Exodus Movement Inc

Our cybersecurity program is designed to protect our information, and that of our customers, against cybersecurity threats that may result in adverse effects on the confidentiality, integrity, and availability of our information systems. Our cybersecurity risk management program, which is integrated into our overall enterprise risk management program, includes policies, processes and technologies to assess, identify and manage risks from cybersecurity threats and leverages the National Institute of Standards and Technology Cybersecurity Framework.

Governance

Our Board, with assistance from its Audit Committee, oversees the Company’s enterprise risk management process, including the management of risks arising from cybersecurity threats. Our Audit Committee receives reports on significant cybersecurity developments from the management team responsible for overseeing the Company’s risk and cybersecurity management processes, including our Chief Compliance Officer and VP of Infrastructure & Security. We also have protocols by which certain cybersecurity incidents are escalated within the Company and, where appropriate, reported to our Board in a timely manner.

At the management level, our VP of Infrastructure & Security leads the team responsible for implementing, monitoring and maintaining our cybersecurity risk management program across our business. He has extensive cybersecurity knowledge and skills gained from over 15 years of relevant work experience, including various leadership and management roles in information technology at the Company and elsewhere. He also has a Bachelor of Science in information systems.

Risk Management and Strategy

Our cybersecurity program includes technical safeguards, including automated tools managed and monitored by our cybersecurity team. Additionally, we regularly conduct penetration and vulnerability testing and tabletop exercises, along with regular employee training on cybersecurity matters. We also employ systems and processes designed to oversee, identify, and reduce the potential impact of a security incident at a third-party vendor, service provider or customer or otherwise implicating the third-party technology and systems we use.

While we have not identified any material cybersecurity threats or incidents in the last year that have had a material adverse effect on our business, there can be no guarantee that we will not be the subject of future successful attacks, threats or incidents. For more information on our cybersecurity related risks, see “Item 1A. Risk Factors—Risks Related to Our Business – Any actual or perceived failure of the Exodus Platform to block malware or prevent failures or security breaches or other cybersecurity incidents could harm our reputation, cause the Exodus Platform to be perceived as insecure, underperforming or unreliable, impede our efforts to attract and retain users and otherwise negatively impact our business, results of operations and financial condition.” of this report.