Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS.
None.
ITEM 1C. CYBERSECURITY.
Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure
We recognize the importance of identifying, assessing
and managing material risks associated with cybersecurity threats. We maintain an information technology and cybersecurity program appropriate
for a company our size, taking into account our operations and risks.
Risk Management and Strategy
Our cybersecurity risk management approach includes:
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A flat network infrastructure powered by Ubiquiti (UBNT) equipment
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Unified firewall and security management through our UDM Pro device
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Remote access controlled via L2TP VPN with pre-shared key authentication
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Regular data backups using RoboCopy, scheduled daily at 2pm EST
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Physical security through UniFi Access control system and ADT security cameras covering the entire building
We utilize third-party services for certain technology
functions, including Microsoft 365 for email, GoDaddy for web hosting, and CodeTwo for email signatures. While we depend on the digital
technologies of these third parties, we monitor our systems to protect against unauthorized access.
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Governance
Our Board of Directors is responsible for overseeing
cybersecurity risks. Management, led by our IT department, is responsible for the operational oversight of the company-wide cybersecurity
strategy and standards. Administrative access to our critical systems is limited to authorized personnel and documented in our IT inventory.
Given our size and operations, we maintain administrative controls including:
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Defined administrator accounts with appropriate access levels
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Documentation of system access credentials
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Regular updates to firmware on network infrastructure (current versions documented)
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Backup verification and monitoring
Cybersecurity Risks
As of April 15, 2025, we are not aware of any cybersecurity
threats, including as a result of any previous cybersecurity incidents, that have materially affected our business strategy, results of
operations, or financial condition, or are reasonably likely to have such a material effect. However, like all organizations, we face
potential risks from cybersecurity threats which could materially affect our operations or financial condition if they were to occur.
Areas for potential improvement in our cybersecurity
posture include upgrading our WiFi access points, and implementing a cloud backup solution to complement our current on-site backup strategy.
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