Item 1B. Unresolved Staff Comments
Item
1B. Unresolved Staff Comments.
None.
Item
1C. Cybersecurity.
Risk
management and strategy
With
the assistance of our IT vendor, we established policies and processes for assessing, identifying, and managing material risk
from cybersecurity threats and have integrated these processes into our overall risk management systems and processes. We routinely
assess material risks from cybersecurity threats, including any potential unauthorized occurrence on or conducted through our
information systems that may result in adverse effects on the confidentiality, integrity, or availability of our information systems
or any information residing therein. Primary responsibility for assessing, monitoring and managing our cybersecurity risks rests
with an information technology (IT) consultant who reports to our Chief Financial Officer, to manage the risk assessment and
mitigation process. Our Board of Directors provides oversight to our cybersecurity efforts to ensure effective governance in
managing risks associated with cybersecurity threats. Our CFO provides periodic updates to the Board of Directors regarding our
cybersecurity program, including information about cyber risk management governance and status updates on various projects intended
to enhance the overall cybersecurity posture of the Company.
We
conduct periodic risk assessments to identify cybersecurity threats, as well as assessments in the event of a material change in our
business practices that may affect information systems that are vulnerable to such cybersecurity threats. These risk assessments include
identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that could result from such
risks, and the sufficiency of existing policies, procedures, systems, and safeguards in place to manage such risks.
Following these risk assessments, responses may include re-design,
implementation, and maintenance of reasonable safeguards to minimize identified risks and address any identified gaps in existing safeguards;
and regularly monitoring of the effectiveness of our safeguards.
As
part of our overall risk management system, we monitor and test our safeguards and train our employees on these safeguards, in collaboration
with IT and management. Personnel at all levels and departments are made aware of our cybersecurity policies through trainings.
We
engage consultants, or other third parties in connection with our risk assessment processes. These service providers assist us to design
and implement our cybersecurity policies and procedures, as well as to monitor and test our safeguards.
We
have not encountered cybersecurity challenges that have materially impaired our operations or financial standing. For additional
information regarding risks from cybersecurity threats, please refer to “ Cyber-attacks or other failures in
telecommunications or information technology systems and deficiency in our, or those of third parties upon which we rely,
cybersecurity could result in information theft, data corruption and significant disruption of our business operations.” under
Item 1A, “Risk Factors,” in this annual report on Form 10-K.
Governance
One
of the key functions of our board of directors is informed oversight of our risk management process, including risks from cybersecurity
threats. Our board of directors is responsible for monitoring and assessing strategic risk exposure, and our executive officers are responsible
for the day-to-day management of the material risks we face. Our board of directors administers its cybersecurity risk oversight function
directly as a whole, as well as through the audit committee.
Our
Chief Financial Officer is primarily responsible to assess and manage our material risks from cybersecurity threats with assistance from
third-party service providers.
Our
Chief Financial Officer oversees our cybersecurity policies and processes, including those described in “Risk Management and Strategy”
above. The cybersecurity risk management program includes tools and activities to prevent, detect, and analyze current and emerging cybersecurity
threats, and plans and strategies to address threats and incidents.
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