Item 1B. Unresolved Staff Comments
ITEM 1B. Unresolved Staff Comments
Not applicable.
ITEM 1C. Cybersecurity
We recognize the importance
of identifying, assessing, and managing material risks from cybersecurity threats, as defined in Item 106(a) of Regulation S-K. Our risk
management program is designed to detect, evaluate, and mitigate cybersecurity risks, and is informed by applicable laws, regulations,
and industry best practices.
Our Chief Executive Officer
oversees our cybersecurity program and leads our incident response efforts. The incident response team is cross-functional, drawing members
from cybersecurity, IT support, mining operations, software engineering, compliance, legal, contractors, and partners.
When a potential incident
is detected, the cybersecurity team validates it before escalating to the incident response team for triage. Significant incidents are
escalated to executive management. Response actions such as allocating resources, setting priorities, creating action plans, and notifying
external parties are directed by the Chief Executive Officer in coordination with the cross-functional working group. We also consult
outside counsel on materiality assessments and disclosure decisions, with executive management making the final determinations.
In 2025, we did not identify
any cybersecurity threats that materially affected, or are reasonably likely to materially affect , our strategy, operations, or financial
condition. However, no program can eliminate all risks, and we cannot guarantee that undetected incidents have not occurred. See Part
I, Item 1A. “Risk Factors” of this Annual Report for further details.
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