Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS.
None.
ITEM
1C. CYBERSECURITY.
There
have been an increasing number of cyberattacks on companies around the world, which have caused operational failures, compromised sensitive
corporate or customer data, and/or resulted in significant financial damages. These attacks have occurred over the internet, through
malware, viruses or attachments to e-mails, or through inside actors with access to systems within the organization.
Risk
Management and Strategy
We
have recently implemented additional security measures as part of an evolving cybersecurity posture and will continue to devote resources
to address security vulnerabilities in an effort to prevent cyberattacks and mitigate the damage that could result from such an attack.
All employees received cybersecurity training and other education regarding their use of computers, information technology, and sensitive
data including specifically how to recognize common attack strategies. As many of our applications are developed and managed by third
parties, we are dependent on these providers for many functions including disaster recovery during a disaster or cyber incident. Our
goal is to only utilize the most secure and trusted providers for our IT needs. To this end, we are currently reviewing the security
credentials and certifications of our key application providers. Our business continuity plans are evaluated against evolving security
and service level standards, which includes evaluating those cybersecurity threats associated with our use of key third party service
providers.
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Our
current cybersecurity management strategy consists of utilizing a combination of employee education, preventative controls, detective
controls, and periodic cybersecurity testing. Our process and cybersecurity posture will continue to be refined based on the results
of periodic cybersecurity assessments conducted internally and with our IT consultants and service providers, as needed. We have recently
begun reporting on cybersecurity in reports to the Board of Directors and will continue to do so.
Governance
The
Board of Directors is responsible for oversight of cybersecurity risk. Our Chief Financial Officer and Chief Executive Officer are the
members of management responsible for managing and assessing our cybersecurity practices and have commenced reporting on such practices
and risks . The plan for the future is that they will continue to report to the Board on cybersecurity at least quarterly. Should any
cybersecurity threat or incident be detected, our senior management team would timely report such threat or incident to the Board of
Directors and provide regular communications and updates throughout the incident and any subsequent investigation, in order that the
impact, materiality, and reporting requirements of such incident are appropriately identified and assessed for further necessary or appropriate
action to be taken. We believe we are appropriately staffed (as supported by IT consultants and service providers, as needed) to support
a healthy cybersecurity posture given our size and scope.
Our
Chief Financial Officer, who reports to the Chief Executive Officer, is directly responsible for IT functions and has extensive experience
as a chief financial officer, chief operating officer and special projects lead, with expertise in accounting, taxation, business advisory,
business risks identification and management and business systems designs across many industries, including the application of IFRS and
US GAAP for the life science industry.
To
date, there have been no risks identified from cybersecurity threats or previous cybersecurity incidents that have materially affected
or are reasonably likely to materially affect the Company. However, despite all of the above aforementioned efforts, a cyberattack, if
it occurred, could cause system operational problems, compromise important data or systems or result in an unintended release of confidential
information. See “Item 1A. Risk Factors” for additional discussion of cybersecurity risks impacting our Company.