Item 4. Controls and Procedures
Item
4. Controls and Procedures.
Evaluation
of Disclosure Controls and Procedures
Disclosure
controls are procedures that are designed with the objective of ensuring that information required to be disclosed in our reports under
the Securities Exchange Act of 1934, as amended (the “ Exchange Act ”), such as this Quarterly Report, is recorded,
processed, summarized and reported in accordance with the rules of the Securities and Exchange Commission (the “ SEC ”).
Disclosure controls are also designed with the objective of ensuring that such information is accumulated appropriately and communicated
to management, including the chief executive officer and chief financial officer, as appropriate, to allow for timely decisions regarding
required disclosures.
Our
Chief Executive Officer (principal executive officer) and Chief Financial Officer (principal financial and accounting officer) evaluated
the effectiveness of our “disclosure controls and procedures” (as defined in the Exchange Act Rules 13a-15(e) and 15d-15(e))
as of July 31, 2021, the end of the period covered by this report. Based on that evaluation, our Chief Executive Officer and Chief Financial
Officer concluded that our disclosure controls and procedures were not effective as of such date to ensure that information required
to be disclosed by us in reports filed or submitted under the Exchange Act were recorded, processed, summarized, and reported within
the time periods specified in the SEC's rules and forms and that our disclosure controls are not effectively designed to ensure that
information required to be disclosed by us in the reports that we file or submit under the Exchange Act is accumulated and communicated
to management, including our principal executive officer and principal financial officer, or persons performing similar functions, as
appropriate to allow timely decisions regarding required disclosure. See the Company’s Annual Report on Form 10-K for the fiscal
year ended October 31, 2020, for a description of the Company’s material weaknesses in internal control over financial reporting.
Changes
in Internal Controls over Financial Reporting
No
change in our internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act) occurred
during the fiscal quarter ended July 31, 2021 that has materially affected, or is reasonably likely to materially affect, the Company’s
internal control over financial reporting.
34
Part
II – OTHER INFORMATION
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