definiens: as defined in the Jumpstart Our Business Startups Act of 2012 ( the ) . The Company maintains a system of internal accounting controls sufficient to provide reasonable assurance that : ( i ) transactions are executed in accordance with management ’s general or specific authorizations, ( ii ) transactions are recorded as necessary to permit pre paration of financial statements in conformity with GAAP and to maintain asset accountability, ( iii ) access to assets is permitted only in accordance with management ’s general or specific authorization, and ( iv ) the recorded accountability for assets is co mpared with the existing assets at reasonable intervals and appropriate action is taken with respect to any differences . The Company has established 10 disclosure controls and procedures ( as defined in Exchange Act Rules 13a -15(e ) and 15d -15(e ) ) for the Company and designed such disclosure controls and procedures to provide reasonable assurance that information required to be disclosed by the Company in the reports it files or submits under the Exchange Act is recorded, processed, summarized and repor ted, within the time periods specified in the SEC ’s rules and forms