Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
Item
1C. Cybersecurity
Risk
management and strategy
We
recognize the critical importance of developing, implementing, and maintaining robust cybersecurity measures to safeguard our information
systems and protect the confidentiality, integrity, and availability of our data.
Managing
Material Risks & Integrated Overall Risk Management
We
have strategically integrated cybersecurity risk management into our broader risk management framework to promote a company-wide culture
of cybersecurity risk management. This integration ensures that cybersecurity considerations are an integral part of our decision-making
processes at every level. Our management team works closely with our IT department to continuously evaluate and address cybersecurity
risks in alignment with our business objectives and operational needs.
Oversee
Third-party Risk
Because
we are aware of the risks associated with third-party service providers, we have implemented stringent processes to oversee and manage
these risks. We conduct thorough security assessments of all third-party providers before engagement and maintain ongoing monitoring
to ensure compliance with our cybersecurity standards. The monitoring includes annual assessments of the SOC reports (or international
equivalent) of our providers and implementing complementary controls. This approach is designed to mitigate risks related to data breaches
or other security incidents originating from third parties.
Governance
Cybersecurity
risk management is an integral part of the Company’s enterprise risk management framework and is overseen at both the Board and
management levels.
Board
Oversight
The
Company’s Board of Directors maintains ultimate oversight of cybersecurity risks. The Audit Committee, which is composed entirely
of independent directors, has primary responsibility for overseeing cybersecurity risk as part of its broader oversight of information
technology and risk management. The Audit Committee receives regular briefings—at least quarterly—from management on cybersecurity
matters.
The
full Board is also periodically briefed on material cybersecurity risks, incident response preparedness, and significant security incidents,
if any.
Management
Oversight
Day-to-day
responsibility for assessing, managing, and mitigating cybersecurity risk lies with the Company’s Chief Financial Officer and Chief
Operating Officer (the CFOO), who reports to the President and has a dotted-line reporting relationship to the Audit Committee.
As
of the date of this filing, the Company has not experienced a cybersecurity incident that has materially affected, or is reasonably likely
to materially affect, its business, financial condition, or results of operations.
ITEM
2. PROPERTIES
Our
corporate headquarters is located in London, England where we lease office space under a lease that expires in April 2026. In addition
to our corporate headquarters, we have an office in Hong Kong, where we lease office space that expires in February 2026.
ITEM
3. LEGAL PROCEEDINGS
For
a discussion of our legal proceedings, refer to Note 14 “ Commitments and Contingencies ,” in the notes to our audited
consolidated financial statements of this Annual Report.
ITEM
4. MINE SAFETY DISCLOSURES
Not
applicable.
29
PART
II
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