Item 1C cybersecurity program disclosure from an annual report. The filer describes its NIST/CIS/CSA/PCI/HIPAA-aligned cybersecurity program, governance via the Audit Committee, and management leadership by the CTO and SVP-TCSS. The filer expressly states it has not been subject to a cybersecurity event with a material impact. No specific incident is disclosed.
About this clustering
DisclosureLens links filings into incidents through layered matchers: deterministic rules (same source document, multistate filings of one breach, tight-window same-victim pairs), a weighted-similarity scorer for cross-source candidates, and an operator review queue for everything uncertain. Each link records its own method and confidence — shown per filing in the timeline below. The system defaults to NOT merging when uncertain, because a false merge (collapsing two unrelated breaches) is more harmful than a false split (showing related filings separately); uncertain pairs route to human review instead of auto-merging. Filing summaries shown in the timeline are AI-generated extracts — verify each against its linked source.