Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
Item
1C. Cybersecurity
Risk
Management and Strategy
We
regularly assess, identify, and manage material risks 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.
We
conduct risk assessments at least annually to identify cybersecurity threats. These risk assessments include identifying reasonably foreseeable
potential internal and external risks, the likelihood of occurrence and any potential damage that could result from such risks, and the
sufficiency of existing policies, procedures, systems, controls and other safeguards we have put in place to manage such risks. Our risk
management process also encompasses cybersecurity risks associated with the use of our major third-party vendors and service providers.
Additionally, we maintain cyber coverage through our insurance carrier to mitigate risks associated with cybersecurity incidents, subject
to customary terms and exclusions.
Following
these risk assessments, we design, implement, and maintain reasonable safeguards to minimize the identified risks; reasonably address
any identified gaps in existing safeguards; update existing safeguards as necessary; and monitor the effectiveness of our safeguards.
Moreover, we remain committed to investing in the development and improvement of our security processes and controls, as well as maintaining
our technology infrastructure. These processes include a plan for notifying, informing, consulting, analyzing, and communicating any
risks or incidents to a range of internal stakeholders, including executive management and the Board of Directors, as well as external
stakeholders, as deemed necessary and appropriate based on the circumstances. We believe we have allocated adequate resources related
to our cybersecurity risk management processes and have designated our Chief Financial Officer with the responsibility of managing the
cybersecurity risk assessment and mitigation process.
As
part of our overall risk management program, we provide required training to employees in high-risk areas on cybersecurity and will distribute
standard operating procedures to all employees. For additional information regarding whether any risks from cybersecurity threats, including
as a result of any previous cybersecurity incidents, have materially affected or are reasonably likely to materially affect us, including
our business strategy, results of operations, or financial condition, please refer to Item 1A, “Risk Factors,” in this Annual
Report .
Governance
One
of the key functions of our Board of Directors is informed oversight of our risk management process, including risks arising from cybersecurity
threats. Our Chief Financial Officer and Chief Operating Officer are primarily responsible for assessing and managing material risks
from cybersecurity threats on a day-to-day basis. Our Board of Directors is responsible for monitoring and assessing strategic risk exposure,
and our management team is additionally 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. We additionally utilizes the assistance of a third-party service
provider, an information technology solutions service provider located in Richmond, BC, for purposes of broadly managing its cybersecurity
risks.
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