heading: Integration with Overall Risk Management

body_start: Our cybersecurity processes have been integrated into our ov


heading: Engagement of Third Parties

body_start: We often engage with specialized third-party assessors, cons


heading: Disclosure of Risks

body_start: We describe how risks from cybersecurity threats could mater


heading: Training and awareness

body_start: We provide recurring information security training (which in


heading: Assessments and testing

body_start: We engage in periodic assessment and testing of our policies


body_start: Management's cybersecurity processes have been integrated in


heading: Engagement of Third Parties

body_start: Management often engages with specialized third-party assess


heading: Disclosure of Risks

body_start: Management describes how risks from cybersecurity threats co


heading: Disclosure of Risks

body_start: We describe how risks from cybersecurity threats, could mate


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for personn


heading: Education and Awareness

body_start: We provide regular training regarding cybersecurity threats


heading: Education and Awareness

body_start: The Company employs a variety of security-focused training/a


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for applica


heading: Policies and procedures

body_start: Our security and legal teams actively participate in industr


heading: Related to Cybersecurity Risks Board oversight

body_start: Our board has final oversight responsibility over cybersecur


heading: Education and Awareness

body_start: The Company provides mandatory annual training for personnel


heading: BOARD AND COMMITTEE OVERSIGHT BOARD

body_start: One of the key functions of our Board is informed oversight


heading: AUDIT COMMITTEE

body_start: Our Audit Committee is responsible for overseeing our major


heading: Risk and Readiness Assessments

body_start: The Company engages in the periodic assessment and testing o


heading: Education and Awareness

body_start: Our Adviser provides regular, mandatory training for its emp


heading: Introduction

body_start: The medical device industry faces unique cybersecurity chall


heading: Risks from Material Cybersecurity Threats

body_start: Despite ongoing threats like cyber-attacks, phishing, and ra


heading: Education and Awareness

body_start: We provide regular, mandatory training for personnel regardi


heading: Confidentiality and Integrity

body_start: To ensure the confidentiality and integrity of data and syst


heading: Availability

body_start: To preserve the availability of data and systems, we perform


heading: Monitoring

body_start: We maintain a security operations center that monitors our s


heading: Education and Awareness

body_start: We provide regular, mandatory security awareness training fo


heading: Policies and Processes

body_start: We engage in the periodic assessment of our policies, standa


heading: Education and Awareness

body_start: Our policies require each of our employees to contribute to


heading: Education and Awareness

body_start: We provide regular training regarding cybersecurity threats


heading: Collaboration

body_start: We have implemented a comprehensive, cross-functional approa


heading: Education and Awareness

body_start: The Company provides training, support and alerts for person


heading: Policies and procedures

body_start: Our security and legal teams actively participate in industr


body_start: Our board of directors has final oversight responsibility ov


heading: Education and Awareness

body_start: The Company provides mandatory annual training for personnel


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for personn


heading: Risk and Readiness Assessments

body_start: The Company engages in the periodic assessment and testing o


heading: Education and Awareness

body_start: Our Adviser provides regular, mandatory training for its emp


heading: Introduction

body_start: The medical device industry faces unique cybersecurity chall


body_start: Despite ongoing threats like cyber-attacks, phishing, and ra


heading: Education and Awareness

body_start: We provide regular, mandatory training for personnel regardi


heading: Confidentiality and Integrity

body_start: To ensure the confidentiality and integrity of data and syst


heading: Availability

body_start: To preserve the availability of data and systems, we perform


heading: Monitoring

body_start: We maintain a security operations center that monitors our s


heading: Education and Awareness

body_start: We provide regular, mandatory security awareness training fo


heading: Policies and Processes

body_start: We engage in the periodic assessment of our policies, standa


heading: Education and Awareness

body_start: We provide annual mandatory training for personnel regarding


heading: Engagement of Third Parties

body_start: These providers are selected based on stringent criteria for


heading: Collaboration

body_start: We have implemented a comprehensive, cross-functional approa


heading: Education and Awareness

body_start: We provide regular training regarding cybersecurity threats


heading: Safeguards

body_start: We deploy technical safeguards that are designed to protect


heading: Response and Recovery Planning

body_start: We have established and maintain comprehensive incident resp


