Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
ITEM
1C. CYBERSECURITY
Cybersecurity
Risk Management and Strategy
In
the ordinary course of our business, we may use, store and process confidential information and data. To effectively prevent, detect,
and respond to cybersecurity threats, we maintain a cyber risk management program, which is comprised of data segregation, physical,
procedural, and technical safeguards along with some documented policies and procedures. By fully outsourcing our IT environment and
placing it within expert third party software-as-a-service, human resource, and clinical providers, our primary means of minimizing cybersecurity
risk is limiting the amount of sensitive data within our enterprise.
We
have certain processes for assessing, identifying, and managing cybersecurity risks, which are built into our overall information technology
function and are designed to help protect our information assets and operations from internal and external cyber threats, and protect
employee, collaborator, and customer information from unauthorized access or attack, as well as secure our networks and systems. Such
processes include physical, procedural, and technical safeguards, response plans, tests on our systems, review of our policies and procedures
to identify risks and refine our practices. We engage certain external parties, including IT consultants and computer security firms,
to enhance our cybersecurity oversight including by gaining valuable insights into the ever-evolving cybersecurity landscape. We consider
the internal risk oversight programs of third-party service providers before engaging them in order to help protect us from any related
vulnerabilities.
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In
an effort to deter and detect cyber threats, we regularly provide all employees with a data protection, cybersecurity, incident response,
and prevention, training and compliance program, which covers timely and relevant topics, including social engineering, phishing, password
protection, confidential data protection, asset use and mobile security, and educates employees on the importance of reporting all incidents
immediately. We also use technology-based tools that are designed to mitigate cybersecurity risks and to bolster our employee-based cybersecurity
programs.
We
do not believe that there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us
or our business strategy, results of operations or financial condition.
Governance;
Board Oversight
Under
the ultimate direction of our Chief Executive Officer, with oversight from our Board and Audit Committee (as described below), we maintain
a security governance structure to evaluate and address cybersecurity risks. Our Chief Executive Officer regularly consults with our
Chief Financial Officer and third-party IT consultants and computer security firms, leveraging and relying upon these consultants’
cybersecurity expertise, to develop strategies that assess and address threats while aligning cybersecurity efforts with business objectives
and operational requirements.
The
Audit Committee of our Board provides direct oversight over cybersecurity risk and provides updates to the Board regarding such oversight
on a periodic basis. The Audit Committee receives periodic updates from management regarding cybersecurity matters and is notified between
such updates regarding significant new cybersecurity threats or incidents. The Audit Committee also notifies the Board of any cybersecurity
incidents (suspected or actual) and provides updates on the incidents as well as cybersecurity risk mitigation activities as appropriate.
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