Item 4. Controls and Procedures
Item 4. Controls and procedures
Management’s evaluation of disclosure controls and procedures
Disclosure Controls and Procedures
Disclosure controls and procedures are designed to ensure that information
required to be disclosed in the reports filed or submitted under the Securities Exchange Act of 1934, as amended (the “Exchange
Act”), is recorded, processed, summarized and reported, within the time period specified in the SEC’s rules and forms and
is accumulated and communicated to our management, including our principal executive officer and principal financial officer, as appropriate,
in order to allow timely decisions regarding required disclosure.
Evaluation of Disclosure Controls and Procedures
Our Chief Executive Officer evaluated the effectiveness of our disclosure
controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act) as of the end of the period covered by this
10-Q Report. Based on that evaluation, our Chief Executive Officer concluded that our disclosure controls and procedures as of the end
of the period covered by this 10-Q Report were effective in providing reasonable assurance that information required to be disclosed by
us in reports that we file or submit under the Exchange Act is (i) recorded, processed, summarized and reported within the time periods
specified in the SEC’s rules and forms and (ii) accumulated and communicated to our management, including our Chief Executive Officer
and Principal Financial Officer, as appropriate, to allow timely decisions regarding required disclosure.
Our Chief Executive Officer does not expect that our disclosure controls
and procedures or our internal controls will prevent all error and all fraud. A control system, no matter how well conceived and operated,
can provide only reasonable, not absolute, assurance that the objectives of the control system are met. Further, the design of a control
system must reflect the fact that there are 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, misstatements, errors, and instances of fraud, if any, within our company have been or will be prevented or detected. Further,
internal controls may become inadequate as a result of changes in conditions, or through the deterioration of the degree of compliance
with policies or procedures.
Changes in internal controls over financial reporting
In connection with our transformation into a pharmaceutical royalty
company, we terminated our executive management team and all other employees, except for our former General Counsel and current Chief
Executive Officer. As of March 31, 2024, we employed one full-time employee primarily engaged in an executive position. We have engaged
external consultants who support our relationship with current partners and assist with certain financial, legal and regulatory matters
and the continued wind-down of our historical commercial business operations. As a result of these changes, we have updated our risk assessment
and design of internal controls over financial reporting that align with reduced transaction volume and reliance on external consultants
to manage the day-to-day operations of the Company. The Company is and will continue to evaluate changes to processes, information technology
systems and other components of internal controls over financial reporting as part of its ongoing business transformation activities,
and as a result, controls may be periodically changed. The Company believes, however, that it will be able to maintain sufficient controls
over its financial reporting throughout this transformation process.
During the first quarter of fiscal year 2024, we deployed a new ERP system
which is anticipated to enhance our operating and financial processes over time. Processes and internal controls have been updated and
are consistent with our internal control framework, and we have evaluated the operating effectiveness of related key controls. Control
processes continue to be evaluated to give appropriate consideration of modifications needed to maintain the effectiveness of internal
controls over financial reporting.
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Part II - Other Information
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