Item 1B. Unresolved Staff Comments
ITEM
1B.
UNRESOLVED
STAFF COMMENTS
None.
ITEM
1C.
CYBERSECURITY
Risk
Management and Strategy
Our
comprehensive risk management strategy for the assessment, identification and management of material risks stemming from cybersecurity
threats involves a systematic evaluation of potential threats, vulnerabilities, and their potential impacts on our organization’s
operations, data, and systems.
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Our
cybersecurity risk management program is integrated into our overall enterprise risk management program and shares common methodologies,
reporting channels, and governance processes that apply across the enterprise risk management program, including legal, compliance, strategic,
operational, and financial risk areas. The cybersecurity risk management program includes:
●
Risk
assessments designed to help identify material cybersecurity risks to our critical systems, information, and broader enterprise IT
environment;
●
A
team principally responsible for managing (i) cybersecurity risk assessment processes, (ii) security controls, and (iii) response
to cybersecurity incidents;
●
The
use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of security controls;
●
Cybersecurity
awareness training for users and senior management, including through the use of third-party providers for regular mandatory training;
●
A
cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents; and
●
A
risk management process for third-party service providers, suppliers and vendors, including a rigorous vetting process and ongoing
monitoring mechanisms designed to ensure compliance with cybersecurity standards.
As
of the date of this Annual Report on Form 10-K, the Company is no t aware of any cybersecurity incidents that have had a materially adverse
effect on our operations, business, results of operations, or financial condition.
Governance
Our
Board of Directors considers cybersecurity risk as part of its risk oversight function. It has delegated oversight of cybersecurity and
other information technology risks to the Audit Committee. The Audit Committee oversees the implementation of the cybersecurity risk
management program.
The
Audit Committee receives periodic reports from management on potential cybersecurity risks and threats and receives presentations on
cybersecurity topics from the Company’s Information Systems Manager. The Audit Committee reports to the full Board of Directors
regarding its activities, including those related to cybersecurity. The full Board of Directors also receives briefings from management
on the cybersecurity risk management program as needed.
Management
is responsible for assessing and managing our material risks from cybersecurity threats. Management has primary responsibility for our
overall cybersecurity risk management program and supervises both the internal cybersecurity personnel and external cybersecurity consultants.
The Company’s Information Systems Manager has many years of experience leading cybersecurity oversight and has extensive experience
with information technology, including security, auditing, compliance, systems, and programming.
The
management team supervises efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means,
which may include briefings from internal security personnel, threat intelligence and other information obtained from governmental, public
or private sources, including external consultants; and alerts and reports produced by security tools deployed in the IT environment.
Our cybersecurity incident response plan governs our assessment and response upon the occurrence of a material cybersecurity incident,
including the process for informing senior management and our Board of Directors.