Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
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.
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Following
these risk assessments, we intend to take any steps necessary to redesign, implement, and
maintain reasonable safeguards to minimize identified risks; to reasonably address any identified
gaps in existing safeguards; and to 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 Executive Officer and Chief Financial Officer,
to manage the risk assessment and mitigation process. As part of our overall risk management
system, we monitor and periodically evaluate our safeguards.
We
may engage consultants, or other third
parties in connection with our risk assessment processes. These
service providers can assist us to design and implement our cybersecurity policies and procedures, as well as to monitor and test our
safeguards.
To
date, 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 Executive 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 Executive Officer and Chief Financial Officer interact with our IT consultant and 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 Executive Officer and Chief Financial Officer 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.
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