Item 1B. Unresolved Staff Comments
Item
1B. Unresolved Staff Comments.
None.
Item
1C. Cybersecurity.
Cybersecurity
Risk Management and Strategy
We
recognize the importance of assessing, identifying, and managing material risks associated with cybersecurity threats, as such term is
defined in Item 106(a) of Regulation S-K. These risks include, among other things: operational risks, intellectual property theft, fraud,
extortion, harm to employees or customers and violation of data privacy or security laws.
Identifying
and assessing cybersecurity risk is integrated into our overall risk management systems and processes. Cybersecurity risks related to
our business, technical operations, privacy and compliance issues are identified and addressed through a multi-faceted approach including
third party assessments, internal IT Audit, IT security, governance, risk and compliance reviews. To defend, detect and respond to cybersecurity
incidents, we, among other things: conduct proactive privacy and cybersecurity reviews of systems and applications, audit applicable
data policies, conduct employee training, monitor emerging laws and regulations related to data protection and information security and
implement appropriate changes.
Our
risk management program also assesses third party risks, and we perform third-party risk management to identify and mitigate risks from
third parties such as vendors, suppliers, and other business partners associated with our use of third-party service providers. Cybersecurity
risks are evaluated when determining the selection and oversight of applicable third-party service providers and potential fourth-party
risks when handling and/or processing our employee, business or customer data.
To
date, we have not identified any cybersecurity threats or past incidents that have had, or are likely to have, a material impact on our
company’s operations, business strategy, financial performance, or results of operations.
Cybersecurity
Governance
To
manage our cybersecurity governance, we use Coalition Control, a cyber risk management platform that combines insurance, technology,
and services from Coalition and its partners into an online experience. It allows us to detect, assess, and mitigate cyber risks proactively.
Coalition Control monitors and detects risks across our entire external digital footprint, including assets, apps, services, and data
leaks. The tool shows us where any potential vulnerabilities are identified and how to fix them.
Our
CFO is responsible for the day-to-day oversight of cybersecurity risks, and who utilizes the Coalition management platform for such risk
management. Our CFO keeps the Board apprised of ongoing cybersecurity risk mitigation and any breaches if presented.
Item
2. Description of Property.
Refer
to Note 2, “Leases” to our consolidated financial statements included in Part IV of this Report on Form 10-K, which is incorporated
into this item by reference.
Item
3. Legal Proceedings.
None
Item
4. Mine Safety Disclosures.
Not
applicable.
67
PART
II
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