What changed in this filing

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Item 4. Controls and Procedures

2020-08-19 compared with 2020-07-06 · 45 added, 43 removed, 4 unchanged (96% of the section changed)

and Procedures

We carried out an evaluation of the

effectiveness of the design and operation of our disclosure controls and procedures (as defined in Exchange Act Rules 13a-15(e)

and 15d-15(e)) as of March 31, 2020.

This evaluation was carried out under the supervision and with the participation of our Chief

Executive Officer and our Chief Financial Officer.

Based upon that evaluation, our Chief Executive Officer and Chief Financial

Officer concluded that, as of March 31, 2020, our disclosure controls and procedures were not effective due to the presence of

material weaknesses in internal control over financial reporting.

A material weakness is a deficiency,

or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that

a material misstatement of the company’s annual or interim financial statements will not be prevented or detected on a timely

Management has identified the following material weaknesses which have caused management to conclude that, as of March

31, 2020, our disclosure controls and procedures were not effective:

(i) inadequate segregation of duties and effective risk assessment;

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

and application of both US GAAP and SEC guidelines.

Remediation Plan to Address the

Material Weaknesses in Internal Control over Financial Reporting

Our company plans to take steps to

enhance and improve the design of our internal controls over financial reporting.

During the period covered by this quarterly

report on Form 10-Q, we have not been able to remediate the material weaknesses identified above.

To remediate such weaknesses,

we plan to implement the following changes during our fiscal year ending December 31, 2020:

(i) appoint additional qualified personnel

to address inadequate segregation of duties and ineffective risk management;

and (ii) adopt sufficient written policies and procedures

for accounting and financial reporting.

The remediation efforts set out are largely dependent upon our securing additional financing

to cover the costs of implementing the changes required.

If we are unsuccessful in securing such funds, remediation efforts may

be adversely affected in a material manner.

Changes in Internal Control over

Financial Reporting

There were no changes in our internal

control over financial reporting during the three months ended March 31, 2020 that have materially affected, or are reasonable

likely to materially affect, our internal control over financial reporting.

We carried out

an evaluation of the effectiveness of the design and operation of our disclosure controls and procedures (as defined in Exchange

Act Rules 13a-15(e) and 15d-15(e)) as of June 30, 2020.

This evaluation was carried out under the supervision and with the participation

of our Chief Executive Officer and our Chief Financial Officer.

Based upon that evaluation, our Chief Executive Officer and Chief

Financial Officer concluded that, as of June 30, 2020, our disclosure controls and procedures were not effective due to the presence

of material weaknesses in internal control over financial reporting.

A material weakness

is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable

possibility that a material misstatement of the company’s annual or interim financial statements will not be prevented or

detected on a timely basis.

Management has identified the following material weaknesses which have caused management to conclude

that, as of June 30, 2020, our disclosure controls and procedures were not effective:

(i) inadequate segregation of duties and

effective risk assessment;

and (ii) insufficient written policies and procedures for accounting and financial reporting with respect

to the requirements and application of both US GAAP and SEC guidelines.

Plan to Address the Material Weaknesses in Internal Control over Financial Reporting

plans to take steps to enhance and improve the design of our internal controls over financial reporting.

During the period covered

by this quarterly report on Form 10-Q, we have not been able to remediate the material weaknesses identified above.

such weaknesses, we plan to implement the following changes during our fiscal year ending December 31, 2020:

(i) appoint additional

qualified personnel to address inadequate segregation of duties and ineffective risk management;

and (ii) adopt sufficient written

policies and procedures for accounting and financial reporting.

The remediation efforts set out are largely dependent upon our

securing additional financing to cover the costs of implementing the changes required.

If we are unsuccessful in securing such

funds, remediation efforts may be adversely affected in a material manner.

Internal Control over Financial Reporting

There were no

changes in our internal control over financial reporting during the three months ended June 30, 2020 that have materially affected,

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

OTHER INFORMATION

are not a party to any pending legal proceeding.

We are not aware of any pending legal proceeding to which any of our officers,

directors, or any beneficial holders of 5% or more of our voting securities are adverse to us or have a material interest adverse

Legal Proceedings

We are not a party to any pending

legal proceeding.

We are not aware of any pending legal proceeding to which any of our officers, directors, or any beneficial

holders of 5% or more of our voting securities are adverse to us or have a material interest adverse to us.

See risk factors included in our

Annual Report on Form 10-K for the year ended December 31, 2019 filed on May 14, 2020.

Sales of Equity Securities and Use of Proceeds

upon Senior Securities

Safety Disclosures

Unregistered Sales of Equity Securities and

Use of Proceeds

Defaults upon Senior Securities

Mine Safety Disclosures

Not applicable.

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-Q

Item 4. Controls and Procedures