Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
ITEM
1C. CYBERSECURITY
Cybersecurity
Risk Management and Strategy
We
have developed and maintain a cybersecurity risk management methodology intended to protect the confidentiality, integrity, and availability
of our critical systems and information. Our cybersecurity risk management methodology is integrated into our overall enterprise risk
management, and shares common methodologies, reporting channels and governance processes that apply across the Company to other legal,
compliance, strategic, operational, and financial risk areas. As part of our overall risk management processes and procedures, we have
instituted a cybersecurity awareness designed to identify, assess and manage material risks from cybersecurity threats, including by
engaging a third-party cybersecurity service provider, which communicates directly with our management and compliance personnel. The
cyber risk management methodology involves risk assessments, implementation of security measures and ongoing monitoring of systems and
networks, including networks on which we rely. Through our cybersecurity awareness, the current threat landscape is actively monitored
in an effort to identify material risks arising from new and evolving cybersecurity threats. We may engage external experts, including
cybersecurity assessors, consultants and auditors to evaluate cybersecurity measures and risk management processes as needed. We also
depend on and engage various third parties, including suppliers, vendors and service providers in connection with our operations. Our
risk management, legal, and compliance personnel oversee and identify, including through a third-party cybersecurity service provider,
material risks from cybersecurity threats associated with our use of such entities.
Our
cybersecurity risk management methodology includes:
We
have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially
affected us, including our operations, business strategy, results of operations, or financial condition. We face risks from cybersecurity
threats that, if realized, are reasonably likely to materially affect us, including our operations, business strategy, results of operations,
or financial condition.
Cybersecurity
Governance
Our
Board of Directors oversees our risk management, including our information technology and cybersecurity policies, procedures, and risk
assessments. Management reports to our Board of Directors on information security matters as necessary, regarding any significant cybersecurity
incidents, as well as any incidents with lesser impact potential.
One
of the key functions of our Board of Directors is informed oversight of our various processes for managing risk. An overall review of
risk is inherent in our Board of Directors ongoing consideration of our long-term strategies, transactions and other matters presented
to and discussed by the Board of Directors. This includes a discussion of the likelihood and potential magnitude of various risk.
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