heading: Training

body_start: We provide cybersecurity and information security compliance


heading: Monitoring of Third Parties

body_start: In 2023, we implemented a Third-Party Risk Management Progra


heading: Certifications

body_start: Certain of our manufacturing sites are certified to ISO 2700


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for personn


heading: Software with Latest Security Updates

body_start: Our IT infrastructure is maintained with up-to-date software


heading: Network and Infrastructure Security

body_start: We employ a range of technical measures to secure our networ


heading: Compliance and Reporting

body_start: We comply with all applicable laws and regulations related t


heading: Resilience and Recovery

body_start: We have developed and regularly test our business continuity


heading: Expertise

body_start: Our current management and Board do not have in-depth cybers


heading: Education and Awareness

body_start: Our policies encourage each of our employees to contribute t


heading: Plan and Testing

body_start: We have an incident response plan supported by a dedicated t


heading: Initiatives

body_start: We provide security awareness training to help our employees


heading: Engagement of Third Parties

body_start: These providers are selected based on stringent criteria for


heading: Collaboration

body_start: We have implemented a comprehensive, cross-functional approa


heading: Education and Awareness

body_start: We provide regular, mandatory training for personnel regardi


heading: Deployment of Technical Safeguards

body_start: We deploy technical safeguards that are designed to protect


heading: Deployment of Technical Safeguards

body_start: We deploy technical safeguards designed to protect our infor


heading: Approach

body_start: The Company, through its information technology partner, has


heading: Safeguards

body_start: The Company, through its information technology partner, dep


heading: Response and Recovery Planning

body_start: The Company, with its information technology partner, mainta


heading: Education and Awareness

body_start: The Company, through its information technology partner, pro


heading: Identification and Reporting

body_start: The Company has implemented a comprehensive, cross-functiona


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for all lev


heading: Compliance and Standards

body_start: We design our cybersecurity program for compliance with indu


heading: Response and Recovery Planning

body_start: We maintain incident response and recovery frameworks, teste


heading: Education and Awareness

body_start: Our personnel undergo mandatory periodic training on cyberse


heading: Identification and Reporting

body_start: We have implemented a cross-functional approach to assessing


heading: Safeguards

body_start: We implement technical safeguards that are designed to prote


heading: Response and Recovery Planning

body_start: We are establishing incident response, business continuity,


heading: Assessments

body_start: We conduct periodic assessments and testing of our policies,


heading: Safeguards

body_start: The Company deploys commensurate technical safeguards, inclu


heading: Review

body_start: The Company regularly reviews its cybersecurity standards, a


heading: Identification and Assessment

body_start: Management must work to continuously identify potential cybe


heading: Prioritization and Response

body_start: Based on assessments, management must prioritize risk mitiga


heading: Oversight and Implementation

body_start: Management oversees the implementation and enforcement of cy


heading: Education and Awareness

body_start: Management establishes a cybersecurity-aware culture within


heading: Identification

body_start: We maintain an updated inventory of critical digital assets


heading: Assessments

body_start: We evaluate cyber threats such as data breaches, ransomware,


heading: Mitigation

body_start: We implement layered security controls, including firewalls,


heading: Monitoring and Review

body_start: We implement tools to continuously monitor network traffic,


heading: Authentication

body_start: Access to Estrella's data and email, hosted on Office 365, i


heading: Identification and Reporting

body_start: The Company has implemented a comprehensive, cross-functiona


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for all lev


heading: Compliance and Standards

body_start: We design our cybersecurity program for compliance with indu


heading: Response and Recovery Planning

body_start: We maintain incident response and recovery frameworks, teste


heading: Education and Awareness

body_start: Our personnel and members of our Board of Directors undergo


heading: Use of Third Parties

body_start: We collaborate with external cybersecurity service providers


heading: Management

body_start: We maintain a controlled patch management process, ensuring


heading: Protection

body_start: We implement best-practice security baselines and hardening


heading: Solutions

body_start: Recognizing that traditional antivirus may not always be app


heading: Analysis

body_start: We utilize advanced behavioral analysis tools to detect rans


heading: Backup and Recovery

body_start: We perform regular backups of critical systems, ensuring the


heading: Expertise

