Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments
None.
Item 1C. Cybersecurity
Our operations and other aspects of
our business rely heavily on various information technology systems which are largely managed by third parties. We face significant cybersecurity
threats, which are continuously increasing in sophistication, including computer viruses, internal and external security breaches, and
other cyber-attacks. These threats could disrupt our operations, lead to the loss of confidential information, and hinder our ability
to accurately report our financial results in a timely manner. We have adopted a Cybersecurity Policy to create effective administrative,
technical, electronic, and physical protections to safeguard the personal information of Company personnel, confidential information concerning
our portfolio investments and the integrity of the Company’s information systems.
We have created an Information
Security Team, consisting of our Chief Financial Officer and our Chief Compliance Officer, to implement and administer our Cybersecurity
Policy. Our Chief Financial Officer and Chief Compliance Officer have each served in senior management
positions for a number of years, have received cybersecurity training from time to time in connection with their professional certifications,
and have overseen and supervised the activities of external information technology personnel of the Fund during this period. Among
the duties and responsibilities of our Information Security Team are the following:
· Ensuring that all Equus personnel are aware of the Cybersecurity Policy
and agree to adhere to its requirements;
· Establishing that information concerning the Fund is stored on encrypted
cloud-based servers accessible only by authorized Equus personnel;
· Providing that all of the Company’s information systems are backed
up daily, with offline copies available in the event that a major security issue arises;
· Testing and evaluating cybersecurity safeguards via the use of third-party
information technology service providers;
· Reviewing the security measures in the Company’s Cybersecurity
Policy annually or when there is a change in applicable laws or regulations or in business activities of Equus; and
· Conducting training as necessary for all Equus personnel; and
· Reporting cybersecurity matters to our Board of Directors who provide
oversight of our Information Security Team.
We utilize third-party services and
tools for identifying, protecting against, and detecting cyber incidents, and also partner with external vendors to augment our internal
security capabilities. Additionally, we engage third-parties to conduct independent assessments of our cybersecurity infrastructure to
evaluate the efficiency and effectiveness of our detection capabilities, along with our response mechanisms, and overall risk management.
Our approach to managing cybersecurity
risks is part of a continuous improvement process, both in the context of cybersecurity and broader operational risk management. This
ongoing process, which includes personnel training, is aimed at routinely reviewing and, as necessary, improving, our oversight processes
and tools to ensure they remain effective and resilient in their management of cybersecurity risk.
Material Impact of Cybersecurity Threats
While we have yet to experience
a material cybersecurity event, we acknowledge the persistent and evolving nature of these threats, which have the potential to materially
impact our business strategy, operations, and financial results adversely. We maintain robust policies and procedures focused on cybersecurity
incident management, ensuring timely communication and escalation to all relevant stakeholders. This enables faster response and effective
communication, including public disclosure if a material cybersecurity event were to occur.
Board of Directors Oversight
Our Board of Directors oversees risks
related to cybersecurity, including the security of our corporate, financial, and portfolio investment information and the steps management
is taking to monitor and control these risks. Our Chief Compliance Officer conducts regular meetings with our independent directors to
discuss various compliance matters, including any cybersecurity issues, and also delivers a comprehensive Annual Compliance Report to
the Board, which report also addresses cybersecurity matters.
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