Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
Not
Applicable.
ITEM
1C, Cybersecurity
Cybersecurity
Management and Strategy
In
the ordinary course of our business, we collect, use, store, and transmit confidential, financial, sensitive, proprietary, personal,
and health-related information. The secure maintenance of this information and our information technology systems is important to our
operations and business strategy. To this end, we consider cybersecurity, along with other significant risks that we face, within our
overall enterprise risk management framework, and have implemented processes designed to assess, identify, and manage risks from potential
unauthorized occurrences on or through our information technology systems that may result in adverse effects on the confidentiality,
integrity, and availability of these systems and the data residing therein. These processes are managed and monitored by a dedicated
Director of Information Technology and an Information Technology Security and Risk Manager. We have developed a cybersecurity program
following the National Institute of Standards and Technology (“NIST”) cybersecurity framework that include mechanisms, controls,
technologies, and systems designed to prevent or mitigate data loss, theft, misuse, or other security incidents or vulnerabilities affecting
the data and maintain a stable information technology environment. For example, we conduct penetration and vulnerability testing, and
data recovery testing on a periodic basis. In addition, we consult with outside advisors and experts, when appropriate, to assist with
assessing, identifying, and managing cybersecurity risks, including to anticipate future threats and trends, and their impact on the
Company’s risk environment.
Third-Party
Risk Management
We
have processes to evaluate third-party service providers and vendors that have access to sensitive systems and company data, which may
include due diligence procedures such as assessments of that service provider’s cybersecurity posture or a recommendation of specific
mitigation controls. Following an assessment, we determine and prioritize service provider risk based on potential threat impact and
likelihood, and such risk determinations drive the level of due diligence and ongoing compliance monitoring required for each service
provider.
Education
and Awareness
We
also provide cybersecurity training to our employees and are formalizing an ongoing information security training program for active
employees and relevant consultants to address matters such as phishing, email security, social engineering and training on data privacy.
Governance
Our
Director of Information Technology, who reports to our CFO, and the Information Technology Security and Risk Manager are responsible
for assessing and managing cybersecurity risks. Our Director of Information Technology has over 25 years of experience managing information
technology and cybersecurity. He has a bachelor’s degree in electrical engineering from Wright State University as well as a master’s
degree in business administration from Ashland University. He has certifications from various information technology vendors as well
as experience in implementing security frameworks such as International Organization for Standardization (“ISO”) 27001 and
NIST. Our Information Technology Security and Risk Manager has a PhD in a scientific field and various information security certifications
such as Certified Ethical Hacker (“CEH”) and Holistic Information Security Practitioner (“HISP”). She also has
decades of experience in managing information technology environments and information security such as security architecture, security
operations and governance risk and compliance.
We
report on our information security program, including the results of periodic testing, to the Audit Committee of the Board of Directors
on a quarterly basis. Our Board’s Audit Committee is responsible for overseeing our cybersecurity and information security procedures.
The Audit Committee reviews management presentations concerning cybersecurity-related issues, including information security, technology
risks, policies, and risk mitigation programs. The Audit Committee reports matters to the Board of Directors as needed. Our CFO, with
the support of our Director of Information Technology, Information Technology Security and Risk Manager and third-party consultants,
assesses and manages cybersecurity risk, including preventing, mitigating, detecting, and addressing cybersecurity incidents, if any.
Our CFO also works closely with other management positions and external legal counsel to ensure that we understand our cybersecurity
risk management responsibilities. In case of a cybersecurity incident or breach, our incident response plan defines in detail reporting
and escalation processes to management and the Board of Directors.
55
Current
Cybersecurity Risk Posture
We
have not identified any cybersecurity incidents or threats that have materially affected us or are reasonably likely to materially affect
us. However, like other companies in our industry, we and our third-party vendors have from time-to-time experienced threats to and security
incidents relating to information systems. Additional information on cybersecurity risks we face is discussed in Part I, Item 1A, “Risk
Factors,” under the heading “Risks related to cybersecurity.”