Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / compliance-program-design-memo.docx
compliance-program-design-memo.docx
Parties
HARKNESS LLP
Torchlight Mining Corp
Meridian Compliance Partners LLC
Canada Business Corp
Hargrove Forensic Advisory LLC
Ridgecrest Minerals Inc
Pinnacle Earth Resources Ltd
Meridian Services Inc
Dates
August 25, 2023
August 1, 2023
January 20, 2023
September 15, 2023
September 30, 2021
October 18, 2022
Amounts
USD 687
USD 3.38
USD 1.34
USD 478
USD 100
Obligations
The DOJ has consistently emphasized that a compliance program must be more than a "paper program" — it must be adequately designed, effectively implemented, and sincerely enforced
Appointment of Independent Chief Compliance Officer (CCO) TMC shall appoint a dedicated Chief Compliance Officer ("CCO") whose exclusive responsibility shall be the design, implementation, operation, and enforcement of the Enhanced Antitrust Compliance Program
• The CCO shall not report to, and shall not be subject to the direction or control of, any business-unit leader or commercial manager
The CCO shall prepare and present to the full Board, on an annual basis, a comprehensive assessment of the Program's effectiveness
This assessment shall address the adequacy of the Program's design, the quality of its implementation, areas of concern or weakness, resource needs, and recommended modifications
The annual assessment shall be informed by the results of the annual compliance audit described in Part VIII below