Immunome Inc. 10-K Cybersecurity GRC - 2024-03-28

Page last updated on April 11, 2024

Immunome Inc. reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-03-28 16:06:07 EDT.

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10-K filed on 2024-03-28

Immunome Inc. filed an 10-K at 2024-03-28 16:06:07 EDT
Accession Number: 0001558370-24-004247

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Item 1C. Cybersecurity.

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, confidential information that is proprietary, strategic or competitive in nature. Our information technology and legal departments, in consultation with third party service providers, help (i) identify, assess and manage our cybersecurity threats and risks, and (ii) identify and assess risks from cybersecurity threats by monitoring and evaluating our threat environment and our risk profile using various methods including, for example: analyzing reports of threats and actors, evaluating threats reported to us, performing security audits, and conducting vulnerability assessments. 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: incident detection and response measures, disaster recovery/business continuity plans, risk assessments, encrypting sensitive data, network security controls, data segregation, access controls, physical security, asset management, tracking and disposal, systems monitoring, vendor risk management program, employee training, penetration testing, and dedicated cybersecurity staff. Additionally, we are in the process of developing an incident response plan and response policy. Our assessment and management of material risks from cybersecurity threats are integrated into our overall risk management processes. For example, (1) our Vice President, Technology Enablement, who leads our information technology department and reports to Mr. Rosett, our Interim Chief Financial Officer and Executive Vice President, Operations, works with management and our third-party service providers to prioritize our risk management processes and mitigate cybersecurity threats that are more likely to lead to a material impact to our business and (2) our senior management, in consultation with our information technology department and third-party service providers, 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, including legal counsel, cybersecurity consultants and cybersecurity software providers. We use third-party service providers to perform a variety of functions throughout our business, such as contract research organizations, contract manufacturing organizations, hosting companies and application providers. We have a vendor management process to manage cybersecurity risks associated with our use of these providers. The process includes conducting a risk assessment of each vendor and imposing contractual obligations on such vendor with respect to the protection of our information. Depending on the nature of the services provided, the sensitivity of the Information Systems and Data at issue, and the identity of the provider, our vendor management process may involve different levels of assessment designed to help identify cybersecurity risks associated with a provider and 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 Part 1. Item 1A. Risk Factors in this Annual Report on Form 10-K, including in the section titled Risks Related to Manufacturing, Commercialization and Reliance on Third Parties. Governance Related to Cybersecurity Risks Our board of directors addresses our cybersecurity risk management as part of its general oversight function. The board of directors audit committee is responsible for overseeing our cybersecurity risk management processes, including oversight and mitigation of risks from cybersecurity threats. 101 Table of Contents Our cybersecurity risk assessment and management processes are implemented and maintained by certain of our management, including Mr. Rosett, our Interim Chief Operating Officer and EVP, Operations, and our VP, Technology Enablement. Mr. Rosett has over 10 years of experience in the biotech and technology industry, including serving as a software engineer at Google. Our VP, Technology Enablement has over 25 years of experience in information technology in the biotech industry and has served in various roles of increasing importance related to information technology. Mr. Rosett and our VP, Technology Enablement are responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into our overall risk management strategy, and communicating key priorities to relevant personnel. Mr. Rosett is responsible for approving budgets, helping prepare for cybersecurity incidents, approving cybersecurity processes, and reviewing security assessments and other security-related reports. Our cybersecurity incident response and vulnerability management processes are designed to escalate certain cybersecurity incidents to members of management depending on the circumstances, including our Mr. Rosett. Mr. Rosett and our VP, Technology Enablement work with our incident response team to help us mitigate and remediate cybersecurity incidents of which they are notified. In addition, our incident response and vulnerability management processes include reporting to the audit committee of the board of directors for certain cybersecurity incidents. The audit committee receives periodic reports from management concerning our significant cybersecurity threats and risk and the processes we have implemented to address them. The audit committee also has access to various reports, summaries or presentations related to cybersecurity threats, risk and mitigation.

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