Antares Private Credit Fund 10-K Cybersecurity GRC - 2025-03-18

Page last updated on March 19, 2025

Antares Private Credit Fund reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2025-03-18 16:03:16 EDT.

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10-K filed on 2025-03-18

Antares Private Credit Fund filed a 10-K at 2025-03-18 16:03:16 EDT
Accession Number: 0000950170-25-041127

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Item 1C. Cybersecurity.

Item 1C. Cybersecurity Assessment, Identification, and Management of Cybersecurity Risks The Company has processes in place to assess, identify and manage material risks from cybersecurity threats. We rely on the cybersecurity strategy implemented by the Adviser and the Antares Parties, the providers of our technology services. The Adviser manages the Company’s day-to-day operations and has implemented, together with the Antares Parties, a firm-wide cybersecurity program that applies to the Company and its operations. References in this Item 1C to (i) any programs or processes of the Adviser shall be deemed to refer to any firm-wide programs and/or processes that have been implemented by the Antares Parties, and (ii) any actions of the Adviser shall be deemed to refer to actions of the Antares Parties and/or the Adviser, as the context may require. The Adviser employs a proactive and risk-based approach to assess, identify, and manage material cybersecurity risks. Under the leadership and direction of the Chief Information Security Officer ( “CISO” ), the cybersecurity program is structured around industry-leading frameworks, including the National Institute of Standards and Technology; MITRE Adversarial Tactics, Techniques, and Common Knowledge; and International Organization for Standardization 27001 (Information Security Management System standard) ensuring a comprehensive risk identification process. The Adviser is fully committed to protecting the Company’s systems and information as well as the information of the clients and professionals it serves. Material Impact of Cybersecurity Risks The Adviser recognizes that cybersecurity risks have the potential to impact business operations, financial performance, regulatory compliance, and reputation. To mitigate these risks, the cybersecurity program is built on scalable, future-ready solutions designed to address current and evolving threats. - Operational Impact: Cyber risks, such as ransomware, data breaches, and insider threats, are managed through a combination of robust Identity and Access Management (IAM), Privileged Access Management (PAM), and Application Security programs. These initiatives ensure secure access to critical systems and protect sensitive data from unauthorized exposure. - Reputational and Regulatory Considerations: With increasing regulatory oversight, the Adviser ensures compliance with industry standards and regulatory requirements, aligning cybersecurity measures with expectations from stakeholders and regulatory bodies. - Business Resilience: Through a well-defined Cyber Crisis Management Plan (CCMP) and Business Impact Analysis (BIA), the Adviser maintains a high level of preparedness, ensuring rapid response and recovery from cyber incidents. During the reporting period, we have not identified any risks from cybersecurity threats , including as a result of previous cybersecurity incidents, that the Company believes have materially affected, or that are reasonably likely to materially affect the Company, including our business strategy, operational results and financial conditions. However, future incidents could have a material impact on our business strategy, results of operations or financial condition. Oversight of Cybersecurity Risk Cybersecurity risk oversight at the Antares Parties is embedded within a governance structure that includes board-level engagement, cross-functional collaboration, and continuous monitoring of key cyber risk indicators. The Company’s Chief Compliance Officer (“CCO”) is responsible for monitoring and reporting to the Board of Trustees about the Adviser’s compliance with its responsibilities for the Adviser’s and the Company’s cybersecurity program. The Adviser’s CISO works closely with Company management, including the CCO, to administer, assess, discuss, and prioritize the Company’s cybersecurity efforts. The Audit Committee provides strategic oversight of risk assessment and risk management matters, including risks associated with cybersecurity threats. The Company’s CCO updates the Audit Committee as well as our full Board, as appropriate, on cybersecurity matters , primarily through presentations by the Company’s CCO and the Adviser’s CISO. Such reporting includes updates on the cybersecurity program applicable to the Company, the external threat environment, and the Adviser’s programs to address and mitigate the risks associated with the evolving cybersecurity threat environment. These reports also include updates on the Company’s preparedness, prevention, detection, responsiveness, and recovery with respect to cyber incidents.
Item 1C to (i) any programs or processes of the Adviser shall be deemed to refer to any firm-wide programs and/or processes that have been implemented by the Antares Parties, and (ii) any actions of the Adviser shall be deemed to refer to actions of the Antares Parties and/or the Adviser, as the context may require. The Adviser employs a proactive and risk-based approach to assess, identify, and manage material cybersecurity risks. Under the leadership and direction of the Chief Information Security Officer ( “CISO” ), the cybersecurity program is structured around industry-leading frameworks, including the National Institute of Standards and Technology; MITRE Adversarial Tactics, Techniques, and Common Knowledge; and International Organization for Standardization 27001 (Information Security Management System standard) ensuring a comprehensive risk identification process. The Adviser is fully committed to protecting the Company’s systems and information as well as the information of the clients and professionals it serves. Material Impact of Cybersecurity Risks The Adviser recognizes that cybersecurity risks have the potential to impact business operations, financial performance, regulatory compliance, and reputation. To mitigate these risks, the cybersecurity program is built on scalable, future-ready solutions designed to address current and evolving threats. - Operational Impact: Cyber risks, such as ransomware, data breaches, and insider threats, are managed through a combination of robust Identity and Access Management (IAM), Privileged Access Management (PAM), and Application Security programs. These initiatives ensure secure access to critical systems and protect sensitive data from unauthorized exposure. - Reputational and Regulatory Considerations: With increasing regulatory oversight, the Adviser ensures compliance with industry standards and regulatory requirements, aligning cybersecurity measures with expectations from stakeholders and regulatory bodies. - Business Resilience: Through a well-defined Cyber Crisis Management Plan (CCMP) and Business Impact Analysis (BIA), the Adviser maintains a high level of preparedness, ensuring rapid response and recovery from cyber incidents. During the reporting period, we have not identified any risks from cybersecurity threats , including as a result of previous cybersecurity incidents, that the Company believes have materially affected, or that are reasonably likely to materially affect the Company, including our business strategy, operational results and financial conditions. However, future incidents could have a material impact on our business strategy, results of operations or financial condition. Oversight of Cybersecurity Risk Cybersecurity risk oversight at the Antares Parties is embedded within a governance structure that includes board-level engagement, cross-functional collaboration, and continuous monitoring of key cyber risk indicators. The Company’s Chief Compliance Officer (“CCO”) is responsible for monitoring and reporting to the Board of Trustees about the Adviser’s compliance with its responsibilities for the Adviser’s and the Company’s cybersecurity program. The Adviser’s CISO works closely with Company management, including the CCO, to administer, assess, discuss, and prioritize the Company’s cybersecurity efforts. The Audit Committee provides strategic oversight of risk assessment and risk management matters, including risks associated with cybersecurity threats. The Company’s CCO updates the Audit Committee as well as our full Board, as appropriate, on cybersecurity matters , primarily through presentations by the Company’s CCO and the Adviser’s CISO. Such reporting includes updates on the cybersecurity program applicable to the Company, the external threat environment, and the Adviser’s programs to address and mitigate the risks associated with the evolving cybersecurity threat environment. These reports also include updates on the Company’s preparedness, prevention, detection, responsiveness, and recovery with respect to cyber incidents.

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