Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
ITEM
1C. CYBERSECURITY
We
face significant and persistent cybersecurity risks due primarily to (i) the substantial level of harm that could occur to us and our
customers were we to suffer impacts of a material cybersecurity incident; and (ii) our use of third-party products, services and components.
We are committed to maintaining strong governance and oversight of these risks and to implementing mechanisms, controls, technologies
and processes designed to help us assess, identify and manage these risks. While we have not, as of the date of this Annual Report, experienced
a cybersecurity threat or incident that resulted in a material adverse impact to our business or operations, there can be no guarantee
that we will not experience such an incident in the future. In addition, these threats are constantly evolving, thereby increasing the
difficulty of successfully defending against them or implementing adequate preventative measures. We seek to detect and investigate unauthorized
attempts and attacks against our network, products and services, and to prevent their occurrence and recurrence where practicable through
changes or updates to our internal processes and tools and changes or updates to our products and services; however, we remain potentially
vulnerable to known or unknown threats.
We
aim to incorporate industry best practices throughout our cybersecurity program. Our cybersecurity strategy focuses on implementing effective
and efficient controls, technologies and other processes to assess, identify and manage material cybersecurity risks. Our cybersecurity
program is designed to be aligned with applicable industry standards and is assessed periodically by independent third parties. We have
processes in place to assess, identify, manage and address material cybersecurity threats and incidents. These include, among other things:
(i) annual and ongoing security awareness training for employees; (ii) mechanisms to detect and monitor unusual network activity; and
(iii) containment and incident response tools. We monitor issues that are internally discovered or externally reported that may affect
our business, and have processes to assess those issues for potential cybersecurity impact or risk. We also have a process in place to
manage cybersecurity risks associated with third-party service providers. We impose security requirements upon our suppliers, including
maintaining an effective security management program and abiding by information handling and asset management requirements. We have an
escalation process in place to inform our senior management and our Board of Directors of these material issues.
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