Firsthand Technology Value Fund, Inc. 10-K Cybersecurity GRC - 2024-03-28

Page last updated on April 14, 2024

Firsthand Technology Value Fund, Inc. reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-03-28 16:50:42 EDT.

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10-K filed on 2024-03-28

Firsthand Technology Value Fund, Inc. filed an 10-K at 2024-03-28 16:50:42 EDT
Accession Number: 0001437749-24-009861

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Item 1C. Cybersecurity.

Item 1C. Cybersecurity Our Board of Directors (the Board ) is responsible for overseeing our risk management program, and cybersecurity is a critical element of this program. Management is responsible for the day-to-day administration of the Company s risk management program and its cybersecurity policies, processes, and practices. In general, the Adviser seeks to address material cybersecurity threats through a company-wide approach that addresses the confidentiality, integrity, and availability of the Adviser s information systems or the information that the Adviser collects and stores, by assessing, identifying and managing cybersecurity issues as they occur. Cybersecurity Risk Management and Strategy The Adviser s cybersecurity risk management strategy focuses on several areas: Identification and Reporting: The Adviser has implemented a comprehensive, cross-functional approach to assessing, identifying and managing material cybersecurity threats and incidents. The Adviser s program includes controls and procedures to properly identify, classify and escalate certain cybersecurity incidents to provide management visibility and obtain direction from management as to the public disclosure and reporting of material incidents in a timely manner. Technical Safeguards: The Adviser implements technical safeguards that are designed to protect the Adviser s information systems from cybersecurity threats, including firewalls, intrusion prevention and detection systems, anti-malware functionality, and access controls, which are evaluated and improved through vulnerability assessments and cybersecurity threat intelligence, as well as assistance from third party experts where necessary. Incident Response and Recovery Planning: The Adviser has established and maintains comprehensive incident response, business continuity, and disaster recovery plans designed to address the Adviser s response to a cybersecurity incident. The Adviser conducts occasional tabletop exercises to test these plans and ensure personnel are familiar with their roles in a response scenario. Third-Party Risk Management: The Adviser maintains a comprehensive, risk-based approach to identifying and overseeing material cybersecurity threats presented by third parties, including vendors and service providers Education and Awareness: The Adviser provides periodic training for all levels of personnel regarding cybersecurity threats as a means to equip the Adviser s personnel with effective tools to address cybersecurity threats, and to communicate the Adviser s evolving information security policies, standards, processes, and practices. The Adviser conducts periodic assessment and testing of its policies, standards, processes, and practices in a manner intended to address cybersecurity threats and eventsThe results of such assessments and reviews are evaluated by management and reported to the Board, and the Adviser adjusts its cybersecurity policies, standards, processes, and practices as necessary based on the information provided by these assessments and reviews. Governance The Board, in coordination with the Adviser, oversees the Company s risk management program, including the management of cybersecurity threats. The Board receives regular updates and reports on developments in the cybersecurity space, including risk management practices, recent developments, vulnerability assessments, third-party and independent reviews, the threat environment, and information security issues encountered by the Company. The Board also receives prompt and timely information regarding any material cybersecurity risk, as well as ongoing updates regarding any such risk. On an annual basis, the Board and the Adviser discuss the Company s approach to overseeing cybersecurity threats. Material Effects of Cybersecurity Incidents Risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have not materially affected and are not reasonably likely to materially affect the Company, including its business strategy, results of operations, or financial condition. 23 Table of Contents

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