Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
None.
Item 1C. Cybersecurity.
Our board of
directors and senior management recognize the critical importance of maintaining the trust and confidence of our clients, business partners
and employees. Our management, led by our Chief Executive Officer, is actively involved in oversight of our risk management efforts, and
cybersecurity represents an important component of the Company’s overall approach to enterprise risk management (“ERM”).
Our cybersecurity processes and practices are fully integrated into the Company’s ERM efforts. In general, we seek to address cybersecurity
risks through a cross-functional approach that is focused on preserving the confidentiality, security and availability of the information
that we collect and store by identifying, preventing and mitigating cybersecurity threats and effectively responding to cybersecurity
incidents when they occur.
Risk Management and Strategy
As one of the
critical elements of our overall ERM approach, our cybersecurity efforts are focused on the following key areas:
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Governance: Management oversees cybersecurity risk mitigation and reports to the board of directors any cybersecurity incidents.
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Collaborative Approach: We have implemented a cross-functional approach to identifying, preventing and mitigating cybersecurity threats and incidents, while also implementing controls and procedures that provide for the prompt escalation of certain cybersecurity incidents so that decisions regarding the public disclosure and reporting of such incidents can be made by management in a timely manner.
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Technical Safeguards : We deploy technical safeguards that are designed to protect our information systems from cybersecurity threats, including firewalls, intrusion prevention and detection systems, anti-virus and anti-malware functionality and access controls, which are evaluated and improved through vulnerability assessments and cybersecurity threat intelligence.
We have not engaged
third-party service providers to conduct evaluations of our security controls, independent audits or consulting on best practices to address
new challenges.
While we have not
experienced any cybersecurity threats in the past in the normal course of business, in the future, we may not be successful in preventing
or mitigating a cybersecurity incident that could have a material adverse effect on us.
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