Diameter Credit Co 10-K Cybersecurity GRC - 2025-03-12

Page last updated on March 12, 2025

Diameter Credit Co reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2025-03-12 16:47:37 EDT.

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10-K filed on 2025-03-12

Diameter Credit Co filed a 10-K at 2025-03-12 16:47:37 EDT
Accession Number: 0000950170-25-038029

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Item 1C. Cybersecurity.

Item 1C. Cybersecurity. Cybersecurity Risk Management and Strategy The Company is externally managed by the Adviser and has no employees or internal information systems. Thus, the Company relies on Diameter and other service providers to protect the Company’s information from cybersecurity threats. Diameter has processes in place to assess, identify, and manage material risks from cybersecurity threats, including pursuant to its Written Information Security Policy (“WISP”) and Cyber Incident Response Plan (“CIR Plan”, and together with the WISP, the “Plans”). Diameter utilizes a third-party managed service provider to support and manage its information technology framework. The Plans promote the Company’s cybersecurity infrastructure through policies and procedures relating to, among others, employee responsibilities, data loss prevention, access controls, cyber risk assessments and management, reporting requirements, and electronic communications . Pursuant to the Plans, Diameter also engage s external parties as it deems appropriate, including cybersecurity consultants to evaluate cybersecurity measures and risk management processes, including those applicable to the Company. The Company relies on the expertise of legal, information technology and compliance personnel of Diameter and external cybersecurity consultants when identifying and overseeing risks from cybersecurity threats associated with the Company’s use of such entities. Since the Company’s inception, it has not experienced a cybersecurity incident that has materially affected the Company, its business strategy, its results of operations, or its financial condition. Board Oversight of Cybersecurity Risks Diameter’s Chief Compliance Officer, or a designee, reports to the Board periodically , and at least annually, an overview of the Adviser’s cybersecurity structure and any material cyber incidents that occurred with respect to the Company or the Adviser since the last report . Diameter’s Chief Compliance Officer may, in his or her discretion, update the Board regarding Diameter’s cybersecurity program in addition to those periodic reports, including providing notice of material cybersecurity incidents that have occurred. Management’s Role in Cybersecurity Risk Management Diameter’s Chief Compliance Officer and Chief Operating Officer oversee Diameter’s cybersecurity operations, with the assistance of additional personnel and Diameter’s external managed service provider. Employees that support Diameter’s cybersecurity infrastructure have relevant educational and industry experience, including in technology and cybersecurity risk. 65 Assessment of Cybersecurity Risk Diameter conducts annual cyber risk assessments, and penetration tests are conducted by third-party service providers . All network environment alerts are reviewed by the third-party SOC team then relayed to Diameter’s appointed technology infrastructure employee and its external managed service provider. Pursuant to the CIR Plan, cyber threats will be assessed for their threat level and the appropriate parties will be alerted.

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