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 and confidential information that is proprietary, strategic or competitive in nature or Information Systems and Data.

Our information security function, led by our Senior Director, IT & Facilities and our Senior Manager, IT Infrastructure and Operations, helps identify, assess and manage our cybersecurity threats and risks. Our information security function identifies and assesses risks from cybersecurity threats by monitoring and evaluating our threat environment using various methods and resources including, for example automated tools, internal and external audits, external intelligence feeds and third-party threat assessments; conducting scans of the threat environment, threat assessments for internal and external risk and vulnerability assessments to identify vulnerabilities; evaluating our and our industry’s risk profile and threats reported to us; subscribing to reports and services that identify cybersecurity threats; analyzing reports of threat and threat actors and coordinating with law enforcement concerning threats; and internal 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, disaster recovery/business continuity plans and cybersecurity insurance; incident detection and response, risk assessments, systems monitoring and penetration testing; encryption of data, network security controls, access controls, physical security and asset management, tracking and disposal; and employee training.

Our assessment and management of material risks from cybersecurity threats are integrated into our overall risk management processes. For example, cybersecurity risk is addressed as a component of our enterprise risk management process; the information security function 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; our senior management evaluates 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 service firms, threat intelligence service providers, cybersecurity software providers, managed cybersecurity service providers, penetration testing firms and forensic investigators.

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We use third-party service providers to perform a variety of functions throughout our business, such as third-party distributors for our products in certain countries and third-party suppliers for the manufacture of our products, as well as third-party application providers and third-party hosting companies. Depending on the nature of the services provided, the sensitivity of the Information Systems and Data at issue, and the identity of the provider, we may impose contractual obligations related to cybersecurity on the provider.

For a description of the risks from cybersecurity threats that may materially affect us and how they may do so, see our risk factors under “Item 1A—Risk Factors” in Part I of this Annual Report on Form 10-K, including the risk factor captioned, “Significant disruptions of information technology systems or actual or alleged breaches of data security could adversely affect our business.”

Governance

Our board of directors addresses our cybersecurity risk management as part of its general oversight function. The audit committee of the board of directors is responsible for overseeing our 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 members of management, including our Senior Director, IT & Facilities and our Senior Manager, IT Infrastructure and Operations. Our Senior Director, IT & Facilities has over 26 years of experience in systems engineering, network design and security and is a Certified Information Systems Security Professional, or CISSP. Our Senior Manager, IT Infrastructure and Operations has over 24 years of experience in network administration, security administration and incident response and remediation.

Our Senior Director, IT & Facilities and our Senior Manager, IT Infrastructure and Operations are responsible for helping to integrate cybersecurity risk considerations into our overall risk management strategy and communicating key priorities to relevant personnel. Our Senior Director, IT & Facilities and our Senior Manager, IT Infrastructure and Operations are responsible for helping prepare for cybersecurity incidents, approving cybersecurity processes and reviewing security assessments and other security-related reports.

Our cybersecurity incident response plan is designed to escalate certain cybersecurity incidents to members of management depending on the circumstances, including Senior Director, IT & Facilities, Chief Legal Officer, Chief Financial Officer, Chief Executive Officer and others. Those individuals work with our incident response team to help us mitigate and remediate cybersecurity incidents of which they are notified. In addition, our incident response plan includes reporting to the audit committee of the board of directors for certain cybersecurity incidents.

The audit committee of the board of directors receives periodic reports from our Senior Director, IT & Facilities concerning our significant cybersecurity threats and risk and the processes we have implemented to address them. The board of directors also has access to various reports, summaries or presentations related to cybersecurity threats, risk and mitigation.