Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS.
None
ITEM
1C. CYBERSECURITY.
We
have implemented processes designed to help assess, identify, and manage risks from potential unauthorized occurrences on or through
our information technology systems that may result in adverse effects on the confidentiality, integrity, and availability of these
systems and the data residing therein. Through our IT consulting firm, we employ monitoring mechanisms controls, technologies,
systems, and other processes designed to help detect and respond to cybersecurity threats promptly including data loss, theft, misuse, or other security incidents or vulnerabilities affecting the data, and help maintain
a stable information technology environment. Reports are generated as needed
for management and the Board of Directors, providing insights into our cybersecurity posture, incidents, and remediation efforts. We
conduct regular assessments and testing of our controls, especially those related to the protection of financial information. The
implementation and management of these processes
are integrated with the Company’s overall operational risk management processes that seek to limit our exposure to
unnecessary risks across our operations and are overseen by the Audit Committee of the Board of Directors.
We
maintain an incident response plan that outlines the steps to be taken in the event of a cybersecurity incident. This plan includes
procedures to escalate, contain, investigate and remediate incidents, as well as to comply with any legal reporting requirements and
communicate with affected stakeholders. We seek to foster a culture of cybersecurity awareness and responsibility throughout the
organization.
The
Board of Directors has delegated oversight of risks related to the Company’s information system controls and security to the
Audit Committee of the Board of Directors. Our
cybersecurity program is managed by the Chief Compliance Officer (CCO), who has over 20 years of business experience as well as a
general familiarity with cybersecurity matters and an understanding of the potential financial impacts, disclosure obligations, and
enterprise risks to the Company as they relate to cybersecurity. The CCO regularly communicates with those responsible for
daily IT operations and infrastructure to assess potential cybersecurity threats and determine whether updates to the cybersecurity
strategy are necessary. The
CCO updates the Audit Committee on cybersecurity matters. The Audit Committee updates the full Board of Directors with respect to
cybersecurity matters.
Since
the beginning of the last fiscal year, we have not identified risks from known cybersecurity threats, including as a result of any prior
cybersecurity incidents, that have materially affected us. Although we are no t
currently aware of any risks from cybersecurity threats that have materially affected us, we face certain ongoing risks from cybersecurity
threats that, if realized, could have a material adverse effect on us, including our business strategy, results of operations, or financial
condition. Additional information on cybersecurity risks we face is discussed in Part 1, Item 1A, “Risk Factors” under the
heading “ Our business and operations may be significantly disrupted upon the occurrence of a catastrophic event, information
technology system failures or cyberattack .”