What changed in this filing

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Item 9A. Controls and Procedures

2022-03-28 compared with 2021-03-29 · 155 added, 227 removed, 80 unchanged (83% of the section changed)

AND PROCEDURES

controls and procedures are designed to ensure that information required to be disclosed in our reports filed or submitted under

the Exchange Act is recorded, processed, summarized and reported, within the time period specified in the SEC’s rules and

forms and is accumulated and communicated to the Company’s management, as appropriate, in order to allow timely decisions

in connection with required disclosure.

controls and procedures are designed to ensure that information required to be disclosed in our reports filed or submitted under the

Exchange Act is recorded, processed, summarized and reported, within the time period specified in the SEC’s rules and forms and

is accumulated and communicated to the Company’s management, as appropriate, in order to allow timely decisions in connection with

required disclosure.

of Disclosure Controls and Procedures

2 unchanged sentences

Doss, respectively, we conducted an evaluation of the effectiveness of the design and operation of our disclosure

controls and procedures, as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act, as of the end of the period covered

by this Annual Report.

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

of December 31, 2020, our disclosure controls and procedures were not effective to provide reasonable assurance that information

required to be disclosed in our reports filed with the SEC pursuant to the Exchange Act, is recorded, processed, summarized and

reported within the time periods specified in the rules and forms of the SEC and that such information is accumulated and communicated

to our management, including our CEO and CFO, as appropriate, to allow timely decisions regarding required disclosures.

controls and procedures, as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act, as of the end of the period covered by this

Annual Report (December 31, 2021).

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

as of December 31, 2021, our disclosure controls and procedures were not effective to provide reasonable assurance that information required

to be disclosed in our reports filed with the SEC pursuant to the Exchange Act, is recorded, processed, summarized and reported within

the time periods specified in the rules and forms of the SEC and that such information is accumulated and communicated to our management,

including our CEO and CFO, as appropriate, to allow timely decisions regarding required disclosures.

a result of the formative stage of our development, the Company has not fully implemented the necessary internal controls.

matters involving internal controls and procedures that the Company’s management considered to be material weaknesses under

the standards of the Committee of Sponsoring Organizations of the Treadway Commission (COSO) were:

(1) insufficient written policies

and procedures for accounting and financial reporting with respect to the requirements and application of accounting principles

generally accepted in the United States of America (“

GAAP ”) and SEC disclosure requirements;

and (2) ineffective

controls over period end financial disclosure and reporting processes.

believes that the material weaknesses set forth above did not have an effect on the Company’s financial results reported

involving internal controls and procedures that the Company’s management considered to be material weaknesses under the standards

of the Committee of Sponsoring Organizations of the Treadway Commission (COSO) were:

(1) The Company did not maintain a fully integrated

financial consolidation and reporting system throughout the period and as a result, extensive manual analysis, reconciliation and adjustments

were required in order to produce financial statements for external reporting purposes.

and (2) The Company does not currently have a

sufficient complement of technical accounting and external reporting personnel commensurate to support standalone external financial

reporting under public company or SEC requirements.

Specifically, the Company did not effectively segregate certain accounting duties

due to the small size of its accounting staff and maintain a sufficient number of adequately trained personnel necessary to anticipate

and identify risks critical to financial reporting and the closing process.

In addition, there were inadequate reviews and approvals

by the Company’s personnel of certain reconciliations and other processes in day-to-day operations due to the lack of a full complement

of accounting staff.

believes that the material weaknesses set forth above did not have an effect on the Company’s financial results reported herein.

We are committed to improving our financial organization.

As part of this commitment, we have recently increased our personnel

resources and technical accounting expertise as we develop the internal and financial resources of the Company.

In addition, the

Company will prepare and implement sufficient written policies and checklists which will set forth procedures for accounting and

financial reporting with respect to the requirements and application of GAAP and SEC disclosure requirements.

believes that preparing and implementing sufficient written policies and checklists will remedy the following material weaknesses

(i) insufficient written policies and procedures for accounting and financial reporting with respect to the requirements and application

of GAAP and SEC disclosure requirements;

As part of this commitment, we have increased our personnel resources and technical

accounting expertise as we develop the internal and financial resources of the Company.

