What changed in this filing

/stocks — the workspaceLOADING

Item 4. Controls and Procedures

2021-05-17 compared with 2020-11-16 · 26 added, 26 removed, 8 unchanged (87% of the section changed)

and Procedures

Controls and Procedures

Disclosure Controls and Procedures

3 unchanged sentences

13a-15(e) and 15d-15(e) under the Exchange Act, as of the end of the period covered by this report.

Disclosure controls and procedures

include, without limitation, controls and procedures designed 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 the SEC’s 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

Based on this evaluation, our Chief Executive Officer and Chief Financial Officer concluded that, as of September 30,

2020, our disclosure controls and procedures were not effective due to a material weakness in our internal control over financial

Specifically, we currently lack sufficient accounting personnel with the appropriate level of knowledge, experience

and training in U.S.

Disclosure controls and

procedures include, without limitation, controls and procedures designed 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 the SEC’s 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.

Based on this evaluation, our Chief Executive Officer and Chief Financial Officer concluded that, as of March

31, 2021, our disclosure controls and procedures were not effective due to a material weakness in our internal control over

financial reporting.

Specifically, we currently lack sufficient accounting personnel with the appropriate level of knowledge,

experience and training in U.S.

GAAP and SEC reporting requirements.

Changes to Internal Control over Financial Reporting

We have taken, and are taking, certain

actions to remediate the material weakness related to our lack of U.S.

We have taken, and are taking, certain actions

to remediate the material weakness related to our lack of U.S.

GAAP experience.

We have engaged consultants with U.S.

knowledge and experience to supplement our current internal accounting personnel and assist us in the preparation of our financial

statements to ensure that our financial statements are prepared in accordance with U.S.

Other than discussed above, there were

no changes in our internal control over financial reporting (as defined in Rule 13a-15(f) of the Exchange Act) that occurred during

the period covered by this report that have materially affected, or are reasonably likely to materially affect, our internal control

over financial reporting.

We have engaged an outside consultant with U.S.

GAAP knowledge

and experience to supplement our current internal accounting personnel and assist us in the preparation of our financial statements to

ensure that our financial statements are prepared in accordance with U.S.

We believe the measures described above will remediate

the material weakness from the quarter identified above.

As we continue to evaluate and work to improve our internal control over financial

reporting, we may determine that additional measures.

Changes to Internal Control over Financial

Other than discussed above, there were no changes

in our internal control over financial reporting (as defined in Rule 13a-15(f) of the Exchange Act) that occurred during the period covered

by this report that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.

OTHER INFORMATION

described in our Annual Report for the year ended December 31, 2019 and the footnotes of this Quarterly Report, we are party to

a number of legal proceedings.

There have been no material developments in those proceedings during the three months ended September

Sales of Equity Securities and Use of Proceeds

upon Senior Securities

Safety Disclosure

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