Item 1B. Unresolved Staff Comments
ITEM
1B. Unresolved Staff Comments
None.
ITEM
1C. Cybersecurity
Risk
management and strategy
We
recognize the critical importance of developing, implementing, and maintaining robust cybersecurity measures to safeguard our information
systems and protect the confidentiality, integrity, and availability of our data.
Managing
Material Risks & Integrated Overall Risk Management
We
have strategically integrated cybersecurity risk management into our broader risk management framework to promote a company-wide
culture of cybersecurity risk management. Our Chief Technology Officer (CTO) evaluates and addresses cybersecurity risks
in alignment with our business objectives and operational needs.
The Company’s cybersecurity
risk management strategy focus on:
● Technical Safeguards: The Company implements
technical safeguards that are designed to protect the Company’s information systems from cybersecurity threats. The company uses
a managed antivirus platform to scan for viruses, manage patching and updates, and provide remote support and monitoring tools. Company
accounts have strong passwords and two factor authentication, where available.
● Third-Party Risk Management: We conduct thorough
security assessments of all third-party providers before engagement and maintain ongoing monitoring to ensure compliance with our cybersecurity
standards. This approach is designed to mitigate risks related to data breaches or other security incidents originating from third parties
● Incident Response and Recovery Planning: The
Company has established and maintains comprehensive incident response, business continuity, and disaster recovery plans designed to address
the Company’s response to a cybersecurity incident.
Recognizing the complexity
and evolving nature of cybersecurity threats, we have engaged with a range of external experts, including cybersecurity assessors,
and consultants in evaluating and testing our risk management systems in an ongoing and as needed basis. These partnerships enable us
to leverage specialized knowledge and insights, ensuring our cybersecurity strategies and processes remain at the forefront
of industry best practices. Our collaboration with these third parties includes threat assessments and consultation on security enhancements.
Risks from Cybersecurity Threats
As of the date of this report,
we are not aware of any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, that have
materially affected our business strategy, results of operations, or financial condition, nor in our view, are such threats currently
or reasonably likely to materially affect the Company.
26
Governance
Acknowledging
the critical importance of cybersecurity, our management and Board are dedicated to maintaining the trust and confidence of our business
partners and employees. Our executive officers manage the day-to-day material risks we face, adopting a cross-functional approach to
address cybersecurity risks by identifying, preventing, and mitigating cybersecurity threats and effectively responding to incidents
when they occur.
The
CTO and the Chief Executive Officer (“CEO”) play a pivotal role in informing the Audit Committee on cybersecurity risks.
The CTO keeps the CEO apprised of any noteworthy activity on an ongoing basis. The CEO in turn provides comprehensive briefings to the
Audit Committee on a regular basis, with a minimum frequency of once per year. These briefings encompass a broad range of topics, including:
●
Current cybersecurity landscape
and emerging threats;
●
Status of ongoing cybersecurity
initiatives and strategies;
●
Incident reports and learnings
from any cybersecurity events; and
●
Compliance with regulatory
requirements and industry standards.
In
addition to our scheduled meetings, the Audit Committee and CEO maintain an ongoing dialogue regarding emerging or potential cybersecurity risks.
Together, they receive updates on any significant developments in the cybersecurity domain, ensuring the Board’s oversight
is proactive and responsive.
ITEM
2. Properties
We are a distributed organization
and do not maintain a central location at which our employees work. Our employees primarily work from home or from coworking spaces.
We believe our current arrangements are adequate for our needs and do not anticipate any difficulty in continuing to support our operations
as the business evolves.
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