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 partners 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 oversees management’s implementation of our cybersecurity risk management
efforts.
Management updates our board
of directors, 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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