What changed in this filing

/stocks — the workspaceLOADING

Item 1B. Unresolved Staff Comments

2025-03-31 compared with 2024-04-02 · 44 added, 40 removed, 39 unchanged (68% of the section changed)

6 unchanged sentences

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 maintain cybersecurity insurance coverage that provides protection against potential

losses arising from certain cybersecurity incidents.

In addition, we have developed the following processes as part of our strategy for

assessing, identifying, and managing material risks from cybersecurity threats.

Managing Material Risks and Integrated Overall

Risk Management

We have integrated cybersecurity risk management

9 unchanged sentences

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

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.

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 Risk Management Systems and Third-Party

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.

of cybersecurity threats, we use risk management systems developed and tested by external experts, including cybersecurity assessors,

consultants, and auditors.

These risk management systems enable us to leverage specialized knowledge and insights as part of our cybersecurity

strategies and processes.

These systems are assessed and maintained with the assistance of third-party service providers, including a

Technology Consultant engaged by the Company.

Overseeing Third-Party Risk

4 unchanged sentences

The monitoring

includes regular assessments by our Chief Experience Officer.

includes regular assessments by our Chief Technology Officer.

This approach is designed to mitigate risks related to data breaches or

8 unchanged sentences

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.

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.

The Company’s Chief Technology Officer,

Chief Operating Officer, and Technology Consultant are primarily responsible for assessing, monitoring and managing our cybersecurity

Our Chief Technology Officer must ensure that all industry standard cybersecurity measures are functioning as required to prevent

or detect cybersecurity threats and related risks.

The Chief Technology Officer provides briefings on cybersecurity threats and related

risks to our Chief Executive Officer on a regular basis.

Our Chief Technology Officer has nine years of experience in the field of information

The Chief Technology Officer oversees and tests our compliance with standards, remediates known risks, and leads our employee

training program.

The Company’s Chief Technology Officer and Technology Consultant have extensive experience in cybersecurity and

possess the necessary knowledge, skills, background, and experience.

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.

The Company’s Chief Technology Officer and

Technology Consultant are continually informed about the latest developments in cybersecurity, including potential threats and innovative

risk management techniques.

The Chief Technology Officer and Technical Consultant implement and oversee 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 Technology Officer and Technical Consultant 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

2 unchanged sentences

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments