Controls and Procedures
−Removed: We maintain disclosure controls and procedures that are designed to ensure material information required to be disclosed in our 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 Controller and Principal Accounting Officer, as appropriate, to allow timely decisions regarding required financial disclosure.
+Added: We maintain disclosure controls and procedures that are designed to ensure material information required to be disclosed in our 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 financial disclosure.
In designing and evaluating the disclosure controls and procedures, we recognized that a control system, no matter how well designed and operated, can provide only reasonable, not absolute, assurance that the objectives of the control system are met.
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Management necessarily was required to apply its judgment in evaluating the cost‑benefit relationship of possible controls and procedures.
−Removed: Under the supervision of and with the participation of our management, including the Company’s Chief Executive Officer and Controller and Principal Accounting Officer, we evaluated the effectiveness of our disclosure controls and procedures (as such term is defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act) as of June 30, 2020.
−Removed: Based upon that evaluation, our Chief Executive Officer and Controller and Principal Accounting Officer concluded that our disclosure controls and procedures were not effective as of June 30, 2020.
−Removed: The material weaknesses related to change management and third-party management controls in our Information Technology General Controls ("ITGC") which had a pervasive impact on other ITGC dependent business activity level controls in our internal controls over financial reporting, described in our Annual Report on Form 10-K for the year ended December 31, 2019, has been remediated.
−Removed: The Company is still evaluating the design, implementation and operating effectiveness of ITGC user access security, segregation of duties as it relates to user access controls and the pervasive effect on other ITGC dependent business activity level internal control cycles.
−Removed: Notwithstanding the material weaknesses, the Company’s management, including the Chief Executive Officer and Controller and Principal Accounting Officer, have concluded that the condensed consolidated financial statements as of June 30, 2020, are fairly stated, in all material respects, in accordance with generally accepted accounting principles in the United States for each of the periods presented herein.
−Removed: In connection with the user access security, segregation of duties as it relates to user access controls and the pervasive effect of the ITGC material weaknesses, management has taken a number of steps with the intention of remediating the above control deficiencies.
−Removed: We continue to implement enhanced procedures and controls to remediate our material weaknesses in internal control over financial reporting.
+Added: Under the supervision of and with the participation of our management, including the Company’s Chief Executive Officer and Chief Financial Officer, we evaluated the effectiveness of our disclosure controls and procedures (as such term is defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act) as of September 30, 2020.
+Added: Based upon that evaluation, our Chief Executive Officer and Chief Financial Officer concluded that our disclosure controls and procedures were not effective as of September 30, 2020.
+Added: The material weaknesses related to change management and third-party management controls, user access security and segregation of duties as it relates to user access controls in our Information Technology General Controls ("ITGC"), described in our Annual Report on Form 10-K for the year ended December 31, 2019, have been remediated.
+Added: The Company is still evaluating the design, implementation and operating effectiveness of the pervasive effect on other ITGC dependent business activity level internal control cycles, which has not been remediated.
+Added: Notwithstanding the material weaknesses, the Company’s management, including the Chief Executive Officer and Chief Financial Officer (Principal Financial Officer), have concluded that the condensed consolidated financial statements as of September 30, 2020, are fairly stated, in all material respects, in accordance with generally accepted accounting principles in the United States for each of the periods presented herein.
+Added: In connection with the pervasive effect of the ITGC material weaknesses, management has taken a number of steps with the intention of remediating the above control deficiencies.
+Added: We continue to implement enhanced procedures and controls to remediate the pervasive impact of our material weaknesses in internal control over financial reporting.
Changes in Internal Control over Financial Reporting
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We continue to make further improvements to our internal controls over financial reporting, in addition to the improvements developed in 2019.
−Removed: During the quarter ended June 30, 2020, we implemented the following:
−Removed: Remediated the ITGC control deficiencies in connection with change management and third-party management controls.
−Removed: Implemented and started our 2020 audit program, utilizing a National Audit firm as our internal audit partner, which includes in-house remediation testing of our user access security, segregation of duties as it relates to user access controls and other ITGC dependent business activity level internal control cycles.
−Removed: Enhanced evidentiary review and documentation of key ITGC controls and implemented new programs and policies to provide improved control over change management and third-party management controls to the ERP system.
+Added: During the quarter ended June 30, 2020, the Company remediated the ITGC control deficiencies in connection with change management and third-party management and enhanced evidentiary review and documentation of key ITGC controls and implemented new programs and policies to provide improved control over change management and third-party management controls to the ERP system.
+Added: During the quarter ended September 30, 2020, we continued our improvements by remediating the ITGC control deficiencies in connection with user access security and segregation of duties as it relates to user access controls.
+Added: We also continued to make progress on our 2020 audit program, utilizing a National Audit firm as our internal audit partner, which includes in-house remediation testing of the pervasive impact on other ITGC dependent business activity level internal control cycles.
The remediation of the material weaknesses is among our highest priorities.
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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.