GERON CORP
For the period ended Dec 31, 2025. Filed Mar 2, 2026.
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FY2025 · Filed Mar 2, 2026
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Item 1C. Cybersecurity
Risk management and strategy
We operate in the biopharmaceutical sector, which is a highly regulated sector subject to various
cybersecurity risks that could adversely affect our business, financial condition, and results of operations, including
intellectual property theft; fraud; extortion; harm to employees or customers; disruption of our clinical trials, manufacturing
or supply chain; violation of privacy laws and other litigation and legal risk; and reputational risk. We rely primarily on
industry-leading third parties and a cloud-based infrastructure for our information technology systems, and accordingly are
dependent on these third parties’ own cybersecurity risk management practices and strategy. We have implemented and
maintain various information security processes designed to identify, assess and manage material risks from cybersecurity
threats to our critical computer networks, third party hosted services, communications systems, hardware and software, and
our critical data, including clinical trial data, intellectual property, confidential information that is proprietary, strategic,
financial or competitive in nature, and personal data (“Information Systems and Data”).
We take a risk-based approach to identify and assess the cybersecurity threats and risks that could affect our
business and Information Systems and Data. Our Information Technology personnel help identify, assess and manage our
cybersecurity threats and risks, and support our efforts to identify and assess risks from cybersecurity threats by monitoring
and evaluating our threat environment. We use various methods and tools to identify, assess and manage cybersecurity
threats and risks, including, for example, automated tools, a third-party managed detection and response firm to monitor
security alerts on a 24-hour basis, industry reports, engaging a virtual Chief Information Security Officer, third party threat
assessments and penetration testing. In addition, we encrypt data at rest and maintain network security controls, such as
firewalls and virtual private networks. We also conduct computerized system monitoring and access control, including
asset management, tracking and disposal associated with onboarding and offboarding of personnel. We maintain
cybersecurity insurance.
Depending on the environment, we implement and maintain various technical, physical, and organizational
measures, processes, standards and policies designed to manage and mitigate material risks from cybersecurity threats to
our Information Systems and Data. For example, in 2025, we expanded our monitoring capabilities by engaging with a
managed detection and response firm to monitor and respond to security alerts on a 24-hour, seven-day-a-week basis. We
have implemented and maintain an incident response plan, and we utilize automated tools designed to maintain email
security. We have also implemented a computerized system security and password policy that defines security for access to
computer systems managed and controlled by us, and a procedure for computerized system incident management to
address any unplanned issues in regulated computerized systems that could impact subject safety, product quality, and data
integrity. We further protect access by monitoring risk-based sign-in attempts, and require stronger authentication (e.g.,
multi-factor authentication) based on defined policies. We periodically conduct cybersecurity incident tabletop training
exercises involving our personnel and plan to continue conducting similar training exercises in 2026.
Our assessment and management of material risks from cybersecurity threats areintegrated into our overall
risk management processes. For example, ourhead of Information Technology evaluates material risks from cybersecurity
threats and reports periodically to the Audit Committee of our Board, which evaluates our overall enterprise risk. We use
third-party service providers to assist us from time to time to identify, assess, and manage material risks from cybersecurity
threats, including, for example, cybersecurity software providers such as our managed detection and response firm,
cybersecurity service providers, penetration testing firms, auditors, and professional services firms, such as our virtual
Chief Information Security Officer, including legal counsel. These relationships enable us to leverage specialized
knowledge and insights, enabling our cybersecurity strategies and processes to remain consistent with industry best
practices.
We rely onthird-party service providers to perform a variety of functions throughout our business, such as
contract manufacturing organizations, contract research organizations, suppliers and consultants, and third party logistics
organizations and distributors to distribute RYTELO. We conduct quality and cyber audits of regulated vendors, which
typically include an assessment of such vendor’s information technology systems, checks for recent cybersecurity
incidents, analyzing potential vulnerabilities associated with such vendor's externally facing infrastructure, and the
cybersecurity controls they have in place to protect the Company's data, and we impose appropriate contractual obligations
on vendors pertaining to information security. Depending on the nature of the services provided, the sensitivity of the
Information Systems and Data at issue, and the identity of the provider, our efforts may involve different levels of
assessment designed to help identify cybersecurity risks associated with a provider and impose contractual obligations
related to cybersecurity on the provider.
For a description of the risks from cybersecurity threats that may materially affect us and how they may do
so, see our risk factors under Part 1. Item 1A. Risk Factors in this Report, including “Risks Related to Information
Technology Systems, Data Security and Data Privacy.”
Governance
Our Board of Directors addresses our cybersecurity risk management as part of its general oversight
function. The Audit Committee of our Board is responsible for overseeing our cybersecurity risk management processes,
including oversight and mitigation of risks from cybersecurity threats.
Our Audit Committee, as well as our Chief Financial Officer and other members of our executive
management as appropriate, receives periodic reports from our head of Information Technology concerning our significant
cybersecurity threats and risks and the processes we have implemented to address them. The Audit Committee also
receives various periodic presentations related to cybersecurity threats, risk and mitigation.
Risk Management Personnel
Our Information Technology personnel responsible for cybersecurity risk assessment and management
processes are managed by certain members of our executive management, including our Chief Financial Officer. Together
with our executive management, our Information Technology personnel are responsible for helping to integrate
cybersecurity risk considerations into our overall risk management strategy, and communicating key priorities to relevant
personnel. We believe these Information Technology personnel have the skills appropriate to help us prepare for
cybersecurity incidents, approve cybersecurity processes, and review security assessments and other security-related
reports.
Our cybersecurity incident response plan is designed to escalate certain cybersecurity incidents to members
of management depending on the circumstances, including executive management. When appropriate given the nature of
any potential cybersecurity incident, our executive management works with our incident response team to help us mitigate
and remediate cybersecurity incidents of which they are notified, and to make any legally required notifications to
individuals or regulatory agencies, including making any required disclosures under the Exchange Act.
The text of this filing, as the company filed it with the SEC, without its images or exhibits. This is not investment advice.