Item 1B. Unresolved Staff Comments
Item 1B.
Unresolved Staff Comments.
None.
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Item 1C.
Cybersecurity.
Risk
Management and Strategy
We
have established policies and processes for assessing, identifying, and managing material risk from cybersecurity threats and integrated
these processes into our overall risk management systems and processes. We assess material risks from cybersecurity threats, including
any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality,
integrity, or availability of our information systems or any information residing therein.
We
conduct technical risk assessments to identify cybersecurity threats, as well as assessments in the event of a material change in our
business practices that may affect information systems that are vulnerable to such cybersecurity threats. We conduct programmatic risk
assessments, including identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that
could result from such risks, and the sufficiency of existing policies, procedures, systems, and safeguards in place to manage such risks.
Following
these risk assessments, we evaluate whether and how to re-design, implement, and maintain reasonable safeguards to minimize identified
risks; evaluate how to reasonably address any identified gaps in existing safeguards; and regularly monitor the effectiveness of our
safeguards. Our Manager of Information Technology, who has over 25 years of information technology experience, and our Chief Operating
Officer, who has over 15 years of information technology management experience, manage the risk assessment and mitigation process.
As
part of our overall risk management system, we monitor and test our safeguards and train our employees on these safeguards, in collaboration
with human resources, information technology and management. Personnel at all levels and departments are made aware of our cybersecurity
policies through internal communications, training and annual policy updates, and are requested to promptly report any suspected breach
of our information systems to management. Additionally, we have implemented annual security training for all employees and staff, which
includes targeting the recognition of phishing campaigns.
We
continually review and update our processes to safeguard our information systems. This includes the deployment of advanced security measures
and regular audits. We have implemented multi-factor authentication (MFA) for email and cloud services and implement controls for incoming
email to mitigate various cyber-attacks, including phishing attacks, malware, viruses and other security breaches. Additionally, we review
and revise, as necessary, our incident response and disaster recovery policies on an annual basis.
For
additional information regarding whether any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents,
have materially affected or are reasonably likely to materially affect us , including our business strategy, results of operations, or
financial condition, please refer to Item 1A, “Risk Factors,” in this Report on Form 10-K, including the risk factors entitled
“Third parties might attempt to gain unauthorized access to our network or seek to compromise our products and services.”
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Governance
A
role of our board of directors is informed oversight of our risk management process, including risks from cybersecurity threats. Our
board of directors is responsible for monitoring and assessing strategic risk exposure, and our management is responsible for the day-to-day
management of the material risks we face. Our board of directors administers its cybersecurity risk function in coordination with the
oversight and periodic review of the audit committee. In the event of a cybersecurity incident impacting us, management will report to
our board of directors and provide updates on management’s incident response plan for addressing and mitigating any risks associated
with such an incident.
Our
cybersecurity incident response and vulnerability management policies are designed to escalate certain cybersecurity incidents and threats
to management members depending on the circumstances, including the Chief Executive Officer and Chief Financial Officer. The Chief Executive
Officer and Chief Financial Officer work with our incident response team to help the Company mitigate and remediate cybersecurity incidents
of which they are notified. In addition, the Company’s management and its designees report to the board of directors for certain
cybersecurity incidents.
Our
board of directors receives periodic reports from management and its designees concerning our significant cybersecurity threats and risks,
and the processes we plan to implement and/or have implemented to address them.