Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
Not applicable.
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Item 1C. Cybersecurity.
The Trust does not have any officers, directors
or employees. The Sponsor is responsible for the oversight and overall management of the Trust. The Sponsor has adopted a written information
security policy for its own risk management. The Sponsor has established an Information Security Committee (“ISC”) that reviews
the status of the Sponsor’s cybersecurity processes and any potential risks or incidents. As of the date of this Report, the Sponsor
has not identified any risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially
affected, or that the Sponsor believes are reasonably likely to materially affect, the Trust, including its operations, results of operations,
or financial condition.
Cybersecurity Program Overview
The Sponsor has a comprehensive cybersecurity
program built around the National Institute of Standards and Technology’s Cybersecurity Framework. The program incorporates a variety
of strategies and measures aimed at identifying, protecting, detecting, responding to and recovering from cyber incidents. The
program’s key components include risk assessment and management, where the ISC, of which the Chief Executive Officer and Chief Financial
Officer of the Sponsor are members, identifies potential threats and vulnerabilities and implements appropriate controls to mitigate those
vulnerabilities. As part of the program, the ISC (i) develops and enforces security policies and procedures, providing guidelines for
safe and secure operations, (ii) prioritizes employee training and awareness, as human error is often a significant factor in security
breaches, (iii) conducts regular security audits and assessments to ensure that the program remains effective and up to date with evolving
threats, and (iv) incorporates advanced technologies such as identify management, encryption, firewalls, anti-malware and intrusion detection
systems to provide multiple layers of defense against cyber-attacks.
The Trust also relies on its other service providers,
including the Trustee and the Cash Custodian, to implement cybersecurity programs and engage external experts, including cybersecurity
assessors, risk management and information technology professionals, attorneys, consultants and auditors to evaluate their cybersecurity
measures and risk management processes.
Management’s Role in Cybersecurity Risk Management
The Sponsor conducts annual due diligence on the
Trust’s service providers, including the Trustee and Cash Custodian, which includes a review of the relevant service provider’s
operational and cybersecurity controls. The Sponsor’s officers review the results of this annual review and any incidents or perceived
risks.
Board Oversight of Cybersecurity Risks
The Sponsor does not have a board of directors
and is instead managed by its sole managing member, who performs the governance and oversight functions typically undertaken by a board
of directors.
Item 2. Properties.
Not applicable.
Item 3. Legal Proceedings.
Not applicable.
Item 4. Mine Safety Disclosures.
Not applicable.
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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.