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. 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 reviews as described below.
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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, SOC 2 Type 1 controls, and
continuous user behavior monitoring. In January 2026, the Company received an unqualified opinion attesting to its compliance with SOC
2 Type 1 following an independent examination.
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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