UNRESOLVED STAFF COMMENTS.
+Added: Not applicable.
CYBERSECURITY.
−Removed: We maintain a cybersecurity risk management program and related policies and processes to identify, assess and manage material risks from cybersecurity threats.
−Removed: Our program includes working groups responsible for the monitoring of and response to threats.
−Removed: Security workgroups assess and monitor risk posture by continuously evaluating IT infrastructure, deploying security information and event management software tools, and enforcing an assortment of other IT security controls.
−Removed: We communicate regularly with partner contractors and agencies to support risk management, threat monitoring, and incident response efforts.
−Removed: Our Tellenger subsidiary engages consultants for security assessments and quality system reviews to provide feedback on existing processes and recommend improvements.
−Removed: Additionally, Tellenger has completed numerous assessments for contract and Federal compliance of our internal systems and the systems we work on.
−Removed: To date, cybersecurity threats have not materially affected our Company, including our business strategy, results of operations or financial condition.
−Removed: We are unaware of any ongoing or previous cybersecurity incidents.
−Removed: The Chief Executive Officer, with assistance from other members of management, is responsible for managing our cybersecurity program, policies and strategy.
−Removed: Our Board of Directors is responsible for overseeing the management of cybersecurity risks, including the review of, as required, our processes around the management and monitoring of such risks.
+Added: Risk Management and Strategy
+Added: The Company recognizes the critical importance of developing, implementing, and maintaining robust cybersecurity measures to safeguard our information systems and protect the confidentiality, integrity, and availability of our data.
+Added: We have developed the following processes as part of our strategy for assessing, identifying, and managing material risks from cybersecurity threats.
+Added: Managing Material Risks and Integrated Overall Risk Management
+Added: We have integrated cybersecurity risk management into our risk management processes.
+Added: This integration is intended to ensure that cybersecurity considerations are part of our decision-making processes.
+Added: We continuously evaluate and address cybersecurity risks in alignment with our business objectives and operational needs.
+Added: Engaging Third Parties on Risk Management
+Added: We engage a range of external experts, including consultants, auditors, and cybersecurity assessors, who assist us in evaluating and testing our cybersecurity systems and processes.
+Added: These partnerships are intended to give us access to specialized knowledge and insights that can inform our cybersecurity strategies and processes, including as to industry-standard control frameworks and applicable regulations, laws, and standards.
+Added: Overseeing Third-Party Risk
+Added: As part of our evolving cybersecurity roadmap, we plan to implement and conduct security assessments of all third -party service providers before engagement and maintain ongoing monitoring to ensure compliance with relevant cybersecurity standards.
+Added: Risks from Cybersecurity Threats
+Added: We have not experienced any material cybersecurity incidents.
+Added: As a result, we do not believe that risks from cybersecurity threats, have materially affected us, our results of operations and financial condition.
+Added: However, as discussed under “Risk Factors” in Part I, Item 1A of this Annual Report, cybersecurity threats pose multiple and potentially material risks to us, including potentially to our results of operations and financial condition.
+Added: See also “Risk Factors — Failure to protect our information technology infrastructure against cyber-based attacks, network security breaches, service interruptions, or data corruption could significantly disrupt our operations and adversely affect our business strategy and operating results.” As cybersecurity threats become more frequent, sophisticated, and coordinated, it is reasonably likely that we may expend greater resources to continue to modify and enhance protective measures against such security risks
+Added: Board of Directors Oversight
+Added: Our board of directors oversees the management of risks associated with cybersecurity threats.
+Added: Management ’ s Role Managing Risk
+Added: The Company’s management is primarily responsible for assessing, monitoring and managing our cybersecurity risks.
+Added: Management must ensure that all industry standard cybersecurity measures are functioning as required to prevent or detect cybersecurity threats and related risks.
+Added: Management oversees and tests our compliance with standards, remediates known risks, and leads our employee training program.
+Added: Monitoring Cybersecurity Incidents
+Added: The Company’s management is continually informed about the latest developments in cybersecurity, including potential threats and innovative risk management techniques.
+Added: Management implements and oversees processes for the regular monitoring of our information systems.
+Added: This includes the deployment of industry-standard security measures and regular system audits to identify potential vulnerabilities.
+Added: In the event of a cybersecurity incident, management will implement an incident response plan.
+Added: This plan includes immediate actions to mitigate the impact and long-term strategies for remediation and prevention of future incidents.
+Added: Reporting to Board of Directors
+Added: Significant cybersecurity matters, and strategic risk management decisions, will be escalated to the board of directors .
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.