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Our management carried out an evaluation under the supervision and with the participation of our Principal Executive Officer and Principal Financial Officer, of the effectiveness of the design and operation of our disclosure controls and procedures pursuant to Rules 13a-15(e) and 15d-15(e) under the Exchange Act.
−Removed: Based upon that evaluation, our Principal Executive Officer and Principal Financial Officer have concluded, as they previously concluded as of December 31, 2019, that our disclosure controls and procedures continue to not be effective as of September 30, 2020, because of material weaknesses in our internal control over financial reporting, as described below and in detail in our Annual Report.
+Added: Based upon that evaluation, our Principal Executive Officer and Principal Financial Officer have concluded, as they previously concluded as of December 31, 2020, that our disclosure controls and procedures continue to be ineffective as of March 31, 2021, because of material weaknesses in our internal control over financial reporting, as described below and in detail in our Annual Report.
Changes in Internal Control over Financial Reporting
3 unchanged sentences
In addition, the Audit Committee and the independent registered public accounting firm have discussed the independent registered public accounting firm’s independence from the Company and its management, including the matters in the written disclosures required by PCAOB Rule 3526 “ Communicating with Audit Committees Concerning Independence .”
−Removed: As of September 30, 2020, we did not maintain sufficient internal controls over financial reporting due to insufficient:
+Added: As of March 31, 2021, we did not maintain sufficient internal controls over financial reporting in the following areas:
· segregation of duties in some areas of Finance;
−Removed: · oversight in the area of Information Technology, where certain processes may affect the internal controls over financial reporting;
+Added: · oversight in the area of IT, where certain processes may affect the internal controls over financial reporting;
· monitoring of review controls with respect to accounting for complex transactions.
We have developed, and are currently implementing, a remediation plan for these material weaknesses.
−Removed: Specifically, we have identified and selected a system for financial reporting that will allow further automation of the reporting process, thereby strengthening the control environment over financial reporting.
+Added: Specifically, we have identified and implemented a system for financial reporting that has allowed further automation of the reporting process, thereby strengthening the control environment over financial reporting.
As we continue to evaluate and work to enhance our internal controls over financial reporting, we may determine that additional measures should be taken to address these or other control deficiencies, and/or that we should modify our remediation plan considering the Company’s size and growth.
−Removed: There have been no changes in our internal controls over financial reporting that occurred during the fiscal quarter ended September 30, 2020, other than those described above, that have materially affected, or are reasonably likely to materially affect, our internal controls over financial reporting.
−Removed: Once the Company is engaged in stable business operations and has sufficient personnel and resources available, then our Board of Directors, in particular and in connection with the aforementioned deficiencies, will establish the following remediation measures:
+Added: There have been no changes in our internal controls over financial reporting that occurred during the fiscal quarter ended March 31, 2021, other than those described above, that have materially affected, or are reasonably likely to materially affect, our internal controls over financial reporting.
+Added: Once the Company is engaged in stable business operations and has sufficient personnel and resources available, then our Board of Directors, will establish the following remediation measures to address the aforementioned deficiencies:
· additional Finance resources will be recruited to resolve the segregation of duties control weaknesses noted above;
13 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.