Zhuoxun Hongtu Inc. 10-K Cybersecurity GRC - 2025-01-06

Page last updated on January 7, 2025

Zhuoxun Hongtu Inc. reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2025-01-06 17:48:24 EST.

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10-K filed on 2025-01-06

Zhuoxun Hongtu Inc. filed a 10-K at 2025-01-06 17:48:24 EST
Accession Number: 0001213900-25-001262

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Item 1C. Cybersecurity.

Item 1C. Cybersecurity . Risk Management As of September 30, 2024, we did not establish policies and processes for assessing, identifying, and managing material risk from cybersecurity threats. We have integrated the processes of assessing, identifying, and managing material risk from cybersecurity threats into our overall risk management systems and processes. We routinely assess material risks from cybersecurity threats that may result in adverse effects on the confidentiality, integrity, or availability of our information systems or any information residing therein. We conduct periodic risk assessments to identify cybersecurity threats, as well as assessments in the event of a material change in our business practices that may affect information systems that are vulnerable to such cybersecurity threats. These risk assessments include identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that could result from such risks, and the sufficiency of existing policies, procedures, systems, and safeguards in place to manage such risks. Following these risk assessments, we re-design, implement, and maintain reasonable safeguards to minimize identified risks, reasonably address any identified gaps in existing safeguards, and regularly monitor the effectiveness of our safeguards. Our Vice President, Mr. Peng, is designated to manage the risk assessment and mitigation process. We may engage consultants and other third parties as needed in connection with our risk assessment policies and processes. These service providers assist us to design and implement our cybersecurity policies and procedures, as well as to monitor and test our safeguards. We require third-party service providers to certify their ability to implement and maintain appropriate security measures, consistent with all applicable laws, to implement and maintain reasonable security measures in connection with their work with us, and to promptly report any suspected breach of their security measures that may affect the Company. As part of our overall risk management strategies, we also conduct cybersecurity trainings for personnel at all levels and in all departments. Governance One of the key functions of our Board of Directors is informed oversight of our risk management process, including risks from cybersecurity threats. Mr. Yi, as sole director of our Board of Directors, is responsible for monitoring and assessing strategic risk exposure, and our executive officers are responsible for the day-to-day management of the material risks we face. Mr. Peng, our Vice President, provides periodic briefings to Mr. Yi regarding our cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity policies and procedures, activities of third parties, and the like. Mr. Peng has more two decades of experience working in IT and technology companies. Before assuming his current positions as chief product officer and VP of our Company, Mr. Peng served as General Manager of Beijing Xuri Yuanfan Technology Development Co., Ltd., an internet solution company, from July 2006 to June 2016. From September 2002 to June 2006, Mr. Peng served as manager of the technology department at Beijing Shidai Saibo Technology Development Co., Ltd., an IT solution company. Earlier in his career, Mr. Peng started at Beijing Jinhaihang Electronic Technology Co., Ltd., serving as a technical support engineer for the company’s education software businesses, from March 2000 to August 2002. Therefore, Mr. Peng has intimate knowledge of IT and cybersecurity issues and our operations. As part of the executive team reporting to the Board , Mr. Peng oversees our cybersecurity policies and processes, including those described in “Risk Management” above. The processes by which Mr. Peng is informed of and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents include log review from IT and operations teams or reports received from network systems and applications if any unusual activity occurs, such as email system notification of items opened that could be malicious. 60

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