Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None
ITEM
1C. CYBERSECURITY
Risk
Management and Strategy
We
rely on our management and third-party service providers to assess, identify, and manage material risks from cybersecurity threats. Our
cybersecurity function is integrated within our broader risk management function that identifies, monitors, and mitigates strategic,
operational, financial, and legal risks.
Depending
on the environment, we implement and maintain various technical, physical, and organizational measures and/or policies designed to manage
and mitigate material risks from cybersecurity threats to our information systems. These include password requirements, onboarding and
termination processes, and other access controls. We also use third-party service providers to assist in assessing our controls and security
systems that identify and prevent malicious activity or unauthorized access on an ongoing basis such as firewalls and email security,
among others.
To
operate our business, we utilize certain third-party service providers to perform a significant portion of our critical functions. We
seek to engage reliable, reputable service providers that maintain cybersecurity programs. We currently do not have any formal processes
to oversee or identify cybersecurity risks associated with third-party service providers but our management generally evaluates such
risks.
We
are not aware of any risks from cybersecurity threats, including as a result of any cybersecurity incidents, which have materially affected
or are reasonably likely to materially affect our company, including our business strategy, results of operations, or financial condition.
Governance
Our
board of directors considers cybersecurity risk as part of its enterprise risk management oversight function. Our management team is
responsible for assessing and managing risks from cybersecurity threats. Because of the small size of our company, we do not have personnel
dedicated to information technology and cybersecurity matters.
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