CONTROLS AND PROCEDURES
−Removed: of Disclosure Controls and Procedures
−Removed: controls and procedures are controls and procedures that are designed to ensure that information required to be disclosed in our
−Removed: reports filed under the Exchange Act is recorded, processed, summarized and reported, within the time periods specified in the
−Removed: Disclosure controls and procedures include, without limitation, controls and procedures designed to ensure that information
−Removed: required to be disclosed by our company in the reports that it files or submits under the Exchange Act is accumulated and communicated
−Removed: to our management, including its principal executive and principal financial officers, or persons performing similar functions,
−Removed: as appropriate to allow timely decisions regarding required disclosure.
−Removed: Our management carried out an evaluation under the
−Removed: supervision and with the participation of our Principal Executive Officer and Principal Financial Officer, of the effectiveness
−Removed: of the design and operation of our disclosure controls and procedures pursuant to Rules 13a-15(e) and 15d-15(e) under the
−Removed: Exchange Act, as of October 31, 2020.
−Removed: Based upon that evaluation, our Principal Executive Officer and Principal Financial Officer
−Removed: have concluded that our disclosure controls and procedures were not effective as of October 31, 2020.
−Removed: disclosure controls and procedures are not effective for the following reasons:
−Removed: not maintain effective controls to identify and maintain segregation of duties in identifying, authorizing, approving,
−Removed: accounting for, and disclosing significant estimates, related-party transactions, significant unusual transactions, and other
−Removed: non-routine events and transactions.
−Removed: Specifically, we only have one individual, our Chief Financial Officer, who reviews,
−Removed: evaluates, approves, and records non-routine transactions and initiates journal entries, approves journal entries, and posts
−Removed: journal entries to the general ledger.
−Removed: There is no independent review of any financial duties performed by this individual.
−Removed: In November 2020, the Company hired a corporate controller to support the Chief Financial Officer and plans to
−Removed: utilize such additional resources to strengthen internal controls, including segregation of duties.
−Removed: in Internal Control over Financial Reporting
−Removed: the period covered by this report, there were no changes in our internal controls over financial reporting that have materially
−Removed: affected, or are reasonably likely to materially affect, our internal control over financial reporting.
−Removed: II - OTHER INFORMATION
+Added: Evaluation of Disclosure Controls and
+Added: Disclosure controls and procedures are controls
+Added: and procedures that are designed to ensure that information required to be disclosed in our reports filed under the Securities
+Added: Exchange Act of 1934, as amended (“Exchange Act”) is recorded, processed, summarized and reported, within the time
+Added: periods specified in the SEC's rules.
+Added: Disclosure controls and procedures include, without limitation, controls and procedures
+Added: designed to ensure that information required to be disclosed by our company in the reports that it files or submits under the
+Added: Exchange Act is accumulated and communicated to our management, including its principal executive and principal financial officers,
+Added: or persons performing similar functions, as appropriate to allow timely decisions regarding required disclosure.
+Added: Our management
+Added: carried out an evaluation under the supervision and with the participation of our Principal Executive Officer and Principal Financial
+Added: Officer, of the effectiveness of the design and operation of our disclosure controls and procedures pursuant to Rules 13a-15(e)
+Added: and 15d-15(e) under the Exchange Act, as of January 31, 2021.
+Added: Based upon that evaluation, our Principal Executive Officer and
+Added: Principal Financial Officer have concluded that our disclosure controls and procedures were not effective as of January 31, 2021.
+Added: Our disclosure controls and procedures are
+Added: not effective for the following reasons:
+Added: We did not maintain effective controls to identify
+Added: and maintain segregation of duties in identifying, authorizing, approving, accounting for, and disclosing significant estimates,
+Added: related-party transactions, significant unusual transactions, and other non-routine events and transactions.
+Added: Specifically,
+Added: we only have one individual, our Chief Financial Officer, who reviews, evaluates, approves, and records non-routine transactions
+Added: and initiates journal entries, approves journal entries, and posts journal entries to the general ledger.
+Added: There is no independent
+Added: review of any financial duties performed by this individual.
+Added: In November 2020, the Company hired a corporate controller to
+Added: support the Chief Financial Officer and plans to utilize such additional resources to strengthen internal controls, including
+Added: segregation of duties.
+Added: Changes in Internal Control over Financial
+Added: During the period covered by this report,
+Added: there were no changes in our internal controls over financial reporting that have materially affected, or are reasonably likely
+Added: to materially affect, our internal control over financial reporting.
+Added: 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.