Item 1C. Cybersecurity.

Risk management and strategy

We have implemented and maintain various information security processes designed to identify, assess and manage material risks from cybersecurity threats to our critical computer networks, third party hosted services, communications systems, hardware and software, and our critical data, including intellectual property, confidential information that is proprietary, strategic or competitive in nature, and personal data of employees and others (“Information Systems and Data”).

Our information technology department helps identify, assess and manage our cybersecurity threats and risks. Our information technology department identifies and assesses risks from cybersecurity threats by monitoring and evaluating our threat environment

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using various methods including, for example: manual and automated cybersecurity tools such as malware scans; vulnerability testing, such as phishing simulations; and analysis of reported threats.

Depending on the environment, we implement and maintain various technical, physical, and organizational measures, processes, standards and policies designed to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data, including, for example: employee training; access controls; data encryption; systems monitoring; regular patching of operating systems and software; a Password Policy; a written IT Security Incident Response Plan; and cybersecurity insurance coverage.

Our assessment and management of material risks from cybersecurity threats are integrated into our overall risk management processes. For example, the information technology department works with management to prioritize our risk management processes and mitigate cybersecurity threats that are more likely to lead to a material impact to our business and reports to the Audit Committee of the Board of Directors, which evaluates cybersecurity and information technology risk as well as other aspects of our overall enterprise risk.

We use third-party service providers to assist us from time to time to identify, assess, and manage material risks from cybersecurity threats, including for example cybersecurity software and training providers.

We use third-party service providers to perform a variety of functions throughout our business, such as electronic communications service providers, cloud-based file storage service providers, and contract research organizations (“CROs”).

For a description of the risks from cybersecurity threats that may materially affect us and how they may do so, see our risk factors under Part I, Item 1A, Risk Factors in this Annual Report on Form 10-K, including the risk factors titled “Significant disruptions of our information technology systems or data security incidents could result in significant financial, legal, regulatory, business and reputational harm to us” and “Artificial Intelligence presents new risks and challenges to our business.”

Governance

Our Board of Directors addresses our cybersecurity risk management as part of its general oversight function. The Board of Directors’ Audit Committee is responsible for overseeing our cybersecurity risk management processes, including oversight and mitigation of risks from cybersecurity threats.

Our cybersecurity risk assessment and management processes are implemented and maintained by certain of our management, including our Senior Director of Information Technology, who has over 25 years of work experience in various roles in information technology and cybersecurity, including in public companies in our industry, and our Chief Financial Officer, who has experience overseeing the information technology function and implementing and overseeing internal controls frameworks in our industry.

Our Senior Director of Information Technology is responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into the Company’s overall risk management strategy, and communicating key priorities to relevant personnel. Our Chief Financial Officer is responsible for approving budgets, helping prepare for cybersecurity incidents, approving cybersecurity processes, and reviewing security assessments and other security-related reports.

Our IT Security Incident Response Plan is designed to escalate certain cybersecurity incidents to members of management depending on the circumstances, including our Chief Financial Officer. Our Chief Financial Officer leads the Company’s Incident Response Team to help us mitigate and remediate cybersecurity incidents of which we are notified. In addition, our IT Security Incident Response Plan includes reporting to the Audit Committee of the Board of Directors for certain cybersecurity incidents.

The Audit Committee receives regular reports from management concerning our significant cybersecurity threats and risk and the processes we have implemented to address them. The Audit Committee also receives various reports, summaries or presentations related to cybersecurity threats, risk and mitigation.