What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-03-25 compared with 2024-03-26 · 49 added, 42 removed, 3 unchanged (97% of the section changed)

UNRESOLVED STAFF COMMENTS

Item 1B is not applicable to smaller reporting companies.

CYBERSECURITY

Cybersecurity

Risk Management and Strategy

cybersecurity risk management program, processes and strategy described in this section are limited to the personal and business information

belonging to or maintained by the Company (collectively, “Confidential Information”), our own third-party critical systems

and services supporting or used by the Company (collectively, “Critical Systems”), and service providers.

The Company’s

subsidiaries lease to our tenants the properties we own, but we do not have actual or contractual access to the systems or information

maintained or used by our tenants.

Our tenants are directly or indirectly (through their own service providers) responsible for maintaining

programs and processes to protect their systems and information from various risks from cybersecurity threats.

will develop and implement a cybersecurity risk management program intended to protect the confidentiality, integrity, and availability

of our Confidential Information and Critical Systems.

Our cybersecurity risk management program will be integrated into our overall enterprise

risk management program and includes a cybersecurity incident response plan.

cybersecurity risk management program shall include:

assessments designed to help identify material cybersecurity risks to our Confidential Information,

Critical Systems and the broader enterprise IT environment;

security team principally responsible for managing (1) our cybersecurity risk assessment

processes, (2) our security controls, and (3) our response to cybersecurity incidents;

● cybersecurity

awareness and spear-phishing resistance training of our employees, and senior management;

cybersecurity incident response plan that includes procedures for responding to cybersecurity

vendor management policy for service providers.

have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially

affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial

We face risks from cybersecurity threats that, if realized, could have a material adverse effect on us including an adverse

effect on our business, financial condition and results of operations.

This Item 1B is not applicable to smaller reporting companies.

CYBERSECURITY

executive management team, along with our managed information technology service provider, is responsible for assessing and managing

risks from cybersecurity threats to the Company, including our Confidential Information and Critical Systems.

The team has primary responsibility

for our overall cybersecurity risk management program.

Cybersecurity Risk Management and Strategy

The cybersecurity risk management program, processes

and strategy described in this section are limited to the personal and business information belonging to or maintained by the Company

(collectively, “Confidential Information”), our own third-party critical systems and services supporting or used by the Company

(collectively, “Critical Systems”), and service providers.

The Company’s subsidiaries lease to our tenants the properties

we own, but we do not have actual or contractual access to the systems or information maintained or used by our tenants.

are directly or indirectly (through their own service providers) responsible for maintaining programs and processes to protect their

systems and information from various risks from cybersecurity threats.

We will develop and implement a cybersecurity

risk management program intended to protect the confidentiality, integrity, and availability of our Confidential Information and Critical

Our cybersecurity risk management program will be integrated into our overall enterprise risk management program and includes

a cybersecurity incident response plan.

Our cybersecurity risk management program shall include:

assessments designed to help identify material cybersecurity risks to our Confidential Information, Critical Systems and the broader

enterprise IT environment;

security team principally responsible for managing (1) our cybersecurity risk assessment processes, (2) our security controls, and

(3) our response to cybersecurity incidents;

cybersecurity awareness

and spear-phishing resistance training of our employees, and senior management;

cybersecurity incident response plan that includes procedures for responding to cybersecurity incidents;

a vendor management policy

for service providers.

We have not identified risks from known cybersecurity

threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially

affect us, including our operations, business strategy, results of operations, or financial condition.

We face risks from cybersecurity

threats that, if realized, could have a material adverse effect on us including an adverse effect on our business, financial condition

and results of operations.

Cybersecurity Governance

Our executive management team , along with our

managed information technology service provider, is responsible for assessing and managing risks from cybersecurity threats to the Company,

including our Confidential Information and Critical Systems.

The team has primary responsibility for our overall cybersecurity risk management

Our management team works closely with our information technology service provider.

management team meets with our information technology service provider periodically to discuss then-current cybersecurity issues, which

may include efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, including threat

intelligence and other information obtained from governmental, public or private sources, and external service providers engaged by us;

and alerts and reports produced by security tools deployed in the information technology environment including a spear-phishing report.

Board considers cybersecurity risk as part of its risk oversight function and oversight of cybersecurity and other information technology

Board oversees management’s implementation of our cybersecurity risk management program.

Our executive management team is responsible

for updating the Board, as necessary, regarding significant cybersecurity incidents.

Board shall also receive period reports from management on our cybersecurity risks and cybersecurity risk management program.

Our management team meets with our information technology service

provider periodically to discuss then-current cybersecurity issues, which may include efforts to prevent, detect, mitigate, and remediate

cybersecurity risks and incidents through various means, including threat intelligence and other information obtained from governmental,

public or private sources, and external service providers engaged by us;

and alerts and reports produced by security tools deployed in

the information technology environment including a spear-phishing report.

Our Board considers cybersecurity risk as part

of its risk oversight function and oversight of cybersecurity and other information technology risks.

Our Board oversees management’s implementation

of our cybersecurity risk management program.

Our executive management team is responsible for updating the Board, as necessary, regarding

significant cybersecurity incidents.

Our Board shall also receive period reports from

management on our cybersecurity risks and cybersecurity risk management program.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments