Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS.
None.
ITEM 1C. CYBERSECURITY.
Risk Management and Strategy
Cyber criminals are becoming more sophisticated
and effective every day, and they are increasingly targeting enterprise software companies. All companies utilizing technology are
subject to threats of breaches of their cybersecurity programs. To mitigate the threat to our business, we have established a comprehensive
approach to cybersecurity risk management and hold securing the data customers and other stakeholders entrust to us as one of our top
priorities. As described in more detail below, we have established policies, standards, processes and practices for testing, training,
and monitoring material risks from cybersecurity threats. We have devoted financial and personnel resources to implement security measures
to meet regulatory requirements and customer expectations, and we intend to continue to make investments to maintain the security of our
data and cybersecurity infrastructure. There can be no guarantee that our policies and procedures will be properly followed in every instance
or that those policies and procedures will be effective. Although our Risk Factors include further details about the material cybersecurity
risks we face, we believe that risks have not materially affected our business to date. We can provide no assurance that there will not
be incidents in the future or that they will not materially affect us, including our business strategy, results of operations, or financial
condition.
We have established controls and procedures designed
to ensure prompt escalation of material cybersecurity incidents so that decisions regarding public disclosure and reporting of such incidents
can be made by management and the Board of Directors in a timely manner. We intend to continue to review and enhance our incident response
and recovery plan for the Company. Our policies require each of our employees to contribute to our data security efforts. We regularly
remind employees of the importance of handling and protecting customer and employee data, including through annual privacy and security
training to enhance employee awareness of how to detect and respond to cybersecurity threats. Our incident response and recovery plans
and policies will address — and guide our employees, management, and the Board of Directors on our response to a cybersecurity incident.
Our cybersecurity policies, standards, processes
and practices are also assessed by third party cybersecurity providers. These assessments include a variety of activities including information
security maturity assessments, audits and independent reviews of our information security control environment and operating effectiveness.
Governance
Our Board
of Directors is responsible for monitoring and assessing strategic risk exposure related to cybersecurity risks, and our executive officers
are responsible for the day-to-day assessment and management of the material risks we face. Our Board of Directors administers its cybersecurity
risk oversight function directly as a whole.
Currently, Jack Wang senior advisor of our subsidiary
PeriShip Global, has primary responsibility for managing material cybersecurity risks. Mr. Wang holds an undergraduate and master’s
degree in computer science and has served in various roles in information technology and security for over 20 years. Mr. Wang is responsible
for reporting any cybersecurity related incidents to our executive officers. Our executive officers are responsible for reporting material
cybersecurity related incidents to our Board of Directors . We may implement other reporting structures governing the day-to-day management
and reporting of cybersecurity risks.