Survey of Cybersecurity Disclosures in Annual Reports on Form 10-K Filed by Selected Well-Known Seasoned Issuers

May 31, 2024

We have developed this survey to provide information to our clients and other interested parties about cybersecurity related disclosures included in annual reports on Form 10-K. Our survey focuses on companies registered with the U.S. Securities and Exchange Commission (SEC) that have disclosed that they qualify as well-known seasoned issuers and that we understand are included in the Fortune 100 index.

The charts included in the survey attached below reflect selected statistics that we believe provide useful information about cybersecurity disclosure characteristics and related governance practices. A list of the companies whose annual reports we reviewed is provided in Annex A.

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) adopted final rules that require annual disclosure by public companies of their cybersecurity risk, management, strategy, and governance practices (Cyber Rules). These requirements apply to annual reports for fiscal years ending on or after December 15, 2023. For more information regarding the Cyber Rules, see our client briefing.

Please contact Megan Gordon, Devika Kornbacher or another member of your Clifford Chance client service team if you would like to discuss this survey or have any related questions.

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