ITEM 15. CONTROLS AND PROCEDURES
|A.||Disclosure Controls and Procedures
As of December 31, 2018, under the supervision
and with the participation of our management, including our Chief Executive Officer and Chief Financial Officer, we performed an
evaluation of the effectiveness of the design and operation of our disclosure controls and procedures (as defined in Rule 13a-15(e)
under the Exchange Act). There are inherent limitations to the effectiveness of any disclosure controls and procedures system,
including the possibility of human error and circumventing or overriding them. Even if effective, disclosure controls and procedures
can provide only reasonable assurance of achieving their control objectives.
Based on such evaluation, our Chief Executive
Officer and Chief Financial Officer concluded that our disclosure controls and procedures were effective in recording, processing,
summarizing and reporting on a timely basis, information required to be included in periodic filings under the Exchange Act and
that such information is accumulated and communicated to management, including our Chief Executive and Chief Financial Officers,
as appropriate to allow timely decisions regarding required disclosure.
|B.||Management’s Annual Report on Internal Control
over Financial Reporting
Our management is responsible for establishing
and maintaining adequate internal control over financial reporting, as such term is defined in Rule 13a-15(f) of the Exchange Act.
Under the supervision and with the participation of our management, including our Chief Executive Officer and Chief Financial Officer,
we conducted an evaluation of the effectiveness of our internal control over financial reporting based upon criteria established
in Internal Control – Integrated Framework (2013) by the Committee of Sponsoring Organizations of the Treadway
Commission. Based on that evaluation, our Chief Executive Officer and Chief Financial Officer concluded that our internal control
over financial reporting was effective as of December 31, 2018.
|C.||Attestation Report of the Registered Public Accounting
This Annual Report does not include an
attestation report of our registered public accounting firm due to an exemption provided to emerging growth companies under the
|D.||Changes in Internal Control over Financial Reporting
have been no changes in the Company’s internal control over financial reporting during the year ended December 31, 2018 that
have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
ITEM 16. [RESERVED]
ITEM 16A. Audit committee financial experts
Our board of directors has determined that
Peter Bollmann, Thomas Graney, Werner Lanthaler and Martin Velasco are audit committee financial experts, as that term is defined
by the SEC, and are independent for the purposes of SEC and Nasdaq rules.
ITEM 16B. Code of ethics
Code of business conduct and ethics
We have adopted a Code of Business Conduct
and Ethics which covers a broad range of matters including the handling of conflicts of interest, compliance issues and other corporate
policies such as insider trading and equal opportunity and non-discrimination standards. Our Code of Business Conduct applies to
all of our directors, executive officers and employees. We have published our Code of Business Conduct and Ethics on our website,
www.acimmune.com. The information contained on our website is not a part of this Annual Report.
ITEM 16C. Principal accountant fees and services
For the Years Ended
|in CHF thousands