Controls and Procedures
−Removed: Evaluation of Disclosure Controls and Procedures
−Removed: We maintain controls
−Removed: and procedures designed to ensure that information required to be disclosed by the issuer in the reports that it files or submits
−Removed: under the Act (15 U.S.C.
−Removed: 78a et seq.) is recorded, processed, summarized and reported, within the time periods specified in the
−Removed: Securities and Exchange Commission’s rules and forms.
+Added: of Disclosure Controls and Procedures
+Added: maintain controls and procedures designed to ensure that information required to be disclosed by the issuer in the reports that it files
+Added: or submits under the Act (15 U.S.C.
+Added: 78a et seq.) is recorded, processed, summarized and reported, within the time periods specified in
+Added: the Securities and Exchange Commission’s rules and forms.
Disclosure controls and procedures include, without limitation, controls
−Removed: and procedures designed to ensure that information required to be disclosed by an issuer in the reports that it files or submits
−Removed: under the Act is accumulated and communicated to the issuer’s management, including its principal executive and principal
−Removed: financial officers, or persons performing similar functions, as appropriate to allow timely decisions regarding required disclosure.
−Removed: As of December 31,
−Removed: 2020, we carried out an evaluation, under the supervision of and with the participation of its management, including our Chief
−Removed: Executive Officer and Acting Chief Financial Officer, of the effectiveness of the design and operation of our disclosure controls
+Added: and procedures designed to ensure that information required to be disclosed by an issuer in the reports that it files or submits under
+Added: the Act is accumulated and communicated to the issuer’s management, including its principal executive and principal financial officers,
+Added: or persons performing similar functions, as appropriate to allow timely decisions regarding required disclosure.
+Added: of March 31, 2021, we carried out an evaluation, under the supervision of and with the participation of its management, including our
+Added: Chief Executive Officer and Acting Chief Financial Officer, of the effectiveness of the design and operation of our disclosure controls
and procedures.
−Removed: Based on the foregoing evaluation, Chief Executive Officer and Acting Chief Financial Officer concluded that our
−Removed: disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended
−Removed: (the “Exchange Act”)) were not effective and adequately designed to ensure that the information required to be disclosed
−Removed: by us in the reports it files or submits under the Exchange Act is recorded, processed, summarized and reported within the time
−Removed: periods specified in the applicable rules and forms, and that such information was accumulated and communicated to the management,
−Removed: including Chief Executive Officer and Acting Chief Financial Officer, in a manner that allowed for timely decisions regarding required
−Removed: The assessment stemmed from the following material weaknesses –
−Removed: Lack of segregation of duties for accounting personnel who prepared
−Removed: and reviewed the journal entries;
−Removed: Lack of a full time U.S.
−Removed: GAAP personnel in the accounting department
−Removed: to monitor the recording of the transactions.
−Removed: Changes in Internal Control over Financial
−Removed: There were no changes
−Removed: in our internal control over financial reporting (as defined in Rule 13a-15(f) of the Exchange Act) during the three months ended
−Removed: December 31, 2020 that have materially affected, or are reasonably likely to materially affect, our internal control over financial
+Added: Based on the foregoing evaluation, Chief Executive Officer and Acting Chief Financial Officer concluded that our disclosure
+Added: 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
+Added: Act”)) were not effective and adequately designed to ensure that the information required to be disclosed by us in the reports
+Added: it files or submits under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in the applicable
+Added: rules and forms, and that such information was accumulated and communicated to the management, including Chief Executive Officer and
+Added: Acting Chief Financial Officer, in a manner that allowed for timely decisions regarding required disclosure.
+Added: The assessment stemmed from
+Added: the following material weaknesses –
+Added: of segregation of duties for accounting personnel who prepared and reviewed the journal entries;
+Added: of a full time U.S.
+Added: GAAP personnel in the accounting department to monitor the recording of the transactions.
+Added: in Internal Control over Financial Reporting.
+Added: were no changes in our internal control over financial reporting (as defined in Rule 13a-15(f) of the Exchange Act) during the three
+Added: months ended March 31, 2021 that have materially affected, or are reasonably likely to materially affect, our internal control over financial
OTHER INFORMATION
−Removed: This item is not applicable
−Removed: to a smaller reporting company such as us.
+Added: Legal Proceedings
+Added: This item is not applicable to a smaller reporting company such as
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.