Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS.
Not applicable.
ITEM 1C. CYBERSECURITY.
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 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
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.
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Engaging Risk Management Systems and Third-Party
Consultant
Recognizing the complexity and evolving nature
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
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 Technology 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.
Management’s Role Managing Risk
The Company’s Chief Technology Officer,
Chief Operating Officer, and Technology Consultant are primarily responsible for assessing, monitoring and managing our cybersecurity
risks. 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
technology. 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 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
Significant cybersecurity matters, and strategic
risk management decisions, will be escalated to the board of directors.
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