Unresolved Staff Comments.
−Removed: We have received no written comments regarding
−Removed: our periodic or current reports from the staff of the Securities and Exchange Commission that were issued 180 days or more preceding
−Removed: the end of our 2024 fiscal year and that remain unresolved.
+Added: We have received no written
+Added: comments regarding our periodic or current reports from the staff of the Securities and Exchange Commission that were issued 180 days
+Added: or more preceding the end of our 2025 fiscal year and that remain unresolved.
Cybersecurity.
4 unchanged sentences
Our cybersecurity framework is rooted in the National Institute
−Removed: of Standards and Technology, or NIST, Cybersecurity Framework, or CSF, as well as the International Organization for Standardization
−Removed: (ISO/IEC 27001), reflecting our commitment to uphold the highest cybersecurity standards.
−Removed: We align our policies, standards and practices
−Removed: with these benchmarks and dynamically refine them to address evolving cybersecurity threats.
+Added: of Standards and Technology, or NIST, Cybersecurity Framework, or CSF, as well as the International Organization for Standardization and
+Added: the International Electrotechnical Commission (ISO/IEC 27001), reflecting our commitment to uphold the highest cybersecurity standards.
+Added: We align our policies, standards and practices with these benchmarks and dynamically refine them to address evolving cybersecurity threats.
Risk Management and Strategy
2 unchanged sentences
cybersecurity events, respond effectively to mitigate their impact and recover from incidents to restore services.
−Removed: Our cybersecurity
−Removed: program is designed to safeguard the confidentiality, integrity and availability of information.
−Removed: Our cybersecurity risk management strategy
+Added: Our cybersecurity program
+Added: is designed to safeguard the confidentiality, integrity and availability of information.
+Added: Our cybersecurity risk management strategy includes:
● Governance:
The Audit Committee of our Board of Directors oversees our cybersecurity risk management.
−Removed: Our Chief Financial Officer and Director of Information Technology, along with key executives,
−Removed: have roles in governance and facilitating alignment across our organization.
−Removed: and Standards:
−Removed: We design our cybersecurity program for compliance with industry-specific
−Removed: and other regulations (e.g., the General Data Protection Regulation (GDPR) and the California
−Removed: Consumer Privacy Act (CCPA)) demonstrating our commitment to both domestic and international
−Removed: information security standards.
+Added: Our Chief Financial Officer
+Added: and Director of Information Technology, along with key executives, have roles in governance and facilitating alignment across our organization.
+Added: ● Compliance and Standards:
+Added: We design our cybersecurity program for compliance with industry-specific and other regulations (e.g.,
+Added: the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA)) demonstrating our commitment to both domestic
+Added: and international information security standards.
Technical Safeguards
3 unchanged sentences
measures based on our ongoing assessments, including cybersecurity threat intelligence updates.
−Removed: Response and Recovery Planning:
−Removed: We maintain incident response and recovery frameworks,
−Removed: tested twice yearly through backup restorations to critical systems, to improve our preparedness
−Removed: to effectively manage and mitigate cybersecurity incidents.
−Removed: and Awareness:
−Removed: Our personnel and members of our Board of Directors undergo mandatory
−Removed: periodic training on cybersecurity threats, with updated insights into effective defense
−Removed: mechanisms and our evolving cybersecurity policies and practices.
+Added: ● Incident Response and Recovery Planning:
+Added: We maintain incident response and recovery frameworks, tested twice yearly through
+Added: backup restorations to critical systems, to improve our preparedness to effectively manage and mitigate cybersecurity incidents.
+Added: ● Education and Awareness:
+Added: Our personnel and members of our Board of Directors undergo mandatory periodic training on cybersecurity
+Added: threats, with updated insights into effective defense mechanisms and our evolving cybersecurity policies and practices.
● Use of Third Parties :
−Removed: We collaborate with external cybersecurity service providers, including auditors, consultants and governmental agencies, to refine our cybersecurity measures.
