What changed in this filing

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Item 4. Controls and Procedures

2022-05-16 compared with 2021-11-19 · 20 added, 18 removed, 26 unchanged (59% of the section changed)

1 unchanged sentence

Disclosure Controls 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 September 30,

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

Based upon that evaluation, our Chief Executive Officer and Chief Financial Officer concluded that, as of September 30, 2021,

our disclosure controls and procedures were not effective due to the presence of material weaknesses in internal control over financial

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, 2022.

This evaluation

was carried out under the supervision and with the participation of our Chief Executive Officer and our Chief Financial Officer.

upon that evaluation, our Chief Executive Officer and Chief Financial Officer concluded that, as of March 31, 2022, 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,

2 unchanged sentences

Management has identified the following material

weaknesses which have caused management to conclude that, as of September 30, 2021, our disclosure controls and procedures were not effective:

weaknesses which have caused management to conclude that, as of March 31, 2022, our disclosure controls and procedures were not effective:

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

1 unchanged sentence

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, 2021:

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, 2022:

(i) appoint additional qualified personnel to address inadequate segregation of duties and ineffective

6 unchanged sentences

There were no changes in our internal control over financial reporting

during the nine months ended September 30, 2021 that have materially affected, or are reasonable likely to materially affect, our internal

during the nine months ended March 31, 2022 that have materially affected, or are reasonable likely to materially affect, our internal

control over financial reporting.

2 unchanged sentences

We are not a party to any pending legal proceeding.

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

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, 2020 filed on April 15, 2021.

See risk factors included in our Annual Report on Form 10-K for the year

ended December 31, 2021 filed on March 31, 2021.

Unregistered Sales of Equity Securities and Use of Proceeds

3 unchanged sentences

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