Item 1B. Unresolved Staff Comments
Item
1B. Unresolved Staff Comments.
None.
Item
1C. Cybersecurity.
Risk
management and strategy
We
rely on our information technology to operate our business. We have policies and processes designed to protect our information technology
systems, some of which are managed by third parties, and resolve issues in a timely manner in the event of a cybersecurity threat or
incident.
As
part of our broader risk management framework, we have identified the potential cybersecurity risks to our business and implemented structured
controls to mitigate them. Our business applications and hosting services are designed to minimize the impact of cybersecurity incidents,
with designated backup systems in place where necessary.
To
enhance cybersecurity resilience, we have implemented a structured Information Security Management System (ISMS) certified in accordance
with ISO 27001, providing a comprehensive approach to managing cybersecurity risks and aligning with industry best practices. Our risk
mitigation efforts include a combination of administrative, technical, and operational controls, such as real-time monitoring and detection
activities, anti-malware and endpoint protection solutions, annual employee cybersecurity training, regular security audits, third-party
penetration testing, and a clear communication and reporting structure to facilitate timely responses to security incidents.
We
have a Cybersecurity Incident Response Plan (CIRP) that defines roles, responsibilities, and reporting mechanisms, as well as a structured
incident response process covering preparation, detection, response, documentation, and post-incident analysis. This plan outlines possible
cybersecurity threats and response measures for incidents such as denial-of-service attacks, malicious code attacks, website defacement,
data corruption, and data leakage. In addition, we maintain a Business Continuity Plan (BCP) in accordance with ISO 27001 to ensure operational
resilience, including detailed continuity procedures, system restoration timeframes, and recovery strategies for various scenarios.
To
address cybersecurity risks associated with third-party service providers, we have established procedures, policies, and tools for identifying,
assessing, and mitigating potential threats. This process begins with a third-party risk assessment, which is performed and updated as
needed. Our Information Security Guidelines for Suppliers ensure compliance with security standards, while our Access Control Policies
regulate third-party access to sensitive systems, and our Cloud System Information Security Procedures govern data security in cloud
environments. We also engage third-party consultants to assist in designing and enhancing our cybersecurity risk management framework,
including penetration testing and continuous threat monitoring.
To
date, we have not encountered cybersecurity threats or incidents that have had a material impact on our business.
Governance
Our
Board of Directors has specific oversight responsibility for cybersecurity, which also oversees our general risk management. The Board
of Directors reviews and discusses with management our policies, practices and risks related to information security and cybersecurity.
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Our
VP Engineering has primary responsibility for assessing, monitoring, and managing cybersecurity risks. Leaders meet quarterly to assess
cybersecurity risks, identify emerging threats, and evaluate our risk management framework. The Chief Financial Officer provides quarterly
updates to the Board of Directors on any cybersecurity-related risks. Our incident response plan includes notifying the Board of Directors
of any material threats or incidents as they arise. Although these members of our senior management do not have direct cybersecurity
expertise obtained through certifications, their experience managing the Company, which includes consulting and coordinating as necessary
with in-house and third-party information technology specialists, enables them to effectively assess and manage material risks from cybersecurity
threats.
This
structured approach ensures that our cybersecurity governance remains robust, proactive, and aligned with industry best practices.