Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
None.
Item 1C. Cybersecurity.
Cybersecurity Risk Management and Strategy
We, like other companies in
our industry, face several cybersecurity risks in connection with our business. Our business strategy, results of operations, and financial
condition have not, to date, been materially affected by risks from cybersecurity threats. During the reporting period, we have not experienced
any material cyber incidents, nor have we experienced a series of immaterial incidents, which would require disclosure.
We are in the process of
implementing our cybersecurity program, which is aimed at safeguarding the confidentiality, integrity, and availability of our essential
systems and information, and is designed to detect and mitigate risks from cybersecurity threats to our data and our systems. Central
to our cybersecurity efforts is a robust incident response plan designed to address potential cyber incidents swiftly and effectively.
In designing and evaluating
our cybersecurity program, we have adopted the National Institute of Standards and Technology Cybersecurity Framework (“NIST CSF
2.0”) as a guiding principle. It is important to clarify that our use of the NIST CSF 2.0 is for guidance purposes to frame our
risk identification, assessment, and management processes and does not equate to compliance with any specific technical standards or requirements.
The key components of our
cybersecurity program will include:
●
conducting risk assessments to pinpoint material cybersecurity threats to our critical systems, data, products, services, and overall IT infrastructure;
●
a third-party security expert consultant overseeing the risk assessment process, maintenance of security controls, and coordination of responses to cybersecurity incidents;
●
engagement with external service providers to evaluate, enhance, or support our security measures;
●
an incident response plan outlining specific procedures for managing cybersecurity incidents; and
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Cybersecurity Governance
The governance of cybersecurity
risks is a critical function of our Board of Directors, with the Audit Committee playing a key role in the oversight of cybersecurity
and related technology risks. The Audit Committee is tasked with monitoring the effectiveness of our cybersecurity risk management program
as implemented by management.
The Audit Committee will
receive regular updates from management on the state of cybersecurity risks facing the Company. This includes briefings on any significant
cyber incidents and ongoing risk management efforts. These updates will enable the Audit Committee to provide informed reports on cybersecurity
matters to the full Board.
The responsibility for day-to-day
management of cybersecurity risks lies with our management team, including the Chief Financial Officer. This team is at the forefront
of our cybersecurity initiatives, coordinating both internal and external resources to anticipate, identify, and mitigate cyber threats.
Our approach includes regular updates from our third-party security expert consultant, leveraging intelligence from various sources, and
utilizing advanced security tools to protect our digital environment. Our third-party security expert consultant has over 30 years of
experience with cybersecurity, information technology development and deployment, and information technology risk assessment and management,
including information security management.