Wellings Real Estate Income Fund 10-K Cybersecurity GRC - 2024-06-27

Page last updated on July 16, 2024

Wellings Real Estate Income Fund reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-06-27 19:21:00 EDT.

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10-K filed on 2024-06-27

Wellings Real Estate Income Fund filed a 10-K at 2024-06-27 19:21:00 EDT
Accession Number: 0001213900-24-056788

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Item 1C. Cybersecurity.

Item 1C. Cybersecurity The Fund has processes in place to assess, identify, and manage material and immaterial risks from cybersecurity threats. The Fund’s business is dependent on the communications and information systems of the Investment Adviser and other third-party service providers. The Investment Adviser manages the Fund’s day-to-day operations and has implemented a cybersecurity program that applies to the Fund and its operations. To that end, the Investment Adviser has provided training to its employees, independent contractors and the Trustees of the Fund about its cybersecurity risk management program. The Fund’s Trustees have been charged with oversight of the program and will be informed about any data incident and how it is being handled, including any regulatory reporting implications. Cybersecurity Program Overview The Fund relies on management of the Investment Adviser to provide oversight and take responsibility for the administration of the cyber risk management program and for informing senior management and other relevant persons regarding the prevention, detection, mitigation, and remediation of cyber incidents. The Fund’s management team has prior experience selecting, deploying, and overseeing cybersecurity technologies, initiatives, and processes directly or via selection of strategic third-party partners. The Fund relies on management of the Investment Adviser to implement third-party risk management processes to manage the risks associated with reliance on vendors, critical service providers, and other third-parties that may lead to a service disruption or an adverse cybersecurity incident. This includes assessment of vendors during the selection/onboarding process, internal controls, compliance with service level agreements, and more. A critical component of the Fund’s cybersecurity program is its incident response plan. This plan includes a requirement to evaluate the materiality of any data incident. Should the evaluation conclude that the data incident rises to the level of materiality it will be incumbent for the Fund, working with the Investment Adviser and legal and cybersercurity professionals, to describe the data incident within four business days of determining that an incident is material. The Fund shall also be responsible to provide ongoing reporting about the status of the material data incident until such time that the material data incident is no longer a factor with respect the Fund’s operations. As the Fund evaluates the materiality level of a data incident it will consider a variety of factors including the operational impact, the type of data impacted, how the data has been impacted, the business continuity and recovery procedurs affected, the impact of the incident on the Fund’s finances and any length of service interruption. Additional factors may also be considered given the nature of the event. The Fund engages various third parties, including vendors and service providers, to assist with operating its business. The Fund relies on the expertise of cybersecurity risk management, legal, information technology, and compliance personnel that have been engaged by the Investment Adviser when identifying and overseeing risks from cybersecurity threats associated with the Fund’s use of such entities.

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