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    1000 Holcomb Woods Parkway | Suite 130 | Roswell, GA 30076 | 770 -643-1114 | Fax: 1-800-418-9088 | www.firestorm.com

    Firestorm recently held the first of its kind, virtual cyber exercise with expert panelists from

    technology, insurance and financial sectors. This document gathers the best thought leadership from

    all participants and addresses the critical questions of a Cyber Breach Crisis.

    TEN CYBER-CRISIS BEFORE NOW

    ACTIONS

    THE HEAVYWEIGHTS WEIGH IN

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    TEN CYBER-CRISIS

    BEFORE NOW

    ACTIONSTHE HEAVYWEIGHTS WEIGH IN

    INTRODUCTION- CYBER BREACH

    Today, 80 percent of the value of corporate assets has shifted from physical

    to virtual. Accordingly, the business risk has increased dramatically over the

    last two decades.A cyber breach is a business problem, not an IT problem.

    Corporations face accelerated, complex, sophisticated attacks resulting in

    expanding impacts. A characteristic of cyber-breaches is that they penetrate

    an organizations perimeter data security defenses through multiple channels

    to exploit all layers of information security. Unfortunately, if a sophisticated

    attacker targets an organization, they will be able to breach the data security

    in place. Your focus must be on response.

    What are the most critical components of an incident response plan?

    Preparedness starts with a strong incident response plan

    that highlights roles and responsibilities when it comes to

    responding to a breach. The organization needs to

    understand escalation procedures that involve identifying,

    investigating, and reporting confirmed data breaches.

    Responsibilities include forensic investigation to validate a

    breach, authority to declare a data breach, reporting the

    breach to appropriate authorities and the organizations

    customers. Thomas Tollerton, DHG

    What follows next are ten common questions related to Cyber Breach and

    answered by our panel of experts from the technology, insurance, finance

    and crisis industries. Our experts are:

    WHAT IS A CYBER

    BREACH?

    Cyber Breach is a term

    that describes a crime

    which may involve IT

    hardware, software or

    access to data. Just as

    Armed Robbery implies

    the use of a weapon to

    steal, Cyber Breach

    implies the use of IT.

    When you

    outsource

    services,

    you do not

    outsource

    liability.

    Shannon Groeber, JLT

    USA

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    1. How d o o rganizat ions look beyond IT secur i ty when assessing their cyber

    breach r isks?

    Shannon Groeber, JLT USA: Assessing your cyber breach risk requires a much broader focus than just IT security.

    In todays world, any organization with electronic data or network connectivity faces the possibility of a cyber

    incident. In order to understand the risk, it is essential to understand what valuable assets you hold, and how an

    attack will impact your organization. How dependent are you upon networks and systems in order to deliver

    your product or service? Can you quantify and qualify the data that your organization manages and holds? Do

    any third parties have access to your data or systems? If so, are they contractually responsible should they suffer

    an incident that impacts your organization? These and many other questions are a crucial first step in

    determining the scope of what could go wrong and what the costs might be. After assessing the impact of a

    cyber incident, organizations can then focus on IT and non-IT security, education and training, proper

    governance and controls, and other measures that create a holistic strategy to protect against cyber incidents.

    Thomas Tollerton, DHG:Executive leadership must understand that an effective cybersecurity program is a

    process, not an end state. Leadership must constantly maintain awareness of threats and always be seeking to

    improve processes and technology to addressing evolving and maturing threats to the organizations data and

    systems.

    Jack Healey, Firestorm: Organizations that focus solely on IT security have failed to recognize that Cyber Breach

    Risks are actually nothing more than human risks. Most, if not all breaches, are due to human error. The more

    sophisticated your organization's defenses, the more sophisticated the attack.

    Social engineering approaches such as enticing an associate to click on a link, or sending via a misspelled or

    compromised email account are simple ways to breach a company. With the introduction of BYOD (Bring your

    own device- laptops, PDAs Apple Watches) and telecommuting, the risks of an associate allowing a breach is

    more prevalent today than any other time. The bad news is, it will get worse before it gets better. Organizations

    need to recognize that we are talking about human risk, and training is the answer.

    2. What act ions can an organizat ion take that clearly demo nstrate to

    consumers and regulators that the org anizat ion has taken ant ic ipatory steps to

    address cyber secur i ty threats?

