Security & privacy at PeriNimble Our security posture, in the open.

Code of Business Conduct — Entity has a documented policy to define behavioral standards and acceptable business conduct.

Organizational Structure — Entity maintains an organizational structure to define authorities, facilitate information flow and establish responsibilities.

Roles & Responsibilities — Entity has established procedures to communicate with staff about their roles and responsibilities.

New Hire Policy Acknowledgement — Entity has established procedures for new staff to acknowledge applicable company policies as a part of their onboarding.

Security & Privacy Awareness — Entity provides information security and privacy training to staff that is relevant to their job function.

Periodic Policy Acknowledgement — Entity has established procedures for staff to acknowledge applicable company policies periodically.

Automated Reporting — Entity has provided information to employees, via various Information Security Policies/procedures, on how to report failures, incidents, concerns, or other complaints related to the services or systems provided by the entity in the event there are problems.

Risk Framing — Entity performs a formal risk assessment exercise annually, as per documented guidelines and procedures, to identify threats that could impair systems' security commitments and requirements.

Risk Assessment — Each risk is assessed and given a risk score in relation to the likelihood of it occurring and the potential impact on the security, availability, and confidentiality of the Company platform. Risks are mapped to mitigating factors that address some or all of the risk.

Fraud — Entity considers the potential for fraud when assessing risks. This is an entry in the risk matrix.

Third-Party Criticality Assessments — Entity performs a formal vendor risk assessment exercise annually to identify vendors that are critical to the systems' security commitments and requirements.

Assigned Cybersecurity & Privacy Responsibilities — Entity's Senior Management assigns the role of Information Security Officer who is delegated to centrally manage, coordinate, develop, implement, and maintain an enterprise-wide cybersecurity and privacy program.

Internal Audit using Sprinto — Entity uses Sprinto, a continuous monitoring system, to track and report the health of the information security program to the Information Security Officer and other stakeholders.

Periodic Review & Update of Cybersecurity & Privacy Program — Entity's Senior Management reviews and approves the state of the Information Security program including policies, standards, and procedures, at planned intervals or if significant changes occur to ensure their continuing suitability, adequacy, and effectiveness.

Management Review of Org Chart — Entity's Senior Management reviews and approves the Organizational Chart for all employees annually.

Management Review of Risks — Entity's Senior Management reviews and approves the "Risk Assessment Report" annually.

Management Review of Third-Party Risks — Entity's Senior Management reviews and approves the "Vendor Risk Assessment Report" annually.

Subservice organization evaluation — Entity reviews and evaluates all subservice organizations periodically, to ensure commitments to Entity's customers can be met.

Segregates Roles and Responsibilities — Entity's Senior Management segregates responsibilities and duties across the organization to mitigate risks to the services provided to its customers.

Asset Ownership Assignment — Entity has set up mechanisms to assign and manage asset ownership responsibilities and establish a common understanding of asset protection requirements.

Data Governance — Entity maintains a list of legal, statutory, and regulatory requirements relevant to information security.

New Hire Security & Privacy Training Records — Entity has established procedures for new staff to complete security and privacy literacy training as a part of their onboarding.

Periodic Security & Privacy Training Records — Entity documents, monitors, and retains individual training activities and records.

Inventory of Endpoint Assets — Entity develops, documents, and maintains an inventory of organizational endpoint systems, including all necessary information to achieve accountability.