Item 1B. Unresolved Staff Comments
Item
1B – UNRESOLVED STAFF COMMENTS
None.
Item
1C – CYBERSECURITY
Our
IT networks and related systems are critical to the operation of our business and essential to our ability to successfully perform day-to-day
operations. We have implemented security measures and controls to mitigate risks to our IT networks and related systems, including the
risks of disruption, release of confidential information, and corruption of data. This includes a variety of technological tools and
systems, including both company-owned IT and technology services provided by outside parties to support our critical functions, and in
particular, the following:
●
External
port penetration testing;
●
Security
violation report reviewed routinely for any abnormalities;
●
Ongoing
employee training and testing on cyber risks;
●
Site
assessment, procedural review and testing in connection with cyber insurance renewals; and Routine server back-up.
In
terms of governance, the Company employs an IT director, with over 20 years of relevant experience, who supervises our other IT employees
and is also responsible for our outside technology services. Our IT director reports directly to our President and reviews cybersecurity
assessments with our President on at least a monthly basis. Our President is responsible for escalating any cybersecurity matters as
appropriate, in consultation with our General Counsel. Our Board of Directors is ultimately responsible for oversight of cybersecurity
risk management and receives regular reports from, and engages in regular dialogue with, Company management.
While
we believe we have implemented appropriate measures and controls for our business, there can of course be no assurance that cyber incidents
will be prevented or of their severity if they occur. To date, to our knowledge, there have been no incidents materially affecting the
Company, but a material incident could result in disruption of critical IT networks and systems, impeding our operations, release of
confidential information, and/or corruption of data. Such an incident could damage our reputation and brand and our future sales and
could expose us to potential liability. See Item 1A. Risk Factors - A cyber security incident or other technology disruption could harm
us.
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