What changed in this filing

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Item 4. Controls and Procedures

2024-09-06 compared with 2024-05-15 · 31 added, 22 removed, 23 unchanged (70% of the section changed)

3 unchanged sentences

as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the “ Exchange Act ”),

as of March 31, 2024, to ensure that information required to be disclosed by us in the reports filed or submitted by us under the Exchange

as of June 30, 2024, to ensure that information required to be disclosed by us in the reports filed or submitted by us under the Exchange

Act is recorded, processed, summarized and reported, within the time periods specified in the rules and forms of the SEC, including to

3 unchanged sentences

Based on that evaluation, our Chief Executive Officer and Chief Financial Officer have concluded that as

of March 31, 2024, our disclosure controls and procedures were not effective at the reasonable assurance level in that:

We do not have written documentation for some of our internal control policies and procedures.

Written documentation of key internal controls over financial reporting is a requirement of Section 404 of the Sarbanes-Oxley Act.

Management evaluated the impact of our failure to have written documentation for some of our internal controls and procedures on our assessment of our disclosure controls and procedures and has concluded that the control deficiency that resulted does not represent a material weakness.

We do not have complete segregation of duties within accounting functions, which is a basic internal control.

Due to our size and nature, segregation of all conflicting duties may not always be possible and may not be economically feasible.

However, to the extent possible, the initiation of transactions, the custody of assets and the recording of transactions should be performed by separate individuals.

Management evaluated the impact of our failure to have segregation of duties on our assessment of our disclosure controls and procedures and procedures and has concluded that the control deficiency that resulted does not represent a material weakness.

of June 30, 2024, our disclosure controls and procedures were not effective at the reasonable assurance level in that:

do not have written documentation for some of our internal control policies and procedures.

Written documentation of key internal controls

over financial reporting is a requirement of Section 404 of the Sarbanes-Oxley Act.

Management evaluated the impact of our failure to

have written documentation for some of our internal controls and procedures on our assessment of our disclosure controls and procedures

and has concluded that the control deficiency that resulted does not represent a material weakness.

do not have complete segregation of duties within accounting functions, which is a basic internal control.

Due to our size and nature,

segregation of all conflicting duties may not always be possible and may not be economically feasible.

However, to the extent possible,

the initiation of transactions, the custody of assets and the recording of transactions is largely performed by separate individuals.

Management evaluated the impact of our failure to have segregation of duties on our assessment of our disclosure controls and procedures

and has concluded that the control deficiency that resulted does not represent a material weakness.

Notwithstanding the foregoing,

1 unchanged sentence

staff of our Indian operating subsidiary (“ SSI-India ”).

We have also begun to implement a new ERP system at SSI-India

which will integrate all business functions within the accounting and financial department to further address the abovementioned weaknesses.

Some of the functional modules like Human Resource Management, Suppliers Chain Management, Production and material management have already

been rolled out on test basis while work on other ERP modules is currently in progress.

We have also obtained help from certain external professional

consulting teams for various internal controls improvement programs.

We are also in the process of implementing a new ERP system at SSI-India

which will integrate all business functions to further address the abovementioned weaknesses.

Some of the functional modules like Human

Resource Management, Suppliers Chain Management, Inventory management, Production and material management have already been rolled out

recently on test basis while work on other ERP modules is currently in progress.

Our Chief Executive Officer and Chief Financial

5 unchanged sentences

the design of any control system is subject to resource constraints and the benefits of controls must be considered relative to their

Because of the inherent limitations in all control systems, no evaluation of controls can provide absolute assurance that all

control issues and instances of fraud, if any, within the Company have been detected.

These inherent limitations include the realities

that judgments in decision-making can be faulty, and that breakdowns can occur because of simple errors or mistakes.

Additionally, controls

can be circumvented if there exists in an individual a desire to do so.

There can be no assurance that any design will succeed in achieving

its stated goals under all potential future conditions.

(b) Changes in Internal Controls Over Financial

Because of the inherent limitations in all control systems, no evaluation of controls can provide absolute assurance that all control

issues and instances of fraud, if any, within the Company have been detected.

These inherent limitations include the realities that judgments

in decision-making can be faulty, and that breakdowns can occur because of simple errors or mistakes.

Additionally, controls can be circumvented

if there exists in an individual a desire to do so.

There can be no assurance that any design will succeed in achieving its stated goals

under all potential future conditions.

Changes in Internal Controls Over Financial

There were no changes in our internal controls

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