3 unchanged sentences
To date, the Company has not identified any cybersecurity incidents which have materially affected , or are reasonably likely to materially affect, the Company's business strategy, results of operations or financial condition.
−Removed: The Company has not implemented any specific policies with respect to monitoring and managing cybersecurity threats.
−Removed: Moreover, the Company is aware of the evolution of cybersecurity risks and is taking proactive steps by keeping up to date our information systems and educating our personnel about these risks.
+Added: The Company is aware of the evolution of cybersecurity risks and is taking proactive steps by keeping up to date our information systems and educating our personnel about these risks.
+Added: The company maintains a structured cybersecurity risk-management framework focused on identifying, assessing, and mitigating material risks from cybersecurity threats within its digital payments division, HammerPay.
+Added: HammerPay's platform architecture, which supports regulated payment processing, prepaid merchant card issuance, and digital wallet operations, is continuously monitored to protect customer data and transaction integrity.
+Added: The Company conducts continuous threat detection, routine penetration testing, and access-control audits, while incident-response protocols are coordinated by the Compliance and IT Security teams.
+Added: Cybersecurity oversight is an integral component of the Company's enterprise risk-management (ERM) process.
+Added: Identified threats and mitigation plans are reviewed alongside financial and operational risks.
+Added: The Chief Compliance Officer (CCO) and Chief Technology Officer (CTO) jointly oversee cybersecurity posture and report quarterly to the Board of Directors.
+Added: Cybersecurity objectives align with corporate governance and business-continuity strategies.
+Added: The Company engages independent cybersecurity consultants, auditors, and compliance specialists to validate internal controls, including penetration testing, PCI-DSS and SOC 2 assessments, and KYC/AML compliance audits.
+Added: Findings are documented, tracked, and reviewed with the Board of Directors.
+Added: HammerPay's vendor-management program governs all third parties that handle or access sensitive data, including banking partners, cloud providers, and API vendors.
+Added: Each provider undergoes due diligence, contractual data-protection obligations, and ongoing certification reviews (SOC 2, PCI-DSS).
The Company recognizes the importance of developing, implementing, and maintaining cybersecurity measures to safeguard its information systems and protect the confidentiality, integrity , and availability of the data.
1 unchanged sentence
The Company does not own any real property, nor have any long term lease obligations.
+Added: The Company does currently hold a month-to-month tenancy agreements for office space.
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.