GCM Grosvenor Inc. 10-K Cybersecurity GRC - 2024-02-29

Page last updated on July 16, 2024

GCM Grosvenor Inc. reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-02-29 20:04:09 EST.

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10-K filed on 2024-02-29

GCM Grosvenor Inc. filed a 10-K at 2024-02-29 20:04:09 EST
Accession Number: 0001819796-24-000005

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Item 1C. Cybersecurity.

ITEM 1C. CYBERSECURITY Cybersecurity Risk Management and Strategy We have developed and implemented a cybersecurity risk management program intended to protect the confidentiality, integrity and availability of our critical systems and information. We design and assess our program based on the National Institute of Standards and Technology Cybersecurity Framework (NIST CSF) and the Center for Internet Security (CIS) Critical Security Controls. This does not imply that we meet any particular technical standards, specifications, or requirements, only that we use the NIST CSF and CIS Controls as a guide to help us identify, assess and manage cybersecurity risks relevant to our business. Our cybersecurity risk management program is integrated into our overall enterprise risk management program, and shares common methodologies, reporting channels and governance processes that apply across the enterprise risk management program to other legal, compliance, strategic, operational and financial risk areas. Our cybersecurity risk management program includes: - risk assessments designed to help identify material cybersecurity risks to our systems, information, products, services and our broader enterprise IT environment; - a security team principally responsible for managing our (1) cybersecurity risk assessment processes, (2) security controls and (3) response to cybersecurity incidents; - policies, security technologies and safeguards to fulfill overall NIST CSF program goals and key controls established by the CIS; - the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security program; this includes penetration testing, and assisting internal audit in assessing the effectiveness of our controls; - cybersecurity awareness training of our employees, incident response personnel and senior management; - a cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents; and - a third-party risk management process for key service providers, suppliers and vendors who have access to our critical systems and information. We have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations or financial condition. However, there can be no assurance that our cybersecurity risk management program and processes, including our policies, controls, or procedures, will be fully implemented, complied with or effective in protecting our systems and information. Please see the section entitled “Risk Factors - Failure to maintain the security of our information and technology networks, or those of our third-party service providers, or cyber security incidents could harm our reputation and have a material adverse effect on our results of operations, financial condition and cash flow ,” for more information. Cybersecurity Governance Our board of directors considers cybersecurity risk as part of its risk oversight function and has delegated to the audit committee oversight of cybersecurity and other information technology risks. The audit committee oversees management’s implementation of our cybersecurity risk management program. 75 The audit committee receives periodic reports from management on our cybersecurity risks. In addition, management updates the audit committee, as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential. The audit committee reports to the full board of directors regarding its risk management activities, including those related to cybersecurity. The full board of directors also receives briefings from management on our cyber risk management program from time to time. Members of the board of directors receive presentations on cybersecurity topics from our Chief Technology Officer, internal security staff or external experts as part of the board of directors’ continuing education on topics that impact public companies. Our management team, including the Chief Technology Officer and Chief Information Security Officer, are responsible for assessing and managing our material risks from cybersecurity threats. The team has primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our retained external cybersecurity consultants. Our current Chief Technology Officer has over 25 years of cybersecurity experience, including past roles as a Chief Information Security officer and with a leading accounting and professional services firm. Our current Chief Information Security Officer has 20 years of relevant information technology and cybersecurity experience. Our management team supervises efforts to prevent, detect, mitigate and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel; threat intelligence and other information obtained from governmental, public or private sources, including external consultants engaged by us; and alerts and reports produced by security tools deployed in the IT environment.

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