What changed in this filing

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Item 4. Controls and Procedures

2021-05-13 compared with 2021-02-16 · 56 added, 60 removed, 8 unchanged (94% of the section changed)

Controls and Procedures.

Management’s Evaluation of Disclosure Controls and

Our Chief Executive Officer and our Chief

Financial Officer evaluated the effectiveness of our disclosure controls and procedures as of the end of the period covered by

this Quarterly Report on Form 10-Q.

Based on this evaluation, our Chief Executive Officer and our Chief Financial Officer have

concluded that our disclosure controls and procedures, including internal control over financial reporting, were not effective

as of December 13, 2019, to ensure the information we are required to disclose in reports that we file or submit under the Securities

Exchange Act of 1934, as amended (i) is recorded, processed, summarized, and reported within the time periods specified in Securities

and Exchange Commission rules and forms, and (ii) is accumulated and communicated to our management, including our Chief Executive

Officer and our Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure.

Our disclosure

controls and procedures are intended to be designed to provide reasonable assurance that such information is accumulated and communicated

to our management.

Based on this evaluation, our management concluded that our internal control over financial reporting was not

effective as of December 31, 2020.

Management’s Evaluation of Disclosure Controls and Procedures

Our Chief Executive Officer and our Chief Financial

Officer evaluated the effectiveness of our disclosure controls and procedures as of the end of the period covered by this Quarterly Report

on Form 10-Q.

Based on this evaluation, our Chief Executive Officer and our Chief Financial Officer have concluded that our disclosure

controls and procedures, including internal control over financial reporting, were not effective as of March 31, 2021, to ensure the information

we are required to disclose in reports that we file or submit under the Securities Exchange Act of 1934, as amended (i) is recorded, processed,

summarized, and reported within the time periods specified in Securities and Exchange Commission rules and forms, and (ii) is accumulated

and communicated to our management, including our Chief Executive Officer and our Chief Financial Officer, as appropriate to allow timely

decisions regarding required disclosure.

Our disclosure controls and procedures are intended to be designed to provide reasonable assurance

that such information is accumulated and communicated to our management.

Based on this evaluation, our management concluded that our internal

control over financial reporting was not effective as of March 31, 2021.

The following is a description of two material

1 unchanged sentence

Segregation of Duties :

As previously

disclosed in our Annual Reports on Form 10-K for the fiscal years ended June 30, 2008-2020, our management identified a control

deficiency during the 2008 fiscal year because we lacked sufficient staff to segregate accounting duties.

We believe the control

deficiency resulted primarily because we have the equivalent of one and one-half persons performing all accounting-related on-site

As a result, we did not maintain adequate segregation of duties within our critical financial reporting applications, the

related modules and financial reporting processes.

This control deficiency could result in a misstatement of balance sheet and

income statement accounts in our interim or annual consolidated financial statements that would not be detected.

Accordingly, management

has determined that this control deficiency constitutes a material weakness.

During the period beginning with fiscal year 2008

through June 30, 2020, no audit adjustments resulting from this condition were required.

As previously disclosed

in our Annual Reports on Form 10-K for the fiscal years ended June 30, 2008-2020, our management identified a control deficiency during

the 2008 fiscal year because we lacked sufficient staff to segregate accounting duties.

We believe the control deficiency resulted primarily

because we have the equivalent of one and one-half persons performing all accounting-related on-site duties.

As a result, we did not maintain

adequate segregation of duties within our critical financial reporting applications, the related modules and financial reporting processes.

This control deficiency could result in a misstatement of balance sheet and income statement accounts in our interim or annual consolidated

financial statements that would not be detected.

Accordingly, management has determined that this control deficiency constitutes a material

During the period beginning with fiscal year 2008 through June 30, 2020, no audit adjustments resulting from this condition

were required.

