Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
None
ITEM 1C. CYBERSECURITY.
Risk Management and
Strategy
The Company’s policies and
practices are based on frameworks and standards that address risks through a comprehensive, cross-functional approach that assess,
identify, monitor, and mitigate material risks from cybersecurity threats as part of the overall enterprise risk management
(“ERM”) process. This includes the collection and storage of data, and being responsive to incidents as they occur. Further,
the Company’s processes and technology are utilized to develop, implement, and maintain appropriate measures to safeguard information
systems in protecting the integrity, availability, and confidentiality of data. Additionally, the Company engages certain third parties
to assist in network monitoring and control testing, among other functions of similar capacity.
The Company’s
cybersecurity program focuses on the following areas:
● Technological safeguards that are designed to protect the Company’s information systems from cybersecurity threats, including the prevention and detection of systems, access controls, and firewalls, which the Company assesses the vulnerability and cybersecurity threat and makes necessary improvements.
● Utilization of third parties as part of the Company’s risk-based approach in identifying and overseeing cybersecurity risks.
● The Company maintains an incident plan that addresses the Company’s response to a cybersecurity event, which is periodically reviewed and updated.
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While the Company is working
to adopt the National Institute of Standards and Technology (“NIST”) cybersecurity framework, the Company’s on-going investment
in information systems and utilization of external 3rd parties represents the best means for extensively testing both the design
and operational effectiveness of cybersecurity controls, and to ensure continuity and functionality of the Company’s operating systems.
As of the date of this report, the
Company has not experienced any material cybersecurity events. However, the presence of new or more advanced forms of cybersecurity
threats could have a material and adverse impact on the business, results of operations, and financial position. For further
discussion relating to this topic, see Item 1A. Risk Factors “The Company’s information technology systems may be negatively
affected by cybersecurity threats. ”
Governance
The Audit Committee of the
Board of Director’s has the responsibility of overseeing the Company’s cybersecurity risks. The Chief Financial Officer provides
periodic updates to the Board of Director’s regarding actions taken to mitigate the Company’s exposure and protection to cybersecurity
risks. Management routinely evaluates the Company’s security processes, procedures, and systems to determine if enhancements are needed
to reduce the possibility of a future cybersecurity event. This includes safeguards implemented by the Company, such as a multi-factor
authentication process for remote access to systems; restricted firewall settings; network monitoring, email phishing tests, and
enhancing the Company’s backup recovery strategy, among others.
The IT Director is responsible
for assessing, monitoring, and managing the Company’s cybersecurity risks.
The IT Director, along with
members of management, inform the Audit Committee on cybersecurity risks by providing periodic updates regarding (i) Status of ongoing
cybersecurity initiatives and strategies, (ii) The overall state of the Company’s security program and potential exposure to risks, and
(iii) Incident reports and learning from any cybersecurity events. Further, the IT Director maintains an open dialog regarding any
significant developments in cybersecurity risks, ensuring the Audit Committee’s oversight is proactive and responsive.
In addition to periodic updates
to the Audit Committee, the IT Director, in his capacity, regularly informs the Chief Executive Officer (“CEO”) and the Chief
Financial Officer (“CFO”) regarding matters related to cybersecurity risks and incidents. This ensures the highest level
of management are informed of potential risks associated with cybersecurity that could have a material and adverse effect on the
Company.
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