EFTA Document EFTA01381292

Form S-1 Table of Contra' strategies in the future consistent with our Commodity Price Risk Management Policy. If commodity price changes result in unexpected increases in raw materials, we may not be able to increase our prices to offset these increased costs without suffering reduced volume, net sales and operating results. Controls and Procedures Internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements in accordance with GAAP. We are currently in the process of reviewing, documenting and testing our internal control over financial reporting. We have not performed an evaluation of our internal control over financial reporting, as required by Section 404 of the Sarbanes-Oxley Act, nor have we engaged an independent registered public accounting fern to perform an audit of our internal control over financial reporting as of any balance sheet date or for any period reported in our financial statements. Our management is not presently re uired to perform an annual assessment of the effectiveness of our internal control over financial reporting. This requirement will first apply to our Annual Report on Form 10- K for the year ending December 31, 2016. For as long as we arc an "emerging growth company,- our independent register-text public accounting firm will not be required to attest to the effectiveness of our internal control over financial reporting. When we lose our status as an "emerging growth company" and reach an accelerated filer thmhold. our independent registered public accounting firm will be required to attest to the effectiveness of our internal control over financial reporting. 61 http://vanv. see. gov/Archi vecledgaddatatl 609989/000119312515218883/d734898dsl.htm(7/20/2015 10:30:13 AM) CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL DB-SDNY-0080148 SDNY GM_00228332 EFTA01381292