body_start: Our current management and Board do not have in-depth cybers


heading: Education and Awareness

body_start: We provide various training programs and tools to employees


heading: Collaboration

body_start: We have implemented a comprehensive, cross-functional approa


heading: Education and Awareness

body_start: We provide regular, mandatory training for personnel regardi


heading: Education and Awareness

body_start: We provide regular, mandatory training for personnel and con


heading: Risk and Readiness Assessments

body_start: We engage in the periodic assessment and testing of our poli


heading: Education and Awareness

body_start: We provide periodic mandatory training for personnel regardi


heading: Identification and Reporting

body_start: The Company has implemented a comprehensive approach to asse


heading: Education and Awareness

body_start: The Company provides regular, mandatory training and assessm


heading: Identification and Reporting

body_start: We have implemented a comprehensive approach to assessing, i


heading: Education and Awareness

body_start: We provide regular, mandatory training and assessment for al


heading: Education and Awareness

body_start: Our Adviser provides regular, mandatory training for its emp


heading: Education and Awareness

body_start: We provide mandatory training and resources for personnel re


heading: Education and Awareness

body_start: We provide regular, mandatory, and ongoing training and rein


heading: Identification and Reporting

body_start: We have implemented a cross - functional approach to assessi


heading: Education and Awareness

body_start: We provide regular, mandatory training for all levels of emp


heading: Policies and Procedures

body_start: Management reviews and approves the Company's cybersecurity


heading: Budgeting and Resource Allocation

body_start: Management reviews budgets for cybersecurity initiatives and


heading: Identification

body_start: We aim to proactively identify sources of risk, areas of imp


heading: Assessment

body_start: We conduct periodic risk assessments to identify cybersecuri


heading: Management

body_start: Following our risk assessments, we design and implement reas


heading: Resilience and Recovery

body_start: We have developed and regularly test our business continuity


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for personn


heading: Network and Infrastructure Security

body_start: We employ a range of technical measures to secure our networ


heading: Compliance and Reporting

body_start: We comply with all applicable laws and regulations related t


heading: Policies and Procedures

body_start: The Company's IT department has developed and implemented cy


heading: Training and awareness

body_start: We have a cybersecurity training program designed to educate


heading: Assessments and testing

body_start: We use third party specialists to conduct periodic assessmen


heading: Education and Awareness

body_start: A third-party security firm provides training to our Manager


heading: Vigilance

body_start: We maintain an extensive presence, with cybersecurity threat


heading: Collaboration

body_start: We use collaboration mechanisms established with public and


heading: Training

body_start: We provide periodic mandatory training for personnel regardi


heading: Expertise and Leadership

body_start: Our Chief Compliance & Audit Officer (CCO/CAO) possesses ove


heading: Vigilance

body_start: We maintain 24/7 cybersecurity threat operations in order to


heading: Education

body_start: All of our employees are trained at least annually on cybers


heading: Communication and Coordination

body_start: We utilize a cross-functional approach to address the risk f


heading: Education and Awareness

body_start: A third-party security firm provides training to our employe


heading: Vigilance

body_start: The Company uses a reputable third-party managed service pro


heading: Training

body_start: The Company provides annual mandatory training for personnel


heading: Identification and Reporting

body_start: The Adviser has implemented a comprehensive, cross-functiona


heading: Training

body_start: We provide security awareness training to our employees so t


heading: Awareness

body_start: We maintain an extensive presence with cybersecurity threat


heading: Training

body_start: We provide regular mandatory training for personnel regardin


heading: Education and Awareness

body_start: A third -party security firm provides training to our employ


heading: Team

body_start: The Company has an internal cybersecurity team that is respo


heading: Engagement of Expert Assistance

body_start: The Company leverages the expertise of independent consultan


heading: Vigilance

body_start: The Company uses a reputable third -party managed service pr


heading: Vigilance

body_start: The Company's endpoints and networks are monitored 24/7 by i


heading: Collaboration

body_start: The Company collaborates with public and private entities, i


heading: Training

body_start: The Company provides periodic training for personnel regardi


heading: Approach

body_start: We have implemented a cross-functional approach to identifyi


heading: Safeguards

body_start: We deploy technical safeguards that are designed to protect


heading: Assessment

