Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
Not
applicable.
ITEM
1C. CYBERSECURITY
Risk
Management and Strategy
Securing
our business information, intellectual property, customer and employee data and technology systems is essential for the continuity of
our business, meeting applicable regulatory requirements and maintaining the trust of our stockholders. Cybersecurity is an important
and integrated part of our enterprise risk management function that identifies, monitors and mitigates business, operational and legal
risks.
To
help protect us from a major cybersecurity incident that could have a material impact on operations or our financial results, the Company
is in the process of continually implementing policies, programs and controls, including technology investments that focus on cybersecurity
incident prevention, identification and mitigation. The steps we expect to take to reduce our vulnerability to cyberattacks and to mitigate
impacts from cybersecurity incidents include but are not limited to: penetration testing by a third-party vendor, agent-based security
scanning that runs continuously, establishing information security policies and standards, implementing information protection processes
and technologies, monitoring our information technology systems for cybersecurity threats and implementing cybersecurity training. The
Company has reached SOC 2 Type 2 status which shows the Company’s compliance with best industry practices. The SOC 2 Report has
become a benchmark standard, and now an often-specified requirement, in the software procurement process. Established by the American
Institute of Certified Public Accountants (AICPA), criteria and reporting principles are outlined as a means for organizations to create
a documented framework of policies and procedures to prove how they manage and secure data in the cloud and ensure protection of customer
privacy and ensure internal communications are suitably handled. This achievement reflects the Company’s stated goals of best-in-class
data protection and internal processes. In addition, we annually purchase a cybersecurity risk insurance policy that would help defray
the costs associated with a covered cybersecurity incident if it occurred.
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Table of Contents
Governance
Our
CEO and management are actively engaged in overseeing and reviewing our strategic direction and objectives, taking into account, among
other considerations, our risk profile and related exposures, including oversight of risks from cybersecurity threats. As part of this
oversight, the Company will update the CEO and Board of Directors periodically, and at least annually, on our cybersecurity program,
including with respect to particular cybersecurity threats, cybersecurity incidents, new developments in our risk profile, the status
of projects to strengthen our cybersecurity systems, assessments of our cybersecurity program, and the emerging threat landscape.
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