Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
None.
ITEM 1C. CYBERSECURITY.
Risk Management and Strategy
Cybersecurity risk management
is an integral part of our overall enterprise risk management program. The Company manages cybersecurity and data protection through a
continuously evolving program. Our cybersecurity risk management program is designed to provide a framework for assessing, identifying
and managing cybersecurity threats and incidents, including threats and incidents associated with the use of services provided by third-party
service providers, and to facilitate coordination across different departments of our Company. Our processes include steps for assessing
the severity of a cybersecurity threat, identifying the source of a cybersecurity threat, including whether the cybersecurity threat is
associated with a third-party service provider, and implementing cybersecurity countermeasures and mitigation strategies and informing
management and the board of directors of material cybersecurity threats and incidents.
Governance
The Board of Directors has
oversight for the most significant risks facing us and for our processes to identify, prioritize, assess, manage and mitigate those risks.
The Audit Committee of the Board of Directors (the “Audit Committee”) has been designated to oversee cybersecurity risks.
The Audit Committee receives regular updates on cybersecurity and information technology matters and related risk exposures from our management.
The Board of Directors also receives periodic updates from management and the Audit Committee on cybersecurity risks. Management
is responsible for identifying, considering and assessing material cybersecurity risks on an ongoing basis, establishing processes designed
to ensure that such potential cybersecurity risk exposures are monitored, putting in place mitigation measures and maintaining cybersecurity
programs. Our cybersecurity programs are under the direction of our Chief Executive Officer . Management regularly updates the Audit Committee
on our cybersecurity programs, which includes cybersecurity risks and mitigation strategies, vulnerability management, and on-going cybersecurity
projects. While none of our directors has formal professional certifications in cybersecurity, several members of the Board have experience
overseeing information technology and enterprise risk management in prior executive or board roles. The Board receives periodic updates
on cybersecurity matters as part of its overall risk oversight responsibilities. Day-to-day responsibility for identifying and managing
cybersecurity risks rests with our Director of IT Security & Future Solutions and his information security team. The team is responsible
for monitoring our networks, systems, and data, implementing technical safeguards , conducting employee training, and coordinating incident
response procedures.
Management provides regular
reports to the Audit Committee, generally on an annual basis, or more frequently as needed covering:
· the Company’s cybersecurity strategy and policies,
· results of system monitoring and testing,
· recent threat environment developments, and
· any cybersecurity incidents and responses.
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In addition, in the event
of a significant cybersecurity incident, the Chief Operating Officer will promptly inform the Chief Executive Officer and General Counsel,
who in turn will notify the Chair of the Audit Committee and the Board as appropriate.
Management regularly updates the Audit Committee
on our cybersecurity programs, which includes cybersecurity risks and mitigation strategies, vulnerability management, and on-going cybersecurity
projects. We ordinarily do not engage assessors, consultants, auditors or other third parties in connection with such oversight.
As of June 30, 2025, we did
not identify any cybersecurity incidents that materially affected or are reasonably likely to materially affect our business strategy,
results of operations, or financial condition. However, despite our efforts, we cannot eliminate all risks from cybersecurity threats
or provide assurances that we have not experienced an undetected cybersecurity incident. It is possible that we may not implement appropriate
controls if we do not detect a particular risk. In addition, security controls, no matter how well designed or implemented, may only mitigate
and not fully eliminate the risks. Even when a risk is detected, disruptive events may not always be immediately and thoroughly interpreted
and acted upon.
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