Risk Management and Strategy

We have established policies and processes for assessing, identifying, and managing material risk from cybersecurity threats, and have integrated these processes into our overall risk management systems and processes. We routinely assess material risks from cybersecurity threats, including any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality, integrity or availability of our information systems or any information residing therein.

We conduct periodic risk assessments to identify cybersecurity threats and assessments in the event of a material change in our business practices that may affect information systems that are vulnerable to such cybersecurity threats. These risk assessments include the identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that could result from such risks, and the sufficiency of existing policies, procedures, systems and safeguards in place to manage such risks.

Following these risk assessments, we re-design, implement, and maintain reasonable safeguards to minimize identified risks, reasonably address any identified gaps in existing safeguards, and regularly monitor the effectiveness of our safeguards. We devote significant resources and designate high-level personnel, including our VP of Information Technology, who reports to our General Counsel & Head of Operations, to manage the risk assessment and mitigation process.

As part of our overall risk management system, we monitor and test our safeguards and train our employees on these safeguards in collaboration with management. Personnel at all levels and departments know our cybersecurity policies through training. Random attack simulations are conducted monthly to familiarize all personnel with various phishing methods with positive reinforcement on identifying and reporting suspicious content to the IT Department.

We engage third parties like a penetration testing firm and our managed service provider (MSP) in connection with our risk assessment processes. These service providers assist us in identifying vulnerabilities to design and implement, suggesting remediation of our cybersecurity policies and procedures, as well as monitor and test our safeguards. We require each third-party service provider to implement and maintain reasonable security measures in connection with their work with us, and to promptly report any suspected breach of its security measures that may affect our company.

For additional information regarding whether any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have materially affected or are reasonably likely to materially affect our company, including our business strategy, results of operations, or financial condition, please refer to “Item 1A. Risk Factors,” in this Annual Report on Form 10-K, including the risk factors entitled “Our internal computer systems, or those of any of our CROs, manufacturers, other contractors or consultants or potential future collaborators, may fail or suffer security or data privacy breaches or other unauthorized or improper access to, use of, or destruction of our proprietary or confidential data, employee data, or personal data, which could result in additional costs, loss of revenue, significant liabilities, harm to our brand and material disruption of our operation.”

Governance

One of the key functions of our board of directors is oversight of our risk management process, including risks from cybersecurity threats. Our board of directors is responsible for monitoring and assessing strategic risk exposure, and our executive officers manage the material risks we face. Our board of directors administers its cybersecurity risk oversight function directly as a whole and through the audit committee.

Our VP of Information Technology, and our management committee on cybersecurity, which includes the Company's audit committee, are primarily responsible for assessing and managing our material risks from cybersecurity threats. The VP of Information Technology has twenty years of experience in IT on-premise and cloud infrastructure, enterprise applications, and operations across large and mid size life science companies with a focus on IT controls for compliance an security.

Our VP of Information Technology oversees our cybersecurity policies and processes, including those described in “Risk Management and Strategy” above. The processes by which our VP of Information Technology or department designee are informed about and monitor the prevention, detection, mitigation and remediation of cybersecurity incidents include weekly assessments for all endpoints and real-time notifications from security solutions, which include a combination of cloud and client-based applications.

Our VP of Information Technology provides annual briefings to the audit committee regarding the Company’s cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity systems testing, activities of third parties, and the like. Our audit committee provides regular updates to the board of directors on such reports. In addition, our VP of Information Technology or department designee provides annual briefings to the board of directors on cybersecurity risks and activities.