What changed in this filing

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Item 4. Controls and Procedures

2021-05-21 compared with 2020-11-13 · 27 added, 14 removed, 5 unchanged (89% of the section changed)

Controls and Procedures

Evaluation of Disclosure Controls and

Our management, with

the participation of our principal executive officer and principal financial officer, carried out an evaluation of the effectiveness

of the design and operation of our disclosure controls and procedures as of the end of the period covered by this report, as defined

in Rules 13a-15(e) and 15d-15(e) under the Exchange Act.

Based on this evaluation, our management, with the participation

of our principal executive officer and principal financial officer, concluded that, as of the end of the period covered by this

report, our disclosure controls and procedures were effective at the reasonable assurance level.

Evaluation of Disclosure Controls and Procedures

Our management, with the participation

of our principal executive officer and principal financial officer, carried out an evaluation of the effectiveness of the design and operation

of our disclosure controls and procedures as of the end of the period covered by this report, as defined in Rules 13a-15(e) and

15d-15(e) under the Exchange Act.

Based on this evaluation, our management, with the participation of our principal executive officer

and principal financial officer, concluded that, as of the end of the period covered by this report, our disclosure controls and procedures

were not effective at the reasonable assurance level.

During the year ended December

31, 2020, our management identified a material weakness in our internal control over financial reporting whereas we did not design or

maintain effective controls to ensure that there is an independent review and approval of electronic payments (wires, EFT’s, ACH’s

and credit card payments) as our policy of providing timely support to ensure completeness and accuracy of the payment was not followed.

We are currently implementing a detailed plan for remediation of the material weakness, including developing and maintaining preventative

controls around the electronic payment process to ensure proper segregation of duties.

Changes in Internal Control over Financial

There has been no change

in our internal control over financial reporting that occurred during the second quarter of 2020 that has materially affected,

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

There has been no change in

our internal control over financial reporting that occurred during the first quarter of 2021 that has materially affected, or is reasonably

likely to materially affect, our internal control over financial reporting.

Inherent Limitations of the Effectiveness of

does not expect that our disclosure controls and procedures or our internal control over financial reporting will prevent or detect all

error and fraud.

A control system, no matter how well designed and operated, is based upon certain assumptions and can provide only reasonable,

not absolute, assurance that its objectives will be met.

Further, no evaluation of controls can provide absolute assurance that misstatements

due to error or fraud will not occur or that all control issues and instances of fraud, if any, within the Company have been detected.

PART II –

1 unchanged sentence

Legal Proceedings

There have been no material changes to the

risk factors discussed in Item 1A.

Risk Factors in our Annual Report on Form 10-K which was filed with the SEC on May 14,

There have been no material changes to the risk

factors discussed in Item 1A.

Risk Factors in our Annual Report on Form 10-K which was filed with the SEC on March 19, 2021.

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