Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
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ITEM
1C. CYBERSECURITY
Risk
Management and Strategy
We
have established policies and processes for assessing, identifying, and managing material risk from cybersecurity threats, and have integrated
these processes into our overall risk management systems and processes. We routinely assess material risks from cybersecurity threats,
including any potential unauthorized occurrence on or conducted through our information and email systems that may result in adverse
effects on the confidentiality, integrity, or availability of our information and email systems or any information residing therein.
We
conduct periodic risk assessments to identify cybersecurity threats, as well as assessments in the event of a material change in our
business practices that may affect information systems that are vulnerable to such cybersecurity threats. These risk assessments include
identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that could result from such
risks, and the sufficiency of existing policies, procedures, systems, and safeguards in place to manage such risks.
Following
these risk assessments, we will redesign, implement, and maintain reasonable safeguards to minimize identified risks; reasonably address
any identified gaps in existing safeguards; and regularly monitor the effectiveness of our safeguards. Primary responsibility for assessing,
monitoring and managing our cybersecurity risks rests with an IT consultant, who reports to our Chief Operating Officer, to manage the
risk assessment and mitigation process. As part of our overall risk management system, we monitor and periodically evaluate our safeguards
and advise our executives on these safeguards.
We
engage consultants, or other third parties in connection with our risk assessment processes. These service providers assist us to design
and implement our cybersecurity policies and procedures, as well as to monitor and test our safeguards. In the future, we intend to require
each significant third-party service provider to certify that they have the ability to implement and maintain appropriate security measures,
consistent with all applicable laws, to implement and maintain reasonable security measures in connection with their work with us, and
to promptly report any suspected breach of its security measures that may affect us.
We
have not encountered cybersecurity challenges that have materially impaired our operations or financial condition. Additional information
regarding risks from cybersecurity threats is provided at “Item 1A. Risk Factors”.
Governance
One
of the functions of our Board of Directors is informed oversight of our risk management process, including risks from cybersecurity threats.
Our Board of Directors is responsible for monitoring and assessing strategic risk exposure, and our executive officers are responsible
for the day-to-day management of the material risks that we face. Our Board of Directors administers its cybersecurity risk oversight
function directly as a whole, as well as through the audit committee.
Our
Chief Operating Officer and Chief Financial Officer are primarily responsible to assess and manage our material risks from cybersecurity
threats with assistance from third-party service providers.
Our
Chief Operating Officer and Chief Financial Officer oversee our cybersecurity policies and processes, including those described above
at “Risk Management and Strategy”. The cybersecurity risk management program includes tools and activities to prevent, detect,
and analyze current and emerging cybersecurity threats, and plans and strategies to address threats and incidents.
Our
Chief Operating Officer and IT consultant provide periodic briefings to the audit committee regarding the Company’s cybersecurity
risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity systems testing, activities of
third parties, and similar issues. Our audit committee provides regular updates to the Board of Directors on such reports.
ITEM
2. PROPERTIES
None.
ITEM
3. LEGAL PROCEEDINGS
The
Company may be subject to legal claims and actions from time to time as part of its business activities. As of December 31, 2023 and
2022, the Company was not subject to any threatened or pending lawsuits, legal claims or legal proceedings.
ITEM
4. MINE SAFETY DISCLOSURES
Not
applicable.
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PART
II
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