Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
None.
Item 1C. Cybersecurity.
Risk Management, Strategy and Governance
The Trust has no employees or internal information
systems and is managed by the Sponsor. Thus, the Trust relies on the Sponsor and VanEck, the parent company of the Sponsor, as
well as the SOL Custodian and other service providers to protect the Trust’s information from cybersecurity threats. VanEck
has policies, standards and procedures on information security (the “Cybersecurity Documents”). The Cybersecurity Documents
govern the procurement, use, storage, protection and permissions of data systems, applications and devices. The Cybersecurity Documents
outline the correct usage of elements and tasks on the networks/infrastructure to ensure safe operation, high availability, performance
and data accuracy.
VanEck has adopted the National Institute of
Standards and Technology’s (“NIST”) cybersecurity framework as its security outline. The program is reviewed
annually. Using the NIST framework as a guide, VanEck’s cybersecurity program is organized around the following program domains:
● Identify critical assets, data, systems and capabilities, cybersecurity strategy and governing
elements, threats and cybersecurity risks;
● Protect assets (data, systems, networks, personnel, etc.) from external or internal malicious actors
and failed practices;
● Detect anomalies and security events through environments monitoring, analysis, remediation and
reporting. Engage outside vendors to periodically test the network infrastructure and software applications against known vulnerabilities
and to ensure the use of a best practice security program;
● Respond to incidents regardless of source or causality;
● Recover through planning, improvements and communications (external and internal); and
● Conduct after-action evaluation to identify what went well, what did not go well and improve VanEck
systems on the back of an issue.
VanEck employs third-party firms to assess
its cybersecurity posture, conduct penetration testing and forensic analysis.
VanEck maintains a risk-based approach to identifying
and overseeing cybersecurity risks presented by third parties, including vendors, service providers, counterparties and clients,
as well as the systems of third parties that could significantly and adversely impact VanEck’s business in the event of a
cybersecurity incident affecting those third-party systems. Third-party risks are included within VanEck’s NIST framework,
and risk identification and mitigation are supported by VanEck’s cybersecurity program. VanEck also performs diligence on
certain third parties and monitors cybersecurity threats and risks identified through such diligence.
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Roles and Responsibilities
Roles and responsibilities for cybersecurity
have been established first by VanEck’s cybersecurity policy and secondly by its connection to the governance structure of
the firm and VanEck’s risk management committee (the “Risk Management Committee”), which is comprised of senior-level
employees. Cybersecurity is closely aligned with not only risk management, but also with business continuity planning and response.
In addition, the importance of cybersecurity protection and its practice at the manager and employee level is frequently communicated
to the staff globally. Specifically, VanEck’s Chief Information Security Officer, reporting to the co-chair of the Risk Management
Committee, is responsible for conducting the firm’s cybersecurity risk assessment, as well as providing regular staff educations
with a special emphasis on proper desktop and email security and conduct. Special training is also given to recently on-boarded
staff. VanEck’s Chief Administrative Officer and Chief Technology Officer, together with VanEck’s Chief Information
Security Officer, are responsible for the day-to-day operations of the firm cybersecurity infrastructure including normal operations,
as well as any remedial work required in response to an incident. The communication responsibility in the event of an incident
is shared by VanEck’s CEO and the General Counsel.
Since our commencement of operations, we have
not experienced a material information security breach incident and we are not aware of any cybersecurity risks that are reasonably
likely to materially affect our business. However, future incidents could have a material impact on our business strategy, results
of operations or financial condition. See “Item 1A. Risk Factors—Other Risks—Due To The Increased Use Of Technologies,
Intentional And Unintentional Cyberattacks Pose Operational And Information Security Risks.”
Item 2. Properties.
Not applicable.
Item 3. Legal Proceedings.
None.
Item 4. Mine Safety Disclosures.
Not applicable.
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PART II