What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-03-24 compared with 2024-03-19 · 22 added, 28 removed, 25 unchanged (67% of the section changed)

12 unchanged sentences

risks, and the sufficiency of existing policies, procedures, systems, and safeguards in place to manage such risks.

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.

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.

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.

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

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.

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.

date, we have not encountered cybersecurity challenges that have materially impaired our operations or financial condition.

information regarding risks from cybersecurity threats is provided at “Item 1A.

Risk Factors”.

4 unchanged sentences

function directly as a whole, as well as through the audit committee.

Chief Operating Officer and Chief Financial Officer are primarily responsible to assess and manage our material risks from cybersecurity

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.

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.

Chief Operating Officer and IT consultant provide periodic briefings to the audit committee regarding the Company’s cybersecurity

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.

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.

Our audit committee provides regular updates to the Board of Directors on such reports.

LEGAL PROCEEDINGS

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.

As of December 31, 2024, the

Company was not subject to any threatened or pending lawsuits, legal claims or legal proceedings.

MINE SAFETY DISCLOSURES

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments