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 clinical trial data, or Information Systems and Data.

Our fractional Chief Information Officer (“CIO”), along with our legal and information security functions, help identify, assess and manage the Company’s cybersecurity threats and risks. This group works to identify and assess risks from cybersecurity threats by monitoring and evaluating our threat environment using various methods including, for example manual and automated tools, analyzing reports of threats and actors, evaluating our and our industry’s risk profile, evaluating threats reported to us, internal and external audits, conducting threat assessments for internal and external threats, third party threat assessments, conducting vulnerability assessments designed to identify vulnerabilities, and use of external intelligence feeds.

Depending on the environment, we implement and maintain various technical, physical, and organizational measures, processes, standards or policies designed to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data, including, for example those related to: incident response, incident detection and response, data protection, access controls, physical security, systems monitoring, and employee training.

Our assessment and management of material risks from cybersecurity threats are integrated into the Company’s overall risk management. For example, (1) cybersecurity risk is addressed as a component of the Company’s enterprise risk management program; (2) the IT department works with management to prioritize our risk management processes and mitigate cybersecurity threats that are more likely to lead to a material impact on our business; and (3) our senior management evaluates material risks from cybersecurity threats and reports to the audit committee of the board of directors. The board of directors evaluates our overall enterprise risk.

We use third-party service providers to assist us in our efforts to identify, assess, and manage material risks from cybersecurity threats, including for example threat intelligence service providers, cybersecurity consultants, cybersecurity software providers, managed cybersecurity service providers, and dark web monitoring services.

We use third-party service providers to perform a variety of functions throughout our business, such as application providers and hosting companies. Depending on the nature of the services provided, the sensitivity of the Information Systems and Data at issue, and the identity of the provider, our vendor management process may involve different levels of assessment designed to help identify cybersecurity risks associated with a provider and impose contractual obligations related to cybersecurity on the provider.

For a description of the risks from cybersecurity threats that may materially affect the Company and how they may do so, see our risk factors under Part 1. Item 1A. Risk Factors in this Annual Report on Form 10-K, including “If our information technology systems or those of third parties with whom we work, or our data are or were compromised, we could experience adverse consequences resulting from such compromise, including but not limited to regulatory investigations or actions; litigation; fines and penalties; disruptions of our business operations; reputational harm; loss of revenue or profits; and other adverse consequences”.

The audit committee receives periodic reports from the Senior Vice President of Finance concerning the Company’s overall cybersecurity posture. The audit committee also receives various reports, summaries or presentations related to cybersecurity threats, risk and mitigation.

Governance

Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management, including the Information Technology Manager (IT Manager) and the fractional CIO who have over 30 years of combined experience addressing cybersecurity related issues through prior work experience.