Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
Not
Applicable.
ITEM
1C. CYBERSECURITY
Risk
Management and Strategy
We
recognize the importance of assessing, identifying, and managing material risks associated with cybersecurity threats, as such term is
defined in Item 106(a) of Regulation S-K. To identify and assess material risks from cybersecurity threats, our enterprise risk management
program considers cybersecurity risks alongside other company risks as part of our overall risk assessment process. Our cybersecurity
risk management strategy prioritizes (i) detection, analysis, and response to known, anticipated, or unexpected threats, (ii) effective
management of security risks, and (iii) resiliency against incidents.
We
have implemented several cybersecurity processes, technologies, and controls to aid in our efforts to assess, identify, and manage material
risks associated with cybersecurity threats. Such processes include technical security controls, policy enforcement mechanisms, monitoring
systems, employee training, contractual arrangements, tools and related services from third-party providers, and management oversight.
Our
risk-based control principles are based on the standards set by the National Institute of Standards and Technology (NIST), other industry-recognized
standards, and contractual requirements, as applicable. Through these controls, we seek to maintain an information technology infrastructure
that implements physical, administrative, and technical controls that are calibrated based on risk and designed to protect the confidentiality,
integrity, and availability of our information systems and information stored on our networks.
As
part of our cybersecurity risk management strategy, we periodically engage with consultants, auditors, and other third parties to help
identify areas for continued focus, improvement, and compliance. We also incorporate cybersecurity risk management considerations in
our processes for selecting, evaluating, and overseeing third-party providers.
In
the last fiscal year, we have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity
incidents, that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of
operations, or financial condition.
Governance
The
Audit Committee of our Board of Directors is responsible for board-level oversight of risks from cybersecurity threats, and the Audit
Committee reports back to the full Board of Directors about this and other areas within its responsibility. As part of its oversight
role, the Audit Committee receives reporting about our cybersecurity risk management and strategy processes covering topics such as data
security, results from third-party assessments, progress towards cybersecurity risk management goals, our incident response plan, notable
threats or incidents, and other developments related to cybersecurity, including through periodic updates from the Company’s CEO,
other management team members, and consultants.
Our
cybersecurity risk management and strategy processes are led by Gerbrand van Heerden (CFO). Such individual has over 20
years of prior work experience in various roles involving managing information security, developing cybersecurity strategy, implementing
effective information and cybersecurity programs, as well as several relevant degrees and certifications.
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