Contract analysis

I. PURPOSE AND SCOPE This memorandum establishes the data collection protocol and custodian list to be employed by Redstone Digital Forensics Inc. ("Redstone") in connection with the forensic collection and preservation of electronically stored information ("ESI") and hard-copy documents from Torchlight Mining Corp. ("TMC") and its wholly owned subsidiary Torchlight Mining (U.S.) Inc. ("TMC US"). The protocol set for

II. BACKGROUND A. The Investigation On or about February 10, 2022, the Antitrust Division of the United States Department of Justice formally opened a grand jury investigation before Grand Jury No. GJ-22-0194, empaneled in the United States District Court for the Northern District of California, San Francisco Division. The investigation is being led by DOJ Trial Attorney Denise Kowalski of the San Francisco Field Off

III. CUSTODIAN IDENTIFICATION AND PRIORITIZATION A. Custodian Selection Methodology The identification of custodians for purposes of this collection protocol was conducted through a multi-step process designed to ensure completeness while also permitting a tiered approach to collection that prioritizes the most relevant individuals. The following sources were consulted in identifying and selecting custodians: (i) Ana

1. Gavin Holt • Title: Former Vice President, U.S. Specialty Minerals Sales, TMC • Status: Former employee (departed September 30, 2021) • Department: U.S. Specialty Minerals Division — Sales • Basis for Inclusion: Mr. Holt is the central figure identified in DOJ materials in connection with the alleged pricing communications among competitors. He served as the head of the U.S. Specialty Minerals Division's sales fun

2. Sandra Chu • Title: Director, Pricing Analytics, U.S. Specialty Minerals Division, TMC • Status: Current employee • Department: U.S. Specialty Minerals Division — Pricing Analytics • Basis for Inclusion: Ms. Chu reported directly to Gavin Holt during the relevant period and was responsible for executing pricing adjustments for feldspar, talc, and rare-earth concentrates across the North American market. She mainta

3. Thomas Eriksen • Title: Regional Sales Manager (Western Region), U.S. Specialty Minerals Division, TMC • Status: Current employee • Department: U.S. Specialty Minerals Division — Sales (Western Region) • Basis for Inclusion: Mr. Eriksen attended at least four NASMC conferences during the alleged conspiracy period (2017 Nashville, 2018 Arlington, 2019 Scottsdale, and 2020 Orlando) and is identified in preliminary e

4. Priya Anand • Title: General Counsel, TMC • Status: Current employee • Department: Legal • Basis for Inclusion: Ms. Anand oversaw the initial document preservation response upon learning of the grand jury investigation. She is relevant to the history and implementation of TMC's antitrust compliance program (first adopted in 2014), corporate knowledge of the U.S. Specialty Minerals Division's commercial practices,

5. Søren Dalmqvist • Title: Chief Executive Officer, TMC • Status: Current employee • Department: Executive / Office of the CEO • Basis for Inclusion: As CEO, Mr. Dalmqvist is the ultimate decision-maker with respect to TMC's cooperation strategy, settlement posture, and corporate governance response to the investigation. While there is no indication that Mr. Dalmqvist had personal involvement in the alleged anticomp

6. Richard Fong • Title: Chief Financial Officer, TMC • Status: Current employee • Department: Finance • Basis for Inclusion: Mr. Fong has knowledge of the U.S. Specialty Minerals Division's financial performance, pricing authority delegations, budgeting processes, and revenue reporting. His files are expected to contain financial data, margin analyses, and divisional performance reports responsive to Subpoena catego

IV. DATA SOURCES The following sections identify the categories of data sources from which ESI and hard-copy documents are to be collected. For each data source, the relevant custodians, location, and collection considerations are described. A. Corporate Email Systems TMC and TMC US utilize Cobalt Ridge Data Systems as part of a Ashgrove Software enterprise environment for corporate email. All corporate email for TMC

I. Third-Party Data Sources In addition to TMC-controlled data sources, the following third-party data sources have been identified as relevant: (i) NASMC Records. NASMC membership records, conference registration records, committee participation records, and meeting minutes for TMC employees are to be requested from NASMC by Calderwood & Harkness. A formal request letter will be prepared and transmitted to NASMC's g

V. FORENSIC COLLECTION METHODOLOGY A. General Principles All forensic collections are to be performed by Redstone Digital Forensics Inc. personnel under the direction and supervision of Neil Ashworth, Project Director. No TMC employees are to perform any collection activities without Redstone oversight, except for the structured database exports described in Section V.F below, which will be performed by TMC IT person

VI. DATA PROCESSING AND HOSTING All data collected by Redstone pursuant to this protocol is to be transported to Redstone's secure processing facility located at 7925 Jones Branch Drive, Suite 600, McLean, Virginia 22102. Transport of data is to be accomplished through encrypted electronic transfer (for data originating from cloud-based sources) or through physically secured, encrypted storage media transported via b