Item 1B. Unresolved Staff Comments
Item 1B. Unresolved
Staff Comments
None.
Item 1C. Cybersecurity
We maintain a comprehensive cybersecurity program
designed to protect our information systems and digital assets, including identity and access management controls, network security monitoring,
employee awareness training, and periodic third-party assessments. Our cybersecurity policies are reviewed by management and overseen
by the board’s audit committee at least annually. We regularly evaluate emerging threats and update our security controls and incident-response
procedures accordingly.
Incident and Remediation Summary
In May 2025, we detected unauthorized changes
to our domain, DNS, and email configurations originating from administrative credentials retained by a former employee. The impact was
limited to a brief email-routing disruption; all production systems remained fully operational. Based on internal reviews and independent
external assessment, we found no evidence of data exfiltration or compromise involving customer data, financial information, or internal
systems, and the issue was contained on the same day it was discovered.
Upon detection, we immediately purged and rotated
credentials across all critical systems, enforced company-wide multi-factor authentication, closed orphaned accounts, and moved registrar
and DNS administration under centralized secure access controls. We also hardened email authentication (SPF, DKIM, DMARC), implemented
registry-level domain locks and DNSSEC, and completed a secure migration of domain and DNS records to a new registrar environment.
We have since completed a forensic investigation,
automated off-boarding and access-revocation processes, established 24/7 SIEM/SOC monitoring for identity and domain anomalies, and conducted
targeted cybersecurity training. Our domain, DNS, and email operations are now fully stabilized and secured, with quarterly access reviews
and ongoing monitoring to ensure continued resilience.
The incident did not have a material impact on our operations or financial
condition.
Item 2. Properties.
Our principal executive offices are located at 276 5 th Avenue,
Suite 704 #739, New York, New York 10001 and B03-C-13A, Menara 3A, KL Eco City, No. 3 Jalan Bangsar, 59200 Kuala Lumpur, Malaysia. We
lease and maintain our offices, and we currently do not own any real estate.
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