Item 1B. Unresolved Staff Comments
ITEM
1B.
UNRESOLVED
STAFF COMMENTS
None.
ITEM
1C.
CYBERSECURITY
Cyber
Risk Management and Strategy
We
have developed and maintain processes designed to assess, identify, and manage cybersecurity risks from potential unauthorized occurrences
on or through our information technology systems that may result in adverse effects on the confidentiality, integrity, and availability
of these systems and the data residing therein. The scope of these processes includes risks that may be associated with both our internally
managed information technology (“IT”) systems and key business functions and sensitive data operated or managed by or maintained
at third-party service providers. These processes are managed and monitored by a dedicated information technology team, which is led
by our head of IT, and include mechanisms, controls, technologies, systems, and other processes designed to prevent or mitigate data
loss, theft, misuse, or other security incidents or vulnerabilities affecting the data and maintain a stable information technology environment.
We constantly monitor our information technology environment for abnormal behavior, conduct penetration and vulnerability testing, data
recovery testing, security audits, and ongoing risk assessments, including due diligence on our key technology vendors and other third
party service providers that have access to the personal information we collect, use, store, and transmit. We also conduct periodic employee
trainings on cyber and information security, among other topics. We leverage standard industry tools from a software and hardware perspective
and maintain a cybersecurity risk insurance policy.
We
consider cybersecurity, along with other significant risks that we face, within our overall enterprise risk management framework. In
the last fiscal year, we have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity
incidents, which have materially affected us, but we face certain ongoing cybersecurity risks threats that, if realized, are reasonably
likely to materially affect us.
Governance
Related to Cybersecurity Risks
The
Board of Directors, as a whole and at the committee level, has oversight for the most significant risks facing us and for our processes
to identify, prioritize, assess, manage, and mitigate those risks. The Compliance Committee, which is comprised solely of independent
directors, has been designated by our Board to oversee cybersecurity risks. The Compliance Committee receives periodic updates on cybersecurity
and information technology matters and related risk exposures. The Board also receives updates from management and the Compliance Committee
on cybersecurity risks on at least an annual basis.
Our
Vice President of Information Technology has over 10 years of experience managing information technology and cybersecurity matters. The
Vice President of Information Technology, together with our senior leadership team, are responsible for assessing and managing cybersecurity
risks and they work collaboratively across our company to implement policies and procedures designed to protect our information and systems
from cybersecurity threats and to respond promptly to any material cybersecurity incidents in accordance with our incident response plans.
A cross-functional team is responsible for responding to cybersecurity incidents.
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