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 March 31, 2026, 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 March 31, 2026, our disclosure controls and procedures were not effective.

Changes in Internal Control Over Financial Reporting

As disclosed in the 2025 Annual Report, management identified material weaknesses in the Company's internal control over financial reporting that had not been fully remediated as of March 31, 2026. The 2025 Annual Report also described the remediation actions taken during 2025, including the appointment of a Vice President of Finance, the transition of day-to-day accounting functions in-house, the implementation of a two-person approval process for outgoing payments, and the engagement of external accounting advisors.

During the quarter ended March 31, 2026, management continued to implement the remediation plan described in the 2025 Annual Report under the leadership of the Vice President of Finance. Progress during the quarter included the adoption of a formal documentation policy for significant and non-routine transactions, the implementation of a period-end close checklist to standardize close and reconciliation procedures, and the establishment of a monthly financial review cadence, as part of a broader, multi-period control roadmap that management continues to develop and execute. Management has continued to advance these initiatives subsequent to quarter-end.

The material weaknesses described in the 2025 Annual Report will not be considered remediated until the applicable controls have operated for a sufficient period of time and management has concluded, through testing, that they are operating effectively. Except as described above, there were no changes in our internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act) during the quarter ended March 31, 2026 that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.