19 unchanged sentences
Remediation Efforts and Status of Material Weakness
−Removed: During fiscal 2023, we continued to take steps to remediate the material weaknesses described above by retaining additional qualified accounting personnel, and further evolving our accounting processes.
−Removed: Specifically, since the material weakness related to the lack of qualified personnel was identified, we retained third party experts on complex technical accounting issues and taxes, as well as hiring additional accounting personnel with the requisite experience to improve the process around financial reporting.
−Removed: We have also improved certain accounting processes and re-designed risk assessment and control activities to support our remediation of the other
−Removed: material weaknesses noted above.
−Removed: During fiscal 2023 we started to assess whether these improved control activities have been designed effectively, but that evaluation is ongoing.
−Removed: We plan on continuing to improve our processes and control activities in support of our remediation activities.
−Removed: In future periods, we will ensure that the improved processes & controls have been designed & implemented effectively, and we will also evaluate the operational effectiveness of the new and redesigned controls.
−Removed: We will not be able to fully remediate these material weaknesses until the applicable controls operate for a sufficient period of time, and we have concluded, through testing, that the newly implemented and enhanced controls are operating effectively.
+Added: During fiscal 2024, we continued to take significant steps to remediate the material weaknesses described above as follows:
+Added: an ineffective control environment due to improper segregation of duties and a lack of qualified personnel to address certain complex accounting transactions
+Added: ● Enhanced our segregation of duties by reassigning certain responsibilities, further restricting privileged access to our Enterprise Resource Planning (ERP) and other systems, establishing automated workflow within our ERP to enforce segregation of duties between preparation and review / approval of journal entries for most legal entities with plans to implement this common control for the remainder of the entities
+Added: ● Improved our knowledge of complex accounting transactions by retaining third party specialists on complex technical accounting issues and taxes, as well as previously hired additional accounting personnel with the requisite experience to improve our general accounting and financial reporting processes
+Added: an ineffective risk assessment process resulting in improper design of control activities to address certain risks of material misstatement.
+Added: ● Conducted a financial statement line-item risk assessment to identify significant entities, accounts, assertions, risks, business processes, business applications, and service providers that could have a material impact on the accuracy and completeness of our financial statements.
+Added: This risk assessment served as the foundation of our fiscal year 2024 Sarbanes-Oxley compliance program
+Added: ● Conducted a fraud risk assessment in accordance with COSO Internal Control – Integrated Framework Principle 8:
+Added: Assesses Fraud Risk
+Added: ● Expanded and enhanced our process-level risk and control documentation, as well as the design of controls and documentation supporting control execution for multiple material account balances, including entity level controls and information technology general controls
+Added: ● Provided training to process and control owners
+Added: ● Enhanced relevant policies, procedures, guidelines, and documentation templates
+Added: We continue to improve our processes and control activities, and are testing the design and operating effectiveness of our newly implemented and enhanced controls as remediation progresses.
+Added: While the Company has made significant progress this year, we will not be able to fully remediate these material weaknesses until we have implemented the remaining planned corrective actions and the applicable controls operate effectively for a sufficient period of time.
Our management will continue to monitor the effectiveness of our remediation plans in future periods and will make the changes we determine to be appropriate.
6 unchanged sentences
Other Information
+Added: Rule 10b5-1 and Non-Rule 10b5-1 Trading Arrangements
+Added: None of our directors or officers (as defined in Rule 16a-1 (f) under the Exchange Act) adopted, modified , or terminated a Rule 10b5-1 trading arrangement or a non-Rule 10b5-1 trading arrangement (each as defined in Item 408 of Regulation S-K) during the period covered by this Annual Report on Form 10-K.
Disclosure Regarding Foreign Jurisdictions That Prevent Inspections
53 unchanged sentences
Form of Stock Award Agreement (incorporated by reference to Exhibit 10.5 to Reservoir Media, Inc.’s Registration Statement on Form S 8 filed with the SEC on October 14, 2021).
−Removed: Letter of Employment, dated April 1, 2021, by and between Reservoir Media Management, Inc.
−Removed: and Golnar Khosrowshahi (incorporated by reference to Exhibit 10.13 to Roth CH Acquisition II Co.’s Registration Statement on Form S 1 filed with the SEC on July 1, 2021).
+Added: Amended & Restated Letter of Employment, dated June 29, 2023, by and between Reservoir Media Management, Inc.
+Added: and Golnar Khosrowshahi (incorporated by reference to Exhibit 10.1 to Reservoir Media Inc’s Quarterly Report on Form 10-Q filed with the SEC on August 2, 2023).
Amended and Restated Letter of Employment, dated April 1, 2021, by and between Reservoir Media Management, Inc.
11 unchanged sentences
Section 1350, as adopted Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002.
+Added: Clawback Policy of Reservoir Media, Inc.
Inline XBRL Instance Document - the instance document does not appear in the Interactive Data File because its XBRL tags are embedded within the Inline XBRL document
36 unchanged sentences
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.