Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
ITEM
1C. CYBERSECURITY
Item
1C. Cybersecurity
Cybersecurity
Risk Management and Strategy
The
cybersecurity risk management program, processes and strategy described in this section are limited to the personal and business information
belonging to or maintained by the Company (collectively, “Confidential Information”), our own third-party critical systems
and services supporting or used by the Company (collectively, “Critical Systems”), and service providers.
We
will develop and implement a company-wide cybersecurity risk management program intended to protect the confidentiality,
integrity, and availability of our Confidential Information and Critical Systems. Our cybersecurity risk management program will be
integrated into our overall enterprise risk management program and includes a cybersecurity incident response plan.
Our
cybersecurity risk management program shall include :
●
risk
assessments designed to help identify material cybersecurity risks to our Confidential Information, Critical Systems and the broader
enterprise IT environment;
●
a
security team principally responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls, and
(3) our response to cybersecurity incidents;
●
cybersecurity
awareness and spear-phishing resistance training of our employees, and senior management;
●
a
cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents; and
●
a
vendor management policy for service providers.
We
have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially
affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial
condition. We face risks from cybersecurity threats that, if realized, could have a material adverse effect on us including
an adverse effect on our business, financial condition and results of operations.
Cybersecurity
Governance
Our
executive management team, along with our managed information technology service provider, is responsible for assessing and managing
risks from cybersecurity threats to the Company, including our Confidential Information and Critical Systems. The team has primary responsibility
for our overall cybersecurity risk management program. Our management team works closely with our information technology service provider.
Our
management team meets with our information technology service provider periodically to discuss then-current cybersecurity issues, which
may include efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, including threat
intelligence and other information obtained from governmental, public or private sources, and external service providers engaged by us;
and alerts and reports produced by security tools deployed in the information technology environment including a spear-phishing report.
Our
Board considers cybersecurity risk as part of its risk oversight function and oversight of cybersecurity and other information technology
risks.
Our
Board oversees management’s implementation of our cybersecurity risk management program. Our executive management team is responsible
for updating the Board, as necessary, regarding significant cybersecurity incidents.
Our
Board shall also receive period reports from management on our cybersecurity risks and cybersecurity risk management program.