Willow Tree Capital Corp 10-K Cybersecurity GRC - 2025-03-31

Page last updated on March 31, 2025

Willow Tree Capital Corp reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2025-03-31 14:22:56 EDT.

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10-K filed on 2025-03-31

Willow Tree Capital Corp filed a 10-K at 2025-03-31 14:22:56 EDT
Accession Number: 0001944831-25-000007

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Item 1C. Cybersecurity.

ITEM 1C. CYBERSECURITY We have processes in place to assess, identify, and manage material risks from cybersecurity threats. Our business is dependent on the communications and information systems of the Adviser and other third-party service providers. The Adviser manages the our day-to-day operations and has implemented a cybersecurity program that applies to us and our operations. Governance and Oversight of Cybersecurity Risk The Adviser has instituted a cybersecurity program, overseen by the Adviser’s Chief Compliance Officer (“CCO”) , which is designed to assess, identify, and manage material cyber risks applicable to us. The cyber risk management program involves risk assessments, identification of sensitive information assets (“Critical Information”), implementation of security measures, and ongoing monitoring of systems and networks, including networks on which we rely on. The Adviser actively monitors the current threat landscape in an effort to identify material risks arising from new and evolving cybersecurity threats, including material risks faced by us. We rely on the Adviser to engage external experts, including cybersecurity consultants, to evaluate cybersecurity measures and risk management processes, and depends on and engages various third parties, including suppliers, vendors, and service providers. The Adviser conducts ongoing due diligence of its significant service providers to determine whether the cybersecurity programs of service providers include, among other things, procedures and safeguards designed to ensure the protection of Critical Information. Our Board would be made aware of any material risks associated with cybersecurity threats. Our Board currently receives periodic updates from our CCO regarding the overall state of the Adviser’s cybersecurity program, information on the current threat landscape, and risks from cybersecurity threats and cybersecurity incidents impacting us. Our management team, including our CCO, is responsible for assessing and managing material risks from cybersecurity threats. Our CCO, in managing such risks relating to cybersecurity threats, relies on the assistance provided by the Adviser. Our management team is informed about and monitors the prevention, detection, mitigation, and remediation of material cybersecurity incidents impacting us, including through the receipt of notifications from service providers and reliance on communications with legal, information technology, and/or compliance personnel of the Adviser . Impact of Cybersecurity Risk The potential impact of risks from cybersecurity threats on us are assessed on an ongoing basis, and how such risks could materially affect our business strategy, results of operations, and financial condition are regularly evaluated. During the reporting period, we have not identified any material risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that we believe have materially affected, or are reasonably likely to materially affect, us, including our business strategy, results of operation, and financial condition.

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