Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
None.
ITEM 1C. CYBERSECURITY
Risk Management and Strategy
The Company’s cybersecurity risk management program
is integrated into the overall risk management framework, including risk identification, assessment, and mitigation across all business
areas. We have collaborated with third-party consultants and built a cybersecurity program designed to protect and safeguard the confidentiality,
integrity and availability of our information systems, which aligns with industry standards and regulatory requirements. Key components
of our cybersecurity risk management and strategy include:
◾ Risk assessments, including vulnerability scans
and penetration testing to identify potential system weaknesses. These assessments are performed internally and supported by third-party
consultants;
◾ Alignment of our cybersecurity framework with
industry standards;
◾ Employee training and awareness: all employees
receive mandatory regular cybersecurity training, with additional specialized sessions for high-risk roles. We also conduct simulated
phishing exercises to enhance awareness and preparedness;
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◾ Continuous monitoring and threat detection: our
IT security team utilizes advanced tools for real-time network and system monitoring, enabling rapid detection and response to potential
threats; and
◾ Comprehensive cyber insurance coverage, including
protection against social engineering fraud and other cyber incidents, to further mitigate potential financial losses.
We have previously experienced actual or attempted
cyber-attacks on our information systems or networks; to date, none of these incidents had a material impact on our operations or financial
condition. However, cybersecurity threats continue to evolve, and future incidents could have a material impact. For additional information
on the impact of cyber risks, refer to Part I, Item 1A. Risk Factors on page 14.
Governance
The board of directors oversees the Company’s
practice for assessing, identifying and managing material risks from cybersecurity threats. The Audit Committee, consisting of all of
the board’s independent directors, with one member holding the CERT Certificate in Cybersecurity Oversight, reviews and discusses
with management and the independent auditor on the Company’s significant financial risk exposures for matters related to cybersecurity
risk, including the steps management has taken to monitor and manage such exposures.
Management is responsible for the day-to-day oversight
and management of cybersecurity risks. The Company’s VP of Enterprise Systems and Applications leads the overall cybersecurity strategy
and risk management program. This role oversees development and execution of risk assessments, implementation of security policies and
procedures, regular cybersecurity training for our employees, and leadership of the IT security team and coordination with third-party
consultants.
The VP of Enterprise Systems and Applications
has over 30 years of experience in information technology, enterprise systems, and operational risk management, including responsibility
for infrastructure and operations in complex, multi-site environments. This experience includes the implementation and oversight of IT
governance and control frameworks aligned with recognized standards, including ITIL and ISO/IEC 20000, as well as the establishment of
processes related to service continuity, supplier management, configuration management, and operational controls. In addition, the VP’s
experience also includes leading enterprise technology initiatives, including system implementations, data center migrations, business
continuity planning, and vendor and third-party risk management.
Senior executives, including the Company’s
CEO and CFO , integrate cybersecurity risks into the overall business strategy and financial planning. The VP and IT security team provide
regular updates to senior management on the Company’s identified vulnerabilities, progress on cybersecurity initiatives and remediation
efforts, and details of ongoing incidents. Management notifies the board of directors when significant incidents occur and provides the
Audit Committee with quarterly updates on the Company’s cybersecurity practices.
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