What changed in this filing

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Item 4. Controls and Procedures

2020-11-16 compared with 2020-08-14 · 37 added, 44 removed, 15 unchanged (84% of the section changed)

Controls and Procedures.

Evaluation of Disclosure Controls

and Procedures

Our management, under the supervision and

with the participation of our Chief Executive Officer (“CEO”) and Chief Financial Officer (“CFO”), has

evaluated the effectiveness of our disclosure controls and procedures as defined in SEC Rules 13a-15(e) and 15d-15(e) as of the

end of the period covered by this quarterly report.

The purpose of this evaluation is to determine if, as of Evaluation Date, our

disclosure controls and procedures were operating effectively such that the information, required to be disclosed in our Securities

and Exchange Commission (“SEC”) reports (i) was recorded, processed, summarized and reported within the time periods

specified in SEC rules and forms, and (ii) was accumulated and communicated to our management, including our Chief Executive

Officer and Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure.

Based on their evaluation, our Chief Executive

Officer and Chief Financial Officer have concluded that, as of June 30, 2020, our disclosure controls and procedures were not effective,

based on the material weakness described below:

We did not have sufficient skilled accounting

personnel that are either qualified as Certified Public Accountants in the U.S.

or that have received education from U.S.

or other educational programs that would provide enough relevant education relating to U.S.

The Company’s CFO and Financial

Manager have worked for U.S.

listed companies but have limited experience with U.S.

of Disclosure Controls and Procedures

management, under the supervision and with the participation of our Chief Executive Officer (“CEO”) and Chief Financial

Officer (“CFO”), has evaluated the effectiveness of our disclosure controls and procedures as defined in SEC Rules

13a-15(e) and 15d-15(e) as of the end of the period covered by this quarterly report.

The purpose of this evaluation is to determine

if, as of Evaluation Date, our disclosure controls and procedures were operating effectively such that the information, required

to be disclosed in our Securities and Exchange Commission (“SEC”) reports (i) was recorded, processed, summarized

and reported within the time periods specified in SEC rules and forms, and (ii) was accumulated and communicated to our management,

including our Chief Executive Officer and Chief Financial Officer, as appropriate to allow timely decisions regarding required

on their evaluation, our Chief Executive Officer and Chief Financial Officer have concluded that, as of September 30, 2020, our

disclosure controls and procedures were not effective, based on the material weakness described below:

did not have sufficient skilled accounting personnel that are either qualified as Certified Public Accountants in the U.S.

that have received education from U.S.

institutions or other educational programs that would provide enough relevant education

relating to U.S.

The Company’s CFO and Financial Manager have worked for U.S.

listed companies but have limited experience

GAAP and are not U.S.

Certified Public Accountants.

Further, our operating subsidiaries are based in China, and in accordance with PRC laws and regulations, are required to comply

with PRC GAAP, rather than U.S.

Thus, the accounting skills and understanding necessary to fulfill the requirements of U.S.

GAAP-based reporting, including the preparation of financial statements and consolidation, are inadequate, and determined to be

a material weakness.

Remediation Initiative

Further, our operating subsidiaries are based in China, and in accordance

with PRC laws and regulations, are required to comply with PRC GAAP, rather than U.S.

Thus, the accounting skills and understanding

necessary to fulfill the requirements of U.S.

GAAP-based reporting, including the preparation of financial statements and consolidation,

are inadequate, and determined to be a material weakness.

have started a training program in the principles and rules of U.S.

9 unchanged sentences

Currently, we are still in the process of seeking for a proper candidate to perform as our internal audit manager.

We believe that the foregoing steps will

remediate the significant deficiencies identified above, and we will continue to monitor the effectiveness of these steps and make

any changes that our management deems appropriate.

Because of its inherent limitations, internal

control over financial reporting may not prevent or detect misstatements.

Projections of any evaluation of effectiveness to future

periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance

with the policies or procedures may deteriorate.

All internal control systems, no matter how well designed, have inherent limitations.

Therefore, even those systems determined to be effective can provide only reasonable assurance with respect to financial statement

preparation and presentation.

Changes in Internal Control over

Financial Reporting

There were no changes in our internal control

over financial reporting for the six months ended June 30, 2020 that materially affected, or were reasonably likely to materially

affect our internal control over financial reporting.

PART II - OTHER INFORMATION

believe that the foregoing steps will remediate the significant deficiencies identified above, and we will continue to monitor

the effectiveness of these steps and make any changes that our management deems appropriate.

of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.

Projections of

any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes

in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

All internal control systems,

no matter how well designed, have inherent limitations.

Therefore, even those systems determined to be effective can provide only

reasonable assurance with respect to financial statement preparation and presentation.

in Internal Control over Financial Reporting

were no changes in our internal control over financial reporting for the nine months ended September 30, 2020 that materially

affected, or were reasonably likely to materially affect our internal control over financial reporting.

II - OTHER INFORMATION

Legal Proceedings.

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