Item 1B. Unresolved Staff Comments
ITEM 1B.
UNRESOLVED STAFF COMMENTS
None.
ITEM 1C.
CYBERSECURITY
Risk Management and Strategy
The Company’s information security program consists
of various processes designed to ensure that the Company and its electronic assets are shielded from cyber events that may compromise
the Company’s ability to successfully execute its business on a day-to-day basis. These processes cover areas such as, but not limited
to, risk management, access control, anti-virus management, sensitive data management, electronic communication, risk/security reporting,
incident response planning and business continuation planning. Our Information Security Team is comprised of our Chief Financial Officer
and third-party IT support. It is responsible for (i) administering the Company’s policies and procedures in conjunction with our
third-party information technology provider, Netranom Communications (“IT Provider”); (ii) distributing our policies to consultants
and providing training; (iii) responding to consultant inquiries regarding our policies; (iv) overseeing our cybersecurity program and
leading incident response efforts; (v) monitoring for cybersecurity-related legal or regulatory developments; coordinating with management,
our IT Provider and /or legal counsel to discuss cybersecurity-related issues or topics; and (vi) reviewing and updating our policies
as necessary and on an annual basis.
The Information Security Team carries out risk management
primarily by outsourcing risks to those companies and agencies that specialize in handling such risks and that have the appropriate resources
to do so. Our IT Provider has more than 20 years of experience in the latest technologies and experiences in a variety of network configurations.
The IT Provider also has the ability to analyze cybersecurity presence and technology processes to provide reports as needed. The
IT Provider currently manages and monitors our network, configures systems and controls, provides assistance and support during an incident
and detects threats through antivirus scans, firewalls and base level spam filters.
Governance
Management is ultimately responsible for assessing
and managing the Company’s cybersecurity risk. The information security program is overseen by the Chief Financial Officer . The
Board is then briefed upon the occurrence of any cybersecurity incidents and is provided an overview of the information security program
on an annual basis, including updates on the IT team, IT training, implementation of IT controls, cybersecurity testing, the incident
response process and the cybersecurity assets of the Company.
In the last fiscal year, we have not identified any
risks from known cybersecurity threats that have materially affected the Company or our financial position, results of operations and/or
cash flows. We continue to invest in cybersecurity and the resiliency of our networks and to enhance our internal controls and processes,
which are designed to help protect our systems and infrastructure, and the information they contain. For more information regarding the
risks we face from cybersecurity threats, please see “Risk Factors.”