What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-03-27 compared with 2024-03-28 · 57 added, 62 removed, 2 unchanged (98% of the section changed)

STAFF COMMENTS.

UNRESOLVED STAFF COMMENTS.

CYBERSECURITY.

The Company, with the assistance

of a third party, has policies, standards, processes and practices for assessing, identifying, and managing material risks from cybersecurity

We engage third party personnel resources to implement and maintain security measures to meet regulatory requirements, and we

intend to add internal personnel and further investments to maintain the security of our data and cybersecurity infrastructure.

can be no guarantee that our policies and procedures will be properly followed in every instance or that those policies and procedures

will be effective.

Our risk factors, which can found be found in Item 1A.

“Risk Factors,” include further detail about the

material cybersecurity risks we face.

There can be no assurance that there will not be incidents in the future or that they will not materially

affect us, including our business strategy, results of operations, or financial condition.

Risk Management and Strategy

Currently, we rely on our third

party for much of our cybersecurity efforts.

Internally, we are working towards formally employing and documenting a risk-based approach

to cybersecurity which aligns with corporate strategy, risk management and governance, and adaptable information technology (“IT”)

infrastructure.

Our cybersecurity program will consist of policies, procedures, systems, controls and technology designed to help prevent,

identify, detect and mitigate cybersecurity risk and will be based on a cybersecurity framework, such as the National Institute of Standards

and Technology (“NIST”) Cybersecurity framework.

To protect our IT systems and

information from cybersecurity risks, we, through our third-party provider, use various security tools that help prevent, identify, escalate,

investigate, resolve, and recover from identified cybersecurity vulnerabilities and incidents in a timely manner.

These include the utilization

of a third-party security operations center connected to a network operation center to identify, investigate, and resolve any cybersecurity

threats and incidents.

We assess, at least annually,

the technological risks to our key IT systems and information.

We have implemented controls to identify and manage cybersecurity risks

associated with all third-party service providers.

These include, but are not limited to, an understanding of access controls, a records

and information management policy, change control procedures, risk and control registry, attestation report reviews, and configuration

Employee awareness of cybersecurity

risks and threats is also an important part of an effective control environment.

We periodically communicate to employees about this cybersecurity

In 2024, we plan to require each of our employees to complete annual information security training, in addition to other training

requirements.

This should lead to an educated, informed, and prepared workforce, with an awareness of potential cybersecurity threats,

how they may occur, and how to report and escalate such matters.

Our cybersecurity strategy focuses

on implementing effective and efficient controls, technologies, and other processes to assess, identify, and manage material cybersecurity

risks to our IT systems and information.

As a part of this process, we have engaged an independent third-party specialist to review our

cybersecurity environment, including formal reviews and assessments, and we have requested specific, actionable recommendations for improvement

and implementation.

While we have not, as of

the date of this Annual Report on Form 10-K, experienced a cybersecurity incident that has materially impacted our business or

operations, there can be no guarantee that we will not experience such a threat or incident in the future.

Company continues to implement policies, standards, processes and practices for assessing, identifying, and managing material risks from

cybersecurity threats.

We employ a variety of tools designed to identify, assess and maintain security measures to meet regulatory requirements,

and possess technical personnel to maintain the security of our data and cybersecurity infrastructure.

There can be no guarantee that

our policies and procedures will be properly followed in every instance or that those policies and procedures will be effective.

risk factors, which can be found in Item 1A.

“Risk Factors,” include further detail about the material cybersecurity risks

There can be no assurance that there will not be incidents in the future or that they will not materially affect us, including

our business strategy, results of operations, or financial condition.

Management and Strategy Overview

continue the process of designing and implementing a formal risk-based approach to cybersecurity which aligns with corporate strategy,

risk management and governance, and adaptable information technology (“IT”) infrastructure.

