Cybersecurity Risk Management and Strategy To maintain a consistently
high level of service experience for our clients, preserve the confidentiality, integrity, and availability of our information systems,
safeguard our assets, data, intellectual property, and network infrastructure, while meeting regulatory requirements, it is crucial to
effectively manage cybersecurity risks. To achieve this, we have implemented a comprehensive cybersecurity risk management framework,
which is integrated in our overall enterprise risk management system and processes and is internally managed. Our dedicated cybersecurity
staff is tasked with assessing, identifying and managing risks related to cybersecurity threats and, under the leadership of our head
of cybersecurity, is responsible for
| ● | risk
assessments designed to help identify material cybersecurity risks to our critical systems,
information, products, services, and our broader enterprise IT environment; |
| ● | development
of risk-based action plans to manage identified vulnerabilities and implementation of new
protocols and infrastructure improvements; |
| ● | cybersecurity
incident investigations; |
| ● | monitoring
threats to sensitive data and unauthorized access to our systems; |
| ● | secure
access control measures applied to critical IT systems, equipment and devices, designed to
prevent unauthorized users, processes, and devices from assessing IT systems and data; |
| ● | developing
and executing protocols to ensure that information regarding cybersecurity incidents is promptly
shared with the board of directors, as appropriate, to allow for risk and materiality assessments
and to consider disclosure and notice requirements; and |
| ● | developing
and implementing training on cybersecurity, information security and threat awareness. |
There were no cybersecurity
incidents during the year ended December 31, 2023, that resulted in an interruption to our operations, known losses of any critical data
or otherwise had a material impact on our strategy, financial condition or results of operations. However, the scope and impact of any
future incident cannot be predicted. See “Item 3. Key Information - D. Risk Factors” for more information on how material
cybersecurity attacks may impact our business.
|