What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-03-31 compared with 2024-03-29 · 29 added, 30 removed, 25 unchanged (70% of the section changed)

16 unchanged sentences

training which includes phishing attack simulation testing.

key element of the Company’s Cybersecurity System is to mature the program to align with the Center for Internet Security

(CIS) Critical Security Controls security framework.

The CIS controls are designed based on real-world data about cyber-attacks, to

ensure that the measures are effective against current threats.

The framework provides a prioritized set of actions, which enables

the Company to focus its efforts on the most effective defensive measures first.

This prioritization helps in optimizing the use of

resources for maximum impact on security.

This strategy provides a structured and effective approach to cybersecurity, helping the

Company to protect its assets, comply with regulations, manage risks, and improve its overall security posture.

key element of the Company’s Cybersecurity System is to mature the program to align with the Center for Internet Security (CIS)

Critical Security Controls security framework.

CIS controls are designed based on real-world data about cyber-attacks, to ensure that

the measures are effective against current threats.

The framework provides a prioritized set of actions, which enables the Company to

focus its efforts on the most effective defensive measures first.

This prioritization helps in optimizing the use of resources for maximum

impact on security.

This strategy provides a structured and effective approach to cybersecurity, helping the Company to protect its assets,

comply with regulations, manage risks, and improve its overall security posture.

Company maintains cyber insurance coverage that may, subject to policy terms, conditions, and limitations, cover certain aspects of cybersecurity

6 unchanged sentences

oversight responsibility of information security risks to its Audit Committee.

Matters determined to present potential material impacts to the Company’s financial

results, operations, and/or reputation are reported by management to the Company’s Board of Directors or its Audit

Committee, as appropriate, in accordance with its escalation framework.

addition, the Company has established procedures to ensure that management personnel are informed in a timely manner of known

cybersecurity risks and incidents that may materially impact the Company’s operations and that timely public disclosure is

made as appropriate.

The Company’s Cybersecurity System is led by the Chief Information Officer (“CIO”) in

collaboration with a third-party virtual Chief Information Security Officer (“vCISO”) and other third-party

cybersecurity service providers which in turn assist in monitoring the Company’s exposure from significant information

technology suppliers, significant software as service providers and major vendors with access to the Company’s information

technology systems.

The Company’s CIO has 10 years of cybersecurity industry experience.

Further, team members who support the

Company’s cybersecurity program have relevant educational and industry experience through various roles involving information

technology, security, auditing, compliance, systems, and programming, as well as cybersecurity certifications such as a Certified

Information Systems Security Professional (CISSP) and Certified Information Security Manager (CISM).

During the last three years, the Company has not experienced a material security breach and, as a

result, the Company has not incurred any material expenses from such a breach.

Furthermore, during such time, the Company has not

been penalized or paid any amount under any information security breach settlement.

Matters determined to present potential material impacts

to the Company’s financial results, operations, and/or reputation are reported by management to the Company’s Board of Directors

or its Audit Committee, as appropriate, in accordance with its escalation framework.

addition, the Company has established procedures to ensure that management personnel are informed in a timely manner of known cybersecurity

risks and incidents that may materially impact the Company’s operations and that timely public disclosure is made as appropriate.

The Company’s Cybersecurity System is led by the Chief Information Officer (“CIO”) in collaboration with a third-party

virtual Chief Information Security Officer (“vCISO”) and other third-party cybersecurity service providers which in turn

assist in monitoring the Company’s exposure from significant information technology suppliers, significant software as service

providers and major vendors with access to the Company’s information technology systems.

The Company’s CIO has 10+ years

of cybersecurity industry experience.

Further, team members who support the Company’s cybersecurity program have relevant educational

and industry experience through various roles involving information technology, security, auditing, compliance, systems, and programming,

as well as cybersecurity certifications such as a Certified Information Systems Security Professional (CISSP) and Certified Information

Security Manager (CISM).

During the last three years, the Company has not experienced a material security breach and, as a result, the

Company has no t incurred any material expenses from such a breach.

Furthermore, during such time, the Company has not been penalized

or paid any amount under any information security breach settlement.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments