Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
Not applicable.
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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
Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.