−Removed: These service providers carry out cybersecurity risk evaluations such as periodic assessments and vulnerability scans to pinpoint potential security flaws and suggest enhancements.
−Removed: In addition, we employ third-party technology and other solutions to enhance our protection against cybersecurity risks.
−Removed: These solutions include our use of a managed security service provider to support our in-house technology team, an endpoint detection and response, or EDR, system for ongoing surveillance, detection, and action against threats, as well as a security information and event management, or SIEM, system designed to automate the real time identification, investigation and prioritization of critical alerts.
+Added: We collaborate with external cybersecurity service providers, including
+Added: auditors, consultants and governmental agencies, to refine our cybersecurity measures.
+Added: These service providers carry out cybersecurity
+Added: risk evaluations such as periodic assessments and vulnerability scans to pinpoint potential security flaws and suggest enhancements.
+Added: addition, we employ third-party technology and other solutions to enhance our protection against cybersecurity risks.
+Added: These solutions
+Added: include our use of a managed security service provider to support our in-house technology team, an endpoint detection and response, or
+Added: EDR, system for ongoing surveillance, detection, and action against threats, as well as a security information and event management, or
+Added: SIEM, system designed to automate the real time identification, investigation and prioritization of critical alerts.
● Third-Party Risk Management:
−Removed: We use a comprehensive due diligence process to manage third-party risks, emphasizing continuous monitoring and to ensure our business partners’ cybersecurity practices meet our stringent standards.
+Added: We use a comprehensive due diligence process to manage third-party risks, emphasizing continuous
+Added: monitoring and to ensure our business partners’ cybersecurity practices meet our stringent standards.
As of the filing of this report, we do not believe
2 unchanged sentences
● We take a comprehensive and forward-looking approach to cybersecurity risk management under the oversight of our Audit Committee.
−Removed: Management, including our Chief Financial Officer and our Director of Information Technology, provide regular updates to ensure a strategic, unified response to cybersecurity challenges.
−Removed: Management is notified of, and monitors, cybersecurity incidents through our EDR and SIEM systems.
−Removed: ● Our Director of Information Technology has over 20 years of experience in information technology and five years of experience serving directly as a Chief Information Security Officer for other organizations.
−Removed: networks and systems are continuously monitored by a combination of third-party service providers
−Removed: and an internal cybersecurity team.
+Added: Management, including our Chief Financial Officer and our Director of Information Technology , provide regular updates to ensure a strategic,
+Added: unified response to cybersecurity challenges.
+Added: Management is notified of, and monitors, cybersecurity incidents through our EDR and SIEM
+Added: ● Our Director of Information Technology has over 20 years of experience in information technology and five years of experience serving
+Added: as a Virtual Chief Information Security Officer for other organizations.
+Added: ● Our networks and systems are continuously monitored by a combination of third-party service providers and an internal cybersecurity
Management is promptly notified of cybersecurity incidents.
−Removed: Audit Committee is promptly notified by our management of any material cybersecurity breach.
−Removed: Board of Directors is briefed at least quarterly on the state of our cybersecurity program.
−Removed: internal cybersecurity team collaborates with external cybersecurity service providers, including
−Removed: auditors, consultants and governmental agencies, to refine our cybersecurity measures.
−Removed: service providers carry out cybersecurity risk evaluations such as periodic assessments and
−Removed: vulnerability scans to pinpoint potential security flaws and suggest enhancements.
+Added: ● Our Audit Committee is promptly notified by our management of any material cybersecurity breach.
+Added: ● Our Board of Directors is briefed at least quarterly on the state of our cybersecurity program.
+Added: ● Our internal cybersecurity team collaborates with external cybersecurity service providers,
+Added: including auditors, consultants and governmental agencies, to refine our cybersecurity measures.
+Added: These service providers carry out cybersecurity
+Added: risk evaluations such as periodic assessments and vulnerability scans to pinpoint potential security flaws and suggest enhancements.
Engagement and Continuous Improvement
4 unchanged sentences
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.