Item 1B. Unresolved Staff Comments
Item
1B.
Unresolved
Staff Comments
Not
applicable to smaller companies.
Item 1C.
Cybersecurity
Risk
Management and Strategy
The
Company has processes for assessing, identifying, and managing material risks from cybersecurity threats. These processes are integrated
into the Company’s overall risk management systems, as overseen by the Company’s board of directors, primarily through its
audit committee. These processes also include overseeing and identifying risks from cybersecurity threats associated with the use of
third-party service providers. The Company conducts security assessments of certain third-party providers before engagement and has established
monitoring procedures in its effort to mitigate risks related to data breaches or other security incidents originating from third parties.
The Company has a third-party consultant who, from time to time, evaluates any potential cybersecurity risks on the Company’s
behalf.
Governance
Board
of Directors
The
audit committee of the Company’s board of directors, with the input of management, oversees the Company’s internal
controls, including internal controls designed to assess, identify, and manage material risks from cybersecurity threats. The audit
committee is informed of material risks from cybersecurity threats by the Company’s Chief Executive Officer and interim Chief Financial
Officer and, given the size of the Company, its IT consultant. In the event that there were ever suspicions of cybersecurity risks,
updates on such risks, including material risks and threats, would be provided to the Company’s audit committee and the
Company’s board of directors as required. Given the limited nature of the Company’s IT infrastructure, in the conduct of
its business, there have not been any cybersecurity issues.
Management
Under
the oversight of the audit committee of the Company’s board of directors, and as directed by the Company’s Chief Executive
Officer who, from time to time, engages the Company’s IT consultant to review the security of its IT structure is primarily responsible
for the assessment and management of material cybersecurity risks. The IT consultant has more than 20 years of experience and is fully
capable of dealing with any potential cybersecurity risks.
The
audit committee of the Company’s board of directors, with the assistance of the Company’s interim Chief Financial
Officer, is responsible for overseeing the establishment and effectiveness of controls and other procedures, including controls and
procedures related to the public disclosure of material cybersecurity matters.
As
of the date of this report, the Company is not aware of any cybersecurity incidents that have materially affected or are reasonably likely
to materially affect the Company, including its business strategy, results of operations, or financial condition and that are required
to be reported in this report. For further discussion of the risks associated with cybersecurity incidents, see the cybersecurity risk
factors in Item 1A. Risk Factors in this report.
Item
2.
Properties
The
Company has access to its corporate offices at 271 Brock Street, Peterborough, Ontario Canada K9H 2P8 and its main corporate telephone
number is (877) 334-3820. In the previous four years we have operated from home offices and continue to do so and will use the Corporate
Offices on an as needed basis.
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