Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
Not applicable to smaller
reporting companies.
Item 1C. Cybersecurity.
Our Board and management
recognize the critical importance of maintaining the trust and confidence of our customers, clients, business pa rtners
and employees.
In
general, we seek to address cybersecurity risks through a comprehensive, cross-functional approach that is focused on preserving the
confidentiality, security and availability of the information that we collect and store by identifying, preventing and mitigating cybersecurity
threats and effectively responding to cybersecurity incidents when they occur.
Our
cybersecurity risk management efforts include:
● risk
assessments designed to help identify material cybersecurity risks to our critical systems,
information, products, services, and our broader enterprise IT environment;
● a
security team principally responsible for managing (1) our cybersecurity risk assessment
processes, (2) our security controls, and (3) our response to cybersecurity incidents; and
● a
cybersecurity incident response plan that includes procedures for responding to cybersecurity
incidents.
Cybersecurity Governance
Our board of directors considers
cybersecurity risks as part of its risk oversight function and has delegated to the Audit Committee oversight of cybersecurity and other
information technology risks. The Audit Committee oversees management’s implementation of our cybersecurity risk management efforts.
Management updates the Audit
Committee, as necessary, regarding any material cybersecurity incidents, as well as any incidents with lesser impact potential.
Our CEO and CFO are responsible
for assessing and managing our material risks from cybersecurity threats, our overall cybersecurity risk management efforts, and supervise
both our internal cybersecurity personnel and our retained external cybersecurity consultants.
Our CEO and CFO supervise efforts
to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which include ensuring routine briefings
from internal security personnel, obtaining threat intelligence and other information obtained from governmental, public or private sources,
including external consultants engaged by us, and providing Company personnel with alerts and reports produced by security tools deployed
in the IT environment.
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