerability assessments to identify vulnerabilities.
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, a cybersecurity incident response plan, incident detection and response, a disaster recovery and business continuity plan, risk assessments, implementation of security standards, encryption of data, network security controls, data segregation, access controls, physical security, asset management, tracking and disposal, systems monitoring, employee training, penetration testing, cybersecurity insurance, and systems monitoring.
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 addressed as a component of the Company’s enterprise risk management program; (2) the Cybersecurity Risk Management 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; (3) our Senior Vice President and General Counsel, our Chief Financial Officer and our Vice President, Finance and Controller evaluate material risks from cybersecurity threats against our overall business objectives and reports to the audit committee of 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 and cybersecurity consultants.
We use third-party service providers to perform a variety of functions throughout our business, such as hosting companies, contract research organizations, contract manufacturing organizations 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, system and organization controls reporting, and audits. 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, as well as 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 1. Item 1A. Risk Factors in this Annual Report on Form 10-K, including ”Cybersecurity risks and the failure to maintain the security, confidentiality, integrity, and availability of our information technology systems or data, and those maintained on our behalf, could result in material adverse impact to our business, including without limitation regulatory investigations or actions, a material interruption to our operations, including clinical trials, damage to our reputation and/or subject us to costs, fines and penalties or lawsuits.”
Governance
Our board of directors addresses the Company’s cybersecurity risk management as part of its general oversight function. The board of directors’ audit committee is responsible for overseeing Company’s cybersecurity risk management processes, including oversight and mitigation of risks from cybersecurity threats.
Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management, including our Senior Vice President and General Counsel, Chief Financial Officer, Vice President, Finance and Controller. Our Senior Vice President and General Counsel has expertise as a Life Sciences executive, has had a key role in information technology and cybersecurity oversight for several years and has completed several cybersecurity trainings. Our Chief Financial Officer has several years of expertise performing audits as a public accountant, including audits over information technology controls, and has also completed several cybersecurity trainings. Our Vice President, Finance and Controller has expertise playing a key role with information technology general controls and control testing for the Company for many years, and has several years of expertise leading and performing audits as a public accountant, including audits over information technology controls. He has also completed several cybersecurity trainings.
These positions are 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. They are also responsible for preparing and 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 the Senior Vice President and General Counsel, Chief Financial Officer and Chief Executive Officer. The Cybersecurity Risk Management Team and others work with the Company’s incident response team to help the Company mitigate and remediate cybersecurity incidents of which they are notified. In addition, the
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Company’s incident response processes include reporting to the audit committee of the board of directors for certain cybersecurity incidents.
The audit committee receives periodic reports from the Senior Vice President and General Counsel, Chief Financial Officer, Vice President, Finance and Controller concerning the Company’s significant cybersecurity threats and risk and the processes the Company has implemented to address them. The audit committee also receives and has access to various reports, summaries or presentations related to cybersecurity threats, risk and mitigation.