Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS.
Not applicable.
ITEM
1C. CYBERSECURITY.
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Risk Management and Strategy
The Company recognizes 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. We have developed the following processes as part of our strategy for assessing, identifying,
and managing material risks from cybersecurity threats.
Managing Material Risks & Integrated
Overall Risk Management
We have integrated cybersecurity risk management
into our risk management processes. This integration is intended to ensure that cybersecurity considerations are part of our decision-making
processes. We continuously evaluate and address cybersecurity risks in alignment with our business objectives and operational needs.
We have adopted the standard 2FA (two factor authentication)
for all our eData access (emails, online storage, etc.). In addition, all our applications and third-party applications have timed, authentication
and environmental disposable cookie processes that force every user to reauthenticate their credentials. Our business transactional data
includes dumb access controls that are vendor-specific, a set or specified range of costs, faceless entry point, and a unique 4FA (four
factor authentication) process, protecting access to our banking and application systems.
Moreover, our commitment to data security extends beyond industry standards
through the implementation of advanced access controls. We have developed a sophisticated access control system, referred to as “dumb
access controls,” which limits access to only specific vendors within a predefined range of costs. This system operates through
a faceless entry point with a unique 4FA process, ensuring that access to sensitive banking or application systems is strictly controlled
and virtually nonexistent for unauthorized entities. These comprehensive security measures not only protect our business transactional
data but also uphold the integrity and confidentiality of our systems and information assets.
Engaging Third-Parties on Risk Management
Recognizing the complexity and evolving nature
of cybersecurity threats, our Chief Experience Officer periodically evaluates and tests our risk management systems. Our Chief Experience
Officer has specialized knowledge and insights, ensuring our cybersecurity strategies and processes remain at the forefront of industry
best practices.
Overseeing Third-Party Risk
Because we are aware of the risks associated with
third-party service providers, we implement 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 regular assessments by our Chief Experience Officer. This approach is designed to mitigate risks related to data breaches or
other security incidents originating from third parties.
Risks from Cybersecurity Threats
We have not encountered cybersecurity challenges
that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations,
or financial condition.
Governance
Board of Directors Oversight
Our board of directors oversees the management
of risks associated with cybersecurity threats.
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Management’s Role Managing Risk
The Company’s Chief Experience Officer is
primarily responsible for assessing, monitoring and managing our cybersecurity risks. The Chief Experience Officer must ensure that all
industry standard cybersecurity measures are functioning as required to prevent or detect cybersecurity threats and related risks. The
Chief Experience Officer provides briefings on cybersecurity threats and related risks to our Chief Executive Officer on a regular basis.
Our Chief Experience Officer has ten years of experience in the field of information technology. The Chief Experience Officer oversees
and tests our compliance with standards, remediates known risks, and leads our employee training program. The Chief Experience Officer
has extensive experience in cybersecurity and possesses the knowledge and skills and background and experience necessary, as described
in his biography.
Monitoring Cybersecurity Incidents
The Chief Experience Officer is continually informed
about the latest developments in cybersecurity, including potential threats and innovative risk management techniques. The Chief Experience
Officer implements and oversees processes for the regular monitoring of our information systems. This includes the deployment of industry-standard
security measures and regular system audits to identify potential vulnerabilities. In the event of a cybersecurity incident, the Chief
Experience Officer will implement an incident response plan. This plan includes immediate actions to mitigate the impact and long-term
strategies for remediation and prevention of future incidents.
Reporting to Board of Directors
Significant cybersecurity matters, and strategic
risk management decisions, will be escalated to the board of directors.