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 March 31, 2021, 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 March 31, 2021 that have materially affected, or are reasonably likely to materially affect, our internal control over financial
reporting.
40
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.