Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
Not applicable.
Item 1C. Cybersecurity.
The Sponsor recognizes the importance of managing
cybersecurity risks to protect its business operations, clients, and stakeholders. The Sponsor has implemented a comprehensive Cybersecurity
Policies and Procedures Plan applicable to the Funds, which outlines the Sponsor’s approach to identifying, assessing, and mitigating
cybersecurity threats and vulnerabilities in alignment with industry standards and best practices.
Risk Management and Strategy
Cybersecurity Risk Assessment and Management :
The Sponsor has established a risk-based cybersecurity framework for the Funds to manage cybersecurity risks. This framework includes
regular assessments of its information systems, physical and virtual infrastructure, and the data therein, to identify potential cybersecurity
threats and vulnerabilities. This cybersecurity strategy is integrated into the Funds’ overall risk management processes, with specific
consideration given to the confidentiality, integrity, and availability of our information systems.
Third-Party Service Providers : The Sponsor
engages with various third-party service providers for critical operations and services. The Sponsor conducts cybersecurity risk assessments
of all vendors and business partners with access to our networks or sensitive information. These assessments ensure that third-party cybersecurity
policies align with our cybersecurity standards.
Material Impact of Cybersecurity Threats :
To date, there have been no known material cybersecurity incidents that have significantly impacted the Funds’ business strategies,
results of operations, or financial condition. The Sponsor continues to monitor systems and processes to mitigate potential cybersecurity
risks actively.
Governance
Sponsor Oversight : The Sponsor has a fundamental
role in overseeing the Funds’ cybersecurity risk management. The Sponsor receives regular updates on cybersecurity matters from
management and third-party service providers, ensuring that cybersecurity risks are managed proactively at the highest level of the organization.
Management’s Role : The Sponsor’s Chief Compliance Officer is responsible for overseeing the
development, implementation, and ongoing management of the Fund’s Cybersecurity Policies and Procedures including the monitoring
of our systems for potential cybersecurity events and the implementation of preventive and mitigative measures.
Item 2. Properties.
Not applicable.
Item 3. Legal Proceedings
Although the Funds may, from time to time, be
involved in litigation arising out of their operations in the normal course of business or otherwise, the Funds are currently not a party
to any pending legal proceedings.
Item 4. Mine Safety Disclosures.
Not applicable.
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Part II