Investcorp Credit Management BDC, Inc. 10-K Cybersecurity GRC - 2024-09-25

Page last updated on September 26, 2024

Investcorp Credit Management BDC, Inc. reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2024-09-25 17:22:43 EDT.

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10-K filed on 2024-09-25

Investcorp Credit Management BDC, Inc. filed a 10-K at 2024-09-25 17:22:43 EDT
Accession Number: 0000950170-24-109384

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Item 1C. Cybersecurity.

Item 1C. Cyb ersecurity We have processes in place to assess, identify, and manage material risks from cyber security threats. The Company’s business is dependent on the communications and information systems of Investcorp Group, of which the Adviser is a part. The Adviser manages the Company’s day-to-day operations and has adopted a cyber security program that applies to the Company and its operations. Cyber Security Program Overview The Adviser’s cyber security program is reliant on the Investcorp Group’s information security team, which is responsible for assessing, identifying, and managing material cyber risks, including those applicable to the Company. The cyber security program involves a periodic risk assessment, implementation of security measures, and ongoing monitoring of systems and networks, including networks on which the Company relies. The Investcorp Group’s information security team actively monitors the current threat landscape to identify material risks arising from new and evolving cyber security threats, including material risks faced by the Company, and advises the Adviser of such risks during periodic reviews. The cyber security program relies on the Adviser and the Investcorp Group to engage external experts, which may include assessors, consultants, auditors, or other third parties as appropriate to evaluate its cyber security measures and risk management processes, including those applicable to the Company. The Company depends on and engages various third parties, including suppliers, vendors and service providers, to operate its business. The Company takes steps to identify and oversee risks from cyber security threats associated with our use of such entities, and the Chief Compliance Officer of the Company periodically reviews cyber security-related reports regarding key service providers. Oversight of Cyber Security Risks by our Board of Directors The Board of Directors provides oversight on cyber security matters, including risks associated with cyber security threats. The Board of Directors receives periodic updates from the Company’s Chief Compliance Officer and the Heads of Technology of Investcorp Group regarding the overall state of the Adviser’s cyber security program, information on the current threat landscape, and risks from cyber security threats and cyber security incidents impacting the Company. Management’s Role in Cyber Security Risk Management The Chief Compliance Office of the Company oversees the Company’s compliance oversight function generally and relies on Investcorp Group’s Heads of Technology and information security team for assessing and managing material risks from cyber security threats impacting the Company. Investcorp Group’s Heads of Technology and information security team have extensive experience in managing cyber security and information security programs for financial services companies with complex information systems. The information security team includes seasoned professionals who are experienced with information security protocols and receive appropriate training and industry certifications regarding information security. The Chief Compliance Officer is responsible for this oversight function as Chief Compliance Officer to the Company more broadly and has significant experience in the financial services industry, during which time the Chief Compliance Officer 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 cyber security 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 Adviser. 55 Assessment of Cyber Security Risk The potential impact of risks from cyber security threats on the Company are assessed on an ongoing basis, and how such risks could materially affect the Company’s business strategy, results of operation, and financial condition are regularly evaluated. During the reporting period, the Company has not identified any risks from cyber security threats, including as a result of previous cyber security incidents, that the Company believes have materially affected, or are reasonably likely to materially affect, the Company, including its business strategy, results of operation, and financial condition.

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