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    Steve Bridges, JLT USA: Though most regulators will be examining an organizations practices retrospectively,

    we are seeing an expansion of legislation and regulatory actions that are prospective in nature. Regardless,

    regulators will look to organizational commitment to cyber security from the highest levels in determining

    whether an organization is or has properly addressed cyber security. Board level involvement and board

    committee participation are important. An organizations resource commitment both people and moneyinto

    this issue will also be examined. Regulators will also look to industry specific rules on security practicesthings

    like PCI, HIPAA, or NIST complianceand will want to see evidence of third party assessments, testing, and

    similar proactive measures that demonstrate an organizations commitment to prevention.

    Companies with a comprehensive cyber security strategyincluding

    physical security (such as fences, cameras and motion detectors);

    perimeter security (including firewalls, unified threat management,

    and intrusion prevention and detection); authentication (or two-

    factor authentication for employees with access to sensitive data);

    endpoint security (such as encryption and anti-virus software); and

    monitoring (including data logging, packet inspection and network

    traffic monitoring)will shine.

    Shannon Groeber, JLT USA: On the consumer side, it is much more

    difficult to convince consumers that you are addressing cyber

    security prior to an incident. Things like strong privacy policies, a

    commitment to encryption, and educational efforts to share with

    consumers that your organization takes security seriously are all

    helpful. Unfortunately, most evidence suggests that consumers only

    care about security after a data breach. Consumers tire of demands

    that they update passwords or that they answer security questions.

    Typically, they just want to complete their transaction with your

    company as swiftly as possible. Meeting the balance between an

    efficient transaction and rigorous security is a key challenge for most

    organizations.

    Jack Healey, Firestorm: Organizations who wish to achieve Best in Class should focus on the elements of a

    well-designed Cyber Risk Program. This begins with comprehensive IT Intrusion and Detection controls, a Cyber

    Breach Incident Response Plan, Cyber Awareness Training, and Cyber Breach Scenario Testing for all associates,

    board members and third parties, and performing After Action (Hot Wash) events. These plans are not static,

    they need to evolve as technology and threats change and keep pace with the most recent scams and intrusiontactics. A great resource to track these tactics is theFBIs Cyber Task Forceon the FBIs web page. In addition,

    larger organizations may wish to undergo a SOC 1 (Service Organization Controls) or SOC 2 evaluation by their

    outside auditors. These reports test the overall IT infrastructure and IT controls and provide third parties with a

    report. It is a Good Housekeeping seal of approval for IT controls.

    Thomas Tollerton, DHG:

    Objective, third party

    assessments of

    cybersecurity posture are

    not only helpful in

    identifying gaps in

    cybersecurity functions,

    but also in providing

    reassurance to an

    organizations

    stakeholders that

    leadership takes threats

    seriously. Reports such asSSAE16 provide such

    assurance.

    https://www.fbi.gov/about-us/investigate/cyber/cyber-task-forces-building-alliances-to-improve-the-nations-cybersecurity-1https://www.fbi.gov/about-us/investigate/cyber/cyber-task-forces-building-alliances-to-improve-the-nations-cybersecurity-1https://www.fbi.gov/about-us/investigate/cyber/cyber-task-forces-building-alliances-to-improve-the-nations-cybersecurity-1https://www.fbi.gov/about-us/investigate/cyber/cyber-task-forces-building-alliances-to-improve-the-nations-cybersecurity-1
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    3. What is the best appro ach to educating emplo yees about approp riate

    handl ing and pro tect ion of sensi t ive data?

    Shannon Groeber, JLT USA: Like learning any skill, repetition is the key, but organizations risk employees tuning

    out the message if education is done poorly. A demonstrated commitment at the top levels of the organizationwill aid in the success of your educational efforts. In addition, education around the costs of failing to handle

    data appropriately will also be helpful.

    Similar to many other events that threaten an organizations reputation, successful prevention measures are

    ingrained in an organizations culture. When employees at every level of the organization can understand the

    harm associated with deviating from preventative measure, and feel empowered to protect the brand from a

    cyber (or other damaging) event, education and training transitions from another corporate requirement to the

    backbone of the organization. Living and demonstrating the prevention measures through every level of the

    organization by way of example helps to instill those behaviorslike all other elements of corporate culture,

    actions are more powerful than words.

