Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
None.
Item 1C. Cybersecurity
The Sponsor recognizes the importance of managing
cybersecurity risks to protect its business operations, clients, and stakeholders. The Sponsor has implemented a comprehensive Cybersecurity
Policies and Procedures Plan for the Funds, which outlines our approach to identifying, assessing, and mitigating cybersecurity threats
and vulnerabilities in alignment with industry standards and best practices.
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Risk Management and Strategy
Cybersecurity Risk Assessment and Management :
The Funds have established a risk-based cybersecurity framework to manage cybersecurity risks effectively. This framework includes regular
assessments of its information systems, physical and virtual infrastructure, and the data therein, to identify potential cybersecurity
threats and vulnerabilities. Our cybersecurity strategy is integrated into the Funds’ overall risk management processes, with specific
consideration given to the confidentiality, integrity, and availability of our information systems.
Third-Party Service Providers : The Funds engage
with various third-party service providers for critical operations and services. The Sponsor conducts rigorous cybersecurity risk assessments
of all vendors and business partners with access to our networks or sensitive information. These assessments ensure that third-party cybersecurity
policies are robust and align with our cybersecurity standards.
Material Impact of Cybersecurity Threats :
To date, there have been no material cybersecurity incidents that have significantly impacted the Funds’ business strategies, results
of operations, or financial condition. The Sponsor continues to monitor our systems and processes to mitigate potential cybersecurity
risks actively.
Governance
Sponsor Oversight : The Sponsor of the Fund
has a fundamental role in overseeing the Funds’ cybersecurity risk management. The Sponsor receives regular updates on cybersecurity
matters from management and third-party service providers, ensuring that cybersecurity risks are managed proactively at the highest level
of the organization.
Management’s Role : Our Chief Compliance
Officer, Chang Kim, is responsible for overseeing the development, implementation, and ongoing management of the Fund’s Cybersecurity
Policies and Procedures including the monitoring of our systems for potential cybersecurity events and the implementation of preventive
and mitigative measures.
Item 2. Properties.
Not applicable.
Item 3. Legal Proceedings.
None
Item 4. Mine Safety Disclosures.
Not applicable.
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Part II.
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