Item 1B. Unresolved Staff Comments
Item
1B. UNRESOLVED STAFF COMMENTS
None.
Item
1C. Cybersecurity
Cybersecurity
Risk Management and Strategy
We,
like other companies in our industry, face several cybersecurity risks in connection with our business. Our business strategy, results
of operations, and financial condition have not, to date, been materially affected by risks from cybersecurity threats. During the reporting
period, we have not experience any material cyber incidents, nor have we experienced a series of immaterial incidents, which would require
disclosure.
We
will implement a cybersecurity program in the future. The program will be aimed at safeguarding the confidentiality, integrity, and availability
of our essential systems and information, and will be designed to detect and mitigate risks from cybersecurity threats to our data and
our systems. Central to our future cybersecurity efforts will be a robust incident response plan designed to address potential cyber
incidents swiftly and effectively.
In
designing and evaluating our cybersecurity program, we will adopt the National Institute of Standards and Technology Cybersecurity Framework
(“NIST CSF 2.0”) as a guiding principle. It is important to clarify that our use of the NIST CSF 2.0 is for guidance purposes
to frame our risk identification, assessment and management processes and does not equate to compliance with any specific technical standards
or requirements.
The
key components of our future cybersecurity program will include:
● conducting
risk assessments to pinpoint material cybersecurity threats to our critical systems, data,
products, services, and overall IT infrastructure;
● a
third-party security expert consultant overseeing the risk assessment process, maintenance
of security controls, and coordination of responses to cybersecurity incidents;
● engagement
with external service providers to evaluate, enhance, or support our security measures; and
● an
incident response plan outlining specific procedures for managing cybersecurity incidents;
Cybersecurity
Governance
The
governance of cybersecurity risks is a critical function of our Board of Directors which has a key role in the oversight of
cybersecurity and related technology risks. The Board of Directors is tasked with monitoring the effectiveness of our
cybersecurity risk management program as implemented by management.
The
Board of Directors will receive regular updates from management on the state of cybersecurity risks facing the Company. This
includes briefings on any significant cyber incidents and ongoing risk management efforts.
The
responsibility for day-to-day management of cybersecurity risks lies with our management team, including the Chief Financial Officer
and Chief Executive Officer. This team will be at the forefront of our cybersecurity initiatives, coordinating both internal and external resources to
anticipate, identify, and mitigate cyber threats. Our approach will include regular updates from our third-party security expert
consultant, leveraging intelligence from various sources, and utilizing advanced security tools to protect our digital
environment.