    Thomas Tollerton, DHG:Awareness begins from the top of an organization. Executive leaders need to believe in

    the importance of their leadership; in understanding current threats and appropriate user behaviors in order to

    more effectively motivate employees to maintain their own awareness. Employees tend to respond to engaging

    and dynamic awareness education that communicates how heightened awareness helps protect the individuals

    confidential data, as well as corporate data.

    Jack Healey, Firestorm: Education should take place at all levels of the organization and be both General Cyber

    Security Awareness as well as Specific Functional Detection and Prevention training.

    General Awareness covers:

    a.

    What data is considered sensitive and why;

    b.

    what company data is encrypted,

    c.

    who has access to the data,

    d.

    how the data is transferred internally and externally,

    e.

    where and how data is retained ,

    f.

    how data should be destroyed,

    g.

    and General Security such as the use of passwords, use of dual authentication of the most sensitive

    or vulnerable data (e.g. cash); BYOD policies, use of firewalls and anti-virus software at home and on

    all BYOD devices, social engineering awareness, see something say something; use of help desk and

    other resources the organization has in place.

    Specific Functional Detection and Prevention training is geared towards a specific job function; as an example,

    how can an Administrative Assistant recognize a fraudsters attempt to gain information about an organization

    (calls asking the name of the CFO and treasurer to institute a wire transfer fraud)? Human Resource, Supply

    Chain, Finance and Legal departments should have intensive training since they maintain some of the most

    valuable data or will be involved in a Cyber Breach if one occurs.

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    4. How can organizat ions ensure that everyone know s what to do in the event

    of a breach?

    Jim Satterfield and Jack Healey, Firestorm:In the event of a Breach, an organization should have a Cyber Breach

    Incident Response Plan (CIRP). This plan is detailed, provides for escalation of risk and assigns responsibility. A

    plan identifies the team that will manage the data breach and should include all business disciplines.

    Many times associates include IT, HR and legal, but overlook finance, customer service, and procurement

    (supply chain). A CIRP covers the management and communication of a breach to stakeholders. It will address,

    before a breach occurs,such issues of when to notify the Board, when to contact law enforcement, what type of

    breach constitutes a significant breach (a lost laptop versus a loss of all customer data), and provides for post

    breach After Action (hot wash) to review the breach. Most of the plans that Firestorm has written are well over

    100 pages long, easily indexed and provide the guiding principles and level of specificity to allow a responseteam to have confidence in their actions. A CIRP should be tested, and reviewed by the Board of Directors. The

    CIRP also mandates the inclusion of third parties such as experts in Cyber law, Cyber forensics and Cyber

    insurance.

    Steve Bridges, JLT USA:At this point, many companies do have a formalized plan in place to help organize

    response (and those that dont should begin putting one in place). Chaos tends to ensue when a plan is never

    tested. Companies should create a response plan that includes key leadership responsibilities and a list of third

    party vendors with contracts in place, but should also identify a single decision maker that will have ultimate

    authority after input from the requisite experts. It is also essential to ensure employees know when to escalate a

    particular incident so that it can receive the appropriate attention from the crisis response panel.

    Thomas Tollerton, DHG: While ensuring that everyone knows how to respond to a security incident is virtually

    impossible, leadership can evaluate security awareness within the organization through performance of social

    engineering testing. Social engineering tests simulate attack scenarios, such as phishing email campaigns or

    fraudulent phone calls (vishing) and records the results related to

    how employees respond to such attacks.

    5. What is the best way for an org anizat ion to

    ident i fy if i t has acqu ired new areas or levels of

    r isk?

    Thomas Tollerton, DHG: Understanding evolving risk requires

    awareness of changing and enhanced business processes and

    technologies. In addition to evolving threat actors, changes to the

    IF YOU OPENED

    YOUR

    ORGANIZATIONSDOOR FOR BUSINESS

    THIS MORNING, YOU

    ACQUIRED NEW RISK.

    JACK HEALEY, FIRESTORM

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    way an organization functions, its physical locations, and new technology infrastructure are all factors that can

    change the risks an organization faces with regard to protecting sensitive information. Management must

    consider all of these factors when performing ongoing assessments of cybersecurity risk.

