Item 1B. Unresolved Staff Comments
Item
1B. Unresolved Staff Comments.
Not
applicable.
Item
1C. Cybersecurity.
We
face risks associated with cybersecurity. For additional details on risks from cybersecurity threats, please refer to “Item 1A.
Risk Factors - The occurrence of security breaches and cyber-attacks could negatively impact our business .” and “-
If the Chinese government chooses to exert more oversight and control over offerings that are conducted overseas and/or foreign investment
in China-based issuers, such action could significantly limit or completely hinder our ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless. ”
The
purpose of our cybersecurity program is to assess, identify, manage and mitigate cybersecurity risk while supporting the achievement
of our business objectives. Under our comprehensive risk management program, the Board of Directors of the Company maintains oversight
of the most significant risks facing the Company, including cybersecurity risks, while senior management is responsible for the identification
and prioritization of risks that are material to our business, corresponding risk-mitigation efforts and day-to-day management of our
risk management program. The full Board of Directors retains oversight over management’s cybersecurity efforts. At least annually,
and often more frequently, our Board of Directors receives cybersecurity briefings from senior executives, including, when appropriate,
executives focused on cybersecurity matters.
Our
companywide cybersecurity policy sets the framework for our approach to cybersecurity. Each business unit and our corporate headquarters
designate individuals with appropriate qualifications and experience to be responsible for addressing cybersecurity matters, including
assessing, identifying and managing risks from cybersecurity threats, with a direct reporting line to senior management. Under our approach
to cybersecurity, each business unit designs and operates its own information and cybersecurity program tailored to its market, customer
requirements, regulatory requirements and threats. Our cybersecurity policy and procedures are designed to ensure senior management receives
timely and adequate information regarding cybersecurity matters, including threats and incident response, as appropriate to the matter.
Our policies and procedures are also designed to oversee and identify material cybersecurity risks related to third-party vendors and
service providers.
As
part of our approach to cyber risk management, we regularly perform internal audits of internal processes and controls relating to cybersecurity.
From time to time, as appropriate under our overall cybersecurity program, we engage third-party experts to support the assessment of
cyber related risks, including to conduct cyber penetration testing.
To
its knowledge, the Company has not experienced a material cybersecurity breach within the last three years, nor identified any risks
from cybersecurity threats that have materially affected us, including our business strategy, results of operations or financial condition.
Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.