1 unchanged sentence
(a) Evaluation of Disclosure Controls and Procedures.
−Removed: The Company’s management, with the participation of the Chief Executive Officer and the Chief Financial Officer, performed an evaluation of the disclosure controls and procedures, as defined in Rules 13a-15(e) and 15d-15(e) of the Securities Exchange Act of 1934 (the “Exchange Act”), as of June 30, 2020.
−Removed: Based on that evaluation, management has concluded that, as of June 30, 2020, due to the existence of the material weaknesses in the Company’s internal control over financial reporting described below, the disclosure controls and procedures were not effective to provide reasonable assurance that the information required to be disclosed by us in reports we file or submit under the Exchange Act were recorded, processed, summarized and reported within the time periods specified in the rules and forms of the SEC, and to ensure that the information required to be disclosed by us in reports that we file or submit under the Exchange Act, is accumulated and communicated to management, including the principal executive officer and principal financial officer, as appropriate, to allow timely decisions regarding required disclosure.
+Added: The Company’s management, with the participation of the Chief Executive Officer and the Chief Financial Officer, performed an evaluation of the disclosure controls and procedures, as defined in Rules 13a-15(e) and 15d-15(e) of the Securities Exchange Act of 1934 (the “Exchange Act”), as of September 30, 2020.
+Added: Based on that evaluation, management has concluded that, as of September 30, 2020, due to the existence of the material weaknesses in the Company’s internal control over financial reporting described below, the disclosure controls and procedures were not effective to provide reasonable assurance that the information required to be disclosed by us in reports we file or submit under the Exchange Act were recorded, processed, summarized and reported within the time periods specified in the rules and forms of the SEC, and to ensure that the information required to be disclosed by us in reports that we file or submit under the Exchange Act, is accumulated and communicated to management, including the principal executive officer and principal financial officer, as appropriate, to allow timely decisions regarding required disclosure.
Material Weaknesses in Internal Controls Over Financial Reporting
11 unchanged sentences
During the first half of 2020, the Company implemented all remediation controls identified in its remediation plan as disclosed in the table below.
−Removed: During the six months ended June 30, 2020, the Company enhanced its quarterly review risk assessment model and its risk control matrices, established a risk committee, which reviews the risk assessment for changes in the business, enhanced its delegation of authority policy, conducted revenue recognition training, created and implemented a non-routine transaction policy, established a review process for and reviewed its vendor and customer transactions to identify potential related transactions, implemented procedures for the preparation of business cases for all non-routine business-to-business unbranded sales and purchases, and enhanced its sub-certification processes to identify non-routine transactions.
−Removed: The Company has completed internal testing on six of the eight controls identified in its remediation plan and expects to complete internal testing on the remaining controls during the third quarter of 2020.
+Added: During the nine months ended September 30, 2020, the Company enhanced its quarterly review risk assessment model and its risk control matrices, established a risk committee, which reviews the risk assessment for changes in the business, enhanced its delegation of authority policy, conducted revenue recognition training, created and implemented a non-routine transaction policy, established a review process for and reviewed its vendor and customer transactions to identify potential related transactions, implemented procedures for the preparation of business cases for all non-routine business-to-business unbranded sales and purchases, and enhanced its sub-certification processes to identify non-routine transactions.
+Added: The Company has completed internal testing on all of the eight controls identified in its remediation plan.
However, the Company does not expect full remediation until year end 2020.
8 unchanged sentences
• Establish review process and internal database to identify entities that are both vendors and customers of the Company
−Removed: Implemented Testing in Q3
+Added: Implemented Tested
• Create and implement revenue recognition training
6 unchanged sentences
• Formalization of business cases for all non-routine business to business unbranded sales and purchases to be reviewed on a quarterly basis to ensure alignment with the objectives of the business
−Removed: Implemented Testing in Q3
+Added: Implemented Tested
• Expand the sub-certification process to additional members of management to ensure that non routine transactions are identified
4 unchanged sentences
(b) Changes in Internal Control over Financial Reporting
−Removed: Subsequent to the second quarter of 2020, the Company successfully implemented a new ERP system across the Canadian business.
+Added: During the third quarter of 2020, the Company successfully implemented a new ERP system across the Canadian business.
The new ERP system will be a meaningful component of our internal control over financial reporting and is expected to enable us to realize efficiencies throughout our finance, supply chain and operations processes.
−Removed: Other than the ERP system and those measures described above to remediate the material weaknesses, there were no further changes in the Company’s internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act), that occurred during the quarter ended June 30, 2020, that have materially affected, or are reasonably likely to materially affect, the Company’s internal control over financial reporting.
−Removed: PART II OTHER INFORMATION
+Added: In connection with the ERP implementation, we updated the processes and controls that constitute our internal control over financial reporting, as necessary, to accommodate related changes to our accounting procedures and business processes.
+Added: The Company is currently in the process of updating its processes and internal control over financial reporting in the U.S.
+Added: segment for the year ended December 31, 2020.
+Added: In 2019, the U.S.
+Added: segment was excluded from management’s assessment of the effectiveness of the Company’s internal control over financial reporting as it was the first year of the Redwood Acquisition.
+Added: Other than the ERP system, the updates of processes and internal control over financial reporting for the U.S.
+Added: segment and those measures described above to remediate the material weaknesses, there were no further changes in the Company’s internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act), that occurred during the quarter ended September 30, 2020, that have materially affected, or are reasonably likely to materially affect, the Company’s internal control over financial reporting.
+Added: 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.