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.
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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.
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.
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