UNRESOLVED STAFF COMMENTS
−Removed: Smaller reporting companies such as us are not required to provide the information required by this item.
+Added: As a smaller reporting company, the Company is not required to provide the information required by this item.
CYBERSECURITY
6 unchanged sentences
KULR engages with these partners to monitor and maintain the performance and effectiveness of products and services that are deployed in KULR’s environment.
−Removed: KULR’s Chief Technology Officer (“CTO”) , in conjunction with our third-party providers, is responsible for assessing and managing KULR’s cyber risk management program, informs senior Management regarding the prevention, detection, mitigation, and remediation of cybersecurity incidents, and supervises such efforts.
−Removed: In addition, KULR has made additional investment into cybersecurity by hiring an on-premises Information Technology (“IT”) Manager who will dedicate time weekly to supporting the development of KULR cyber related policies and working on enforcement with 3 rd party managed solutions providers.
+Added: KULR’s Chief Technology Officer , in conjunction with our third-party providers, is responsible for assessing and managing KULR’s cyber risk management program, informs senior Management regarding the prevention, detection, mitigation, and remediation of cybersecurity incidents, and supervises such efforts.
+Added: In addition, KULR has made additional investment into cybersecurity by hiring an on-premises Information Technology Manager who will dedicate time weekly to supporting the development of KULR cyber related policies and working on enforcement with 3 rd party managed solutions providers.
We deploy online cybersecurity training for employees and consider this a critical step in safeguarding the Company’s data and assets.
5 unchanged sentences
We maintain a cyber risk management program designed to identify, assess, manage, mitigate, and respond to cybersecurity threats.
−Removed: This program is integrated within the Company’s enterprise risk management system and addresses both the corporate information technology (“IT”) environment and customer-facing products.
+Added: This program is integrated within the Company’s enterprise risk management system and addresses both the corporate information technology environment and customer-facing products.
The underlying controls of the cyber risk management program are based on recognized best practices and standards for cybersecurity and information technology, including the National Institute of Standards and Technology (“NIST”) Cybersecurity Framework (“CSF”).
We conduct an annual assessment of our practices and standards against the NIST CSF.
−Removed: KULR is actively engaged with third-party specialists to update policies and institute controls that would ensure Cybersecurity Maturity Model Certification (“CMMC”) level 2 compliance.
+Added: KULR is actively engaged with third-party specialists to update policies and institute controls that would ensure Cybersecurity Maturity Model Certification level 2 compliance.
Identifying and assessing cybersecurity risk is integrated into our overall risk management systems and processes.
6 unchanged sentences
For a description of the risks from cybersecurity threats that may materially affect the Company, see our risk factors under Item 1A.
−Removed: Risk Factors, including Significant disruptions of information technology systems, breaches of data security and other incidents could materially adversely affect our business, results of operations and financial condition.
+Added: Risk Factors, including the risk
+Added: factor entitled Significant disruptions of information technology systems, breaches of data security and other incidents could materially adversely affect our business, results of operations and financial condition.
Our principal executive office is located at 555 Forge River Road, Suite 100, Webster, Texas 77598, and the telephone number at such address is 408-663-5247.
+Added: LEGAL PROCEEDINGS
+Added: From time to time we may become involved in legal proceedings arising in the ordinary course of business.
+Added: We are not currently a party to any material legal or administrative proceedings.
+Added: MINE SAFETY DISCLOSURES
+Added: 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.