Item 1C. Cybersecurity.

 

The Company employs several strategies for assessing, identifying, and managing material risks from cybersecurity threats. Components of this strategy include the use of industry standard traffic monitoring tools, training users to detect, report, and prevent unusual behavior.

We employ continuous monitoring mechanisms to detect and respond to cybersecurity threats promptly. Regular reports are generated as needed for management and the board, providing insights into our cybersecurity posture, incidents, and remediation efforts. We conduct regular assessments and testing to ensure the effectiveness of these controls, especially those related to the protection of financial information. The implementation and management of these processes are integrated with the Company’s overall operational risk management processes that seeks to limit our exposure to unnecessary risks across our operations.

Our cybersecurity program is overseen by the Chief Financial Officer (CFO), who reports directly to the Chief Executive Officer (CEO) and updates the Board of Directors (BOD) on cyber security matters.

Our employees receive regular training on cybersecurity best practices, emphasizing the protection of financial information. We foster a culture of cybersecurity awareness and responsibility throughout the organization.

We maintain a comprehensive incident response plan that outlines the steps to be taken in the event of a cybersecurity incident. This plan includes procedures for promptly reporting material incidents to the SEC, as required, and for communicating with affected stakeholders. Upon discovery of a cybersecurity incident, the identifying party immediately notifies the Company's CFO. The CFO activates the incident response plan to include the following:

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Gather preliminary information about the cybersecurity incident.

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CFO notifies the CEO and the Board of Directors of the cybersecurity threat.

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The CFO allocates resources for disclosure if determined to be a material cybersecurity event.

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The CFO consults with cybersecurity consultants and other involved parties to identify the undesirable effects of the cybersecurity incident.

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The CFO develops a recommendation for determination of materiality.

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If disclosure is required, the material incident disclosure plan is executed by the CFO.