NEVRO CORP - (NVRO)

10-K Filing Date: February 23, 2024
ITEM 1C. CYBERSECURITY

Risk Management and Strategy

We have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability of our critical systems and information. Our cybersecurity risk management program includes a cybersecurity incident response plan.

We design and assess our program based on the National Institute of Standards and Technology Cybersecurity Framework (NIST CSF). This does not imply that we meet any particular technical standards, specifications, or requirements, only that we use the NIST CSF as a guide to help us identify, assess, and manage cybersecurity risks relevant to our business.

Our cybersecurity risk management program is integrated into our overall enterprise risk management program, and shares common methodologies, reporting channels and governance processes that apply across the enterprise risk management program to other legal, compliance, strategic, operational, and financial risk areas.

Our cybersecurity risk management program includes:

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risk assessments designed to help identify material cybersecurity risks to our critical systems, information, products, services, and our broader enterprise information technology environment;
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a security team principally responsible for managing (i) our cybersecurity risk assessment processes, (ii) our security controls, and (iii) our response to cybersecurity incidents;
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the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security controls;
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cybersecurity awareness training of our employees, incident response personnel, and senior management;
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a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents; and
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a third-party risk management process for service providers, suppliers, and vendors that have access to our critical systems and information.

We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.

Governance

Our Board considers cybersecurity risk as part of its risk oversight function and has delegated to the Audit Committee (the “Committee”) oversight of cybersecurity and other information technology risks. The Committee oversees management’s implementation of our cybersecurity risk management program.

The Committee receives periodic reports from management on our cybersecurity risks. In addition, management updates the Committee, as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential.

The Committee reports to the full Board regarding its activities, including those related to cybersecurity. The full Board also receives briefings from management on our cyber risk management program. Board members receive presentations on cybersecurity topics from our Chief Information Security Officer (CISO), Vice President of Information Technology, internal security staff or external experts as part of the Board’s continuing education on topics that impact public companies.

Our CISO oversees our cybersecurity risk management in partnership with our Vice President of Information Technology, Chief Financial Officer, General Counsel, Chief Compliance and Privacy Officer and other members of management. These members of management monitor and are informed of the prevention, mitigation, detection and remediation of cybersecurity incident through their management of, and participation in, the cybersecurity risk management and strategy processes described above.

Our Vice President of Information Technology has developed expertise in cybersecurity and compliance, enterprise architecture and rod mapping, data and analytics, digital transformation, and customer service through her extensive experience in information technology. She earned her Bachelor of Science in Accounting and emphasis in Information Systems Management from North Dakota State University. Our CISO has worked for 30 years in product development and information technology, including the areas of infrastructure and application architecture. In the last 15 years, he has worked in security for healthcare, pharmaceutical and technology companies, the last six years as CISO. He earned his Bachelor of Science in Electronic Engineering from Universidade Federal do Rio de Janeiro in Brazil.

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