body_start: We conduct risk assessments to identify cybersecurity threat


heading: Response and Recovery Planning

body_start: We have established a comprehensive incident response and re


heading: Education and Awareness

body_start: Our policies require each of our employees to contribute to


heading: Assessment and Management

body_start: We conduct risk assessments to identify potential cybersecur


heading: Network and Infrastructure Security

body_start: We employ a range of technical measures to secure our networ


heading: Training and Awareness

body_start: We provide cybersecurity training to employees to raise awar


heading: Compliance and Reporting

body_start: We comply with all applicable laws and regulations related t


heading: Impact of Cybersecurity Threats

body_start: To date, there have been no material cybersecurity incidents


heading: Oversight

body_start: The Sponsor of the Fund has a fundamental role in overseeing


heading: Role

body_start: Our management team Xinyu Jiang and Weixuan Zhang are respon


heading: Technology

body_start: We use external consultants or other third-party experts and


heading: Consultants

body_start: We have identified and, as appropriate and when we have the


heading: Breaches

body_start: A breach of our information systems could lead to unauthoriz


heading: Relationships

body_start: Our reliance on third-party vendors and service providers ex


heading: Management and Oversight

body_start: Our board, as part of the board's enterprise risk management


heading: Approval

body_start: The board reviews and approves cybersecurity budgets and res


heading: Decisions

body_start: The board, based upon recommendation of management or our ex


heading: Training and Awareness

body_start: Members of management and members of our board take reasonab


heading: Identification

body_start: We aim to proactively identify the manners in which our busi


heading: Assessment

body_start: We periodically assess our risks relating to cybersecurity t


heading: Management

body_start: If deemed appropriate, we design and implement reasonable sa


heading: Evaluation

body_start: If a cybersecurity breach occurs, the Board of Directors and


heading: Disclosure

body_start: To ensure compliance with SEC requirements and maintain over


heading: Assessment and Management

body_start: We conduct risk assessments to identify potential cybersecur


heading: Network and Infrastructure Security

body_start: We employ a range of technical measures to secure our networ


heading: Training and Awareness

body_start: We provide cybersecurity training to employees to raise awar


heading: Compliance and Reporting

body_start: We comply with all applicable laws and regulations related t


heading: Approach

body_start: We have implemented a cross-functional approach to identifyi


heading: Safeguards

body_start: We deploy technical safeguards that are designed to protect


heading: Assessment

body_start: We conduct risk assessments to identify cybersecurity threat


heading: Response and Recovery Planning

body_start: We have established a comprehensive incident response and re


heading: Education and Awareness

body_start: Our policies require each of our employees to contribute to


heading: Vigilance

body_start: The Company maintains a global presence, with cybersecurity


heading: Collaboration

body_start: The Company has established collaboration mechanisms with pu


heading: Education

body_start: The Company provides periodic training for personnel regardi


heading: Communication and Coordination

body_start: The Company utilizes a cross-functional approach to address


heading: Education and Awareness

body_start: As directed by the Company, the MSP provides regular trainin


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for personn


heading: Vigilance

body_start: The Company employs tools to identify, prevent and mitigate


heading: Training

body_start: The Company communicates regularly with employees to increas


heading: Education and Awareness

body_start: We provide regular, mandatory training for personnel regardi


heading: Detection and Prevention

body_start: We utilize various securities tools and technologies designe


heading: Team

body_start: The Company has an internal cybersecurity team that is respo


heading: Engagement of Expert Assistance

body_start: The Company leverages the expertise of independent consultan


heading: Disclosure and Transparency

body_start: The Company has implemented policies and procedures related


heading: Education and Awareness

body_start: All new hires are required to complete mandatory cybersecuri


heading: Risk and Vulnerability Management

body_start: Our risk and vulnerability management program encompasses bo


heading: Team and Outside Resources

body_start: We have formed an Incident Response Team that monitors and m


heading: Board

body_start: Our full Board receives biannual updates on cybersecurity fr


heading: Management

body_start: Our CTPO is responsible for assessing and managing the Compa


heading: Education and Awareness

body_start: The Company provides annual training for personnel regarding


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for employe


heading: Identification

body_start: We aim to proactively identify sources of risk, areas of imp


heading: Assessment

