Item 1B. Unresolved Staff Comments
Item 1B.
Unresolved Staff Comments
None.
Item 1C.
Cybersecurity
Cybersecurity Program Overview
As part of our overall risk management processes and procedures, we have instituted a cybersecurity program designed to identify, assess, and manage
material risks from cybersecurity threats. The cyber risk management program involves risk assessments, implementation of security measures, and ongoing monitoring of systems and networks, including networks on which we rely. Through our
cybersecurity program, the current threat landscape is actively monitored in an effort to identify material risks arising from new and evolving cybersecurity threats. We may engage external experts, including cybersecurity assessors, consultants,
and auditors to evaluate cybersecurity measures and risk management processes, as needed. We also depend on and engage various third parties, including suppliers, vendors, and service providers in connection with our operations. Our risk
management, legal, and compliance personnel identify and oversee material risks from cybersecurity threats associated with our use of such entities.
Board Oversight of Cybersecurity Risks
Our Board provides strategic oversight on cybersecurity matters, including material risks associated with cybersecurity threats. Our Board receives
periodic updates from our Chief Compliance Officer regarding the overall state of our cybersecurity program, information on the current threat landscape, and material risks from cybersecurity threats and cybersecurity incidents.
Management’s Role in Cybersecurity Risk Management
Our management team, including our Chief Compliance Officer, is responsible for assessing and managing material risks from cybersecurity threats.
Members of our management team possess relevant expertise in various disciplines that are key to effectively managing such risks, such as operations management, information technology management, oversight of third-party service providers and
managing relationships with outside cybersecurity experts. Our management team is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents, including through the receipt of notifications from
third-party service providers and reliance on communications with our risk management, legal, and/or compliance personnel.
Assessment of Cybersecurity Risk
The potential impact of risks from cybersecurity threats are assessed on an ongoing basis, and how such risks could materially affect our business
strategy, operational results, and financial condition are regularly evaluated. During the reporting period, we have not identified any risks from cybersecurity threats, including as a result of previous cybersecurity incidents, that we believe
have materially affected, or are reasonably likely to materially affect, us, including our business strategy, operational results, and financial condition.