5C Lending Partners Corp. 10-K Cybersecurity GRC - 2025-03-13

Page last updated on March 14, 2025

5C Lending Partners Corp. reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2025-03-13 16:25:26 EDT.

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10-K filed on 2025-03-13

5C Lending Partners Corp. filed a 10-K at 2025-03-13 16:25:26 EDT
Accession Number: 0000950170-25-038779

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Item 1C. Cybersecurity.

Item 1C. Cy bersecurity. The Company relies on the cybersecurity strategy and policies implemented by the Advisor. The cybersecurity program seeks to address cybersecurity risks and support the Company’s operational resilience. Cybersecurity Program Overview The Advisor has established a cybersecurity program designed to identify, evaluate, and mitigate risks from cybersecurity threats applicable to the Company. The program encompasses: - Risk Assessments : Regular evaluations to identify and address potential vulnerabilities and threats to the Company’s systems and data. - Security Measures : Implementation of cybersecurity controls, technologies, and protocols to protect against unauthorized access and mitigate risk. - Monitoring : Surveillance of systems, networks, and potential threats to timely detect and respond to evolving cyber risks. - Incident Response : Monitors systems for unauthorized access or data breaches. Follows an incident response plan to contain, investigate, and resolve incidents as well as reports significant incidents to senior management and regulatory authorities as needed. The Advisor through the Resource Sharing Agreement utilizes external cybersecurity vendors and consulting firms to perform internal and external penetration testing, vulnerability assessments, and cybersecurity reviews. These independent evaluations assess the effectiveness of the Advisor’s, and in turn the Company’s, cybersecurity framework and risk management practices and help identify areas for continued focus and improvement. The Company leverages the Advisor’s expertise in cybersecurity risk management and compliance, including the assessment and ongoing oversight of risks associated with our use of third-party vendors, suppliers, and service providers critical to the Company’s business functions. Any material risks identified by the Advisor’s chief technology officer (the “CTO”), will be reported to the Advisor’s chief operating officer (the “COO”) and the Company’s chief compliance officer (the “CCO”). Board Oversight of Cybersecurity Risks The Company’s Board of Directors is primarily responsible for overseeing the Company’s management of cybersecurity risks. The Company’s CCO, consults with the Advisor’s CTO and COO to develop cybersecurity updates that the Company’s CCO, along with the Advisor’s CTO, delivers periodically to the Board of Directors on topics including: - Updates on the Advisor’s cybersecurity program as it impacts us. - The effectiveness of the Company’s cybersecurity program. - Current and emerging cybersecurity threats. - Significant cybersecurity incidents impacting the Company and its operations. 73 Management’s Role in Cybersecurity Risk Management The Advisor’s management team, including its CTO, collaborates to execute and oversee the Company’s cybersecurity program. Responsibilities include: - Incident Management : Addressing and remediating cybersecurity incidents that may impact the Company. - Compliance Oversight : Ensuring adherence to regulatory standards and best practices for cybersecurity. - Risk Evaluation : Ongoing assessment of risks posed by third-party service providers and internal operations. - Enhancements to the Program : Ongoing improvements necessitated by the changing environment. At 5C’s Executive Committee meetings the CTO provides an executive summary report disclosing needed changes to our cybersecurity program, incidents, and potential threats. The Advisor’s CTO has over twenty years of specialized experience in managing cybersecurity and information security programs for financial services organizations. The Company’s CCO has over twenty-seven years of experience in the financial services industry, including eighteen years specializing in compliance and nine years in technology. The Company’s CCO is actively involved in monitoring and addressing cybersecurity risks in consultation with the Advisor’s CTO and COO. The Company’s CCO is informed of incidents, vulnerabilities, and control enhancements in order to ensure robust and effective cybersecurity practices. Cybersecurity Incidents and Material Impacts The Company has not experienced any cybersecurity incidents that materially affected our business strategy, operational results, or financial condition. The Company remains vigilant in monitoring and mitigating potential cybersecurity risks to safeguard its long-term resilience and operational integrity, but there is no guarantee that any risks from cybersecurity threats will not materially affect us in the future. For additional discussion of the Company’s risks from cybersecurity threats, see “Item 1A. Risk Factors-Risks Related to the Company’s Business and Structure-Cybersecurity risks and cyber incidents may adversely affect the Company’s business or the business of the Company’s portfolio companies by causing a disruption to the Company’s operations or the operations of the Company’s portfolio companies, a compromise or corruption of the Company’s confidential information or the confidential information of the Company’s portfolio companies and/or damage to the Company’s business relationships or the business relationships of the Company’s portfolio companies, all of which could negatively impact the business, financial condition and operating results of the Company or the Company’s portfolio companies.”

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