What changed in this filing

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Item 4. Controls and Procedures

2022-06-09 compared with 2022-06-09 · 36 added, 42 removed, 13 unchanged (86% of the section changed)

4 unchanged sentences

procedures, as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act as of the end of the period covered by this

Based on that evaluation, our Chief Executive Officer and Chief Financial Officer, concluded that, as of June 30, 2021, due to

the material weaknesses in our internal control over financial reporting described below, our disclosure controls and procedures were

Based on that evaluation, our Chief Executive Officer and Chief Financial Officer, concluded that, as of March 31, 2021, due

to the material weaknesses in our internal control over financial reporting described below, our disclosure controls and procedures were

not effective to provide reasonable assurance that the information required to be disclosed in the reports required to be filed or submitted

3 unchanged sentences

Report on Internal Control over Financial Reporting

is res ponsible for establishing and maintaining adequate internal control over financial reporting (as defined in Rules 13a-15(f)

and 15d-15(f) under the Exchange Act) for the Company.

Management, with the participation of our principal executive officer and our

principal financial officer, evaluated the effectiveness of our internal control over financial reporting as of June 30, 2021, based

on the framework and criteria established in the 2013 Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations

of the Treadway Commission.

At the time of our Original

Filing, management, including our Chief Executive Officer and our Chief Financial Officer, initially concluded that our internal control

over financial reporting was effective as of June 30, 2021.

As a result of the restatement of the Company’s financial statements

and the filing of this Form 10-Q/A, our management has reconsidered its assessment and now concludes that we did not maintain effective

internal control over financial reporting as of June 30, 2021, due to the material weakness in internal control over financial reporting

described below that existed as of June 30, 2021.

A material weakness is a deficiency,

or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material

misstatement of the Company’s annual or interim financial statements will not be prevented or detected on a timely basis.

Management identified the

following material weaknesses in our internal control over financial reporting related to its accounting for equity compensation.

Specifically,

the Company did not maintain a compliment of accounting personnel with sufficient knowledge, experience and training in the application

is responsible for establishing and maintaining adequate internal control over financial reporting (as defined in Rules 13a-15(f) and

15d-15(f) under the Exchange Act) for the Company.

Management, with the participation of our principal executive officer and our principal

financial officer, evaluated the effectiveness of our internal control over financial reporting as of March 31, 2021, based on the framework

and criteria established in the 2013 Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations of the

Treadway Commission.

the time of our Original Filing, management, including our Chief Executive Officer and our Chief Financial Officer , initially

concluded that our internal control over financial reporting was effective as of March 31, 2021.

As a result of the restatement of the

Company’s financial statements and the filing of this Form 10-Q/A, our management has reconsidered its assessment and now concludes

that we did not maintain effective internal control over financial reporting as of March 31, 2021, due to the material weakness in internal

control over financial reporting described below that existed as of March 31, 2021.

material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is

a reasonable possibility that a material misstatement of the Company’s annual or interim financial statements will not be prevented

or detected on a timely basis.

identified the following material weaknesses in our internal control over financial reporting related to its accounting for equity compensation.

Specifically, the Company did not maintain a compliment of accounting personnel with sufficient knowledge, experience and training in

the application of U.S.

GAAP as it relates to accounting and reporting for equity compensation.

This material weakness contributed to a failure to maintain

effective controls over the accounting and reporting for stock options.

Remediation Plan

Historically, the Company

managed the administration and recordkeeping of the Company’s equity compensation in-house.

Managing this complex process was unduly

burdensome and directly contributed to the material weakness.

Beginning in the second quarter

of 2022, the Company will no longer maintain the administration and recordkeeping of its equity compensation plans internally but instead

will outsource this function to a third-party brokerage firm specializing in these tasks.

This specialization will improve the accuracy

of reporting and the Company’s legal and regulatory compliance around equity compensation.

The Company has also engaged

a professional services firm to oversee the implementation of a global broker-dealer firm specializing in equity compensation platforms,

as well as provide recommendations on best practices, processes, and internal controls going forward.

Changes in Internal Controls over Financial Reporting

There was no change in our internal

controls over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act) during the second quarter

of 2021 covered by this Quarterly Report on Form 10-Q/A that have materially affected, or are reasonably likely to materially

affect, our internal controls over financial reporting.

This material weakness contributed to

a failure to maintain effective controls over the accounting and reporting for stock options.

Historically,

the Company managed the administration and recordkeeping of the Company’s equity compensation in-house.

Managing this complex process

was unduly burdensome and directly contributed to the material weakness.

in the second quarter of 2022, the Company will no longer maintain the administration and recordkeeping of its equity compensation plans

internally but instead will outsource this function to a third-party brokerage firm specializing in these tasks.

This specialization

will improve the accuracy of reporting and the Company’s legal and regulatory compliance around equity compensation.

Company has also engaged a professional services firm to oversee the implementation of a global broker-dealer firm specializing in equity

compensation platforms, as well as provide recommendations on best practices, processes, and internal controls going forward.

in Internal Controls over Financial Reporting

was no change in our internal controls over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act)

during the first quarter of 2021 covered by this Quarterly Report on Form 10-Q/A that have materially affected, or are reasonably likely

to materially affect, our internal controls over financial reporting.

II - Other Information

1 unchanged sentence

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/A

Item 4. Controls and Procedures