UNRESOLVED STAFF COMMENTS
−Removed: Not applicable.
CYBERSECURITY
8 unchanged sentences
in our Risk Factors , and have integrated these processes into our overall risk management systems and processes.
−Removed: We have devoted financial
−Removed: and personnel resources to implement and maintain security measures to meet regulatory requirements and stakeholder expectations, and
−Removed: we intend to continue to make investments as may be required to maintain the security of our data and cybersecurity infrastructure.
−Removed: there can be no guarantee that our policies and procedures will be properly followed in every instance or that those policies and procedures
−Removed: will be effective, we believe that the Company’s sustained investment in people and technologies has contributed to a culture of
−Removed: continuous improvement that has put the Company in a position to protect against potential compromises.
+Added: We have devoted
+Added: financial and personnel resources to implement and maintain security measures to meet regulatory requirements and stakeholder expectations,
+Added: and we intend to continue to make investments as may be required to maintain the security of our data and cybersecurity infrastructure.
+Added: While we cannot guarantee complete effectiveness of our cybersecurity measures despite our best efforts and continuous monitoring, we
+Added: believe that the Company’s sustained investment in people and technologies has contributed to a culture of continuous improvement
+Added: that has put the Company in a position to protect against potential compromises.
of the date of this report, we are not aware of any cybersecurity threats, including as a result of any previous cybersecurity incidents,
9 unchanged sentences
that we use the NIST CSF as a guide to help us identify, assess, and manage cybersecurity risks relevant to our business.
+Added: Our cybersecurity
+Added: program is an integral part of our broader Enterprise Risk Management (ERM) framework and business continuity efforts.
+Added: By incorporating
+Added: cybersecurity into our overall risk assessment and management processes, we aim to address interconnected risks that could impact critical
+Added: operations, systems, and assets.
+Added: This alignment allows us to proactively evaluate and prioritize cybersecurity risks in the context of
+Added: broader organizational objectives and resilience planning, ensuring a comprehensive approach to safeguarding the Company’s infrastructure
+Added: and stakeholders.
key objectives for the Company’s cybersecurity program are to implement and sustain effective security controls to stop intrusion
38 unchanged sentences
to our senior management any irregular or suspicious activity that could indicate a cybersecurity threat or incident.
−Removed: senior management team, led by our Chief Financial Officer and Chief Technology Officer, is responsible for assessing and managing our
+Added: senior management team, led by our Chief Financial Officer and Chief Operating Officer, is responsible for assessing and managing our
material risks from cybersecurity threats.
3 unchanged sentences
and alerts and reports produced by security tools deployed in the IT environment.
−Removed: Audit Committee of our Board of Directors considers cybersecurity risks and other information technology risks as part of its risk oversight
−Removed: function and evaluates our risk assessment and management policies, including periodic discussions with our senior officers.
−Removed: management updates the Board of Directors, as necessary, regarding any material cybersecurity incidents, as well as any incidents with
−Removed: lesser impact potential.
−Removed: Our Audit Committee also meets at least quarterly with our independent registered accounting firm and communicates
−Removed: with them regarding any cybersecurity-related risks.
+Added: Audit Committee considers cybersecurity risks and other information technology risks as part of its risk oversight function and evaluates
+Added: our risk assessment and management policies, including periodic discussions with our senior officers.
+Added: In addition, management updates
+Added: the Board of Directors , as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential.
+Added: Our Audit Committee also meets at least quarterly with our independent registered accounting firm and communicates with them regarding
+Added: any cybersecurity-related risks.
of the date of this report, the Company did not have any owned or leased properties.
1 unchanged sentence
time to time, we are party to certain legal proceedings that arise in the ordinary course and are incidental to our business.
−Removed: of no material, active or pending legal proceedings against us.
+Added: As of the filing date of this report, to our knowledge, there are no material, active or pending legal proceedings against us.
MINE SAFETY DISCLOSURES.
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.