Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS.
None.
ITEM
1C. CYBERSECURITY.
We
manage cybersecurity and data protection through a continuously evolving framework, as described in further detail below. The framework
allows us to identify, assess and mitigate the risks we face, and assists us in establishing policies and safeguards to protect our systems
and the information of those we serve.
49
Risk
Management Strategy
The
Company’s cybersecurity risk management program is focused on the following key areas:
● Governance: Our Audit Committee of our Board of Directors has oversight of our cybersecurity program and is in the process of implementing procedures to obtain regular updates on our cybersecurity program, including recent developments, key initiatives to strengthen our systems, applicable industry standards, vulnerability assessments, third-party and independent reviews, and other information security considerations. Our cybersecurity program is led by Mohan Gundu, our Senior Vice President of Engineering and Cloud Platform. Mr. Gundu holds an MBA in Business Administration from Babson College, a Master of Science in Computer Science from Worcester Polytechnic Institute and a Bachelor of Technology in Electronics and Communication from Jawaharlal Nehru Technological University. Mr. Gundu has over 20 years of development experience focused on architecture and security. Mr. Gundu has led transformative projects, cultivated cybersecurity awareness and promoted holistic cybersecurity practices that were aligned with policies defined and approved by management. Mr. Gundu and his team are dedicated to integrating security into development, ensuring robust cloud security, enforcing security policies, and driving shift-left practices with operational excellence at the Company.
● Approach:
We use a cross-functional approach to identifying, preventing, assessing, and mitigating
cybersecurity threats and incidents, while also implementing controls and procedures that
are designed to provide for the prompt escalation of cybersecurity incidents and support
appropriate public disclosure and reporting of incidents as required in a timely manner.
Our cybersecurity efforts include the use of risk-based administrative, technical, and physical
controls. Veea has implemented policies, procedures, systems and tools designed to help safeguard
our systems and data, including firewalls, intrusion detection systems, access controls including
multi-factor authentication, vulnerability scanning, penetration testing, independent third-party
control audits, and other systems and processes.
● Incident
Response Planning: We maintain a breach reporting and resolution plan that includes defined
processes, roles, communications, responsibilities and procedures for responding to cybersecurity
incidents and other events that impact our operations. Our incident response plans are tested
and evaluated on a regular basis.
● Third-Party Risk Management: Our business relies on various services from third party service providers that could adversely impact the security of our systems and business. We have implemented processes designed to identify and assess cybersecurity risks associated with our use of third-party service providers.
● Education
and Awareness: We provide various training programs and tools to employees so they can avoid
risky practices and help us promptly identify potential or actual issues. We also have global
incident response procedures, global service tools to log incidents and issues for investigation,
and an ethics line to report concerns and follow up on matters already reported. The Compliance
team, led by our Chief Technology Officer, develops and implements our strategy, as well
as monitors systems and devices for risks and threats.
We
regularly review and update our policies, procedures, processes and practices to address changes in the threat landscape and as a result
of lessons learned from suspected, actual or simulated incidents. We also conduct tabletop exercises and engage third party services
to conduct evaluations of our security controls through penetration testing and independent audits. We also review industry best practices
to assist in evaluating responses to new challenges and risks. These evaluations include testing both the design and operational effectiveness
of security controls.
Cybersecurity
Risks
While we dedicate resources and
efforts to our cybersecurity program, we may be unable to successfully identify threats, prevent attacks, satisfactorily resolve cybersecurity
incidents, or implement adequate mitigating controls. Any breach of our network security and information systems or other cybersecurity-related
incidents that results in, or may result in, the loss, theft or unauthorized disclosure of data, or any delay in determining the full
extent of a potential breach, could have a material adverse impact on our business, results of operations, and financial condition, including
harm to our reputation and brand, reduced demand for our solutions, time-consuming and expensive litigation, fines, penalties, and other
damages. To date and except as otherwise may be noted in this Annual Report, we do not believe that any cybersecurity threats, including
as a result of any previous cybersecurity incidents have materially affected, or are reasonably likely to materially affect the Company,
including its business strategy, results of operations or financial condition. For more information relating to cybersecurity risks and
uncertainties, please see the risk factor entitled “Cybersecurity incidents may have a material adverse effect on Veea’s business,
operations, financial performance, customer and vendor relationships, reputation and brand.” in Part I, Item 1A, and other risk
factors in this 10-K.
ITEM
2. PROPERTIES.
We
are headquartered in New York City, New York. We have engineering offices in Iselin, New Jersey; Bath, United Kingdom; and Juvigny, France.
We also maintain a sales and marketing office in Paris, France and Mexico City, Mexico.