UNRESOLVED STAFF COMMENTS
−Removed: Not applicable.
CYBERSECURITY
−Removed: We are a SPAC with no business
−Removed: Since our IPO, our sole business activity has been identifying and evaluating suitable acquisition transaction candidates.
−Removed: Therefore, we do not consider that we face significant cybersecurity risk and have not adopted any cybersecurity risk management program
−Removed: or formal processes for assessing cybersecurity risk.
−Removed: Our Board is generally responsible for the oversight of risks from cybersecurity
−Removed: threats, if there is any .
−Removed: We have not encountered any cybersecurity incidents since our IPO.
+Added: Administration
+Added: The Board of Directors of
+Added: our company is responsible for overseeing cybersecurity-related risks.
+Added: The Board shall:
+Added: (i) monitor the disclosure of cybersecurity matters
+Added: in current or periodic reports;
+Added: (ii) review quarterly updates on significant cybersecurity incidents or major threat risks submitted by
+Added: management, along with any resulting disclosure issues;
+Added: and (iii) examine cybersecurity disclosures in the annual report (Form 10-K) filed
+Added: by management.
+Added: At the managerial level,
+Added: our cybersecurity team is responsible for monitoring and mitigating cybersecurity risks, including those associated with third-party service
+Added: The team investigates and responds to any suspicious activities within our data environment.
+Added: Upon identifying significant cybersecurity
+Added: threats or incidents, our cybersecurity team reports them to the head of the Information Technology and Cybersecurity Department, who
+Added: assumes responsibility for managing risks related to such major cybersecurity incidents and oversees preventive, mitigation, and remediation
+Added: The head of our IT and Cybersecurity functions must report the status of significant cybersecurity threats, major cybersecurity
+Added: incidents, or other relevant risks to the Board of Directors and, when necessary, discuss disclosure matters with the Board regarding
+Added: critical cybersecurity threats or incidents.
+Added: The head of IT and Cybersecurity functions possesses extensive experience in cybersecurity,
+Added: with specialized expertise in cybersecurity risk management and compliance.
+Added: In the event of a cybersecurity
+Added: incident, our cybersecurity team will immediately assemble personnel to conduct an internal assessment.
+Added: If further analysis determines
+Added: that the incident may constitute a major cybersecurity breach, our cybersecurity team will promptly report the incident and evaluation
+Added: results to the heads of our IT and cybersecurity departments, and engage external legal counsel for consultation when appropriate.
+Added: to public disclosure, our management team must prepare disclosure materials regarding the cybersecurity incident for review and approval
+Added: by the board of directors.
+Added: Risk Management and Strategies
+Added: We have implemented comprehensive
+Added: procedures to ensure effectiveness in cybersecurity management, policies, governance, and reporting of cybersecurity risks.
+Added: Additionally,
+Added: we have integrated cybersecurity risk management into our overall enterprise risk management system.
+Added: We have established a comprehensive
+Added: cybersecurity threat defense system to address both internal and external threats.
+Added: This system covers multiple layers including network
+Added: security, host security, and application security, integrating systematic capabilities such as threat defense, monitoring, analysis, response,
+Added: deception, and countermeasures.
+Added: We are committed to managing cybersecurity risks and protecting sensitive information through various
+Added: approaches, including technical safeguards, procedural requirements, a robust program for monitoring our enterprise networks and applications,
+Added: continuous testing of internal and external security vendors across all aspects of security posture, a well-established incident response
+Added: program, and regular employee training.
+Added: Our cybersecurity team conducts regular monitoring of application operations, platform status,
+Added: and infrastructure health to enable rapid response to potential issues, including emerging cybersecurity threats.
+Added: As of the reporting date
+Added: of this annual report, we have not experienced any major cybersecurity incidents, nor have we identified any significant cybersecurity
+Added: threats that have affected or could reasonably affect the Company, its business strategies, operational results, or financial condition.
+Added: Our cybersecurity risk assessment
+Added: and management processes are implemented and maintained by a third-party service provider reporting to the Company’s management.
+Added: is also responsible for integrating cybersecurity considerations into our overall risk management strategy, communicating key priorities
+Added: to employees, approving budgets, helping to prepare for cybersecurity incidents, approving cybersecurity processes, reviewing security
+Added: assessments and making required disclosures.
+Added: Management participates in cybersecurity incident response efforts by being a member of the
+Added: incident response team and helping direct our response to cybersecurity incidents.
+Added: Our board of directors addresses
+Added: our cybersecurity risk management as part of its general oversight function.
+Added: The Audit Committee of the board of directors is responsible
+Added: for overseeing our cybersecurity risk management processes, including oversight and mitigation of risks from cybersecurity threats.
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.