Copper Property CTL Pass Through Trust 10-K Cybersecurity GRC - 2024-03-08

Page last updated on July 16, 2024

Copper Property CTL Pass Through Trust reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-03-08 18:08:25 EST.

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10-K filed on 2024-03-08

Copper Property CTL Pass Through Trust filed a 10-K at 2024-03-08 18:08:25 EST
Accession Number: 0001837671-24-000015

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Item 1C. Cybersecurity.

ITEM 1C. CYBERSECURITY We rely on our technology infrastructure and information systems to perform operational activities as well as to maintain the Trust’s business records and financial data. Our internally developed system and processes, may be susceptible to damage or interruption from cybersecurity threats, which include any unauthorized access to our information systems that may result in adverse effects on the confidentiality, integrity, or availability of such systems or the related information. Potential cybersecurity threats include terrorist or hacker attacks, the introduction of malicious computer viruses, ransomware, falsification of banking and other information, insider risk, or other security breaches. Such attacks have become more and more sophisticated over time, especially as threat actors have become increasingly well-funded by, or themselves include, governmental actors with significant means. We expect that sophistication of cyber-threats will continue to evolve as threat actors increase their use of AI and machine-learning technologies. Many threat actors are well funded. We have implemented controls and processes to assess, identify, and manage cybersecurity risks, including potentially material risks, related to our internal information systems and our products. The Trust’s management, 18 including its Principal Executive Officer and Principal Financial Officer, has direct oversight of the management of cybersecurity risks. Management oversees our enterprise risk management process. Under the supervision and with the participation of our management, including our Principal Executive Officer and Principal Financial Officer, we conduct an annual comprehensive enterprise risk assessment, which includes details of our management of enterprise-wide risk topics, such as those related to cybersecurity risks. Management receives the full results of the annual enterprise risk assessment, including an evaluation of cybersecurity risks presented, a detailed description of the actions we have taken to mitigate these risks and an analysis of cybersecurity threats and incidents across the industry. Management reviews the results of the enterprise risk assessment in detail on a regular basis. We have adopted the National Institute of Standards and Technology (“NIST”) Cybersecurity Framework to continually evaluate and enhance our cybersecurity procedures. Activities include technical security controls, enhanced data protection, the maintenance of backup and protective systems, policy review and implementation and periodic assessments of third-party service providers to assess cyber preparedness of key vendors. We are not aware of any risks from cybersecurity threats, including any cybersecurity incidents, which have materially affected or are reasonably likely to materially affect the Trust, including its business, results of operations or financial condition. Refer to Item 1A. Risk Factors in this Annual Report on Form 10-K, specifically “Information technology, data security breaches and other similar events could harm the Trust,” for additional discussion about cybersecurity-related risks.

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