WisdomTree Bitcoin Fund 10-K Cybersecurity GRC - 2024-03-29

Page last updated on October 1, 2024

WisdomTree Bitcoin Fund reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-03-29 13:39:16 EDT.

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10-K filed on 2024-03-29

WisdomTree Bitcoin Fund filed a 10-K at 2024-03-29 13:39:16 EDT
Accession Number: 0001214659-24-005564

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Item 1C. Cybersecurity.

ITEM 1C. CYBERSECURITY Cybersecurity Risk Management and Strategy The Trust does not have any officers, directors or employees. The Sponsor, a subsidiary of WisdomTree, Inc., is responsible for the oversight and overall management of the Trust. The Sponsor relies on WisdomTree Inc.’s cybersecurity framework for the Trust’s cybersecurity risk management and strategy. Key aspects of such framework are summarized below. 85 WisdomTree Inc.’s enterprise-wide cybersecurity risk management policies and procedures are informed by industry standards, and they are designed to address cybersecurity risks identified by external auditors and assessors, threat intelligence providers, internal stakeholders, vulnerability management programs and security management programs. WisdomTree Inc.’s team of information technology and cybersecurity professionals, led by its Chief Information Officer, or CIO, manages and maintains remediation strategies for identified cybersecurity risks. WisdomTree Inc.’s cybersecurity risk management program is designed to be aligned with its business strategy. It shares common methodologies, reporting channels and governance processes that apply to other areas of enterprise risk, including legal, compliance, strategic, operational and financial risk. Governance Related to Cybersecurity Risks The cybersecurity risk management program and related operations and processes are directed by WisdomTree Inc.’s CIO. Currently, the CIO role is held by an individual who has been in the role for over nine years, has over 22 years of cybersecurity, information technology and systems engineering experience, and has advanced training in the field of technology. The CIO is a member of WisdomTree, Inc.’s Governance Committee and regularly reports on cybersecurity risk management to other members of the Governance Committee comprised of WisdomTree Inc.’s senior executive officers. The Governance Committee oversees the prioritization and escalation of risks from cybersecurity threats and is responsible for strategy, operations, financial management, information technology, compliance, legal, administration and corporate governance. The members of the Governance Committee collectively possess experience in these areas, including cybersecurity and risk management. The audit committee of WisdomTree, Inc. (the “Audit Committee”) oversees the management of cybersecurity risks. Pursuant to the Audit Committee charter, the Audit Committee is responsible for discussing cybersecurity-related risks with management and the steps management has taken to monitor and control such risks, including WisdomTree Inc.’s risk assessment and risk management policies. The CIO regularly reports to the Audit Committee on cybersecurity risks, and the chair of the Audit Committee reports on these discussions with the full board of directors of WisdomTree, Inc. In addition, the CIO provides periodic reports to the board of directors. As of December 31, 2023, cybersecurity risks have not materially affected the Trust’s business strategy, results of operations or financial condition. However, the Trust can provide no assurance that there will not be cybersecurity threats or incidents in the future or that they will not materially affect the Trust. For more information regarding the risks the Trust faces from cybersecurity threats, see Item 1A. “Risk Factors” included in this report.

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