Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments
Not applicable.
Item 1C. Cybersecurity.
We face risks associated with
cybersecurity. For additional details on risks from cybersecurity threats, please refer to “Item 1A. Risk Factors - The occurrence
of security breaches and cyber-attacks could negatively impact our business .” and “- Our business may be subject to
a variety of PRC laws and other obligations regarding cybersecurity and data protection .”
The purpose of our cybersecurity
program is to assess, identify, manage and mitigate cybersecurity risk while supporting the achievement of our business objectives. Under
our comprehensive risk management program, the Board of Directors of the Company maintains oversight of the most significant risks facing
the Company, including cybersecurity risks, while senior management is responsible for the identification and prioritization of risks
that are material to our business, corresponding risk-mitigation efforts and day-to-day management of our risk management program. The
full Board of Directors retains oversight over management’s cybersecurity efforts. At least annually, and often more frequently,
our Board of Directors receives cybersecurity briefings from senior executives, including, when appropriate, executives focused on cybersecurity
matters.
Our companywide cybersecurity
policy sets the framework for our approach to cybersecurity. Each business unit and our corporate headquarters designates individuals
with appropriate qualifications and experience to be responsible for addressing cybersecurity matters, including assessing, identifying
and managing risks from cybersecurity threats, with a direct reporting line to senior management. Under our approach to cybersecurity,
each business unit designs and operates its own information and cybersecurity program tailored to its market, customer requirements, regulatory
requirements and threats. Our cybersecurity policy and procedures are designed to ensure senior management receives timely and adequate
information regarding cybersecurity matters, including threats and incident response, as appropriate to the matter. Our policies and procedures
are also designed to oversee and identify material cybersecurity risks related to third-party vendors and service providers.
As part of our approach to
cyber risk management, we regularly perform internal audits of internal processes and controls relating to cybersecurity. From time to
time, as appropriate under our overall cybersecurity program, we engage third-party experts to support the assessment of cyber related
risks, including to conduct cyber penetration testing.
To its knowledge, the Company
has not experienced a material cybersecurity breach within the last three years, nor identified any risks from cybersecurity threats that
have materially affected us, including our business strategy, results of operations or financial condition.