What changed in this filing

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Item 4. Controls and Procedures

2021-05-17 compared with 2020-11-16 · 36 added, 37 removed, 5 unchanged (94% of the section changed)

1 unchanged sentence

of Disclosure Controls and Procedures

conducted an evaluation under the supervision and with the participation of our management, including our Co-Chief Executive Officers

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

“disclosure controls and procedures,”

as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act

of 1934, as amended, or Exchange Act, means controls and other procedures of a company that are designed to ensure that information

required to be disclosed by the company in the reports it files or submits under the Exchange Act is recorded, processed, summarized

and reported, within the time periods specified in the Securities and Exchange Commission’s rules and forms.

controls and procedures also include, without limitation, controls and procedures designed to ensure that information required

to be disclosed by a company in the reports that it files or submits under the Exchange Act is accumulated and communicated to

the company’s management, including its principal executive and principal financial officers, or persons performing similar

functions, as appropriate, to allow timely decisions regarding required disclosure.

Based on this evaluation, our Co-Chief Executive

Officers and Chief Financial Officer concluded as of September 30, 2020 that our disclosure controls and procedures were effective

at a reasonable assurance level.

conducted 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.

The term “disclosure

controls and procedures,”

as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended, or

Exchange Act, means controls and other procedures of a company that are designed to ensure that information required to be disclosed

by the company in the reports it files or submits under the Exchange Act is recorded, processed, summarized and reported, within the

time periods specified in the Securities and Exchange Commission’s rules and forms.

Disclosure controls and procedures also include,

without limitation, controls and procedures designed to ensure that information required to be disclosed by a company in the reports

that it files or submits under the Exchange Act is accumulated and communicated to the company’s management, including its principal

executive and principal financial officers, or persons performing similar functions, as appropriate, to allow timely decisions regarding

required disclosure.

Based on this evaluation, our Chief Executive Officer and Chief Financial Officer concluded as of March 31, 2021

that our disclosure controls and procedures were effective at a reasonable assurance level.

in Internal Control over Financial Reporting

has been no change in our internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange

Act) during the most recently completed fiscal quarter that has materially affected, or is reasonably likely to materially affect,

our internal control over financial reporting.

has been no change in our internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act)

during the most recently completed fiscal quarter that has materially affected, or is reasonably likely to materially affect, our internal

control over financial reporting.

Limitations on the Effectiveness of Controls

does not expect that our disclosure controls and procedures or our internal control over financial reporting will prevent or detect

all errors and all fraud.

A control system, no matter how well conceived and operated, can provide only reasonable, not absolute,

assurance that the objectives of the control systems are met.

Further, the design of a control system must reflect the fact that

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

Because of the inherent

limitations in a cost-effective control system, no evaluation of internal control over financial reporting can provide absolute

assurance that misstatements due to error or fraud will not occur or that all control issues and instances of fraud, if any, have

been or will be detected.

inherent limitations include the realities that judgments in decision-making can be faulty and that breakdowns can occur because

of a simple error or mistake.

Controls can also be circumvented by the individual acts of some persons, by collusion of two or

more people, or by management override of the controls.

The design of any system of controls is based in part 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.

Projections of any evaluation of controls effectiveness to future periods are subject to

Over time, controls may become inadequate because of changes in conditions or deterioration in the degree of compliance

with policies or procedures.

does not expect that our disclosure controls and procedures or our internal control over financial reporting will prevent or detect all

errors and all fraud.

A control system, no matter how well conceived and operated, can provide only reasonable, not absolute, assurance

that the objectives of the control systems are met.

Further, the design of a control system must reflect the fact that there are resource

constraints, and the benefits of controls must be considered relative to their costs.

Because of the inherent limitations in a cost-effective

control system, no evaluation of internal control over financial reporting can provide absolute assurance that misstatements due to error

or fraud will not occur or that all control issues and instances of fraud, if any, have been or will be detected.

inherent limitations include the realities that judgments in decision-making can be faulty and that breakdowns can occur because of a

simple error or mistake.

Controls can also be circumvented by the individual acts of some persons, by collusion of two or more people,

or by management override of the controls.

The design of any system of controls is based in part 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

Projections of any evaluation of controls effectiveness to future periods are subject to risks.

Over time, controls may become

inadequate because of changes in conditions or deterioration in the degree of compliance with policies or procedures.

II - 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