Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
Not applicable.
ITEM 1C. CYBERSECURITY
Overview
At IPM, cybersecurity is at the core of our business operations and
an integral part of our commitment to delivering secure, compliant, and resilient technology solutions to customers operating in highly
regulated industries. Prior to the Transactions, the Company employed a comprehensive strategy with respect to cybersecurity, which was
supported by both management and our Board. Historically, our Board was responsible for overseeing our risk management activities in general,
and certain of our Board committees assisted the Board in the role of risk oversight. The operations team prior to the Transactions conducted
manual and automated testing of our systems, with the goal of identifying vulnerabilities and proactively strengthening our defenses.
Following the Transactions,
in order to support our comprehensive range of IT-related services and digital infrastructure, we have embraced a multi-layered defense
approach, which helps us recognize and address the dynamic nature of cyber threats. By integrating diverse security measures, we aim to
fortify our infrastructure against a spectrum of potential risks and adapt to the ever-evolving cybersecurity landscape.
Our cybersecurity strategy is proactively designed
to protect our digital infrastructure, customer environments, and business continuity. This approach is supported by our management and
Board, with structured oversight to ensure compliance with evolving regulatory, risk, and industry best practices.
Proactive Security Measures and Threat Management
We employ a multi-layered defense strategy, leveraging
advanced threat intelligence, automation, and security analytics to proactively detect, prevent, and respond to cyber threats. Our core
security practices include:
● continuous
threat monitoring and response utilizing real-time security operations centers and next-generation endpoint detection and response to
rapidly identify and neutralize threats;
● regular
vulnerability assessments and penetration testing conducted through automated and manual assessments with prioritized remediation workflows
to enhance security across infrastructure, applications, and client environments;
● zero
trust security architecture, which implements strict identity verification, least privilege access and network segmentation to reduce
attack surfaces and prevent lateral movement of threats; and
● partnerships
with leading cybersecurity firms for independent security audits, risk assessments, and compliance rev iews as described below.
Recognizing that human factors play a critical
role in cybersecurity, our workforce and compliance training includes comprehensive security awareness program. All employees undergo
quarterly security training, covering data protection, insider threat mitigation, phishing awareness, and compliance best practices. Additionally,
we implement strict enforcement of multi-factor authentication, just-in-time access controls, and continuous user behavior monitoring.
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Incident Response and Business Continuity
Our incident response framework follows a structured
escalation and notification process focused on rapid containment, mitigation, and recovery from cybersecurity incidents. Key response
protocols include:
● automated
detection and response workflows to leverage rapid assessment detection technology to detect
breaches in real time;
● escalation
of critical incidents to our Chief Executive Officer, President, and Chief Operating Officer
and the Board based on severity and regulatory reporting requirements; and
● secure
backup and disaster recovery, which implement immutable backups, air-gapped storage, and
rapid failover solutions to protect data integrity and minimize downtime in case of cyber
incidents.
Governance
Both management and the Board are actively involved
in the oversight of risks from cybersecurity threats. Our information security program is designed to ensure that management and the Board
are adequately informed about, and provided with the tools necessary to monitor, (i) material risks from cybersecurity threats and (ii)
our efforts related to the prevention, detection, mitigation, and remediation of cybersecurity incidents.
Role of the Board
Our Board oversees cybersecurity risk as part
of our enterprise risk management strategy. The Board receives comprehensive cybersecurity updates from our President at least quarterly
to inform our directors of evolving threats and regulatory developments. We undergo regular independent audits, cybersecurity risk assessments,
and compliance reviews to validate our security posture, and our Audit Committee receives annual reports regarding our ongoing security
measures.
Role of Management
At the management level, our Chief Information
Security Officer (“CISO”) leads cybersecurity initiatives and reports regularly to the President on security posture, risk
trends, and key incidents. Our President is a seasoned technology and business leader with over 20 years of experience in managed IT services
and global scale multi-site private cloud datacenter operations. His background and experience provide him with expertise regarding data
privacy and security, vulnerability management, security operations, and application security. In addition, our Chief Operating Officer
has many years of experience with managed IT cyber application delivery.
We face risks from cybersecurity threats that
could have a material adverse effect on its business, financial condition, results of operations, cash flows or reputation. To date, we
have not experienced any risks from cybersecurity threats that have materially affected, or are reasonably likely to materially affect,
our business strategy, financial condition, results of operations, or cash flows. See “ Risk Factors – Risks Related to
Our Business – We could be adversely affected by information security breaches or cyber security attacks .”
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