Item 4. Controls and Procedures
Item 4. Controls and Procedures
Evaluation of Disclosure Controls and Procedures
We maintain controls
and procedures designed to ensure that information required to be disclosed by the issuer in the reports that it files or submits
under the Act (15 U.S.C. 78a et seq.) is recorded, processed, summarized and reported, within the time periods specified in the
Securities and Exchange Commission’s rules and forms. Disclosure controls and procedures include, without limitation, controls
and procedures designed to ensure that information required to be disclosed by an issuer in the reports that it files or submits
under the Act is accumulated and communicated to the issuer’s management, including its principal executive and principal
financial officers, or persons performing similar functions, as appropriate to allow timely decisions regarding required disclosure.
As of December 31,
2020, we carried out an evaluation, under the supervision of and with the participation of its management, including our Chief
Executive Officer and Acting Chief Financial Officer, of the effectiveness of the design and operation of our disclosure controls
and procedures. Based on the foregoing evaluation, Chief Executive Officer and Acting Chief Financial Officer concluded that 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”)) were not effective and adequately designed to ensure that the information required to be disclosed
by us in the reports it files or submits under the Exchange Act is recorded, processed, summarized and reported within the time
periods specified in the applicable rules and forms, and that such information was accumulated and communicated to the management,
including Chief Executive Officer and Acting Chief Financial Officer, in a manner that allowed for timely decisions regarding required
disclosure. The assessment stemmed from the following material weaknesses –
●
Lack of segregation of duties for accounting personnel who prepared
and reviewed the journal entries; and
●
Lack of a full time U.S. GAAP personnel in the accounting department
to monitor the recording of the transactions.
Changes in Internal Control over Financial
Reporting.
There were no changes
in our internal control over financial reporting (as defined in Rule 13a-15(f) of the Exchange Act) during the three months ended
December 31, 2020 that have materially affected, or are reasonably likely to materially affect, our internal control over financial
reporting.
39
PART II. OTHER INFORMATION
Item 1. Legal
Proceedings
None.
Item 1A. Risk Factors
This item is not applicable
to a smaller reporting company such as us.
Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.