What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-03-25 compared with 2024-03-12 · 43 added, 39 removed, 3 unchanged (96% of the section changed)

1 unchanged sentence

Cybersecurity

Company has processes in place for assessing, identifying, preventing, and managing material risks from cybersecurity threats, including

related to the use of third party service providers.

In addition, the Company leverages the security and monitoring tools of third party

service providers.

These processes are integrated into the Company’s overall risk management program and systems, as overseen by

the Board, primarily through the Audit Committee.

maintain physical, technical and administrative safeguards to prevent and identify cybersecurity risks, and have implemented practices

and procedures to address cybersecurity risks.

Management and Strategy

The Company has processes

in place for assessing, identifying, preventing, and managing material risks from cybersecurity threats, including related to the use

of third-party service providers.

In addition, the Company leverages the security and monitoring tools of third-party service providers.

These processes are integrated into the Company’s overall risk management program and systems, as overseen by the Board, primarily

through the Audit Committee.

We maintain physical, technical

and administrative safeguards to prevent and identify cybersecurity risks, and have implemented practices and procedures to address cybersecurity

To this end, among other things, we:

annual mandatory training for our employees regarding cybersecurity threats as a means to

equip them with effective tools to address cybersecurity threats, and to communicate our

evolving information security policies, standards, processes and practices;

regular simulation modules for all employees to enhance awareness and responsiveness to possible

cybersecurity management and incident training for employees involved in our systems and

processes that handle sensitive data;

cyber liability insurance that is intended to provide protection against the potential losses

arising from a cybersecurity incident.

are currently working with outside counsel to further develop a formal cybersecurity incident response plan.

we are regularly exposed to malicious technology-related events and threats, none of these threats or incidents, either individually

or in the aggregate of related occurrences, have materially affected the Company in the period covered by this Annual Report on Form

In determining materiality, cybersecurity incidents are reviewed not only for potential financial impacts, which could include

potential legal and regulatory penalties, stolen assets or funds, system damage, forensic and remediation costs, lost revenue or litigation

costs, but also the breadth and sensitivity of data exposure, data exfiltration, impacts on the ability to operate our business or provide

our services and loss of investor confidence.

Board executes its oversight responsibility for risk management both directly and through delegating oversight of certain of these risks

to its committees, and the Board has authorized the Audit Committee to oversee risks related to cybersecurity threats.

Our Audit Committee

has primary oversight responsibility for cybersecurity and information security risk management and controls.

As part of its oversight

function, the Audit Committee oversees the Company’s risk assessment and risk management policies, including related to cybersecurity

and the overall data protection program.

Our senior management is responsible for assessing and managing the

Company’s various exposures to risk, including those related to cybersecurity, on a day-to-day basis, including the identification

of risks through an enterprise risk management framework and the creation of appropriate risk management programs and policies to address

The Company’s Senior Manager, IT, has 24 years of experience in enterprise IT and has primary responsibility for managing

our cybersecurity program and efforts, and our finance and IT teams are responsible for the testing and audit of our information-technology

related internal controls.

Item 1A, Risk Factors , for additional information on the Company’s cybersecurity risk profile, in particular the risk factors

under the headings entitled “ Risks relating to data privacy could create additional liabilities for us ” and “ Security

breaches and other disruptions could compromise our information and expose us to liability, which would cause our business and reputation

annual mandatory training for our employees regarding cybersecurity threats as a means to equip them with effective tools to address

cybersecurity threats, and to communicate our evolving information security policies, standards, processes and practices;

regular simulation modules for all employees to enhance awareness and responsiveness to possible threats;

cybersecurity management and incident training for employees involved in our systems and processes that handle sensitive data;

cyber liability insurance that is intended to provide protection against the potential losses arising from a cybersecurity incident.

We are currently working

with outside counsel to further develop a formal cybersecurity incident response plan as a part of our review of and improvements to

the Company’s cybersecurity policies.

While we are regularly exposed

to malicious technology-related events and threats, none of these, either individually or in the aggregate of related occurrences, have

materially affected the Company in the period covered by this Annual Report on Form 10-K.

In determining materiality, cybersecurity incidents

are reviewed not only for potential financial impacts, which could include potential legal and regulatory penalties, stolen assets or

funds, system damage, forensic and remediation costs, lost revenue or litigation costs, but also the breadth and sensitivity of data

exposure, data exfiltration, impacts on the ability to operate our business or provide our services and loss of investor confidence.

The Board executes its oversight

responsibility for risk management both directly and through delegating oversight of certain risks to its committees.

The Board has authorized

the Audit Committee to oversee risks related to cybersecurity threats.

Our Audit Committee has primary oversight responsibility for cybersecurity

and information security risk management and controls.

As part of its oversight function, the Audit Committee oversees the Company’s

risk assessment and risk management policies, including related to cybersecurity and the overall data protection program.

Our senior management is responsible for assessing

and managing the Company’s various exposures to risk, including those related to cybersecurity, on a day-to-day basis, including

the identification of risks through an enterprise risk management framework and the creation of appropriate risk management programs

and policies to address such risks.

In particular, the Company’s Senior Manager, IT, has 24 years of experience in enterprise IT

and has primary responsibility for managing our cybersecurity program and efforts.

Our finance and IT teams are responsible for the testing

and audit of our information-technology related internal controls.

See Item 1A, Risk Factors ,

for additional information on the Company’s cybersecurity risk profile, in particular the risk factor under the headings entitled

“ Risks relating to data privacy could create additional liabilities for us ”.

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.

What changed 10-K

Item 1B. Unresolved Staff Comments