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, product, 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, 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 receives 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 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 Interim 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.