FIDUS INVESTMENT Corp
For the period ended Dec 31, 2024. Filed Mar 6, 2025.
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FY2024 · Filed Mar 6, 2025
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Item 1C. Cybersecurity
The Company’s cybersecurity program is designed to identify, assess, and manage material risks from cybersecurity threats. The Company relies on the Investment Advisor to implement the cybersec urity program. The cyber risk management program involves risk assessments relating to the information systems of the Investment Advisor, incident response training and testing, implementation of security measures, and ongoing monitoring of systems and networks and assessment of the associated risks on an annual basis, including networks on which the Company relies on. The Investment Advisor actively monitors the current threat landscape in an effort to identify material risks arising from new and evolving cybersecurity threats. The Investment Advisor has engaged external experts, including consultants, to evaluate cybersecurity measures and risk management processes. The Company depends on andengages various third parties, including suppliers, vendors, and service providers. Thecompliance team of the Company and the Investment Advisor will conduct onboarding and ongoing due diligence of each third-party engaged by them, including identify and oversee risks from cybersecurity threats associated with their use of such entities.
Board Oversight of Cybersecurity Risks
The Board has the primary responsibility for overseeing and reviewing the guidelines and policies with respect to the Company’s risk management, including risks associated with cybersecurity threats. Certain members of the Company’s management will periodically report to the Board, on at least a quarterly basis, on cybersecurity matters, such asthe overall state of the Company’s cybersecurity program, information on the current threat landscape, and risks from cybersecurity threats and material cybersecurity incidents.
Management's Role in Cybersecurity Risk Management
The Company’s management is responsible for assessing and managing material risks from cybersecurity threats, in consultations with cybersecurity consultants engaged by the Investment Advisor. The Company’s management is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents, including through the receipt of notifications from service providers and reliance on communications with risk management, legal, and/or information technology.
Assessment of Cybersecurity Risk
The potential impact of risks from cybersecurity threats are assessed on an ongoing basis, and how such risks could materially affect the Company’s business strategy, operational results, and financial condition are regularly evaluated. During the reporting period, the Company has not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that the Company believes has materially affected, or are reasonably likely to materially affect, the Company, including the Company’s business strategy, operational results, and financial condition.
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