Item 4. Controls and Procedures
ITEM
4.
CONTROLS
AND PROCEDURES
Evaluation
of disclosure controls and procedures
Our
management is responsible for establishing and maintaining a system of disclosure controls and procedures (as defined in Rule
13a-15(e)) under the Exchange Act) that is designed to ensure that information required to be disclosed by our Company in the
reports that we file or submit under the Exchange Act is recorded, processed, summarized and reported, within the time specified
in the Commission’s rules and forms. Disclosure controls and procedures include, without limitation, controls and procedures
designed to ensure that information required to be disclosed by an issuer in the reports that it files or submits under the Exchange
Act is accumulated and communicated to the issuer’s management, including its principal executive officer or officers and
principal financial officer or officers, or persons performing similar functions, as appropriate to allow timely decisions regarding
required disclosure.
Pursuant
to Rule 13a-15(b) under the Exchange Act, our Company carried out an evaluation with the participation of our Company’s
management, including our Company’s Chief Executive Officer (“CEO”) and our Company’s Chief Financial
Officer (“CFO”), of the effectiveness of our Company’s disclosure controls and procedures (as defined under
Rule 13a-15(e) under the Exchange Act) as of December 31, 2018. Based upon that evaluation, our Company’s CEO and CFO concluded
that our Company’s disclosure controls and procedures were not effective as of December 31, 2018 due to our Company’s
limited internal resources and lack of ability to have multiple levels of transaction review.
Management
is in the process of determining how best to change our current system and implement a more effective system to insure that information
required to be disclosed in the reports that we file or submit under the Exchange Act have been recorded, processed, summarized
and reported accurately. Our management intends to develop procedures to address the current deficiencies to the extent possible
given limitations in financial and personnel resources. While management is working on a plan, no assurance can be made at this
point that the implementation of such controls and procedures will be completed in a timely manner or that they will be adequate
once implemented.
Changes
in internal control over financial reporting
There
have been no changes in our internal control over financial reporting during the period ended December 31, 2018 that have materially
affected, or are reasonably likely to materially affect, our internal controls over financial reporting.
PART
II
OTHER
INFORMATION
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