Trump Media & Technology Group Corp. 10-K Cybersecurity GRC - 2024-04-01

Page last updated on April 11, 2024

Trump Media & Technology Group Corp. reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-04-01 17:23:12 EDT.

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10-K filed on 2024-04-01

Trump Media & Technology Group Corp. filed an 10-K at 2024-04-01 17:23:12 EDT
Accession Number: 0001140361-24-017011

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Item 1C. Cybersecurity.

Item 1C. Cybersecurity. The Board is responsible for overseeing the Company s 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. The Company s cybersecurity policies, standards, processes, and practices are based on recognized frameworks established by the National Institute of Standards and Technology, the International Organization for Standardization and other applicable industry standards and are fully integrated into the Company s overall risk management system and processes. In general, the Company seeks to address material cybersecurity threats through a company-wide approach that addresses the confidentiality, integrity, and availability of the Company s information systems or the information that the Company collects and stores, by assessing, identifying and managing cybersecurity issues as they occur. Cybersecurity Risk Management and Strategy The Company s cybersecurity risk management strategy focuses on several areas: Identification and Reporting: The Company has implemented a comprehensive, cross-functional approach to assessing, identifying and managing material cybersecurity threats and incidents. The Company 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. Cybersecurity risks are discussed in weekly executive team meetings across functions. Technical Safeguards: The Company implements technical safeguards that are designed to protect the Company s information systems from cybersecurity threats, including firewalls, web applications firewalls, DDoS mitigation services, intrusion prevention and detection systems, anti-malware functionality, and software and access controls, which are evaluated and improved through vulnerability assessments and cybersecurity threat intelligence. Secure Software Development Life Cycle: The Company develops and deploys software using frameworks and techniques to build in security from the design phase through deployment and maintenance. Software and systems security are part of a comprehensive Software/Systems Development Life Cycle (SDLC) program to ensure security concerns are addressed throughout the process. 68 Table of Contents Incident Response and Recovery Planning: The Company has established and maintains comprehensive incident response, business continuity, and disaster recovery plans designed to address the Company s response to a cybersecurity incident. The Company conducts regular tabletop exercises to test these plans and ensure personnel are familiar with their roles in a response scenario. Third-Party Risk Management: The Company maintains a comprehensive, risk-based approach to identifying and overseeing material cybersecurity threats 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 material cybersecurity incident affecting those third-party systems, including any outside auditors or consultants who advise on the Company s cybersecurity systems. Education and Awareness: The Company provides regular, mandatory training for all levels of employees regarding cybersecurity threats as a means to equip the Company s employees with effective tools to address cybersecurity threats, and to communicate the Company s evolving information security policies, standards, processes, and practices. The Company conducts periodic assessment and testing of the Company s policies, standards, processes, and practices in a manner intended to address cybersecurity threats and events. This assessment and testing is scheduled based on assessed risk of systems, including a mix of continuous monitoring and periodic assessment. The results of such assessments, audits, and reviews are evaluated by management and reported to the Audit Committee 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 Audit Committee, oversees the Company s risk management program, including the management of cybersecurity threats. The Board and the Audit Committee each receive regular presentations and reports on developments in the cybersecurity space, including risk management practices, recent developments, evolving standards, vulnerability assessments, third-party and independent reviews, the threat environment, technological trends, and information security issues encountered by the Company s peers and third parties. The Board and the Audit Committee also receive prompt and timely information regarding any cybersecurity risk that meets pre-established reporting thresholds, as well as ongoing updates regarding any such risk. 4 On an annual basis, the Board and the Audit Committee will discuss the Company s approach to overseeing cybersecurity threats with the Company s CSO and other members of senior management. The CSO, in coordination with senior management including the CEO, CFO, COO, CTO and CLO, 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 material cybersecurity incidents in accordance with the Company s incident response and recovery plans. To facilitate the success of the Company s cybersecurity program, cross-functional teams throughout the Company address cybersecurity threats and respond to cybersecurity incidents. Through ongoing communications with these teams, the CSO and senior management are informed about and monitor the prevention, detection, mitigation and remediation of cybersecurity threats and incidents in real time, and report such threats and incidents to the Audit Committee when appropriate. TMTG s core leadership team responsible for managing risk and assessing cybersecurity threats has remained in place since the launch of Truth Social in 2022, and possesses a wide range of relevant experience: The CSO has served in various roles in information technology and information security for over 25 years, including serving as the Chief Security Officer of multiple similarly-sized organizations and as a founder at cybersecurity startups. The CSO holds the professional certifications of Certified Information Systems Manager, Certified Information Systems Auditor and other relevant certifications and training. The CTO, formerly Private TMTG s CIO, holds an undergraduate degree in computer science and has served in various roles in information technology for over a decade. As a longtime member, Chairman, and Ranking Member of the House Intelligence Committee, the CEO led sensitive oversight and investigations of cybersecurity matters U.S. intelligence community. The COO has over fifteen years experience building and maintaining high-availability web applications and technologies, including of another free-speech-focused social networking service. The General Counsel previously led teams including the Office of Cyber, Infrastructure, Risk and Resilience as Acting Under Secretary for Policy at the U.S. Department of Homeland Security. The CFO previously served in the same role at another public company. 69 Table of Contents Material Affects 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.

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