Item 16K. Cybersecurity

Cybersecurity risk management is an important part of our overall risk management efforts. Our historical services in wealth management and asset management involved the exchange, storage and analysis of highly confidential information, including detailed personal and financial information, through a variety of electronic and non-electronic means. Our new business development in e-commerce, digital assets or other consumer and enterprise technology industries will also involve significant reliance on technology. We rely on a network of process and software controls to protect the confidentiality of data provided to us or stored on our systems. Even though we have exited our historical services in wealth management and asset management, we still have obligations to protect our historical clients’ privacy and confidential information. We will also continue to focus on developing our cybersecurity risk management policies and procedures as we shift our business focus to exploring technology opportunities.

Our board of directors has oversight of our overall compliance and risk management framework, including cybersecurity risk management. Our senior management is responsible for day-to-day supervision of regulation compliance, including compliance with cybersecurity laws and regulations. We also rely on third-party service providers in our operations, including our digital asset custodian, our hosting and colocation providers, our mining pool operators and the Amazon marketplace, and we consider their security certifications and controls, such as SOC 1 or SOC 2 reports and, in the case of our custodian, its regulatory licensing, in selecting and monitoring them.

To date, we have not faced any significant cybersecurity events that have materially affected or are reasonably likely to materially affect us, including our business, results of operations, or financial condition. However, despite the cybersecurity risk management procedures and measures that we have implemented, we still face risks of security breaches and attacks against our systems and network from time to time, which may adversely affect our operation and reputation. For more information, see “Item 3. Key Information—D. Risk Factors—Risks Related to Our Business—Any significant failure in our information technology systems could have a material adverse effect on our business and profitability” and “—We rely on a third-party custodian to safeguard the digital assets we hold, and any security breach, operational failure, or insolvency of our custodian could result in the loss of our digital assets.”