Unresolved Staff Comments
−Removed: This information is not required for smaller reporting companies.
+Added: information is not required for smaller reporting companies.
Cybersecurity
−Removed: We have implemented cybersecurity risk management procedures,
−Removed: in accordance with our risk profile and business size.
−Removed: We rely on our information technology to operate our business.
−Removed: As such, we have
−Removed: policies and processes designed to protect our information technology systems, some of which are managed by third parties, and resolve
−Removed: issues in a timely manner in the event of a cybersecurity threat or incident.
−Removed: We have designed our business applications to minimize the impact
−Removed: that cybersecurity incidents could have on our business and have identified back-up systems where appropriate.
−Removed: We seek to further mitigate
−Removed: cybersecurity risks through a combination of monitoring and detection activities, use of anti-malware applications, employee training,
−Removed: quality audits and communication and reporting structures, among other processes.
−Removed: We have a trained group of people to carry out the activities
−Removed: of monitoring and detection of cybersecurity threats and respond to any cybersecurity threats or incidents.
−Removed: The Head of IT department
−Removed: is responsible for oversight of cybersecurity risks and addressing potential cybersecurity risks to business programs, employees, clients,
−Removed: vendors and partners.
−Removed: The Head of IT Department reports to our Chief Executive Officer who reports to the Audit Committee at the board-level,
−Removed: as appropriate.
−Removed: As of December 31, 2023, we have not identified an indication
−Removed: of a cybersecurity incident that would have a material impact on our business and consolidated financial statements.
−Removed: The disclosures concerning our properties are contained in Item 1 Business
−Removed: above and incorporated herein by reference.
+Added: a technology and communications company that globally transmits large amounts of information over our networks, we recognize the critical
+Added: importance of maintaining the security and integrity of information and systems under our control.
+Added: We view cybersecurity risk as one
+Added: of our principal enterprise-wide risks, subject to control and monitoring at various levels of management throughout our company.
+Added: dedicate resources commensurate with our risk profile and business size to programs designed to identify, assess, manage, mitigate and
+Added: respond to cybersecurity threats.
+Added: described in Item 1A “Risk Factors,” several features of our operations heighten our susceptibility to cyber-attacks, including
+Added: (i) our material reliance on systems owned, operated or controlled by unaffiliated third-party operators and (ii) our processing and
+Added: storage of large amounts of sensitive customer data.
+Added: Cyber-attacks on our systems may be initiated by a wide variety of intruders, including
+Added: employees, cyber-criminals, nation state actors and other advanced persistent threat actors, and may include attempts by outside parties
+Added: to gain access to sensitive data that is stored in or transmitted across our network.
+Added: Cyber-attacks can take many forms, including computer
+Added: hackings, computer viruses, ransomware, worms or other destructive or disruptive software, denial of service attacks, or other malicious
+Added: have implemented cybersecurity risk management procedures, in accordance with our risk profile and business size.
+Added: We rely on our information
+Added: technology to operate our business.
+Added: As such, we have policies and processes designed to protect our information technology systems, some
+Added: of which are managed by third parties, and resolve issues in a timely manner in the event of a cybersecurity threat or incident.
+Added: have designed our business applications to minimize the impact that cybersecurity incidents could have on our business and have identified
+Added: back-up systems where appropriate.
+Added: We seek to further mitigate cybersecurity risks through a combination of monitoring and detection
+Added: activities, use of anti-malware applications, employee training, quality audits and communication and reporting structures, among other
+Added: We have a trained group of people to carry out the activities of monitoring and detection of cybersecurity threats and respond
+Added: to any cybersecurity threats or incidents.
+Added: The Head of IT department is responsible for oversight of cybersecurity risks and addressing
+Added: potential cybersecurity risks to business programs, employees, clients, vendors and partners.
+Added: The Head of IT Department reports to our
+Added: Chief Executive Officer who reports to the Audit Committee at the board-level, as appropriate.
+Added: of December 31, 2024, we have not identified an indication of a cybersecurity incident that would have a material impact on our business
+Added: and consolidated financial statements.
+Added: disclosures concerning our properties are contained in Item 1 Business above and incorporated herein by reference.
Legal Proceedings
−Removed: We have no current legal proceedings.
+Added: have no current legal proceedings.
Mine Safety Disclosures
−Removed: Not applicable.
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.