Item 1B. Unresolved Staff Comments
ITEM
1B.
Unresolved
Staff Comments
None.
ITEM
1C.
Cybersecurity
Risk
Management
We
face significant and persistent cybersecurity risks due to the need to protect our business, our confidential information and information
concerning our personnel and others with whom we conduct business. As with other technology companies, we occasionally face threats from
actors who seek to disrupt our business as well as others who are engaging in malicious activities for profit, to make a political point
or for no particular reason other than creating disruption. Disclosure of certain information as a result of a cybersecurity breach may
result is a breach of privacy laws. The substantial level of harm that could occur to us and our suppliers and customers were we to suffer
impacts of a material cybersecurity incident; and our use of third-party products, services and components requires us to maintain robust
governance and oversight of these risks and to implement mechanisms, technologies and processes designed to help us assess, identify,
and eliminate these risks.
While
we have not, as of the date of this Annual Report, experienced a cybersecurity threat or incident that resulted in a material adverse
impact to our business or operations, we cannot assure you that we will not experience such an incident in the future. Any cybersecurity
incidents, whether or not successful, could result in our incurring additional costs related to, for example, rebuilding our internal
systems, implementing additional threat protection measures, responding to regulatory inquiries or actions, paying damages or making
payments to obtain access to our computer systems, or taking other remedial steps with respect to third parties, as well as incurring
significant reputational harm. We have seen an increase in cyberattack volume, frequency, and sophistication. We seek to detect and investigate
unauthorized attempts and attacks against our network, products, and services, and to prevent their occurrence and recurrence where practicable
through changes or updates to our internal processes and tools and changes or updates to our products and services; however, we remain
potentially vulnerable to known or unknown threats. In some instances, we, our suppliers, our customers, and the users of our products
and services can be unaware of a threat or incident or its magnitude and effects. Further, there are increasing regulation requirements
regarding responses to cybersecurity incidents, including reporting to regulators, which could subject us to additional liability and
reputational harm.
44
Governance
Following
these risk assessments, we evaluate whether and how to re-design, implement, and maintain reasonable safeguards to mitigate identified
risks and reasonably address any identified gaps in existing safeguards. Our IT leadership reports to our Chief Executive Officer (CEO)
periodically and on an as-needed basis to manage our risk assessment and mitigation process. We monitor and test our safeguards and regularly
conduct training for our employees on these safeguards, in collaboration with human resources, IT, and management. We are committed to
promoting a company-wide culture of cybersecurity risk management.
We
have not encountered cybersecurity risks, threats or incidents that have materially affected or are reasonably likely to materially
affect the Company, our business strategy, results of operations, or financial condition during the financial year ended December 31,
2023.