IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL DISCLOSURE |
AND PROCEDURES |
on Internal Control Over Financial Reporting
of December 31, 2018, the Company’s management, with the participation of the Company’s Chief Executive Officer
and Chief Financial Officer, evaluated the effectiveness of the Company’s disclosure controls and procedures (as such term
is defined in Rules 13a-15(e) and 15d-15(e) promulgated under the Securities Exchange Act of 1934, as amended (the “Exchange
Act”)). Based on such evaluation, the Company’s Chief Executive Officer and Chief Financial Officer have concluded
that, as of the end of such period, the Company’s disclosure controls and procedures were effective.
Company’s management is responsible for establishing and maintaining adequate internal control over financial reporting
as defined in Rules 13a-15(f) and 15(d)-15(f) promulgated under the Exchange Act. The Company’s internal control over financial
reporting is designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of
financial statements for external purposes in accordance with generally accepted accounting principles in the United States of
America. The Company’s management assessed the effectiveness of our internal control over financial reporting as of December 31,
2018. In making the assessment, management used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway
Commission (2013 Framework) in Internal Control—Integrated Framework. Based on our assessment, our management has concluded
that our internal control over financial reporting is effective as of December 31, 2018.
control system, no matter how well conceived or 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 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 error or mistake. Additionally, controls can be circumvented by the individual acts of
some persons, by collusion of two or more people, or by management override of the controls. The design of any system of controls
is based in part upon certain assumptions about the likelihood of future events, and there can be no assurance that any design
will succeed in achieving its stated goals under all potential future conditions; over time, controls may become inadequate because
of changes in conditions, or the degree of compliance with the policies or procedures may deteriorate. Because of the inherent
limitations in a cost-effective control system, misstatements due to error or fraud may occur and not be detected.
on the evaluation of internal control over financial reporting, the Chief Executive Officer and Chief Financial Officer have concluded
that there have been no changes in the Company’s internal controls over financial reporting during the period that is covered
by this report that has materially affected or is reasonably likely to materially affect, the Company’s internal control
over financial reporting.