Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
None.
ITEM 1C. CYBERSECURITY
The Company’s cybersecurity program is designed
to identify, assess, and manage material risks from cybersecurity threats. The Company relies on Saratoga Investment Advisors to implement
the cybersecurity program. The cyber risk management program involves risk assessments relating to the information systems of Saratoga
Investment Advisors, incident response training and testing, implementation of security measures, identification of sensitive information
assets (“Critical Information”) and ongoing monitoring of systems and networks and assessment of the associated risks on an
annual basis, including networks on which the Company relies on. The Chief Compliance Officer, along with the Company’s external
information technology consultant (the “IT Consultant”), actively monitors the current threat landscape in an effort to identify
material risks arising from new and evolving cybersecurity threats. The Company and Saratoga Investment Advisors have engaged external
experts, including consultants, such as the IT Consultant, to evaluate cybersecurity measures and risk management processes, and depends
on and engages various third parties, including suppliers, vendors, and service providers. The compliance team of the Company and Saratoga
Investment Advisors will conduct ongoing due diligence of its significant service providers to determine whether the cybersecurity programs
of service providers include, among other things, procedures and safeguards designed to ensure the protection of Critical Information
and the information of the Company’s stockholders and portfolio companies, as well as adequate responses in the case of a cybersecurity
incident.
Board Oversight
of Cybersecurity Risks
The Board has the primary responsibility for overseeing
and reviewing the guidelines and policies with respect to the Company’s risk management, including risks associated with cybersecurity
threats. The Chief Compliance Officer will periodically report to the Board on cybersecurity matters, such as the overall state of the
Company’s cybersecurity program, information on the current threat landscape, and risks from cybersecurity threats and material
cybersecurity incidents.
Management’s Role
in Cybersecurity Risk Management
The Company’s management is responsible
for assessing and managing material risks from cybersecurity threats, in consultations with cybersecurity consultants. The compliance
team of the Company will maintain effective disclosure controls and procedures to ensure timely identification, consideration, and disclosure
of material cybersecurity incidents, including through timely reporting to management and the Board. The Chief Compliance Officer, in
consultation with the IT Consultant, will periodically determine whether the Company requires additional information technology or cybersecurity
support.
Assessment of Cybersecurity
Risk
The potential impact of risks from cybersecurity
threats are assessed on an ongoing basis, and how such risks could materially affect the Company’s business strategy, operational
results, and financial condition are regularly evaluated. During the reporting period, the Company has not identified any risks from cybersecurity
threats, including as a result of previous cybersecurity incidents, that the Company believes has materially affected, or are reasonably
likely to materially affect, the Company, including the Company’s business strategy, operational results, and financial condition.
ITEM 2. PROPERTIES
We do not own any real estate or other physical
properties important to our operations, however, an affiliate of our Investment Adviser leases office space for our executive offices
at 535 Madison Avenue, New York, New York 10022.