Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
Not
applicable to smaller reporting companies.
ITEM
1C. CYBERSECURITY
Cybersecurity
risk
Cybersecurity
risk is the risk of harm or loss resulting from misuse or abuse of technology or the unauthorized disclosure of data.
Overview
To
preserve the confidentiality, integrity , and availability of our information systems, and to safeguard our assets, data, intellectual
property, and network infrastructure, while meeting regulatory requirements, it is crucial to effectively manage cybersecurity risk.
To achieve this, we have implemented a comprehensive cybersecurity risk management framework, which is integrated into our overall enterprise
risk management system and processes and is internally managed.
Our
IT staff is tasked with assessing, identifying, and managing cybersecurity threats and is responsible for:
●
risk
assessments designed to help identify material cybersecurity risks to our critical systems, information, products, and services and
to our broader enterprise IT environment;
●
development
of risk-based action plans to manage identified vulnerabilities and implementation of new protocols and infrastructure improvements;
●
cybersecurity
incident investigations;
●
monitoring
threats to sensitive data and unauthorized access to our systems;
●
applying
access control measures to critical IT systems, equipment, and devices, which measures are designed to prevent unauthorized users,
processes, and devices from accessing IT systems and data;
●
developing
and executing protocols to ensure that information regarding cybersecurity incidents is shared promptly with the Board, as appropriate,
to allow for risk and materiality assessments and to consider disclosure and notice requirements; and
●
developing
and implementing training on cybersecurity, information security, and threat awareness.
28
There
were no cybersecurity incidents during the financial year ended April 30, 2025, that resulted in an interruption to our operations or
known losses of any critical data or that otherwise had a material impact on our business strategy, financial condition, or results of
operations. However, the scope and impact of any future incident cannot be predicted. See Item 1A, “Risk Factors,” for more
information on how material cybersecurity attacks might impact our business.
Governance
and oversight
Our
Board acknowledges the significance of robust cybersecurity management programs and actively participates in overseeing and reviewing
our cybersecurity risk profile and exposures. Our Board receives prompt and timely information regarding any significant cybersecurity
incidents, as well as ongoing updates regarding any such incidents. Furthermore, in the event of any significant updates or adjustments
to our cybersecurity related policies, our IT staff will present them to the Board for their review and approval.
Our
IT staff are responsible for the daily management of our cybersecurity efforts. This includes updates and refinement of cybersecurity
policies, execution and management of cybersecurity measures, and the preparation of regular reports on cybersecurity execution. Their
primary focus is to consistently update our cybersecurity programs and mitigation strategies, ensuring they align with industry best
practices and procedures.