Navan

Risk management and strategy

We have implemented and maintain various information security processes designed to identify, assess and manage material risks from cybersecurity threats to our critical computer networks, third party hosted services, communications systems, hardware and software, and our critical data, including intellectual property, and confidential information that is proprietary, strategic or competitive in nature, including information related to our customers (“Information Systems and Data”).

We have a cross-functional team led by our Chief Information Security Officer (CISO) and comprised of members of our Security, Legal, Engineering, and Governance, Risk, and Compliance (GRC) departments to help identify, assess and manage the Company’s cybersecurity threats and risks. This team identifies and assesses risks from cybersecurity threats by monitoring and evaluating our threat environment and the Company’s risk profile using various methods including, for example by using manual tools, automated tools, subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and threat actors, conducting scans of our environment, evaluating our and

our industry’s risk profile and threats reported to us, conducting internal and external audits, conducting threat assessments and vulnerability assessments, referencing third party intelligence feeds, and conducting tabletop and other testing exercises.

Depending on the environment, we implement and maintain various technical, physical, and organizational measures, processes, standards and policies designed to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data. For example, we have an incident response policy and incident response and detection capabilities, a vulnerability management policy, business continuity and disaster recovery plans, a vendor risk management program, and we maintain cyber insurance. We also conduct risk assessments, encrypt data at rest and in transit, implement network security controls, segregate data based on sensitivity, implement access controls, physical security controls, asset management and tracking, employee training, penetration testing, and use endpoint detection and response tools and data loss prevention tools.

Our assessment and management of material risks from cybersecurity threats are integrated into the Company’s overall risk management processes. For example, (1) cybersecurity risk is addressed as a component of the Company’s enterprise risk management program through our GRC department and is reviewed as part of our risk committee meetings comprised of key senior management; (2) our CISO works with management to prioritize our risk management processes and mitigate cybersecurity threats that are more likely to lead to a material impact to our business; (3) our CISO evaluates material risks from cybersecurity threats against our overall business objectives and reports to the audit committee of the board of directors, which evaluates our overall enterprise risk.

We use third-party service providers to assist us from time to time to identify, assess, and manage material risks from cybersecurity threats, including for example automated cloud security scanning, threat intelligence providers, software providers, penetration testing firms, code security scanning, and dark web monitoring services.

We use third-party service providers to perform a variety of functions throughout our business, application providers, hosting companies, supply chain resources, payment providers, and travel and hospitality providers. We have a vendor management program to manage cybersecurity risks associated with our use of these providers. The program includes risk assessments for vendors, security questionnaires, a review of a vendor’s written information security program and associated audit and compliance documentation, audits of the vendor if needed, vulnerability scans of the vendor in certain circumstances, and in certain cases, security assessment calls with the vendor. We also impose certain contractual obligations related to cybersecurity on certain vendors. Depending on the nature of the services provided, the sensitivity of the Information Systems and Data at issue, and the identity of the provider, our vendor management process may involve different levels of assessment designed to help identify cybersecurity risks associated with a provider and impose contractual obligations related to cybersecurity on the provider.

For a description of the risks from cybersecurity threats that may materially affect the Company and how they may do so, see the section titled “Risk Factors,” including “Risk Factors—Risks Related to Privacy, Cybersecurity, and Intellectual Property—We, our suppliers, our other partners, our customers, and others who use our services obtain and process a large amount of sensitive data. If our information technology systems or data, or those of the third parties upon with whom we work, including our suppliers, our other partners, or customers, are or were compromised, we could experience adverse impacts resulting from such compromise, including, but not limited to, regulatory investigations or actions, litigation, fines and penalties, interruptions to our operations, claims that we breached our data protection obligations, harm to our reputation, and a loss of future customers or sales and other adverse consequences.”

Governance

Our board of directors addresses the Company’s cybersecurity risk management as part of its general oversight function. The board of directors’ audit committee is responsible for overseeing Company’s cybersecurity risk management processes, including oversight of mitigation of risks from cybersecurity threats.

Our cybersecurity risk assessment and management processes are designed, implemented and maintained by certain Company management, specifically our CISO, who has 25 years of technical, senior engineering and product management experience and was previously the Executive Vice President of Security at Salesforce and CISO at Tesla and Vimeo, and our Director of Governance, Risk and Compliance, who has two decades of experience in GRC programs and relevant cybersecurity certifications.

Our CISO is responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into the Company’s overall risk management strategy, and communicating key priorities to relevant personnel. Our CISO is also responsible for approving budgets, helping prepare for cybersecurity incidents, approving cybersecurity processes, and reviewing security assessments and other security-related reports. Our Director of GRC is responsible for leading security compliance, risk management, and third party governance and trust functions across our enterprise.

Our cybersecurity incident response and vulnerability management processes are designed to escalate certain cybersecurity incidents to members of management depending on the circumstances, including the CISO, CEO, COO, and other executive staff members. The CISO, CEO, COO, and other executive staff members work with the Company’s incident response team to help the Company mitigate and remediate cybersecurity incidents of which they are notified. In addition, the Company’s incident response and vulnerability management processes include reporting to the audit committee of the board of directors for certain cybersecurity incidents.

The audit committee receives periodic reports from our CISO concerning the Company’s significant cybersecurity threats and risk and the processes the Company has implemented to address them. The audit committee also has access to various reports, summaries or presentations related to cybersecurity threats, risk and mitigation. The chair of our audit committee has extensive experience serving as an executive officer and director of public and private technology companies providing oversight of cybersecurity risk.