    Shannon Groeber, JLT USA: Cyber risk is dynamic and the threat is ever changing. Various areas of expertise

    throughout the organization should be focused on issues within their domainIT, HR, compliance, legal, etc.

    Companies who are leaders in addressing cyber security and cyber risk have implemented a governancestructure that is able to gather information from these groups and utilize it across the organization. All too

    often, organizations overlook the need to periodically assess their riskif not on a constant basis, at critical

    timeframes, and with a documented and methodical process.

    Because the risk is dynamic, the exposure identification process must be, also. Leaders in exposure identification

    also treat the process as a critical function within an organization - employing an individual or committee with a

    clear job function to constantly assess exposure, as opposed to unofficially adding to an already overburdened

    employee with a number of other responsibilities.

    6. How can an organizat ion hold i ts vendors and partners to their same high

    standards?

    Steve Bridges, JLT USA: Similar to other risk avoidance and prevention measures, a thorough plan includes due

    diligence on the front end, and contractual protections on the back end. It is critical that all vendors who may

    have access to data or systems are evaluated to ensure they will perform in the manner that they promise. This

    can include demonstrating that certain designations or certificates have been achieved, copies of third party

    assessments, etc.

    Once you are satisfied with the assurances they give you, contracts with vendors or business partners who touch

    your client or confidential information must require the vendor or business partner to protect the data they

    touch. Increasingly, the contractual language is more than the standard provide appropriate security controls

    and forward thinking companies are requiring certain standards that can include segregation of data, limitations

    on where the data can be housed geographically, and detailed requirements as to security practices.

    Shannon Groeber, JLT USA: For a number of reasons, it makes sense to also include right to audit language

    that allows you to review your vendor or business partners security practices and procedures. Adding the

    language does not require you to audit, but simply gives you the right to do so. It allows a company to identify

    (and then eliminate) risky vendors and partners, supports your compliance obligations, and strengthens your

    own security practices and procedures.

    Like all contracts, your ability to secure this contractual right will depend on the terms of the deal, but this

    request is becoming more common in with larger companies with considerable amounts of PII who outsource

    some or all of their data management services. Remember, when you outsource services, you do not outsource

    liability.

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    Thomas Tollerton, DHG: Effective vendor management begins with a consistent process for performing due

    diligence on a third partys cybersecurity program. Asking the right questions, such as whether the organization

    has implemented its own risk assessment process and established a plan for addressing high residual risk can go

    a long way to understanding whether vendors consider cybersecurity as part of their organizations operation.

    Jack Healey and Jim Satterfield, Firestorm: The number one conduit for a Cyber Breach incident has been

    through the supply chain. The most recent Ponemon study stated that 57% of all retailers who had beenbreached said that it was a direct result of a supplier. You should understand your suppliers Cyber IQ. Do they

    have strong IT Intrusion and Detection controls in place, Cyber Awareness Training, Cyber Incident Response

    Plans which have been tested and have they performed an After Action program? You can ask for a SOC 1 or

    SOC 2 report, or inquire regarding NIST protocols, but you should assume that they will be breached. The speed

    at which they detect, respond, mitigate and restore services is important to you. Then you need to ask about

    their supply chain. What actions have they taken to assess their suppliers Cyber IQ?

    7. How can an organi zat ion best mit ig ate

    BYOD r isks?

    Shannon Groeber, JLT USA:First, organizations must understand

    the magnitude of their own risk. Who is using their own device?

    Are they owned by the company or the employee? What kind of

    data is on them and are they encrypted? Having a complete

    understanding of these questions is a key cyber risk

    management best practice. Then companies must have the ability to wipe devices in the event a device is lost oran employee leaves. Finally, its crucial to secure and separate environments between personal and

    professional.

    Thomas Tollerton, DHG: When an organization decides to implement a BYOD program, consideration for

    effective monitoring controls must be part of the plan. Access must be limited such that IT has visibility into all

    users and personal devices that have access to corporate resources, and that IT has the ability to immediately

    revoke access as needed. Additionally, users must understand their responsibilities for physically securing their

    devices and not sharing access to personal devices when sensitive corporate data is accessed on such devices.

