Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
None.
ITEM 1C. CYBERSECURITY
Risk management and strategy
We are in the process of implementing
various information security procedures designed to identify, assess and manage material risks from cybersecurity threats to our critical
computer networks, third party hosted services, communications systems, hardware and software, and our critical data, including intellectual
property, confidential information that is proprietary, strategic or competitive in nature.
Our Chief Information Officer,
Chief Legal Officer, Chief Executive Officer, Chief Financial Officer and Chief Administrative Officer help identify, assess and manage
the Company’s cybersecurity threats and risks. They will identify and assess risks from cybersecurity threats by monitoring and
evaluating our threat environment using various methods including, for example manual and automated tools, subscribing to reports and
services that identify cybersecurity threats, conducting scans of the threat environment, evaluating threats reported to us, internal
and external audits, conducting threat assessments for internal and external threats, third-party threat assessments and conducting vulnerability
assessments to identify vulnerabilities.
Depending on the environment,
we are in the process of implementing various technical, physical, and organizational measures, processes, standards and policies designed
to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data, including, for example: incident
response plan, incident detection, vulnerability management policy, network security controls, access controls, physical controls, systems
monitoring, vendor risk management program, employee training, penetration testing, systems monitoring.
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Our assessment and management
of material risks from cybersecurity threats will be integrated into the Company’s overall risk management processes. For example,
our Information Security Management committee will evaluate material risks from cybersecurity threats against our overall business objectives
and report to the audit committee of the board of directors, which evaluates our overall enterprise risk.
We use third-party service
providers to assist us from time to time to identify, assess, and manage material risks from cybersecurity threats, including for example,
professional services firms, including legal counsel, cybersecurity consultants, cybersecurity software providers and penetration testing
firms.
We use third-party service
providers to perform a variety of functions throughout our business, such as application providers and hosting companies.
For a description of the risks
from cybersecurity threats that may materially affect the Company and how they may do so, see our risk factors under Part I. Item 1A.
Risk Factors in this Annual Report on Form 10-K, including “Any unauthorized access to or disclosure or theft of personal information
we gather, store or use could harm our reputation and subject us to claims or litigation.”
Governance
The Audit Committee assists
our board of directors in addressing the Company’s cybersecurity risk management as part of its general oversight function. The
board of directors’ Audit Committee is responsible for overseeing Company’s cybersecurity risk management processes, including
oversight of mitigation of risks from cybersecurity threats. The Audit Committee regularly reviews and discusses the Company’s cybersecurity
risks with management, including the Company’s Chief Information Officer, General Counsel, Vice President of Human Resources and
Vice President of Operations.
Our Vice President of Information
Technology is responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into the Company’s
overall risk management strategy, and communicating key priorities to relevant personnel. The Chief Financial Officer is responsible for
approving budgets, helping prepare for cybersecurity incidents, approving cybersecurity processes, and reviewing security assessments
and other security-related reports.
Our cybersecurity incident
response policy is being designed to escalate certain cybersecurity incidents to members of management depending on the circumstances.
The Company’s Chief Executive Officer and Chief Information Officer work to help the Company mitigate and remediate cybersecurity
incidents of which they are notified . In addition, the Company’s incident response policy will include reporting certain cybersecurity
incidents to the Audit Committee of the board of directors.