What changed in this filing

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Item 4. Controls and Procedures

2021-11-15 compared with 2021-08-12 · 31 added, 33 removed, 2 unchanged (97% of the section changed)

CONTROLS AND PROCEDURES.

Disclosure Controls and Procedures

We maintain disclosure controls and procedures

designed to provide reasonable assurance that material information required to be disclosed by us in the reports we file or submit under

the Securities Exchange Act of 1934 is recorded, processed, summarized and reported within the time periods specified in the SEC’s

rules and forms, and that the information is accumulated and communicated to our management, including our Chief Executive Officer and

Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure.

We performed an evaluation, under the

supervision and with the participation of our management, including our Chief Executive Officer and Chief Financial Officer, of the effectiveness

of the design and operation of our disclosure controls and procedures as of the end of the period covered by this report.

Based on their evaluation, our management, including

our Chief Executive Officer and Chief Financial Officer, concluded that our disclosure controls and procedures were not effective as of

June 30, 2021.

We do not expect that our disclosure controls

and procedures will prevent all errors and all instances of fraud.

Disclosure controls and procedures, no matter how well conceived and

operated, can provide only reasonable, not absolute, assurance that the objectives of the disclosure controls and procedures are met.

Further, the design of disclosure controls and procedures must reflect the fact that there are resource constraints, and the benefits

must be considered relative to their costs.

Because of the inherent limitations in all disclosure controls and procedures, no evaluation

of disclosure controls and procedures can provide absolute assurance that we have detected all our control deficiencies and instances

of fraud, if any.

The design of disclosure controls and procedures is also based partly on certain assumptions about the likelihood of

future events, and there can be no assurance that any design will succeed in achieving its stated goals under all potential future conditions.

Management Plan to Remediate Material Weaknesses

We expect to implement the following measures

in 2021 to continue to remediate the material weaknesses identified:

To continue providing applicable training for our financial and accounting staff to enhance their understanding of U.S.

GAAP and internal control over financial reporting.

To expand involvement of qualified external consultants to supervise and review our financial reporting process.

Changes in Internal Control Over Financial Reporting

There have been no changes in our internal controls

over financial reporting that occurred during our last fiscal quarter to which this Quarterly Report on Form 10-Q relates that have materially

affected, or are reasonably likely to materially affect our internal controls over financial reporting.

Controls and Procedures

maintain disclosure controls and procedures designed to provide reasonable assurance that material information required to be disclosed

by us in the reports we file or submit under the Securities Exchange Act of 1934 is recorded, processed, summarized and reported within

the time periods specified in the SEC’s rules and forms, and that the information is accumulated and communicated to our management,

including our Chief Executive Officer and Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure.

We performed an evaluation, under the supervision and with the participation of our management, including our Chief Executive Officer

and Chief Financial Officer, of the effectiveness of the design and operation of our disclosure controls and procedures as of the end

of the period covered by this report.

on their evaluation, our management, including our Chief Executive Officer and Chief Financial Officer, concluded that our disclosure

controls and procedures were not effective as of September 30, 2021.

do not expect that our disclosure controls and procedures will prevent all errors and all instances of fraud.

Disclosure controls and

procedures, no matter how well conceived and operated, can provide only reasonable, not absolute, assurance that the objectives of the

disclosure controls and procedures are met.

Further, the design of disclosure controls and procedures must reflect the fact that there

are resource constraints, and the benefits must be considered relative to their costs.

Because of the inherent limitations in all disclosure

controls and procedures, no evaluation of disclosure controls and procedures can provide absolute assurance that we have detected all

our control deficiencies and instances of fraud, if any.

The design of disclosure controls and procedures is also based partly on certain

assumptions about the likelihood of future events, and there can be no assurance that any design will succeed in achieving its stated

goals under all potential future conditions.

Plan to Remediate Material Weaknesses

expect to implement the following measures in 2021 to continue to remediate the material weaknesses identified:

continue providing applicable training for our financial and accounting staff to enhance their understanding of U.S.

GAAP and internal

control over financial reporting.

expand involvement of qualified external consultants to supervise and review our financial reporting process.

in Internal Control Over Financial Reporting

have been no changes in our internal controls over financial reporting that occurred during our last fiscal quarter to which this Quarterly

Report on Form 10-Q relates that have materially affected, or are reasonably likely to materially affect our internal controls over financial

- OTHER INFORMATION

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-Q

Item 4. Controls and Procedures