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.”
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.
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