Wright Investors Service Holdings Inc

The Company recognizes the importance of assessing, identifying, and managing material risks associated with cybersecurity threats (as defined in Item 106(a) of Regulation S-K). These risks include, among others, operational risks, fraud, and violation of privacy. The Company, a shell entity, does not have processes in place since cybersecurity is not a risk to the Company due to the size of the Company, nature of its operations, and the number of transactions during the year. As needed, and in order to keep the Company informed of new and evolving cybersecurity risks, the Company consults with external parties such as information technology experts about risk management and strategy.

The audit committee assists the board of directors in fulfilling its oversight responsibilities with respect to the adequacy and effectiveness of the Company’s information security policies and practices and the internal controls regarding information security risks. The board and its committees engage with management to discuss potential enterprise risks, including matters related to cybersecurity.

We do not believe that there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us or our business strategy, results of operations or financial condition.