Risk Management and Strategy:

The Company has processes for assessing, identifying, and managing material risks from cybersecurity threats. The Company has designed and implemented a Security Incident Response Plan for cybersecurity incidents and related processes which are overseen by management and cybersecurity professionals. Cybersecurity threats are identified and escalated to a Security Incident Response Team or member thereof pursuant to criteria set forth in these processes. These processes also include overseeing and identifying risks from cybersecurity threats associated with the use of third-party service providers, if any.

Our cybersecurity policies, standards, processes, and practices are integrated into the Company’s overall risk management and compliance program and are overseen by the Audit Committee. The Compliance Committee, led by our Chief Compliance Officer (“CCO”) and the IT Committee, led by our Chief Financial Officer (“CFO”) are responsible for establishing and monitoring the integrity and effectiveness of controls and other procedures. In general, we seek to address cybersecurity risks through a cross-functional approach focused on preserving the security and availability of information that we collect and store by identifying, preventing, and mitigating cybersecurity threats and effectively responding to cybersecurity incidents when they occur.

The Company also engages consultants, auditors, and other third parties in connection with these processes to assist in the design of cybersecurity measures and employee training and to test the effectiveness of the Company’s processes and measures.

Governance:

Board of Directors

The Board’s oversight of cybersecurity risk management is led by the Audit Committee which interacts with our CFO, who has oversight for information technology and our CCO, as well as other members of management. The Audit Committee receives presentations and reports on cybersecurity risks, which address a wide range of topics including recent developments, evolving standards, vulnerability assessments, the threat environment, technological trends and information security considerations arising with respect to our peers and third parties. The board of directors and the Audit Committee also receive prompt and timely information regarding any cybersecurity incident, as well as ongoing updates regarding any such incident until it has been addressed. On a periodic basis, the board of directors, through the Audit Committee, discuss our approach to cybersecurity risk management with the CFO and CCO.

The Audit Committee is informed of material risks, if any, from cybersecurity threats pursuant to Company policies, and at least once per quarter the Company’s CCO reports to the Audit Committee generally on cybersecurity matters and material risks, if any, from cybersecurity threats.

Management

The Company’s management, including members of its IT and Compliance Committees, also assess and manage material risks, if any, from cybersecurity threats with the assistance of our third-party IT and cybersecurity vendors.

Collaborative Approach: We have implemented a comprehensive, cross-functional approach to identifying, preventing, and mitigating cybersecurity threats and incidents, while also implementing controls and procedures that provide for the prompt escalation of certain cybersecurity incidents so that decisions regarding the public disclosure and reporting of such incidents can be made by management in a timely manner.

Technical Safeguards: We deploy technical safeguards that are designed to protect our information systems from cybersecurity threats, including firewalls, intrusion prevention and detection systems, anti-malware functionality, and access controls, which are evaluated and improved through vulnerability assessments and cybersecurity threat intelligence.

Incident Response and Recovery Planning: We are committed to establishing and maintaining comprehensive incident response and recovery plans to address our response to a cybersecurity incident.

Third-Party Risk Management: We maintain a risk-based approach to identifying and overseeing cybersecurity risks presented by third parties, including vendors, service providers and other external users of our systems, as well as the systems of third parties that could adversely impact our business in the event of a cybersecurity incident affecting those third-party systems.