Onar Holding Corp

Evaluation of Disclosure Controls and Procedures

We have established and maintain a system of disclosure controls and procedures, as such term is defined in Rules 13a-15(e) and 15d-15(e) of the Exchange Act, that are designed to provide reasonable assurance that information required to be disclosed in our reports filed with the Securities and Exchange Commission pursuant to the Exchange Act, is recorded, processed, summarized and reported within the time periods specified in the rules and forms of the Commission and that such information is accumulated and communicated to our management, including our Chief Executive Officer (CEO), to allow timely decisions regarding required disclosures.

In connection with the preparation of this Quarterly Report on Form 10-Q, our management, with the participation of our Chief Executive Officer (our Principal Executive Officer and Principal Financial Officer), carried out an evaluation of the effectiveness of our disclosure controls and procedures as of September 30, 2025, as required by Rules 13a-15(e) and 15d-15(e) of the Exchange Act. Based on the evaluation described above, our management, including our Principal Executive Officer and Principal Financial Officer, concluded that, as of September 30, 2025, our disclosure controls and procedures were not effective.

Changes in Internal Control Over Financial Reporting

During the quarter ended September 30, 2025, management implemented and evaluated significant enhancements to the Company’s internal control environment.

We regularly review and enhance our system of internal control over financial reporting to ensure the accuracy and reliability of our financial statements. During the quarter ended September 30, 2025, the Company implemented several organizational and procedural improvements designed to strengthen its internal control environment and financial oversight.

Key actions included the appointment of a Vice President of Finance to oversee daily accounting and reporting operations, the establishment of a two-person approval and control process for all outgoing payments, and the transition of bookkeeping and day-to-day accounting functions in-house to improve accountability and responsiveness. The Company also engaged a third-party accounting firm to assist with ongoing financial review and audit processes. The Company also engaged a third-party consulting firm, whose members include a former partner from a PCAOB registered firm, to assist with ongoing financial review and audit-readiness processes. Their involvement provides additional technical oversight and supports management’s efforts to maintain robust financial reporting standards.

In addition, during the quarter, the Company’s Chief Financial Officer departed for personal reasons, and interim financial oversight responsibilities have been assumed by senior management, supported by the new finance leadership team. The Company is actively evaluating candidates and engaging in discussions to appoint a new Chief Financial Officer in the near term. These combined measures have strengthened the Company’s control structure, improved segregation of duties, and enhanced transparency across financial operations.

Management believes these actions collectively represent a material improvement in the Company’s internal control environment and will further support the integrity and timeliness of future financial reporting. Management will continue to monitor and test these controls to ensure their continued effectiveness.