    8. How do I determine wh at cyb er insu rance cov erage my organizat ion

    needs?

    Shannon Groeber and Steve Bridges, JLT USA: Cyber threats are a reality for any organization, and proactively

    addressing cyber concerns is essential to companies in a variety of industries. Forward thinking companies are

    utilizing cyber insurance as part of a holistic and proactive cyber risk management plan. However, the cyber

    insurance market is inundated with brokers, insurance carriers and service providers, and its difficult to

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    determine which is the right fit based on your needsnot all participants in this dynamic field carry the same

    expertise.

    The best way to understand your cyber insurance needs is to work with an insurance broker who specializes in

    cyber coverage on a full time basis. The broker should help you collaboratively identify potential cyber

    exposures by reviewing your services, customer base, contracts, and security practices, to name a few critical

    areas of focus. The most effective risk transfer solutions are usually borne from roundtable discussions with RiskManagement, Information Security, Legal (responsible for contractual requirements and compliance with

    vendors and customers), and the individual or team members responsible for regulatory compliance, among

    other relevant functions based on your unique business. This will drive coverage negotiations and help in

    determining which additional resources will be most impactful.

    9. What ro le should insurance play in the cyber cr is is process?

    Shannon Groeber, JLT USA: A well-crafted risk transfer solution carries a number of benefits both pre and post

    breach. Throughout the process of placing coverage, you should benefit from working with a skilled broker that

    can help you quantify and assess your risk, provide feedback, education and consultation on emerging risks and

    how you compare to peers, and help anticipate the ever-evolving insurance market. Once an event occurs, the

    insurance program in place should help you facilitate a response, should a turnkey solution be best suited for

    your firm, or provide the funds to quickly and appropriately minimize the overall harm without further

    interference if thats a better fit. In short, the insurance should be integrated into your breach response process,

    but should not impede it. Unfortunately, the proliferation of insurance options can sometimes result in an

    insured buying a policy based on price or other factors without the guidance of a broker that is proficient in

    cyber placement, and without understanding how the policy functions. The combination can cause further

    exacerbation of the event itself.

    10: What can I do n ow to be ready to effect ively commu nicate before, durin g, and

    after a cyber cr isis ?

    Stacey Giles, MIR3: Before a crisis, establish a system for providing up-to-the-minute information for all your

    stakeholders through every possible mode, like email, text, phone, etc. Make sure your contact data is current

    and complete, and be sure to provide a way for message recipients to respond. Create message templates that

    align with your companys core values so that when the pressure is on, a message can quickly be adapted to fit

    the situation.

    During the event its important you monitor and react appropriately to recipient responses while continuing to

    provide direction and updates. Use your system to provide just the right information for each group of

    recipients, and use a call-bridge system to quickly pull together decision makers on a conference call. After a

    crisis its always a good idea to send follow-up messages to assess losses, reconnect with your team refocus

    everyone on safely resuming productivity.

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    PREDICT.PLAN.PERFORM.

    At Firestorm, we employ a PREDICT.PLAN.PERFORM. methodology to analyze and enhance the Cyber Crisis

    planning process. The process should be evaluated for the five stages of a crisis with distinct decisions to be

    made, actions taken, and communications in each stage:

    Preaction

    Onset

    Impact

    Response & Recovery

    Post-Consequence Management

    Many organizations think of Cyber Breach as an IT issue. Cyber Breach is a Business Crisis-Riskand as such

    it is the responsibility of:

    o The Board of Directors

    o

    Senior Management (CXO)

    o IT (CISO)

    o Functional Areas

    Legal

    Internal Audit Customer Service/Sales

    Procurement/Supply Chain

    Human Resources

    Research and Development

    Finance

    Treasury

    Risk/Insurance

    Operations

    Logistics/Distribution

    Warehouse

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    NOTE:

    Firestorm has used the generic term cyber breach to conveniently represent incidents that could negatively

    impact your company, with respect to the following:

    All company information assets including hardware, network infrastructure, software, electronic and

    physical data, and human knowledge;

    Communication, storage, and processing of data by any means resulting from your companyactions/obligations; and

    Unauthorized security events resulting from intentional or unintentional electronic or human actions

    Firestorm recommends a cyber-risk analysis ofyour companysexisting cyber-breach plans/processes/

    procedures. This review must include your documentation associated with data security and crisis management

    response processes and procedures, as it relates to cyber-breach incidents. The analysis should focus on the

    organizational structure, employees, technology infrastructure, clients, suppliers, operations and other business

    risks associated with the data security process. The analysis must include functional, structural, security,

    systems, response, facilities, and communications perspectives.

