Item 1B. Unresolved Staff Comments
Item
1B. Unresolved Staff Comments.
None.
Item
1C. Cybersecurity.
The
Company employs internal resources and third-party service providers to manage, operate and administer our day-to-day operations, business
and affairs, subject to the direction and supervision of the Board. The Board recognizes the critical importance of maintaining the trust
and confidence of our business partners. The Board plays an active role in overseeing management of our risks, and cybersecurity represents
an important component of the Company’s overall approach to risk management and oversight. The Company and its management are committed
to protecting the confidentiality of all non-public information related to the Company’s clients, shareholders and their personnel.
Risk
Management and Strategy
The
Company relies on its Management and employees to execute its comprehensive cybersecurity program, and has adopted a written information
security program, which is designed to address applicable requirements under Regulation S-P and the FTC Safeguards Rule . Consequently,
the Company also relies on the processes for assessing, identifying, and managing material risks from cybersecurity threats. The processes
include, among other things, maintaining secure digital or physical access to information assets, using manual and automated detection
methods for malicious code, due diligence of third-party vendors, and engaging a leading provider of cybersecurity services to assess
and manage cybersecurity risk. For third-party service vendors that perform a variety of important functions for our business, we seek
to engage reliable, reputable service vendors that maintain cybersecurity programs.
All
of the Company’s officers and employees are subject to its policies and procedures. The Company utilizes both internal and third-party
cybersecurity services, including threat detection and response, vulnerability assessment and monitoring, security incident response
and recovery and general cybersecurity education and awareness. We engage in periodic assessment and training regarding the policies,
standards and practices designed to address cybersecurity threats and incidents. Our cybersecurity risk management is integrated into
our overall enterprise risk management and shares common methodologies, reporting channels and governance processes that apply across
our enterprise risk management.
To
date, we have not experienced any cybersecurity threats, including as a result of any previous cybersecurity incidents, that have materially
affected the Company and we are not aware of any cybersecurity threats that are reasonably likely to affect the Company, including its
business strategy, results of operations or financial condition.
Governance
Management
oversees the Company’s cybersecurity risk management process. Management has adopted a charter that provides to periodically review
and discuss with the Board the guidelines and policies with respect to risk assessment and risk management of cybersecurity and other
risk exposures relevant to the Company’s computerized information system controls and security. Management may receive additional
training in cybersecurity and data privacy matters to enable its oversight of such risks. Management will report to the Board on the
substance of such reviews and discussions and, as necessary, recommend to the Board such actions as management deems appropriate.
As
noted above, the Company relies on our internal Information Systems in connection with the Company’s day-to-day operations. The
Company relies on the internal processes for assessing, identifying, and managing material risks from cybersecurity threats.
The
Company’s Chief Financial Officer, Chief Legal Officer, and Head of IT work collaboratively with other employees of the Company
to ensure protection of the Company’s Information Systems from cybersecurity threats and to promptly respond to any cybersecurity
incidents. These members of the Company’s management team monitor the prevention, detection, mitigation and remediation of cybersecurity
threats and incidents and report such threats and incidents to the board when appropriate. They have gained relevant knowledge, skills
and experience in information technology and cybersecurity risk management, including overseeing third-party vendors in such areas, over
their careers at the Company or other organizations.
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