What changed in this filing

/stocks — the workspaceLOADING

Item 4. Controls and Procedures

2023-11-08 compared with 2023-08-08 · 33 added, 29 removed, 42 unchanged (60% of the section changed)

1 unchanged sentence

of Disclosure Controls and Procedures

management, with the participation of our Chief Executive Officer and our Chief Financial Officer, has evaluated the effectiveness of

our disclosure controls and procedures (as such term is defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act) as of the end

of the period covered by this Interim Report to ensure that the information required to be disclosed by the Company in the reports that

it files or submits under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in SEC rules

and forms, and that information required to be disclosed in the reports we file or submit under the Exchange Act is accumulated and communicated

to our management, including our Chief Executive Officer and Chief Financial Officer, to allow timely decisions regarding required disclosures.

Based on this evaluation, our management concluded that our disclosure controls and procedures were not effective at the reasonable assurance

level as of June 30, 2023 due to the following material weaknesses.

The Company’s management, with the participation of its Chief Executive Officer and Chief Financial Officer, has

evaluated the effectiveness of its disclosure controls and procedures (as such term is defined in Rules 13a-15(e) and 15d-15(e) under

the Exchange Act) as of the end of the period covered by this Interim Report to ensure that the information required to be disclosed by

the Company in the reports that it files or submits under the Exchange Act is recorded, processed, summarized and reported within the

time periods specified in SEC rules and forms, and that information required to be disclosed in the reports it files or submits under

the Exchange Act is accumulated and communicated to the Company’s management, including its Chief Executive Officer and Chief Financial

Officer, to allow timely decisions regarding required disclosures.

Based on this evaluation, the Company’s management concluded that its

disclosure controls and procedures were not effective at the reasonable assurance level as of June 30, 2023 due to the following material

Weaknesses in Internal Control and Plan for Remediation

16 unchanged sentences

relevant systems were also determined to be ineffective as a result of such deficiency.

material weakness related to the ineffective design of a key

manual control to detect material misstatements in revenue.

material weaknesses create a reasonable possibility that a material misstatement to our consolidated financial statements or disclosures

material weakness related to the ineffective design of a key manual control to detect material

misstatements in revenue.

material weaknesses create a reasonable possibility that a material misstatement to the Company’s consolidated financial statements or disclosures

would not be prevented or detected on a timely basis.

Board of Directors and management take internal control over financial reporting and the integrity of our financial statements seriously.

The Company’s

Board of Directors and management take internal control over financial reporting and the integrity of its financial statements seriously.

Management continues to work to improve its controls related to the material weaknesses described above.

3 unchanged sentences

additional opportunities for remediation on an ongoing basis:

the process we started during 2022 of adding to our internal resources to enhance our capabilities

the process that was started during 2022 of adding to the Company’s internal resources to enhance its capabilities

in the areas of technical accounting, financial reporting, and internal controls, including

1 unchanged sentence

the process started during 2022 of utilizing external third-party technical accounting resources

to supplement our ability to interpret and apply GAAP as we continue to build our internal

to supplement the Company’s ability to interpret and apply GAAP as it continues to build its internal

capabilities in these areas

to utilize external third-party audit and SOX 404 implementation firms to enable the Company

to improve the Company’s controls related to our material weaknesses.

to improve the Company’s controls related to its material weaknesses.

to evaluate existing processes and implement new processes and controls where necessary in

connection with remediating our material weaknesses, such

that these controls are designed, implemented, and operating effectively

recognize that the material weaknesses in our internal control over financial reporting will not be considered remediated until the remediated

connection with remediating the Company’s material weaknesses, such that these controls are designed,

implemented, and operating effectively

The Company recognizes that the material weaknesses in its internal control over financial reporting will not be considered remediated until the remediated

controls operate for a sufficient period of time and can be tested and concluded by management to be designed and operating effectively.

Because our remediation efforts are ongoing, we cannot provide any assurance that these remediation efforts will be successful or that

our internal control over financial reporting will be effective as a result of these efforts.

continue to evaluate and work to improve our internal control over financial reporting related to the identified material weaknesses,

Because the Company’s remediation efforts are ongoing, it cannot provide any assurance that these remediation efforts will be successful or that

its internal control over financial reporting will be effective as a result of these efforts.

The Company continues to evaluate and work to improve its internal control over financial reporting related to the identified material weaknesses,

and management may determine to take additional measures to address control deficiencies or determine to modify the remediation plan

described above.

In addition, we will report the progress and status of the above remediation efforts to the Audit Committee on a periodic

part of our ongoing program to implement changes and further improve our internal controls and in conjunction with our Code of Ethics,

our independent directors have been working with management to include protocols and measures aimed at ensuring quality of our internal

Among those measures is the implementation of a whistle blower hotline, which allows third parties to anonymously report noncompliant

In addition, the Company will report the progress and status of the above remediation efforts to the Audit Committee on a periodic

part of the Company’s ongoing program to implement changes and further improve its internal controls and in conjunction with

its Code of Ethics, the Company’s independent directors have been working with management to include protocols and measures aimed at ensuring

quality of its internal controls.

Among those measures is the implementation of a whistle blower hotline, which allows third parties

to anonymously report noncompliant activity.

The hotline may be accessed as follows:

3 unchanged sentences

in Internal Controls.

have been no changes in our internal control over financial reporting during the the six months ended June 30, 2023 that have materially

affected, or are reasonably likely to materially affect, our internal controls over financial reporting other than the ongoing remediation

have been no changes in the Company’s internal control over financial reporting during the nine months ended September 30, 2023 that have materially

affected, or are reasonably likely to materially affect, its internal controls over financial reporting other than the ongoing remediation

efforts undertaken by management.

have engaged accounting consultants to aid us in remediating the issues identified in our Form 10-K for 2022 to ensure consistent and

The Company has engaged accounting consultants to aid it in remediating the issues identified in its Form 10-K for 2022 to ensure consistent and

appropriate financial reporting in those areas identified.

II - OTHER INFORMATION

II - OTHER INFORMATION (All dollar amounts expressed in PART II Items 1-4 are expressed in thousands unless otherwise indicated.)

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