What changed in this filing

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Item 4. Controls and Procedures

2021-05-17 compared with 2020-11-09 · 12 added, 28 removed, 6 unchanged (87% of the section changed)

2 unchanged sentences

the supervision and with the participation of our management, including our Chief Executive Officer and our Chief Financial Officer,

we conducted an evaluation of our disclosure controls and procedures, as such term is defined under Securities and Exchange Act

of 1934 Rules 13a-15(f).

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

the Company’s disclosure controls and procedures were not effective as of September 30, 2020.

As of September 30, 2020,

management’s assessment identified the following material weaknesses in the Company’s internal control over financial

IT Service Providers - The Company relies upon a variety of outsourced Information Technology (IT) service providers for key

elements of the technology infrastructure impacting its financial reporting process.

Certain of these outsourced IT service providers

could not provide System and Organization Controls (SOC) reports.

The Company did not have controls designed to assess the design

and operation of internal controls pertaining to these outsourced IT service providers over the period of reliance.

management did not effectively assess the design and operation of certain outsourced IT service providers’ internal controls,

certain of the Company’s controls over IT systems and business processes were also ineffective, to the extent that they

rely upon information that was subject to the outsourced IT service providers’ control environment.

of Duties - The Company did not maintain effective policies to ensure adequate segregation of duties within its accounting

Specifically, due to the size of the Company and the smaller nature of department teams, opportunities are limited

to segregate duties, resulting in inabilities to soundly manage segregation of job responsibilities.

we conducted an evaluation of our disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities

Exchange Act of 1934, as amended (the “Exchange Act”).

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

Financial Officer concluded that the Company’s disclosure controls and procedures were effective as of March 31, 2021, to provide

reasonable assurance that information required to be disclosed in the reports that we file or submit under the Exchange Act 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 our management, including our Chief Executive Officer and Chief Financial Officer, as appropriate, to

allow timely decisions regarding required disclosures.

in Internal Control Over Financial Reporting

have been no changes in the Company’s internal control over financial reporting during the three months ended September

30, 2020 that have materially affected, or are reasonably likely to materially affect, the Company’s internal control over

financial reporting.

disclosed in the section titled “Risk Factors” in Part II, Item 1A of this Quarterly Report, we have begun, with the

oversight of senior management and our audit committee, to implement measures to remediate the identified material weakness.

execution of our remediation is ongoing and will require validation and testing of the design and operating effectiveness of internal

controls over a sustained period of financial reporting cycles.

Management expects to complete its remediation plan by the

have been no changes in the Company’s internal control over financial reporting during the three months ended March 31, 2021 that

have materially affected, or are reasonably likely to materially affect, the Company’s internal control over financial reporting.

II – OTHER INFORMATION

Legal Proceedings

are subject to various legal proceedings from time to time in the ordinary course of business, none of which are required to be

disclosed under this Item 1.

are subject to various legal proceedings from time to time in the ordinary course of business, none of which are required to be disclosed

under this Item 1.

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