In addition, the Company has prepared and implemented

sufficient written policies and checklists which will set forth procedures for accounting and financial reporting with respect to the

requirements and application of GAAP and SEC disclosure requirements.

has prepared and is in the process of implementing sufficient written policies and checklists to remedy the following material

weaknesses (i) insufficient written policies and procedures for accounting and financial reporting with respect to the requirements and

application of GAAP and SEC disclosure requirements;

and (ii) ineffective controls over period end financial close and reporting processes.

have improved our financial organization as we have increased our personnel resources and technical accounting expertise.

continue to monitor and evaluate the effectiveness of our internal controls and procedures and our internal controls over financial

reporting on an ongoing basis.

Management’s

We will continue

to monitor and evaluate the effectiveness of our internal controls and procedures and our internal controls over financial reporting

on an ongoing basis.

Report on Internal Control Over Financial Reporting

of the Company is responsible for establishing and maintaining adequate internal control over financial reporting as defined in

Rules 13a-15(f) and 15d-15(f) under the Exchange Act.

The Company’s internal control over financial reporting is designed

to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for

external purposes in accordance with GAAP, but because of its inherent limitations, internal control over financial reporting

may not prevent or detect misstatements.

The Company’s internal control over financial reporting includes those policies

and procedures that are designed to:

to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions

of the assets of the Company;

reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance

with GAAP, and that receipts and expenditures of the Company are being made only in accordance with authorizations of management

and directors of the Company;

reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the Company’s

of the Company is responsible for establishing and maintaining adequate internal control over financial reporting as defined in Rules

13a-15(f) and 15d-15(f) under the Exchange Act.

The Company’s internal control over financial reporting is designed to provide

reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes

in accordance with GAAP, but because of its inherent limitations, internal control over financial reporting may not prevent or detect

misstatements.

The Company’s internal control over financial reporting includes those policies and procedures that are designed

to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the

assets of the Company;

reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with

GAAP, and that receipts and expenditures of the Company are being made only in accordance with authorizations of management and directors

of the Company;

reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the Company’s

assets that could have a material effect on the financial statements.

assessed the effectiveness of the Company’s internal control over financial reporting as of December 31, 2020.

this assessment, management used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission

in Internal Control —

Integrated Framework (2013).

Based on our assessment, management believes that the Company’s

internal controls over financial reporting were not effective as of December 31, 2020.

Specifically, management’s evaluation

conducted an assessment of the effectiveness of the Company’s internal control over financial reporting as of December 31, 2021.

In making this assessment, management used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission

in Internal Control — Integrated Framework (2013).

Based on our assessment, management concluded that the Company’s internal

controls over financial reporting were not effective as of December 31, 2021, to provide reasonable assurance regarding the reliability

of financial reporting and the preparation of financial statements in accordance with GAAP.

Specifically, management’s determination

was based on the following material weaknesses which existed as of December 31, 2021:

Reporting Systems :

The Company did not maintain a fully integrated financial consolidation and reporting system throughout

the period and as a result, extensive manual analysis, reconciliation and adjustments were required in order to produce financial

statements for external reporting purposes.

The Company does not currently have a sufficient complement of technical accounting and external reporting

personal commensurate to support standalone external financial reporting under public company or SEC requirements.

Specifically,

the Company did not effectively segregate certain accounting duties due to the small size of its accounting staff and maintain

a sufficient number of adequately trained personnel necessary to anticipate and identify risks critical to financial reporting

and the closing process.

In addition, there were inadequate reviews and approvals by the Company’s personnel of certain

reconciliations and other processes in day-to-day operations due to the lack of a full complement of accounting staff.

written policies and procedures for accounting and financial reporting with respect to the requirements and application of

GAAP and SEC disclosure requirements.

controls over period end financial disclosure and reporting processes.

the year ended December 31, 2020, we reevaluated our most recent assessment of internal controls and concluded that our internal

controls were still not effective.

The Company has recently engaged additional accounting support to provide more resources and

expand the technical accounting knowledge to assist Mr.

Ajjarapu in their responsibilities with respect to financial

The Company did not maintain a fully integrated financial consolidation and reporting system throughout the

period and as a result, extensive manual analysis, reconciliation and adjustments were required in order to produce financial statements

for external reporting purposes.

The Company does not currently have a sufficient complement of technical accounting and external reporting personnel

commensurate to support standalone external financial reporting under public company or SEC requirements.

