PRINCETON CAPITAL CORP 10-K Cybersecurity GRC - 2024-03-29

Page last updated on July 16, 2024

PRINCETON CAPITAL CORP reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-03-29 16:00:49 EDT.

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10-K filed on 2024-03-29

PRINCETON CAPITAL CORP filed a 10-K at 2024-03-29 16:00:49 EDT
Accession Number: 0001213900-24-027958

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Item 1C. Cybersecurity.

Item 1C. CYBERSECURITY Princeton Capital Corporation (the “Company”) has processes in place to assess, identify, and manage material risks from cybersecurity threats. The Company’s business is dependent on the communications and information systems of House Hanover, LLC (the “Investment Adviser”) and other third-party service providers. The Investment Adviser manages the Company’s day-to-day operations and has implemented a cybersecurity program that applies to the Company and its operations. Cybersecurity Program Overview The Investment Adviser has instituted a cybersecurity program designed to identify, assess, and manage cyber risks applicable to the Company. The cyber risk management program involves risk assessments, implementation of security measures, and ongoing monitoring of systems and networks, including networks on which the Company relies. The Investment Adviser actively monitors the current threat landscape in an effort to identify material risks arising from new and evolving cybersecurity threats, including material risks faced by the Company. The Company relies on the Investment Adviser to engage external experts, including cybersecurity assessors, consultants, and auditors, to evaluate cybersecurity measures and risk management processes, including those applicable to the Company. The Company relies on the Investment Adviser’s risk management program and processes, which include cyber risk assessments. The Company depends on and engages various third parties, including suppliers, vendors, and service providers, to operate its business. The Company relies on the expertise of risk management, legal, information technology, and compliance personnel of the Investment Adviser when identifying and overseeing risks from cybersecurity threats associated with the Company’s use of such entities. - 18 - Board Oversight of Cybersecurity Risks The board of directors of the Company (“Board”) provides strategic oversight on cybersecurity matters, including risks associated with cybersecurity threats. The Board receives periodic updates from the Chief Compliance Officer (“CCO”) of the Company, who also serves as Chief Compliance Officer of the Investment Adviser, regarding the overall state of the Investment Adviser’s cybersecurity program, information on the current threat landscape, and briefing on material risks from cybersecurity threats and material cybersecurity incidents impacting the Company. Management’s Role in Cybersecurity Risk Management The Company’s Management, including the Company’s CCO, manages the Company’s cybersecurity program, under the supervision of the Company’s Audit Committee. The CCO of the Company oversees the Company’s risk management function generally and relies on the Investment Adviser to assist with assessing and managing material risks from cybersecurity threats. The Company’s CCO has been responsible for this oversight function as CCO to the Company for over 6 years and has worked in the financial services industry for over 25 years, during which time the CCO has gained expertise in assessing and managing risks applicable to the Company. Management of the Company is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents impacting the Company, including through the receipt of notifications from service providers and reliance on communications with risk management, legal, information technology, and/or compliance personnel of the Investment Adviser. Assessment of Cybersecurity Risk The potential impact of risks from cybersecurity threats on the Company are assessed on an ongoing basis, and how such risks could materially affect the Company’s business strategy, operational results, and financial condition are regularly evaluated. During the reporting period, the Company has not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that the Company believes have materially affected, or are reasonably likely to materially affect, the Company, including its business strategy, operational results, and financial condition.

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