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 have implemented 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. The program is subject to ongoing review and improvement
as our threat environment and operations evolve. Central to our cybersecurity efforts is a robust incident response plan designed to
address potential cyber incidents swiftly and effectively.
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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
include:
● conducting risk assessments to identify 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
● Cybersecurity awareness training for employees to promote a security-conscious culture and reduce the risk of human error.
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 responsible for 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.