To address and remediate the material weakness

in internal control over financial reporting described above, beginning with the quarter ended September 30, 2008, we instituted

a procedure whereby our Chief Executive Officer, our Chief Financial Officer and other members of our Board of Directors perform

a higher level review of the quarterly and annual reports on Form 10-Q and Form 10-K prior to filing.

We believe that the step outlined above

strengthens our internal control over financial reporting and mitigates the material weakness described above.

As part of our assessment

of internal control over financial reporting for the fiscal year ended June 30, 2020, our management has evaluated this additional

control and has determined that it is operating effectively.

in internal control over financial reporting described above, beginning with the quarter ended September 30, 2008, we instituted a procedure

whereby our Chief Executive Officer, our Chief Financial Officer and other members of our Board of Directors perform a higher level review

of the quarterly and annual reports on Form 10-Q and Form 10-K prior to filing.

We believe that the step outlined above strengthens

our internal control over financial reporting and mitigates the material weakness described above.

As part of our assessment of internal

control over financial reporting for the fiscal year ended June 30, 2020, our management has evaluated this additional control and has

determined that it is operating effectively.

Inventory Valuation :

As previously

disclosed in our Annual Report on Form 10-K for the fiscal year ended June 30, 2020, we reported a material weakness with respect

to the valuation of our inventories.

Specifically, the amounts used to value our inventory at June 30, 2009 with respect to overhead

rates and purchased items were often inconsistent with the supporting documentation, due to year-to-year changes in overhead rates

and costs of purchased items that were not properly reflected in inventory valuation.

Accordingly, management had determined that

this control deficiency constituted a material weakness as of June 30, 2009.

Periodic fiscal year end audit adjustments of approximately

$50,000 have been necessary as a result of this condition.

Changes in Internal Control over

Financial Reporting

There was no change in our internal control

over financial reporting that occurred during the second quarter of our fiscal year covered by this Quarterly Report on Form 10-Q

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

As previously disclosed

in our Annual Report on Form 10-K for the fiscal year ended June 30, 2020, we reported a material weakness with respect to the valuation

of our inventories.

Specifically, the amounts used to value our inventory at June 30, 2009 with respect to overhead rates and purchased

items were often inconsistent with the supporting documentation, due to year-to-year changes in overhead rates and costs of purchased

items that were not properly reflected in inventory valuation.

Accordingly, management had determined that this control deficiency constituted

a material weakness as of June 30, 2009.

Periodic fiscal year end audit adjustments of approximately $50,000 have been necessary as a

result of this condition.

Changes in Internal Control over Financial

There was no change in our internal control over

financial reporting that occurred during the second quarter of our fiscal year covered by this Quarterly Report on Form 10-Q that has

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

To address and remediate the material weakness

in internal control over financial reporting described above, beginning in the quarter ended September 30, 2009 and continuing

through the quarter ended December 31, 2020, we implemented processes to improve our inventory controls and documentation surrounding

inventory valuation for overhead rates, and performed procedures to ensure that the pricing of inventory items was consistent with

the supporting documentation.

We believe that the step outlined above strengthens our internal control over financial reporting

and mitigates the material weakness described above.

We intend to continue to remediate material

weaknesses and enhance our internal controls but cannot guarantee that our efforts will result in remediation of our material weaknesses

or that new issues will not be exposed in this process.

in internal control over financial reporting described above, beginning in the quarter ended September 30, 2009 and continuing through

the quarter ended March 31, 2021, we implemented processes to improve our inventory controls and documentation surrounding inventory valuation

for overhead rates, and performed procedures to ensure that the pricing of inventory items was consistent with the supporting documentation.

We believe that the step outlined above strengthens our internal control over financial reporting and mitigates the material weakness

described above.

We intend to continue to remediate material weaknesses

and enhance our internal controls but cannot guarantee that our efforts will result in remediation of our material weaknesses or that

new issues will not be exposed in this process.

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.

What changed 10-Q

Item 4. Controls and Procedures