3 unchanged sentences
Evaluation of Disclosure Controls and Procedures
−Removed: We are required to maintain disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act) that are designed to assure that information required to be disclosed in our Exchange Act reports 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 management, including our Chief Executive Officer and Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosures.
−Removed: Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, evaluated the effectiveness of our disclosure controls and procedures pursuant to Exchange Act Rules 13a-15(b) and 15d-15(b).
−Removed: Based on this evaluation, and due to the material weaknesses in internal control over financial reporting described below, our Chief Executive Officer and Chief Financial Officer concluded that our disclosure controls and procedures as of September 30, 2021 were not effective.
−Removed: As a result of that conclusion, our management re-evaluated the effectiveness of our disclosure controls and procedures as of December 31, 2020 and, based on this re-evaluation, and due to the material weaknesses in internal control over financial reporting described below, our Chief Executive Officer and Chief Financial Officer concluded that our disclosure controls and procedures were not effective as of December 31, 2020.
−Removed: In connection with our evaluation and testing of controls during the third quarter of 2021, our management identified deficiencies in our general information technology controls which were not designed to restrict users’ access privileges to their appropriate authorities and responsibilities.
−Removed: We also identified deficiencies in certain locations
−Removed: principally relating to the review and authorization of certain transactions within portions of our purchasing and revenue processes.
−Removed: Management determined these deficiencies resulted in material weaknesses in internal control over financial reporting.
−Removed: A material weakness is a deficiency, or combination of deficiencies, in internal control over financial reporting such that there is a reasonable possibility that a material misstatement of a company’s annual or interim financial statements would not be prevented or detected on a timely basis.
−Removed: As of the date of this report, we have not identified any financial statement misstatements as a result of these control deficiencies.
−Removed: We are in the process of enhancing our internal controls in the aforementioned areas to remediate the material weaknesses.
−Removed: We are assessing and revising the controls over user access privileges to focus on determining that appropriate authorities and responsibilities are assigned to all individuals.
−Removed: In addition, management is continuing to develop the design and implementation of internal controls to require appropriate reviews as well as retain documentation of those reviews with regards to our purchasing and revenue processes.
−Removed: The Company determined the above deficiencies were primarily due to an inadequate complement of personnel with requisite experience in internal control process design and documentation requirements, and therefore we intend to implement training programs and hire additional resources with the appropriate skills and knowledge to address these internal control deficiencies.
−Removed: We continuously evaluate the effectiveness of our internal control over financial reporting and may implement changes or additional remediation efforts if additional deficiencies or material weaknesses are discovered.
+Added: Under the supervision and with the participation of our management, including our Chief Executive Officer and Chief Financial Officer, we conducted an evaluation of the effectiveness of our disclosure controls and procedures (as defined in Rules 13a–15(e) and 15d–15(e) under the Securities and Exchange Act of 1934, as amended (the “Exchange Act”)) as of March 31, 2022.
+Added: Based on this evaluation, our Chief Executive Officer and Chief Financial Officer have concluded that, as of March 31, 2022, our disclosure controls and procedures were not effective due to material weaknesses in internal control over financial reporting previously disclosed in our Annual Report on Form 10-K for the year ended December 31, 2021.
+Added: As of the date of this report, the material weaknesses did not result in any identified material misstatements to the financial statements and there were no changes to previously reported financial results.
+Added: Remediation Plan for Material Weaknesses
+Added: To remediate the material weaknesses referenced above, the Company has been pursuing the remediation steps identified in the Company’s Annual Report on Form 10-K for the year ended December 31, 2021.
+Added: We have conducted trainings, hired additional qualified resources and have engaged a nationally recognized accounting firm to assist with the design and implementation of control procedures to address the identified risks of material misstatements in key process areas.
+Added: Management is continuing to design and implement internal controls to require appropriate reviews and retention of documentation of those reviews with regards to our purchasing and revenue processes.
+Added: We are also implementing new systems and automating certain processes to enhance our internal controls and to address these material weaknesses.
+Added: We are assessing and revising the controls over user access administration and have implemented manual monitoring activities over batch processing to ensure appropriate segregation of duties on journal entries processed in batches.
+Added: We are also enhancing our change management controls relating to custom reports in certain information technology systems and performing additional analysis of source documentation to implement effective controls over information, primarily in the purchasing and revenue processes.
+Added: The material weaknesses will not be considered remediated until the applicable controls operate for a sufficient period of time and are tested for operating effectiveness.
Changes in Internal Control over Financial Reporting
−Removed: Except for the changes relating to the material weaknesses discussed above, there have been no other changes in the Company’s internal control over financial reporting that occurred during the third quarter of 2021 that have materially affected, or are reasonably likely to materially affect, the Company’s internal control over financial reporting.
+Added: Except the changes in internal control over financial reporting related to the material weaknesses described above, there have been no changes in our internal control over financial reporting identified in connection with the
+Added: evaluation required by Rules 13a-15(d) and 15d-15(d) of the Exchange Act that occurred during our first quarter of 2022 that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
PART II – Other Information
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.