Item 4. Controls and Procedures
ITEM 4 - CONTROLS AND PROCEDURES
 
(a) Evaluation of disclosure controls and procedures.
 
Our
management, with the participation of our Chief Executive Officer
and Chief Financial Officer, evaluated the effectiveness of our
disclosure controls and procedures pursuant to Rule 13a-15 under
the Securities Exchange Act of 1934, as amended (the
“ Exchange Act ”)
as of the end of the period covered by this Report. In designing
and evaluating the disclosure controls and procedures, management
recognizes that any controls and procedures, no matter how well
designed and operated, can provide only reasonable assurance of
achieving the desired control objectives. In addition, the design
of disclosure controls and procedures must reflect the fact that
there are resource constraints and that management is required to
apply its judgment in evaluating the benefits of possible controls
and procedures relative to their costs.
 
Based
on our evaluation, our Chief Executive Officer and Chief
Financial Officer concluded that, as of December 31, 2020, our
disclosure controls and procedures are designed at a reasonable
assurance level and are effective to provide reasonable assurance
that information we are required to disclose in reports that we
file or submit under the Exchange Act is recorded, processed,
summarized and reported within the time periods specified in
Securities and Exchange Commission rules and forms, and that such
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.
 
(b) Changes in internal control over financial
reporting.
 
During the year ended December 31, 2020, the
Company took extensive measures towards remediating the material
weaknesses disclosed in the Company’s Annual Report on Form
10-K for the year ended December 31, 2018, and other periodic
reports filed with the SEC. These measures include, among other
things, additional hiring in the accounting department to ensure
appropriate segregation of duties, strengthening its controls over
IT reporting and management, and the ongoing refinement of our
enterprise resource planning system. We determined that the design
of internal control over financial statement processes is effective
in relation to identified inherent risks for all significant
processes, based on review of controls in whole, and testing of
each control individually for effectiveness in meeting control
objectives. As a result, it has been determined that there were no
material weaknesses of internal control over financial reporting
for the quarter ended March 31, 2021.
 
 
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Table of Contents
 
 
PA R T II - OTHER
INFORMATION
 
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