Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
Not applicable.
ITEM 1C. CYBERSECURITY
Cybersecurity Risk Management and Strategy
We, like other companies in
our industry, face several cybersecurity risks in connection with our business. Our business strategy, results of operations, and financial
condition have not, to date, been affected by risks from cybersecurity threats. During the reporting period, we have not experienced any
material cyber incidents, nor have we experienced a series of immaterial incidents, which would require disclosure.
In the ordinary course of our business, we may use, store and process
sensitive data. To effectively prevent, detect, and respond to cybersecurity threats, we maintain a cyber risk management program,
which is comprised of data segregation, physical, procedural, and technical safeguards along with documented policies and procedures.
By fully outsourcing our IT environment and placing it within expert third party software-as-a-service, human resource, and clinical providers,
our primary means of avoiding cyber risk is minimizing sensitive data within our enterprise.
The cyber risk management program falls under the responsibility of
our Chief Financial Officer (“CFO”) who manages the overall security through constant communication and supervision of our
third-party vendors. Under the guidance of our CFO who reports to the Audit Committee, we seek to minimize our data footprint
to keep our cyber risk low. We use technology-based tools that are designed to mitigate cybersecurity risks and to bolster our employee-based
cybersecurity programs.
We do not believe that there
are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us or our business strategy,
results of operations or financial condition.
Governance; Board Oversight
Under the ultimate direction
of our CFO, with oversight from our board of directors, we maintain a security governance structure to evaluate and address cyber risk.
Our CFO regularly consults with our third-party IT consultant who has expertise in cybersecurity to develop strategies to assess, address
and align cybersecurity efforts with our business objectives and operational requirements.
The Audit Committee of our
Board provides direct oversight over cybersecurity risk, and provides updates to the Board of Directors regarding such oversight, when
and if appropriate. Our CFO provides periodic updates to the Audit Committee regarding cybersecurity matters including significant new
cybersecurity threats or incidents, when and if appropriate.
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