3 unchanged sentences
Management recognizes that any controls and procedures, no matter how well designed and operated, can provide only reasonable assurance of achieving their objectives and management necessarily applies its judgment in evaluating the cost-benefit relationship of possible controls and procedures.
−Removed: Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, evaluated the effectiveness of our disclosure controls and procedures as of June 30, 2023.
+Added: Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, evaluated the effectiveness of our disclosure controls and procedures as of September 30, 2023.
Based upon the evaluation, our Chief Executive Officer and Chief Financial Officer concluded that, as of such date, our disclosure controls and procedures were not effective at a reasonable assurance level, due to the material weaknesses previously identified and disclosed in our 2022 Annual Report and listed below.
A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting (“ICFR”) such that there is a reasonable possibility that a material misstatement of our annual or interim financial statements will not be prevented or detected on a timely basis.
−Removed: Management determined that the previously disclosed material weaknesses in its ICFR continue to exist at June 30, 2023.
+Added: Management determined that the previously disclosed material weaknesses in its ICFR continue to exist at September 30, 2023.
Specifically:
Control Environment, Risk Assessment and Monitoring Activities – We did not maintain appropriately designed entity-level controls impacting the control environment and effective monitoring controls to prevent or detect material misstatements to the consolidated financial statements.
−Removed: These deficiencies were attributed to (i) a lack
−Removed: of a sufficient number of qualified resources and inadequate oversight and accountability over the performance of control activities, (ii) ineffective identification and assessment of risks to properly design and implement relevant controls, and (iii) ineffective evaluation and determination as to whether the components of internal control were present and functioning.
+Added: These deficiencies were attributed to (i) a lack of a sufficient number of qualified resources and inadequate oversight and accountability over the performance of control activities, (ii) ineffective identification and assessment of risks to properly design and implement relevant controls, and (iii) ineffective evaluation and determination as to whether the components of internal control were present and functioning.
Control Activities – These material weaknesses contributed to the following additional material weaknesses within certain business processes:
4 unchanged sentences
• Financial Reporting, Consolidation and Business Combination – We did not appropriately design, implement and maintain effective controls over the financial reporting process.
−Removed: Specifically, we did not maintain effective controls related to (i) preparation of consolidated financial statements, (ii) the accounting for the business combination, including management review controls over the valuation and purchase price allocation, at an appropriate level of precision to detect a material misstatement, and (iii) consolidation of our subsidiaries.
+Added: Specifically, we did not maintain effective controls related to (i) preparation of consolidated financial statements, (ii) the accounting for the business combination, including management review controls over the valuation and
+Added: purchase price allocation, at an appropriate level of precision to detect a material misstatement, and (iii) consolidation of our subsidiaries.
In addition, we did not maintain sufficient appropriate audit evidence to demonstrate execution of the related controls.
1 unchanged sentence
This resulted in the restatement of the Company’s interim unaudited condensed consolidated financial statements.
−Removed: • STI - Although management did not conduct a formal ICFR assessment of STI as of June 30, 2023, management has identified material weaknesses in STI’s ICFR as follows:
+Added: • STI - As 2023 is the first year STI is required to be Sarbanes-Oxley Act of 2002 compliant, management is in the process of conducting a formal ICFR assessment of STI and has identified material weaknesses in STI’s ICFR as follows:
◦ We did not design, implement and monitor general information technology controls in the areas of program change management, user access, and segregation of duties for systems supporting substantially all of STI’s internal control processes.
14 unchanged sentences
We expect to deploy final phases of information system enhancements by the end of 2023.
−Removed: • Revenue Recognition and Accounts Receivable – We are in the process of evaluating our information system capabilities in order to reduce the manual calculations within the revenue recognition business processes.
+Added: • Revenue Recognition and Accounts Receivable – We continue to evaluate our information system capabilities in order to reduce the manual calculations within the revenue recognition business processes.
We have begun to deploy information systems enhancements targeted at eliminating manual processes.
−Removed: Additionally, we are enhancing the design of existing controls to ensure completeness and accuracy of underlying source data for revenue recognition and customer billing.
+Added: Additionally, we are enhancing the design of existing controls to ensure completeness and accuracy of underlying source data for revenue recognition and customer billing, as well as designing monitoring controls to increase oversight and timely detection of potential errors.
Lastly, we will continue to supplement our accounting staff with more experienced personnel which will enable us to incorporate an additional level of review.
−Removed: • Foreign Currency – We have implemented information system enhancements which automate this previously manual process.
−Removed: We will we utilize the enhancements in parallel with our manual process for the near term until we are fully automated.
+Added: • Foreign Currency – We have implemented information system enhancements which will automate this previously manual process.
+Added: We will we utilize the enhancements in parallel with our manual process for the near term until the enhancements are fully deployed and the process is completely automated.
We have continued to enhance the design of existing controls and processes related to the foreign currency translation process and over the consolidation of foreign entities into our condensed consolidated financial statements.
7 unchanged sentences
Changes in Internal Control over Financial Reporting
−Removed: Other than as discussed above, there were no other changes to our internal control over financial reporting during the three months ended June 30, 2023, that have materially affected, or that are reasonably likely to materially affect, our internal control over financial reporting.
+Added: Other than as discussed above, there were no other changes to our internal control over financial reporting during the three months ended September 30, 2023, that have materially affected, or that are reasonably likely to materially affect, our internal control over financial reporting.
PART 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.