Item 1C. CYBERSECURITY.

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Item 1C. CYBERSECURITY.

RISK MANAGEMENT AND STRATEGY

We review cybersecurity risk as part of our overall enterprise risk

management program. This ensures that cybersecurity risk

management remains a top priority in our business strategy and

operations.

MANAGEMENT'S ROLE IN MANAGING RISK

Primary management responsibility for assessing, monitoring and

managing our cybersecurity risks rests with our chief information

security officer ("CISO"). Our current CISO has over 30 years of

experience in information technology and cybersecurity in the

United States military, retail and healthcare sectors and oversees

our team of cybersecurity professionals. The CISO is regularly

informed about recent developments in cybersecurity, including

potential threats and innovative risk management techniques.

The CISO implements and oversees processes for the regular

monitoring of our information systems. We use various tools and

methodologies to manage cybersecurity risk that are tested

regularly. We also monitor and evaluate our cybersecurity

posture and performance on an ongoing basis through regular

vulnerability scans, penetration tests and threat intelligence

feeds. In addition, we engage third-party consultants to conduct

annual cybersecurity assessments and to conduct audits for

compliance with regulatory, Sarbanes-Oxley Act, Service

Organization Control Type 2 and International Organization for

Standardization standards. We also engage third parties to

assess our cybersecurity maturity and risk management

programs.

We use a cross-departmental approach to addressing

cybersecurity risk, with our cybersecurity, product security and

legal teams presenting quarterly on key topics to a committee of

leaders in technology, legal, finance, regulatory and corporate

affairs functions. This leadership committee meets quarterly to

ensure that we have input and oversight from critical

stakeholders into our cybersecurity program and evolving issues.

The CISO oversees a training and awareness program for

employees to take part in protecting the Company against

cybersecurity risks. We have implemented annual mandatory

security education to help employees understand cybersecurity

risks and comply with our cybersecurity policies. Additionally, we

provide frequent communications around pertinent cybersecurity

topics and policies to all employees. We also provide additional

cybersecurity and data protection training to employees in certain

roles.

As part of our cybersecurity risk management program, we also

conduct cybersecurity, data protection, and privacy assessments

on all third parties who integrate with Stryker’s data, network,

systems and products. We use a combination of internal and

external tools to confirm that these third parties meet our security

requirements. We leverage standard industry threat model and

privacy impact assessment concepts to confirm that data

minimization and adequate data protections are in place. We

perform supplemental reviews as necessary, commensurate with

the risk associated with each vendor.

In the event of a cybersecurity incident, we have an incident

response plan that includes immediate actions to mitigate the

impact and long-term strategies for remediation and prevention of

future incidents. The cybersecurity and product security teams

routinely practice this plan with functions across the organization.

We conduct tabletop exercises with senior management, during

which we practice the procedures in place to ensure that

potentially material cybersecurity risks and incidents are

escalated to management and the Board of Directors where

applicable.

GOVERNANCE

Cybersecurity risks are overseen by the full Board of Directors

and the Audit Committee. The Audit Committee is central to the

Board of Directors’ oversight of cybersecurity risks and bears the

primary responsibility for overseeing cybersecurity risk. The Audit

Committee actively participates in strategic decisions related to

cybersecurity, offering guidance and approval for major

cybersecurity initiatives. This involvement ensures that

cybersecurity considerations are integrated into our broader

strategic objectives.

Our CISO provides comprehensive updates to the Audit

Committee at least three times a year and the full Board of

Directors periodically. These briefings include a range of topics,

including:

  • Current cybersecurity landscape and emerging threats;

  • Status of ongoing cybersecurity initiatives and strategies;

  • Incident reports and learnings from any cybersecurity events;

  • Metrics demonstrating company and industry-standard

prevention of common threats; and

  • Regulatory changes impacting cybersecurity requirements

and strategy.

The Board of Directors is aware of the critical nature of managing

risks associated with cybersecurity threats and is actively

engaged in our cybersecurity risk management strategy.

RISKS FROM CYBERSECURITY THREATS

Although cybersecurity risks have not materially affected us,

including our business strategy, results of operations or financial

condition, to date, we face numerous and evolving cybersecurity

threats in our business. For more information about the

cybersecurity risks we face, see the risk factor entitled "We, our

business partners or our third-party vendors could experience a

material failure or breach of a key information technology system,

network, process or site" in Item 1A. Risk Factors.

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