Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
None.
ITEM 1C. CYBERSECURITY
Cybersecurity Risk Management and Strategy
The Trust does not have any officers, directors
or employees. The Sponsor, a subsidiary of WisdomTree, Inc., is responsible for the oversight and overall management of the Trust. The
Sponsor relies on WisdomTree Inc.’s cybersecurity framework for the Trust’s cybersecurity risk management and strategy. Key
aspects of such framework are summarized below.
WisdomTree Inc.’s enterprise-wide cybersecurity
risk management policies and procedures are informed by industry standards, and they are designed to address cybersecurity risks identified
by external auditors and assessors, threat intelligence providers, internal stakeholders, vulnerability management programs and security
management programs. WisdomTree Inc.’s team of information technology and cybersecurity professionals, led by its Chief Information
Officer, or CIO, manages and maintains remediation strategies for identified cybersecurity risks.
66
WisdomTree Inc.’s cybersecurity risk
management program is designed to be aligned with its business strategy. It shares common methodologies, reporting channels and governance
processes that apply to other areas of enterprise risk, including legal, compliance, strategic, operational and financial risk.
Governance Related to Cybersecurity Risks
The cybersecurity risk management program
and related operations and processes are directed by WisdomTree Inc.’s CIO. Currently, the CIO role is held by an individual who
has been in the role for over ten years, has over 23 years of cybersecurity, information technology and systems engineering experience,
and has advanced training in the field of technology.
The CIO is a member of WisdomTree, Inc.’s
Governance Committee and regularly reports on cybersecurity risk management to other members of the Governance Committee comprised of
WisdomTree Inc.’s senior executive officers. The Governance Committee oversees the prioritization and escalation of risks from cybersecurity
threats and is responsible for strategy, operations, financial management, information technology, compliance, legal, administration and
corporate governance. The members of the Governance Committee collectively possess experience in these areas, including cybersecurity
and risk management.
The audit committee of WisdomTree, Inc. (the
“Audit Committee”) oversees the management of cybersecurity risks. Pursuant to the Audit Committee charter, the Audit Committee
is responsible for discussing cybersecurity-related risks with management and the steps management has taken to monitor and control such
risks, including WisdomTree Inc.’s risk assessment and risk management policies. The CIO regularly reports to the Audit Committee
on cybersecurity risks, and the chair of the Audit Committee reports on these discussions with the full board of directors of WisdomTree,
Inc. In addition, the CIO provides periodic reports to the board of directors.
As of December 31, 2024, cybersecurity risks have not materially affected
the Trust’s business strategy, results of operations or financial condition. However, the Trust can provide no assurance that there
will not be cybersecurity threats or incidents in the future or that they will not materially affect the Trust. For more information regarding
the risks the Trust faces from cybersecurity threats, see Item 1A. “Risk Factors” included in this report.
ITEM 2. PROPERTIES
Not applicable.
ITEM 3. LEGAL PROCEEDINGS
None.
ITEM 4. MINE SAFETY DISCLOSURES
Not applicable.
67
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.