Item 4. Controls and Procedures
Item 4. Controls and Procedures.
Our Chief Executive Officer
and Chief Financial Officer conducted an evaluation of the effectiveness of the design and operation of 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 ”),
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
ensure that information required to be disclosed by us in the reports filed or submitted by us under the Exchange Act is accumulated and
communicated to our management, including our Chief Executive Officer and Chief Financial Officer, as appropriate to allow timely decisions
regarding required disclosure. Based on that evaluation, our Chief Executive Officer and Chief Financial Officer have concluded that as
of June 30, 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 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,
over the last year, we have been addressing and remediating these weaknesses with the support and assistance of the accounting and financial
staff of our Indian operating subsidiary (“ SSI-India ”). 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
Officer do not expect that our disclosure controls or internal controls will prevent all errors and all fraud. Although our disclosure
controls and procedures were designed to provide reasonable assurance of achieving their objectives and our Chief Executive Officer and
Chief Financial Officer have determined that our disclosure controls and procedures are effective at doing so, a control system, no matter
how well conceived and operated, can provide only reasonable, not absolute assurance that the objectives of the system are met. Further,
the design of any control system is subject to resource constraints and the benefits of controls must be considered relative to their
costs. 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
Reporting
There were no changes in our internal controls
over financial reporting that occurred during the last fiscal quarter covered by this report that has materially affected, or is reasonably
likely to materially affect, our internal control over financial reporting.
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PART II – OTHER INFORMATION
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.