CONTROLS AND PROCEDURES
−Removed: of disclosure controls and procedures
+Added: Evaluation of Disclosure Controls and Procedures
disclosure controls and procedures are designed to ensure that information we are required to disclose in reports that we file or submit
8 unchanged sentences
the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with U.S.
−Removed: As of April 30, 2021, our management assessed the effectiveness of our internal control over financial reporting using the criteria set
−Removed: forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control-Integrated Framework, or 2013 Framework.
−Removed: Based on this assessment, our management concluded that, as of April 30, 2021, our internal control over financial reporting was not effective
−Removed: because of a material weakness in our internal control over financial reporting related to the lack of accounting department resources
−Removed: and/or policies and procedures to ensure recording and disclosure of items in compliance with generally accepted accounting principles.
−Removed: We have taken and are taking steps to remediate the material weakness, including implementing additional procedures and utilizing external
−Removed: consulting resources with experience and expertise in U.S.
−Removed: GAAP and public company accounting and reporting requirements to assist management
−Removed: with its accounting and reporting of complex and/or non-recurring transactions and related disclosures.
−Removed: in internal control
−Removed: We do not believe that during
−Removed: the quarter ended July 31, 2021, there was yet any change in our internal control over financial reporting that materially affected, or
−Removed: is reasonably likely to materially affect, our internal control over financial reporting.
+Added: As of October 31, 2021, our management assessed the effectiveness of our internal control over financial reporting using the criteria
+Added: set forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control-Integrated Framework, or 2013 Framework.
+Added: Based on this assessment, our management concluded that, as of October 31, 2021, our internal control over financial reporting was not
+Added: effective because of a material weakness in our internal control over financial reporting related to the lack of accounting department
+Added: resources and/or policies and procedures to ensure recording and disclosure of items in compliance with generally accepted accounting
+Added: We have taken and are taking steps to remediate the material weakness, including implementing additional procedures and utilizing
+Added: external consulting resources with experience and expertise in U.S.
+Added: GAAP and public company accounting and reporting requirements to assist
+Added: management with its accounting and reporting of complex and/or non-recurring transactions and related disclosures.
Notwithstanding the identified
4 unchanged sentences
assurance that all internal control issues and instances of fraud, if any, within a company are detected.
+Added: Changes in Internal Control
+Added: During the quarter ended October
+Added: 31, 2021, there was no change in our internal control over financial reporting that materially affected, or is reasonably likely to materially
+Added: affect, our internal control over financial reporting.
Limitations on the Effectiveness of Controls
15 unchanged sentences
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.