Specifically, the Company

did not effectively segregate certain accounting duties due to the small size of its accounting staff and maintain a sufficient number

of adequately trained personnel necessary to anticipate and identify risks critical to financial reporting and the closing process.

In addition, there were inadequate reviews and approvals by the Company’s personnel of certain reconciliations and other processes

in day-to-day operations due to the lack of a full complement of accounting staff.

on the Effectiveness of Controls

of the Company, including its Chief Executive Officer and its Chief Financial Officer, does not expect that the Company’s

disclosure controls and procedures or its internal control over financial reporting will prevent or detect all error and all fraud.

A control system, no matter how well designed and operated, can provide only reasonable, not absolute, assurance that the control

system’s objectives will be met.

The design of a control system must reflect the fact that there are resource constraints,

and the benefits of controls must be considered relative to their costs.

Furthermore, because of the inherent limitations in all

control systems, no evaluation of controls can provide absolute assurance that misstatements due to error or fraud will not occur

or that all control issues and instances of fraud, if any, have been detected.

These inherent limitations include the realities

that judgments in decision-making can be faulty and that breakdowns can occur because of simple error or mistake.

also be circumvented by the individual acts of some persons or by the collusion of two or more persons.

The design of any system

of controls is based in part on certain assumptions about the likelihood of future events, and there can be no assurance that

any design will succeed in achieving its stated goals under all potential future conditions.

Projections of any evaluation of

the effectiveness of controls to future periods are subject to risks.

Over time, controls may become inadequate because of changes

in conditions or deterioration in the degree of compliance with policies or procedures.

of the Company, including its Chief Executive Officer and its Chief Financial Officer, does not expect that the Company’s disclosure

controls and procedures or its internal control over financial reporting will prevent or detect all error and all fraud.

A control system,

no matter how well designed and operated, can provide only reasonable, not absolute, assurance that the control system’s objectives

The design of a control system must reflect the fact that there are resource constraints, and the benefits of controls must

be considered relative to their costs.

Furthermore, because of the inherent limitations in all control systems, no evaluation of controls

can provide absolute assurance that misstatements due to error or fraud will not occur or that all control issues and instances of fraud,

if any, have been detected.

These inherent limitations include the realities that judgments in decision-making can be faulty and that

breakdowns can occur because of simple error or mistake.

Controls can also be circumvented by the individual acts of some persons or

by the collusion of two or more persons.

The design of any system of controls is based in part on certain assumptions about the likelihood

of future events, and there can be no assurance that any design will succeed in achieving its stated goals under all potential future

Projections of any evaluation of the effectiveness of controls to future periods are subject to risks.

Over time, controls

may become inadequate because of changes in conditions or deterioration in the degree of compliance with policies or procedures.

in Internal Control Over Financial Reporting.

have not been any changes in our internal control over financial reporting during the quarter ended December 31, 2020 that have

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

a result of COVID-19, our workforce has operated primarily in a work from home environment for the quarter ended December 31,

While pre-existing controls were not specifically designed to operate in our current work from home operating environment,

we do not believe that such work from home actions have had a material adverse effect on our internal controls over financial

We have continued to re-evaluate and refine our financial reporting process to provide reasonable assurance that we

could report our financial results accurately and timely.

required by Items 10, 11, 12, 13 and 14 of Part III is omitted from this Annual Report and will be filed in a definitive proxy

statement or by an amendment to this Annual Report not later than 120 days after the end of the fiscal year covered by this Annual

have not been any changes in our internal control over financial reporting during the quarter ended December 31, 2021, that have materially

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

a result of COVID-19, our workforce operated primarily in a work from home environment for the year ended December 31, 2021.

While pre-existing

controls were not specifically designed to operate in our current work from home operating environment, we do not believe that such work

from home actions have had a material adverse effect on our internal controls over financial reporting.

We have continued to re-evaluate

and refine our financial reporting process to provide reasonable assurance that we could report our financial results accurately and

OTHER INFORMATION

REGARDING FOREIGN JURISDICTIONS THAT PREVENT INSPECTIONS

required by Items 10, 11, 12, 13 and 14 of Part III is omitted from this Annual Report and will be filed in a definitive proxy statement

or by an amendment to this Annual Report not later than 120 days after the end of the fiscal year covered by this Annual Report (subject

to any extension provided by Exchange Act Rule 0-3).

EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE

information required by this Item will be set forth under the headings “

Election of Directors ”, “Information

about our Executive Officers ”, “

Corporate Governance ”, “

Code of Ethics ”,

Committees of the Board ”, and “

Delinquent Section 16(a) Reports ”

(to the extent applicable

and warranted) in the Company’s 2021 Proxy Statement to be filed with the SEC within 120 days after December 31, 2020 in

connection with the solicitation of proxies for the Company’s 2020 annual meeting of stockholders and is incorporated herein

by reference.

information required by this Item will be set forth under the headings “

Executive Compensation ”,

Directors Compensation ”, “

Outstanding Equity Awards at Fiscal Year-End ”,

Compensation Committee Interlocks and Insider Participation ”

Compensation Committee

Report ”

(to the extent required), in the Company’s 2021 Proxy Statement to be filed with the SEC within 120

days after December 31, 2020 and is incorporated herein by reference.

information required by this Item will be set forth in the Company’s 2022 Proxy Statement to be filed with the SEC within 120 days

after December 31, 2021 (subject to any extension provided by Exchange Act Rule 0-3) in connection with the solicitation of proxies for

the Company’s 2022 annual meeting of stockholders including under the headings “ Election of Directors ”, “ Information

about our Executive Officers ”, “ Corporate Governance ”, “ Code of Ethics ”, “ Committees

of the Board ”, and “ Delinquent Section 16(a) Reports ” (to the extent applicable and warranted), and is incorporated

herein by reference.

information required by this Item will be set forth in the Company’s 2022 Proxy Statement to be filed with the SEC within 120 days

after December 31, 2021 (subject to any extension provided by Exchange Act Rule 0-3) , including

under the headings “ Executive Compensation ”, “ Directors Compensation ”, “ Outstanding Equity

Awards at Fiscal Year-End ”, “ Compensation Committee Interlocks and Insider Participation ” and “ Compensation

Committee Report ” (to the extent required), and is incorporated herein by reference.

OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT AND RELATED STOCKHOLDER MATTERS

information required by this Item will be set forth under the heading “

Voting Rights and Principal Stockholders ”

Equity Compensation Plan Information ”

in the Company’s 2021 Proxy Statement to be filed with the

SEC within 120 days after December 31, 2020 and is incorporated herein by reference.

information required by this Item will be set forth under the heading “ Voting Rights and Principal Stockholders ” and

“ Equity Compensation Plan Information ” in the Company’s 2022 Proxy Statement to be filed with the SEC within

120 days after December 31, 2021 (subject to any extension provided by Exchange Act Rule 0-3) ,

and is incorporated herein by reference.

RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR INDEPENDENCE

information required by this Item will be set forth under the headings “

Certain Relationships and Related Transactions ”

Committees of the Board ”

Director Independence ”

in the Company’s 2021 Proxy

Statement to be filed with the SEC within 120 days after December 31, 2020 and is incorporated herein by reference.

information required by this Item will be set forth in the Company’s 2022 Proxy Statement to be filed with the SEC within 120 days

after December 31, 2021 (subject to any extension provided by Exchange Act Rule 0-3) , including

under the headings “ Certain Relationships and Related Transactions ” and “ Committees of the Board ”

- “ Director Independence ”, and is incorporated herein by reference.

ACCOUNTANT FEES AND SERVICES

information required by this Item will be set forth under the heading “

Ratification of Appointment of Auditors ”

Audit Fees ”

in the Company’s 2021 Proxy Statement to be filed with the SEC within 120 days

after December 31, 2020 and is incorporated herein by reference.

information required by this Item will be set forth under the heading “ Ratification of Appointment of Auditors ” -

“ Audit Fees ” in the Company’s 2022 Proxy Statement to be filed with the SEC within 120 days after December 31,

2021 (subject to any extension provided by Exchange Act Rule 0-3) , and is incorporated herein

by reference.

FINANCIAL STATEMENTS AND SCHEDULES

Documents filed as part of this Annual Report:

following is an index of the financial statements, schedules and exhibits included in this Form 10-K or incorporated herein by

following is an index of the financial statements, schedules and exhibits included in this Form 10-K or incorporated herein by reference.

