Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
None
Item 1C. Cybersecurity.
Management and Strategy
The Company maintains a robust cybersecurity infrastructure to safeguard our operations, networks, third party hosted services, and data through internal management and external service providers. Our security program extends far beyond traditional controls, and includes:
• A multi-tiered system designed to protect the company;
• Mandatory training and proactive phishing tests;
• Continuous risk‑reduction measures addressing behavioral factors and emerging and developing threats; and
• Continuous risk assessments by individuals and third parties to ensure alignment with the Company’s standards.
Management and Governance
Our cybersecurity risk management and strategy processes are led by our Chief Financial Officer and Senior Director, IT Strategy. The Senior Director, IT Strategy, is responsible for the design, implementation, and ongoing operation of the Company’s cybersecurity systems and controls. The Senior Director has over fifteen years of experience in various roles involving managing information systems and security, developing information security strategies, and implementing effective information and cybersecurity programs.
The Information Technology Department, with the assistance of various third-party consultants, identify and assess cybersecurity risks by monitoring our IT environment and various industry publications.
Our assessment of material risks from cybersecurity threats are integrated into our risk management process. The Senior Director and Chief Financia l Officer routinely discuss trends and the Company’s responses and reports to the Audit Committee of our Board of Directors on a quarterly basis. Material cybersecurity incidents are required to be reported to the Board of Directors as soon as practical after the incident is discovered.
Impacts of Risks and Threats
As of the date of this Report, the Company is not aware of any cybersecurity incidents that have had a material impact or likely to have a material impact on the Company, its business strategy, results of operations, or financial condition. No assurance can be given that future cybersecurity events will not result in a material impact on the Company, nor can the Company confirm that an undetected cybersecurity threat or incident is not currently present with the potential to cause such an effect.
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Table of Contents
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