Our cybersecurity program consists

of policies, procedures, systems, controls and technology designed to help prevent, identify, detect and mitigate cybersecurity risk

and will be based on a cybersecurity framework, such as the National Institute of Standards and Technology (“NIST”) Cybersecurity

protect our IT systems and information from cybersecurity risks, we use and continue to implement various security tools that help prevent,

identify, escalate, investigate, resolve, and recover from identified cybersecurity vulnerabilities and incidents in a timely manner.

These include monitoring and detection programs, network security measures, firewall monitoring devices and multi-factor authentication

which are all overseen by our IT Director, who possesses the necessary expertise to implement the appropriate tools and processes to

effectively manage cybersecurity risks.

With over 30 years of experience in the oil and natural gas industry, our IT Director has 12

years of cybersecurity experience where he has led several teams introducing cybersecurity initiatives and implementing robust frameworks

and response plans against cyber threats.

are actively assessing the technological risks to our key IT systems and information and are implementing controls to identify and manage

cybersecurity risks associated with all third-party service providers.

These include, but are not limited to, an understanding of access

controls, a records and information management policy, change control procedures, risk and control registry, and configuration standards.

awareness of cybersecurity risks and threats is also an important part of an effective control environment.

We periodically communicate

to employees about this cybersecurity awareness.

We are working on an implementation plan to require each of our employees to complete

an annual information security training course, in addition to other training requirements.

This should lead to an educated, informed,

and prepared workforce, with an awareness of potential cybersecurity threats, how they may occur, and how to report and escalate such

cybersecurity strategy focuses on implementing effective and efficient controls, technologies, and other processes to assess, identify,

and manage material cybersecurity risks to our IT systems and information.

As a part of this process, we engaged and worked

with an independent third-party specialist to review our cybersecurity environment, which included a formal review and assessment, and determined

specific, actionable recommendations for improvement and implementation.

we have not, as of the date of this Annual Report on Form 10-K, experienced a cybersecurity incident that has materially impacted our

business or operations, there can be no guarantee that we will not experience such a threat or incident in the future.

A material cybersecurity

threat or incident could adversely impact our operations, our sales or financial and administrative functions, or result in the

compromise of personal or other confidential information of our employees, customers, or suppliers.

For this reason, we maintain

cybersecurity liability insurance to provide additional support, expertise, and resources to help ensure the integrity of our

cybersecurity processes and to provide a level of financial protection in the event of cybersecurity incident related costs and

Our Audit Committee has oversight

of our cybersecurity risk processes, as part of its overall oversight of our risk management program.

Our CFO is informed about and facilitates

prevention, detection, mitigation, and remediation efforts through regular communication and reporting from the third party provider.

In addition, we have an escalation process in place to inform our Chief Executive Officer and other members of our senior management and,

if necessary, the Audit Committee and Board of Directors, of important issues or events.

Information regarding our properties is included in

Item 1 above and in our consolidated financial statements, which is incorporated herein by reference.

threat or incident could adversely impact our operations, our sales or financial and administrative functions, or result in the compromise

of personal or other confidential information of our employees, customers, or suppliers.

For this reason, we maintain cybersecurity liability

insurance to provide additional support, expertise, and resources to help ensure the integrity of our cybersecurity processes and to

provide a level of financial protection in the event of cybersecurity incident related costs and losses.

Audit Committee has oversight of our cybersecurity risk processes, as part of its overall oversight of our risk management program.

Chief Executive Officer is informed about and facilitates prevention, detection, mitigation, and remediation efforts through regular

communication and reporting from our IT Director.

In addition, we have an escalation process in place to inform our Chief Executive Officer

and other members of our senior management and, if necessary, the Audit Committee and Board of Directors, of important issues or events.

regarding our properties is included in Item 1 above and in our consolidated financial statements, which is incorporated herein by reference.

LEGAL PROCEEDINGS.

For information regarding legal proceedings, see Note 15 in our consolidated financial statements.

MINE SAFETY DISCLOSURES.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments