What changed in this filing

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Item 1B. Unresolved Staff Comments

2026-09-28 compared with 2025-08-22 · 54 added, 56 removed, 1 unchanged (99% of the section changed)

UNRESOLVED STAFF COMMENTS.

Not applicable.

UNRESOLVED STAFF

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

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

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.

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.

Management and Strategy

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.

Material Risks & Integrated Overall Risk Management

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.

Third-parties on Risk Management

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.

Third-Party Risk

we are aware of the risks associated with third-party service providers, we implement processes to oversee and manage these risks.

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.

from Cybersecurity Threats

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.

of Directors Oversight

board of directors oversees the management of risks associated with cybersecurity threats.

The board receives periodic reports from management

regarding cybersecurity risks and the status of the Company’s information security program.

Role Managing Risk

is primarily responsible for assessing, monitoring and managing our cybersecurity risks.

Members of management responsible

for cybersecurity have overseen IT and cybersecurity in previous roles and regularly consult with third party experts, to assess and protect

the Company’s risk and protections.

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.

Cybersecurity Incidents

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.

to Board of Directors

cybersecurity matters, and strategic risk management decisions, will be escalated to the board

of directors .

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