Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS.
None.
ITEM 1C. CYBERSECURITY
Risk Management and Strategy
We acknowledge 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. While we are in the process of enhancing our cybersecurity practices, we
are committed to continually improving and adapting to evolving threats to maintain a high standard of protection.
Managing Material Risks and Integrated Overall
Risk Management
We have developed and implemented
a cybersecurity program that seeks to ensure the confidentiality, integrity , and availability of our information assets, including its
critical systems. We use information security management standards like ISO 27001 as a guide to help us identify, assess, and manage cybersecurity
risks relevant to our business.
We are actively integrating
cybersecurity risk management into our broader enterprise risk management framework. This integration is designed to promote a company-wide
culture of cybersecurity awareness and risk management. Our risk management team, in collaboration with external consultants, is assessing
and addressing cybersecurity risks in alignment with our operational and business needs. This ongoing integration ensures that cybersecurity
considerations are increasingly embedded in our decision-making processes at every level.
Our cybersecurity framework
draws upon the National Institute of Standards and Technology (“NIST”) cybersecurity framework, which provides guidance for
identifying, assessing, and managing cybersecurity risks. While we are in the early stages of fully implementing this framework, we are
committed to following its principles as we strengthen our cybersecurity measures to protect both our digital and physical assets.
Engage Third-parties on Risk Management
Recognizing the evolving nature
of cybersecurity threats, we have been engaging with external experts, including cybersecurity assessors, consultants, and auditors, to
assess and enhance our risk management systems. These third parties are assisting us with evaluating our cybersecurity posture, recommending
improvements, and advising on the implementation of best practices. As we progress, we will continue leveraging these external insights
to enhance our cybersecurity strategies and ensure alignment with industry standards.
Oversee Third-party Risk
We understand the potential
risks associated with third-party service providers, and we are working on implementing stronger oversight processes. While we have initiated
security assessments for our third-party providers, we are in the process of enhancing these efforts to include more frequent evaluations
and ongoing monitoring. This will help mitigate the risk of security incidents originating from third parties.
Risks from Cybersecurity Threats
To date, we have not encountered
cybersecurity incidents that have materially impaired our operations or financial position. However, we are proactively preparing for
the possibility of cybersecurity risks, ensuring that our systems are protected against potential threats in the future.
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Governance
Our board of directors understands
the critical nature of cybersecurity and is closely involved in overseeing our efforts to mitigate cybersecurity risks. We are in the
process of formalizing governance structures and oversight mechanisms to ensure that these risks are managed effectively, with the aim
of strengthening our operational integrity and enhancing stockholder confidence.
Management’s Role Managing Risk
The Chief Executive Officer
(“CEO”), Chief Operating Officer (“COO”), and Chief Financial Officer (“CFO”) are actively involved
in managing cybersecurity risks. They receive regular updates, which include an overview of the current cybersecurity landscape, the status
of ongoing initiatives, and compliance with regulatory requirements. We are establishing structured processes for ongoing communication
among the executive team to ensure they remain informed and involved in key cybersecurity decisions.
Risk Management Monitoring
We are committed to monitoring
cybersecurity risks and are in the process of implementing enhanced monitoring systems. With the assistance of cybersecurity consultants,
we are refining our cybersecurity policies and controls, including regular audits and the deployment of advanced security measures such
as Multi-Factor Authentication (“MFA”) and stronger email filtering protocols. In addition, we are continuing to develop incident
response plans, communication protocols, and disaster recovery plans to be prepared for any potential cybersecurity incidents.
Security Training
We are providing cybersecurity
training to our employees and plan to continue enhancing this program on an ongoing basis. Regular updates and internal campaigns will
ensure that our employees are well-prepared to identify and respond to cybersecurity threats in an effective manner.
Reporting to Board of Directors
The COO regularly informs
the CEO and CFO on cybersecurity risks and initiatives. Significant cybersecurity matters will be escalated to the audit committee for
review, where management will provide detailed updates on risk assessments, incident response, and the effectiveness of our cybersecurity
strategies. The audit committee will continue to evaluate the progress of our cybersecurity initiatives and offer guidance to help strengthen
our efforts.