Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments
Not applicable.
Item 1C. Cybersecurity
Cybersecurity: Risk Management and Strategy
We have developed and implemented a cybersecurity
risk management program that is designed to protect the confidentiality, integrity, and availability of the Company’s data and systems.
Our cybersecurity risk management program includes a cybersecurity incident response plan.
Our cybersecurity risk management program is integrated
into our overall enterprise risk management program, and shares common methodologies, reporting channels and governance processes that
apply across the enterprise risk management program to other legal, compliance, strategic, operational, and financial risk areas.
Our cybersecurity risk management program includes:
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A risk assessment process designed to help identify material cybersecurity risks to our critical systems, information, services, and our broader enterprise IT environment;
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A security team principally responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls, and (3) our response to cybersecurity incidents;
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The use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security controls;
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Cybersecurity awareness training of our employees, incident response personnel, and senior management; and
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A cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents.
Additionally, the Company assesses and manages
cybersecurity threats associated with its third party service providers’ information technology systems that could compromise the
Company’s information security or data. Identified cybersecurity threats are communicated to management for review, response and
mitigation as appropriate.
As of the date of this filing, we have not identified
risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected us,
including our operations, business strategy, results of operations, or financial condition. We face risks from cybersecurity threats that,
if realized, are likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.
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Cybersecurity: Governance
Our Board of Directors considers cybersecurity
risk within the Board’s risk oversight function. The board of directors has charged management with responsibility for oversight
of cybersecurity risks and incidents and any other risks and incidents relevant to the Company’s computerized information system
controls and security. The Board oversees management’s implementation of our cybersecurity risk management program.
Our Chief Financial Officer reviews the efficacy
of our cybersecurity program from time to time as circumstances make appropriate and annually in connection with the annual audit of the
Company’s financial statements.
Our Chief Financial Officer reports to our CEO
on matters of cybersecurity, and together they carry responsibility for our overall cybersecurity risk management program. Our CEO and
CFO provide prompt reports to the Board regarding cybersecurity risks and incidents as they are revealed, as well as periodic reports,
as appropriate, regarding the Company’s cybersecurity program.
Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.