Financial Statements

3 unchanged sentences

Consolidated Statements of Operations

Statements of Changes in Stockholders’

Consolidated Statements of Changes in Stockholders’ Equity

Consolidated Statements of Cash Flows

1 unchanged sentence

Financial Statement Schedules

as provided above, all financial statement schedules have been omitted, since the required information is not applicable or is

not present in amounts sufficient to require submission of the schedule, or because the information required is included in the

consolidated financial statements and notes thereto included in this Form 10-K.

Underwriting Agreement dated February 13, 2020, by and between Trxade Group, Inc.

and Dawson James Securities, Inc.

as the representative of the underwriters named therein

February 13, 2020

Merger and Reorganization Agreement of XCELLINK INTERNATIONAL, INC., a Delaware corporation (predecessor to Trxade Group, Inc.

a Delaware corporation) and Trxade Group, Inc., a Nevada corporation

June 11, 2014

Asset Purchase Agreement dated October 23, 2019 between Trxade Group, Inc.’s wholly-owned subsidiary Bonum Health, LLC, a Delaware limited liability company, Bonum Health, LLC, a Florida limited liability company, and Hardikkumar Patel

October 28, 2019

as provided above, all financial statement schedules have been omitted, since the required information is not applicable or is not present

in amounts sufficient to require submission of the schedule, or because the information required is included in the consolidated financial

statements and notes thereto included in this Form 10-K.

Incorporated by Reference

Filed/Furnished

Equity Distribution Agreement, dated August 6, 2021 between the Company and EF Hutton, division of Benchmark Investments, LLC

Second Amended and Restated Certificate of Incorporation of Trxade Group, Inc.

October 15, 2019

Certificate of Amendment to Second Amended and Restated Certificate of Incorporation (1-for-6 Reverse Stock Split of Common Stock) filed with the Delaware Secretary of State on February 12, 2020, and effective February 13, 2020

February 13, 2020

Certificate of Amendment of Certificate of Incorporation (changing name TRxADE HEALTH, INC.)

Limited Liability Company Agreement of SOSRx LLC effective February 15, 2022

Amended and Restated Bylaws of Trxade Group, Inc.

July 24, 2014

Description of Registered Securities

March 30, 2020

$300,000 Promissory Note dated October 15, 2018 with Nikul Panchal

October 16, 2018

Revocable Warrant dated October 15, 2018 with Nikul Panchal

October 16, 2018

Warrant Agreement dated December 31, 2016 with Gajan A.

Mahendiran and Amudha Mahendiran

January 5, 2017

Indemnification Agreement dated February 6, 2019 with Prashant Patel and Suren Ajjarapu

March 22, 2019

Shareholder Agreement dated January 1, 2019 between the Company and the stockholders party thereto

January 22, 2019

Form of Investment Warrant Agreement

July 13, 2018

Promissory Note with Sansur Associates LLC in the amount of $100,000 dated July 17, 2017

Promissory Note with Prashant Patel in the amount of $122,551.88 dated July 1, 2017

Form of Indemnification Agreement dated August 22, 2016 with Michael L.

August 25, 2016

Amendment to Convertible Note Agreement and Note dated June 2, 2016, with Gajan A.

Mahendiran and Amudha Mahendiran

Form of Warrant dated October 2015 with Gajan A.

Mahendiran and Amudha Mahendiran

October 27, 2015

Form of Warrant Agreement

September 26, 2014

Form of Registration Rights Agreement

September 26, 2014

Employment Agreement between Trxade, Inc.

and Prashant Patel dated May 24, 2013

July 24, 2014

2014 Equity Incentive Plan

June 11, 2014

Form of Indemnification Agreement entered into between Trxade Group, Inc.

and its directors and certain officers

June 11, 2014

Form of Securities Purchase Agreement (July 30, 2019 Offering)

July 11, 2019

Form of Securities Purchase Agreement (September 30, 2019 Offering)

October 2, 2019

Securities Purchase Agreement dated October 23, 2019, by and among Trxade Group, Inc.

and Bonum Health, LLC, a Florida limited liability company

October 28, 2019

Form of Registration Rights Agreement dated October 23, 2019, by and among Trxade Group, Inc.

and Bonum Health, LLC, a Florida limited liability company

October 28, 2019

Transition Services Agreement dated October 23, 2019, by and among Trxade Group, Inc.

and Bonum Health, LLC, a Florida limited liability company

October 28, 2019

Amended and Restated Trxade Group, Inc.

