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.
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.