Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
5
ITEM 1C. CYBERSECURITY
CYBERSECURITY
The
Company employs several strategies for assessing, identifying, and managing material risks from cybersecurity threats. Components of
this strategy include the use of industry standard traffic monitoring tools, and training users to detect, report, and prevent unusual
behavior.
Through
our IT consulting firm, we employ continuous monitoring mechanisms to detect and respond to cybersecurity threats promptly. Regular reports
are generated as needed for management and the board, providing insights into our cybersecurity posture, incidents, and remediation efforts.
We conduct regular assessments and testing to ensure the effectiveness of these controls, especially those related to the protection
of financial information. The implementation and management of these processes are integrated with the Company’s overall operational
risk management processes that seeks to limit our exposure to unnecessary risks across our operations.
Our
cybersecurity program is overseen by the Chief Financial Officer (CFO), who reports directly to the Chief Executive Officer (CEO) and
updates the Board of Directors on cybersecurity matters.
Our
employees receive regular training on cybersecurity best practices, emphasizing the protection of financial information. We foster a
culture of cybersecurity awareness and responsibility throughout the organization.
We
maintain a comprehensive incident response plan that outlines the steps to be taken in the event of a cybersecurity incident. This plan
includes procedures for promptly reporting material incidents to the SEC, as required, and for communicating with affected stakeholders.
Upon discovery of a cybersecurity incident, the identifying party immediately notifies the Company’s CFO. The CFO activates the
incident response plan to include the following:
●
Gather
preliminary information about the cybersecurity incident.
●
CFO
notifies the CEO and the Board of Directors of the cybersecurity threat.
●
The
CFO allocates resources for disclosure if determined to be a material cybersecurity event.
●
The
CFO consults with cybersecurity consultants and other involved parties to identify the undesirable effects of the cybersecurity incident.
●
The
CFO develops a recommendation for determination of materiality.
●
If
disclosure is required, the material incident disclosure plan is executed by the CFO.
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