    Upon completion of the analysis, you will be positioned to understand the current state of your existing data

    security and cyber-breach crisis management response environment.

    The analysis should include the following:

    Identification of cyber-breach exposures;

    Impact assessment of cyber-breach events;

    Response and recovery priorities;

    Mitigation of existing exposures; and

    Response & recovery strategy selection.

    What do you need?

    A.

    Cyber Breach Awareness Indicators Matrix

    A Cyber Breach Awareness Indicators Matrix is designed to provide your employees with a tool to identify

    events which may indicate that a cyber breach has occurred.

    B.

    Cyber Breach Response Activation Matrix

    A detailed Cyber Breach Response Activation Matrix identifies the considerations and triggers needed for

    leadership, response, and communications. This process provides guidelines for escalation, based upon

    potential for a cyber breach. The activation triggers will not override or supersede any existing policies currently

    in place for communications and coordination.

    C.

    Cyber Breach Response Roadmap

    Focus of the Cyber Breach Response Roadmap is directed on the notification, containment, response, and

    recovery of a cyber-breach incident.

    The Roadmap should include:

    Team members identified with two (2) alternates for each

    Role & Responsibilities

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    Checklist actions to be taken at each of the five (5) phases of activation: Preaction, Onset,

    Impact Assessment, Response & Recovery, and Post-Event

    Cyber Breach Awareness Indicators and Activation Matrices

    Incident Tracking Forms

    D. Cyber Breach Crisis Communications Plan with Message Maps

    Your company has established tools to address communication. Those tools must be integrated into acomprehensive enterprise Cyber Breach Crisis Communication Plan that will help you address internal and

    external communication during any cyber-breach incident. The plan will ensure that your company retains

    control of the narrative in any situation and not be forced into a potentially damaging response mode.

    The Cyber Breach Crisis Communications Plan will document protocols, tailored to Coordination, Crisis, and

    Compliance, that will guide your company in promptly sharing information with all stakeholders during a cyber-

    breach incident, as required.

    The 3 Cs of Cyber Breach Crisis Communications

    CoordinationCommunicate internally to direct coordination activities regarding cyber breach

    response and recovery.

    CrisisProvide communications to address the potential crisis impacts on brand and reputation.

    ComplianceCommunications responsibilities related to compliance notification to those parties who

    are impacted (or potentially impacted) by a cyber breach. These communications serve the dual

    purposes of notification and remedy actions to mitigate or prevent potential impacts.

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    Learn more about Firestorm and our Partners

    With more than 1,800 people in 12 states, Dixon Hughes Goodman ranks

    among the nations top 20 public accounting firms. Offering

    comprehensive assurance, tax and advisory services, DHG focuses on

    major industry lines and serves clients in all 50 states as well as

    internationally. Visitwww.dhgllp.comfor additional information.

    JLT Specialty USA is the U.S. platform of the leading specialty business

    advisory firm Jardine Lloyd Thompson Group. JLT experts have deep

    industry and product experience serving leading U.S. and global firms. JLT

    is one of the worlds leading providers of insurance, reinsurance and

    employee benefits-related advice, brokerage and associated services. Visitwww.jltus.com

    MIR3 is the premier provider of Intelligent Notification and response

    software for business operations, including crisis management, IT service

    management, corporate communications, customer relations, supply

    chain management, event management, or any area that needs reliable

    two-way notification for groups from one to many thousands. Visitwww.mir3.com

    Firestorm transforms crisis into value. The Firestorm

    PREDICT.PLAN.PERFORM. methodology combinesC-Suite level consulting,

    dynamic software solutions, andproven crisis management expertiseto

    empower clients to create resilient organizations. Firestorm is a

    nationally recognized leader in Crisis Management, Continuity Planning, Critical Decision Support, Crisis

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