Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS.
Not
applicable.
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. We have developed the following processes as part
of our strategy for assessing, identifying, and managing material risks from cybersecurity threats.
Managing
Material Risks & Integrated Overall Risk Management
We
have integrated cybersecurity risk management into our risk management processes. This integration is intended to ensure that cybersecurity
considerations are part of our decision-making processes. We continuously evaluate and address cybersecurity risks in alignment with
our business objectives and operational needs.
Engaging
Third-parties on Risk Management
Recognizing
the complexity and evolving nature of cybersecurity threats, we plan to engage external experts, including consultants and auditors,
in evaluating and testing our risk management systems. These services will 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 is expected to include annual audits, ongoing threat assessments, and regular consultations on security enhancements.
Overseeing
Third-Party Risk
Because
we are aware of the risks associated with third-party service providers, we implement processes to oversee and manage these risks. 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.
Risks
from Cybersecurity Threats
We
have not encountered cybersecurity challenges that have materially affected or are reasonably likely to materially affect us, including
our business strategy, results of operations, or financial condition.
Governance
Board
of Directors Oversight
Our
board of directors oversees the management of risks associated with cybersecurity threats.
Management’s
Role Managing Risk
Management
is primarily responsible for assessing, monitoring and managing our cybersecurity risks. Management must ensure that all industry standard
cybersecurity measures are functioning as required to prevent or detect cybersecurity threats and related risks. Management oversees
and tests our compliance with standards, remediates known risks, and leads our employee training program.
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Monitoring
Cybersecurity Incidents
Management
is continually informed about the latest developments in cybersecurity, including potential threats and innovative risk management techniques.
Management implements and oversees processes for the regular monitoring of our information systems. This includes the deployment of industry-standard
security measures and regular system audits to identify potential vulnerabilities. In the event of a cybersecurity incident, management
will implement an incident response plan. This plan includes immediate actions to mitigate the impact and long-term strategies for remediation
and prevention of future incidents.
Reporting
to Board of Directors
Significant
cybersecurity matters, and strategic risk management decisions, will be escalated to the board of directors.