body_start: We conduct periodic risk assessments to identify cybersecuri


heading: Management

body_start: Following our risk assessments, we design and implement reas


heading: Education and Awareness

body_start: In consultation with our cybersecurity team, we mandate annu


heading: Impact of Cybersecurity Threats

body_start: To date, there have been no risks from cybersecurity threats


heading: Education and Awareness

body_start: We provide regular training on cybersecurity threats to equi


heading: Preparing for Cybersecurity Risks

body_start: The Company's Cybersecurity Plan lays out on-going processes


heading: Management

body_start: The Company has a Cyber Incident Response Team (the "IRT"),


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for personn


heading: Training and awareness

body_start: We have a cybersecurity training program designed to educate


heading: Assessments and testing

body_start: We use third party specialists to conduct periodic assessmen


heading: Prevention

body_start: Our cyber security consultants operate a remote monitoring a


heading: Detection

body_start: Our cyber security consultants continuously monitor our envi


heading: Engagement of Expert Assistance

body_start: The Company leverages the expertise of independent consultan


heading: Training and Awareness Programs

body_start: We provide training to our management and employees designed


heading: Technology and External Consultants

body_start: We use external consultants or other third-party experts and


heading: Approach

body_start: We have implemented a cross-functional approach to identifyi


heading: Safeguards

body_start: We deploy technical safeguards that are designed to protect


heading: Consultants

body_start: We have identified and, as appropriate and when we have the


heading: Identification

body_start: We aim to proactively identify sources of risk, areas of imp


heading: Assessment

body_start: We conduct periodic risk assessments to identify cybersecuri


heading: Management

body_start: Following our risk assessments, we design and implement reas


heading: Management

body_start: Our financial data and primary operational systems are hoste


heading: Management

body_start: We have strategically integrated cybersecurity risk manageme


heading: Education and Awareness

body_start: We plan to establish a security and privacy awareness progra


heading: Controls

body_start: We deploy advanced firewalls, endpoint protection, and intru


heading: Training

body_start: All employees receive mandatory cybersecurity awareness trai


heading: Breaches

body_start: A breach of our information systems could lead to unauthoriz


heading: Relationships

body_start: Our reliance on third-party vendors and service providers ex


heading: Management and Oversight

body_start: Our board, as part of the board's enterprise risk management


heading: Approval

body_start: The board reviews and approves cybersecurity budgets and res


heading: Decisions

body_start: The board, based upon recommendation of management or our ex


heading: Training and Awareness

body_start: Members of management and members of our board take reasonab


heading: Network and Infrastructure Security

body_start: We employ a range of technical measures to secure our networ


heading: Compliance and Reporting

body_start: We comply with all applicable laws and regulations related t


heading: Safeguards

body_start: We deploy technical and non-technical safeguards that are de


heading: Education and Awareness

body_start: We provide regular, mandatory training, including ongoing en


heading: Education and Awareness

body_start: The Company provides regular, mandatory trainings for applic


heading: Education and Awareness

body_start: The Company provides regular, mandatory training for personn


heading: Education and Awareness

body_start: We understand the importance of informed personnel, so we co


heading: Assessment

body_start: We periodically assess our risks relating to cybersecurity t


heading: Management

body_start: If deemed appropriate, we design and implement reasonable sa


heading: Management

body_start: If deemed appropriate, we would design and implement reasona


heading: Oversight

body_start: Currently, our sole director does not have a formal structur


heading: Risk and Compliance

body_start: Our approach to cybersecurity governance, risk and complianc


heading: Architecture

body_start: Our information security architecture is focused on designin


heading: Education and Awareness

body_start: We provide regular, mandatory training for our employees reg


heading: Education and Awareness

body_start: We work in partnership with our human resources team to prov


heading: Education and Awareness

body_start: Our Manager provides regular, mandatory training for its emp


heading: Education and Awareness

body_start: All employees must complete mandatory, annual comprehensive


heading: Education and Awareness

body_start: We provide annual mandatory training for personnel regarding


heading: Identification of Strategic Objectives

body_start: The alignment of strategic objectives and risk management to


heading: Identification of Risks

body_start: A continuous effort to identify which risks are likely to af


heading: Expertise

body_start: While current management and the Board do not have in-depth