1 unchanged sentence
Controls and Procedures
−Removed: Securities and Exchange Commission (“SEC”) defines the term “disclosure controls and procedures”
−Removed: a company’s controls and other procedures of an issuer that are designed to ensure that information required to be disclosed
−Removed: in the reports that it files or submits under the Securities Exchange Act of 1934 (the “Exchange Act”) is recorded,
−Removed: processed, summarized and reported, within the time periods specified in the SEC’s rules and forms.
−Removed: Disclosure controls
−Removed: and procedures include, without limitation, controls and procedures designed to ensure that information required to be disclosed
−Removed: by an issuer in the reports that it files or submits under the Exchange Act is accumulated and communicated to the issuer’s
−Removed: management, including its principal executive and principal financial officers, or persons performing similar functions, as appropriate
−Removed: to allow timely decisions regarding required disclosure.
−Removed: The Company maintains such a system of controls and procedures in an
−Removed: effort to ensure that all information which it is required to disclose in the reports it files under the Exchange Act is recorded,
−Removed: processed, summarized and reported within the time periods specified under the SEC’s rules and forms and that information
−Removed: required to be disclosed is accumulated and communicated to principal executive and principal financial officers to allow timely
−Removed: decisions regarding disclosure.
−Removed: of the end of the period covered by this report, the Company made an evaluation of the effectiveness of the design and operation
−Removed: of the disclosure controls and procedures over financial reporting for the timely alert to material information required to be
−Removed: included in the Company’s periodic SEC reports and of ensuring that such information is recorded, processed, summarized
−Removed: and reported within the time periods specified.
+Added: Securities and Exchange Commission (“SEC”) defines the term “disclosure controls and procedures” to mean a company’s
+Added: controls and other procedures of an issuer that are designed to ensure that information required to be disclosed in the reports that
+Added: it files or submits under the Securities Exchange Act of 1934 (the “Exchange Act”) is recorded, processed, summarized and
+Added: reported, within the time periods specified in the SEC’s rules and forms.
+Added: Disclosure controls and procedures include, without limitation,
+Added: controls and procedures designed to ensure that information required to be disclosed by an issuer in the reports that it files or submits
+Added: under the Exchange Act is accumulated and communicated to the issuer’s management, including its principal executive and principal
+Added: financial officers, or persons performing similar functions, as appropriate to allow timely decisions regarding required disclosure.
+Added: The Company maintains such a system of controls and procedures in an effort to ensure that all information which it is required to disclose
+Added: in the reports it files under the Exchange Act is recorded, processed, summarized and reported within the time periods specified under
+Added: the SEC’s rules and forms and that information required to be disclosed is accumulated and communicated to principal executive
+Added: and principal financial officers to allow timely decisions regarding disclosure.
+Added: of the end of the period covered by this report, the Company made an evaluation of the effectiveness of the design and operation of the
+Added: disclosure controls and procedures over financial reporting for the timely alert to material information required to be included in the
+Added: Company’s periodic SEC reports and of ensuring that such information is recorded, processed, summarized and reported within the
+Added: time periods specified.
This evaluation resulted in the identification of significant deficiencies.
−Removed: on the context in which the individual deficiencies occurred, management has concluded that these significant deficiencies, in
−Removed: combination, represent a material weakness.
−Removed: The Company’s CEO and CFO also concluded that updates to the disclosure controls
−Removed: and procedures should be made to improve the effectiveness of the controls and procedures to provide reasonable assurance of the
−Removed: assurance of these objectives.
+Added: Based on the context in which the
+Added: individual deficiencies occurred, management has concluded that these significant deficiencies, in combination, represent a material
+Added: The Company’s CEO and CFO also concluded that updates to the disclosure controls and procedures should be made to improve
+Added: the effectiveness of the controls and procedures to provide reasonable assurance of the assurance of these objectives.
in Internal Control Over Financial Reporting
−Removed: Mitigating these significant deficiencies,
−Removed: however, is that, commencing in 2020 and 2021, the Company has a new management team and new members of the Board of Directors,
−Removed: including a new Chair of the Audit Committee, and a new Chief Financial Officer, which are focused on transitioning the Company
−Removed: to a new management approach, modern thinking, new systems and practices, modern approaches to engagement and a system of internal
−Removed: controls and procedures.
−Removed: Management’s daily involvement i n
−Removed: the business provides it with more than adequate knowledge to identify the areas of financial reporting risks and related controls.
−Removed: In addition, the procedures followed are integrated within the daily responsibilities of the Company’s employees, allowing
−Removed: management to rely on their own intimate knowledge and supervision of controls.
−Removed: As the Company’s business plan is implemented
−Removed: and additional staff is added, management will be able to address these significant deficiencies.
+Added: these significant deficiencies, however, is that, commencing in 2020 and 2021, the Company has a new management team and new members
+Added: of the Board of Directors, including a new Chair of the Audit Committee, and a new Chief Financial Officer, which are focused on transitioning
+Added: the Company to a new management approach, modern thinking, new systems and practices, modern approaches to engagement and a system of
+Added: internal controls and procedures.
+Added: Management’s daily involvement in the business provides it with more than adequate knowledge
+Added: to identify the areas of financial reporting risks and related controls.
+Added: In addition, the procedures followed are integrated within the
+Added: daily responsibilities of the Company’s employees, allowing management to rely on their own intimate knowledge and supervision
+Added: As the Company’s business plan is implemented and additional staff is added, management will be able to address these
+Added: significant deficiencies.
has also engaged a contract Controller and a third-party firm to assist in developing Disclosure Controls and Procedures and Internal
2 unchanged sentences
resources available to complete them.
−Removed: OTHER INFORMATION
+Added: 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.