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Our disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934) are designed to ensure that information required to be disclosed in the reports that we file or submit under the Exchange Act is recorded, processed, summarized, and reported within the time periods specified in the rules and forms of the Securities and Exchange Commission and to ensure that such information required to be disclosed is accumulated and communicated to management, including our principal executive and financial officers, as appropriate to allow timely decisions regarding required disclosure.
−Removed: The Chief Executive Officer ("CEO") and the Chief Financial Officer ("CFO"), with assistance from other members of management, have evaluated the effectiveness of our disclosure controls and procedures as of April 3, 2020 and, based on their evaluation, the CEO and CFO have concluded that the disclosure controls and procedures were not effective as of such date due to the material weaknesses in internal control over financial reporting that were disclosed in our Annual Report on Form 10-K for the fiscal year ended September 27, 2019.
+Added: The Chief Executive Officer ("CEO") and the Chief Financial Officer ("CFO"), with assistance from other members of management, have evaluated the effectiveness of our disclosure controls and procedures as of July 3, 2020, and based on their evaluation, the CEO and CFO have concluded that the disclosure controls and procedures were not effective as of such date due to the material weaknesses in internal control over financial reporting that were disclosed in our Annual Report on Form 10-K for the fiscal year ended September 27, 2019.
Changes in Internal Control Over Financial Reporting
−Removed: Other than the implementation of the remediation measures described below, there were no other changes in our internal control over financial reporting that occurred during the period covered by this report that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
−Removed: As previously described in Part II, Item 9A of our Annual Report on Form 10-K for the fiscal year ended September 27, 2019, we began implementing a remediation plan to address the material weaknesses mentioned above.
−Removed: The material weaknesses will not be considered remediated until the applicable controls operate for a sufficient period of time and management has concluded, through testing, that these controls are operating effectively.
+Added: During the quarter ended July 3, 2020, we made the following changes to our internal control over financial reporting that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting:
+Added: • Re-designed and enhanced control activities related to inventory, including inventory count procedures, inventory valuation, and the classification of inventory.
+Added: • Enhanced control activities, including the evidence maintained in support of the execution of the control activities.
+Added: related to business performance monitoring controls at our international entities.
+Added: • Enhanced the design of existing controls and implemented new control activities related to the elimination of intercompany balances.
+Added: Remediation of Previously Identified Material Weaknesse s
+Added: As previously described in Part II, Item 9A of our Annual Report on Form 10-K for the fiscal year ended September 27, 2019, we began to implement a remediation plan to address the material weaknesses mentioned above.
+Added: During the first three quarters of fiscal 2020, we began the implementation of a remediation plan to address the material weaknesses identified as of that date.
+Added: During the first three quarters of fiscal 2020, we hired additional experienced accounting and financial reporting personnel and engaged knowledgeable consultants to provide advice and assistance in the design and implementation of specific remediation plans to address the reported fiscal 2019 control deficiencies.
+Added: In addition to the items noted above, we have, with the participation of these accounting personnel and consultants, performed the following:
+Added: • Enhanced the design and performance of control activities related to the accuracy of customer order entry, quantity, and pricing information.
+Added: • Enhanced the design and performance of control activities related to the assessment of accounting for customer arrangements in accordance with Revenue from Contracts with Customers (“ASC 606”).
+Added: • Designed and implemented control activities to identify and appropriately assess the impact of post-close events which occur before the financial statements are available to be issued.
+Added: • Re-designed and enhanced control activities, including the evidence maintained in support of the execution of the control activities related to the preparation and review of statement of cash flows.
+Added: Because the reliability of the internal control process requires repeatable execution, the successful remediation of these material weaknesses will require review and evidence of operating effectiveness prior to concluding that the controls are effective and there is no assurance that additional remediation steps will not be necessary.
+Added: As such, as we continue to evaluate and work to improve our internal control over financial reporting, our management may decide to take additional measures to address the material weaknesses or modify the remediation steps already underway.
+Added: Although significant progress has been made, the previously identified material weaknesses continue to exist as of July 3, 2020, and will not be considered remediated until the applicable controls operate for a sufficient period of time and management has concluded, through testing, that these controls are operating effectively
OTHER INFORMATION
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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.