Item 1B. Unresolved Staff Comments
Item
1B. Unresolved Staff Comments.
Not
applicable.
Item
1C. Cybersecurity.
We
are committed to our goal to protect sensitive business-related and personal information, as well as our information systems. Although
the size and scope of our operations is limited compared to larger global operations, we are subject to numerous and evolving cybersecurity
risks that could adversely and materially affect our business, financial condition and results of operations. In that regard, we have
increased our investment in information systems by upgrading outsourced services and technology platforms previously utilized.
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Our
Management Leadership Team, with oversight from the Board of Directors, has implement ed a comprehensive cybersecurity program, including
incident response process, aligned with the National Institute of Standards and Technology (NIST) Cybersecurity Framework and NIST Computer
Security Incident Handling Guide (NIST SP 800-61) to assess, identify, address and manage risks from cybersecurity threats that may result
in material adverse effects on the confidentiality, integrity and availability of our business and information systems.
Our
Chief Financial Officer has operational responsibility for oversight of our outsourced information technology services, our information
security programs, protections, and efforts, along with leading efforts for implementing, monitoring, and maintaining cybersecurity and
data security strategy, policy, standards, architecture, and practices across our business. We anticipate that our outsourced services
will update the Chief Financial Officer and Chief Executive Officer on these matters and work closely with these Senior Executives to
oversee compliance with legal, regulatory, and contractual security requirements with the guidance of outside counsel.
Our
Board, in coordination with the Audit Committee, will oversee the Company’s enterprise risks arising from cybersecurity threats
and will periodically review the measures we have implemented to identify and mitigate data protection and cybersecurity risks. We have
a Cybersecurity Incident Response Plan (“CSIRP”) to provide the organizational and operational structure, processes, and
procedures for investigating, containing, documenting and mitigating cybersecurity incidents. We have implemented a risk-based approach
to identifying, preventing and mitigating cybersecurity threats and incidents, while also implementing controls and procedures that provide
for the prompt escalation of certain cybersecurity incidents so that decisions regarding the public disclosure and reporting of such
incidents can be made by management in a timely manner.
We
also rely on information technology and third-party vendors to support our operations, including our secure processing of personal, confidential,
sensitive, proprietary and other types of information. Despite ongoing efforts to continuously improve our and our vendors’ ability
to protect against cyber incidents, we may not be able to protect all information systems, and such incidents may lead to reputational
harm, revenue and customer loss, legal actions, statutory penalties, among other consequences. While we have not experienced any material
cybersecurity threats or incidents in recent years, there can be no guarantee that we will not be the subject of future threats or incidents.
Additional information on cybersecurity risks we face can be found in Item 1A, Risk Factors , which should be read in conjunction
with the foregoing information.