UNIVERSAL STAINLESS & ALLOY PRODUCTS INC 10-K Cybersecurity GRC - 2024-03-29

Page last updated on April 11, 2024

UNIVERSAL STAINLESS & ALLOY PRODUCTS INC reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-03-29 13:59:17 EDT.

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10-K filed on 2024-03-29

UNIVERSAL STAINLESS & ALLOY PRODUCTS INC filed an 10-K at 2024-03-29 13:59:17 EDT
Accession Number: 0001437749-24-010032

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Item 1C. Cybersecurity.

ITEM 1C. CYBERSECURITY The Company s Board of Directors (the Board ) recognizes the critical importance of maintaining the trust and confidence of our customers, clients, business partners and employees. The Board is actively involved in oversight of the Company s risk management program, and cybersecurity represents an important component of the Company s overall approach to cyber risk management ( CRM ). The Company s cybersecurity policies, standards, processes, and practices are fully integrated into the Company s CRM program and are based on recognized frameworks established by the National Institute of Standards and Technology and other applicable industry standards. In general, the Company seeks to address cybersecurity risks through a comprehensive, cross-functional approach that is focused on preserving the confidentiality, security, and availability of the information that the Company collects and stores by identifying, preventing and mitigating cybersecurity threats and effectively responding to cybersecurity incidents when they occur. Risk Management and Strategy As one of the critical elements of the Company s overall CRM approach, the Company s cybersecurity program is focused on the following key areas: Governance: As discussed in more detail under the heading Governance, The Board s oversight of cybersecurity risk management includes interaction with the Company s Chief Information Officer ( CIO ) at least quarterly and similar interaction on this topic with other members of management. Collaborative Approach: The Company has implemented a comprehensive, cross-functional approach to identifying, preventing, and mitigating cybersecurity threats and incidents, while also implementing controls and procedures that provide for the prompt escalation of certain cybersecurity incidents so that decisions regarding the public disclosure and reporting of such incidents can be made by management in a timely manner. Technical Safeguards: The Company deploys technical safeguards that are designed to protect the Company 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. Incident Response and Recovery Planning: The Company has established and maintains comprehensive incident response and recovery plans that fully address the Company s response to a cybersecurity incident, and such plans are tested and evaluated on a regular basis. Third-Party Risk Management: The Company maintains a comprehensive, risk-based approach to identifying and overseeing cybersecurity risks presented by third parties, including vendors, service providers and other external users of the Company s systems, as well as the systems of third parties that could adversely impact our business in the event of a cybersecurity incident affecting those third-party systems. Education and Awareness: The Company provides regular, mandatory training for personnel regarding cybersecurity threats to equip the Company s personnel with effective tools to address cybersecurity threats, and to communicate the Company s evolving information security policies, standards, processes, and practices. The Company engages in the periodic assessment and testing of the Company s policies, standards, processes, and practices that are designed to address cybersecurity threats and incidents. These efforts include a wide range of activities, including audits, assessments, tabletop exercises, threat modeling, vulnerability testing and other exercises focused on evaluating the effectiveness of our cybersecurity measures and planning. The Company regularly engages third parties to perform assessments on our cybersecurity measures, including information security maturity assessments, audits and independent reviews of our information security control environment and operating effectiveness. The results of such assessments, audits and reviews are reported to the CIO and the Board, and the Company adjusts its cybersecurity policies, standards, processes, and practices as necessary based on the information provided by these assessments, audits, and reviews. Governance The Board, in coordination with the CIO and Company management, oversees the Company s CRM process, including the management of risks arising from cybersecurity threats. The Board receives at least a quarterly update on cybersecurity risks, which addresses a wide range of topics including recent developments, evolving standards, vulnerability assessments, third-party and independent reviews, the threat environment, technological trends, and information security considerations arising with respect to the Company s peers and third parties. The Board also receives prompt and timely information regarding any cybersecurity incident that meets established reporting thresholds, as well as ongoing updates regarding any such incident until it has been addressed. The Board, the CIO and other members of the Company s management team will discuss, at least annually, the Company s approach to cybersecurity risk management. The CIO, in coordination with our Chief Executive Officer ( CEO ), Chief Financial Officer ( CFO ) and General Counsel ( GC ), works collaboratively across the Company to implement a program designed to protect the Company s information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents in accordance with the Company s incident response and recovery plans. To facilitate the success of the Company s cybersecurity risk management program, members of the CIO s team are deployed to address cybersecurity threats and to respond to cybersecurity incidents. The Company s management team, through ongoing communications with CIO s team, monitors the prevention, detection, mitigation and remediation of cybersecurity threats and incidents in real time, and report such threats and incidents to the Board when appropriate. The CIO holds a B.S.B.A. degree in Management Information Systems and has served in various roles in information technology and information security for over 25 years, including serving as the Chief Information Officer for the Company. The Company s CEO, CFO and GC each hold undergraduate degrees in their respective fields, and collectively have over 50 years of experience managing risks at the Company and at similar companies. Cybersecurity threats, including all previous cybersecurity incidents, have not materially affected, or currently are believed by the Company to not materially affect the Company, including its business strategy, results of operations or financial condition. While these risks have yet to materially affect the Company, the Company cannot guarantee that its ongoing and robust approach towards cybersecurity will be able to prevent all cybersecurity incidents that could have a material effect on the Company. For more information about cybersecurity risks that the Company faces, see If we are unable to protect our information technology infrastructure against service interruptions, data corruption, cyber-based attacks or network security breaches, our operations could be disrupted in Item 1A, Risk Factors. 11 Table of Contents

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