Second Amended and Restated Trxade Group, Inc.

2019 Equity Incentive Plan

Form of Stock Option Agreement (April 2020 Grants to Employees) April 14, 2020

April 16, 2020

Form of Restricted Stock Grant Agreement (Independent Directors 2020 Award, 2020 CFO Award and 2020 Legal Counsel) April 14, 2020

April 16, 2020

April 14, 2020 Executive Employment Agreement with Suren Ajjarapu

April 16, 2020

First Amendment to Executive Employment Agreement with Suren Ajjarapu dated May 5, 2020

3 unchanged sentences

and Howard A.

June 26, 2020

Trxade Group, Inc.

Independent Director Compensation Policy adopted April 14, 2020

July 27, 2020

Form of First Amendment to Trxade Group, Inc.

1 unchanged sentence

Independent Directors 2020 Award, 2020 CFO Award and 2020 Legal Counsel Award)

August 4, 2020

Form of Stock Option Agreement Trxade Group, Inc.

Amended and Restated 2019 Equity Incentive Plan

August 14, 2020

Form of Restricted Stock Grant Agreement Trxade Group, Inc.

Amended and Restated 2019 Equity Incentive Plan

August 14, 2020

Form of Trxade Group, Inc.

2019 Equity Incentive Plan Restricted Stock Grant Agreement

Non-Recourse Promissory Note in the amount of $500,000, dated February 15, 2022, by TRxADE HEALTH, INC.

in favor of Exchange Health, LLC

Distribution Services Agreement dated February 15, 2022, by and between SOSRx LLC and Integra Pharma Solutions LLC

Member Asset Contribution Agreement dated February 15, 2022, between Exchange Health, LLC and SOSRx LLC

Code of Ethics

March 23, 2015

List of Subsidiaries

4 unchanged sentences

Certification of Principal Accounting Officer Pursuant to Section 906 of the Sarbanes-Oxley Act**

XBRL Instance Document

XBRL Taxonomy Extension Schema Document

XBRL Taxonomy Extension Calculation

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XBRL Taxonomy Extension Definition Linkbase

XBRL Taxonomy Extension Label Linkbase

XBRL Taxonomy Extension Presentation

Linkbase Document

management contract or compensatory plan or arrangement.

Certain schedules, exhibits, annexes and similar attachments have been omitted pursuant to Item 601(b)(2) of Regulation S-K.

copy of any omitted schedule or exhibit will be furnished supplementally to the Securities and Exchange Commission upon request;

provided, however that Trxade Group, Inc.

may request confidential treatment pursuant to Rule 24b-2 of the Exchange Act, for any

schedule or exhibit so furnished.

Certain schedules, annexes and similar attachments have been omitted pursuant to Item 601(a)(5) of Regulation S-K.

A copy of any

omitted schedule or exhibit will be furnished supplementally to the Securities and Exchange Commission upon request;

however that Trxade Group, Inc.

may request confidential treatment pursuant to Rule 24b-2 of the Securities Exchange Act of 1934,

as amended, for any schedule or exhibit so furnished.

10–K SUMMARY

to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report

to be signed on its behalf by the undersigned, thereunto duly authorized.

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

Taxonomy Extension Schema Document

Taxonomy Extension Calculation Linkbase Document

Taxonomy Extension Definition Linkbase Document

Taxonomy Extension Label Linkbase Document

Taxonomy Extension Presentation Linkbase Document

XBRL for the cover page of this Annual Report on Form 10-K, included in the Exhibit 101 Inline XBRL Document Set.

Filed herewith.

Furnished herewith.

Indicates management contract or compensatory plan or arrangement.

to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed

on its behalf by the undersigned, thereunto duly authorized.

March 28, 2022

Suren Ajjarapu

/s/ Suren Ajjarapu

Ajjarapu, Chief Executive Officer (Principal Executive Officer)

March 28, 2022

/s/ Howard A.

Doss, Chief Financial Officer (Principal Financial and Accounting Officer)

to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following persons on behalf

of the registrant and in the capacities and on the dates indicated.

to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following persons on behalf of the

registrant and in the capacities and on the dates indicated.

Suren Ajjarapu

5 unchanged sentences

President and Chief Operating Officer

Pamela Tenaerts

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-K

Item 9A. Controls and Procedures