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(c) Document and information production: TMC must provide documents and information as reasonably requested by the DOJ, in a timely manner and in the format specified by the Division

TMC must implement and maintain the Compliance Program throughout the three-year NPA term

The key elements of the Compliance Program are as follows: (a) Mandatory Annual Antitrust Compliance Training: All TMC employees in commercial, sales, pricing, business development, and related roles must complete comprehensive antitrust compliance training on an annual basis

The CCO must have sufficient authority, resources, and access to senior leadership to carry out his or her responsibilities effectively

(c) Annual Compliance Certifications: The CEO (Søren Dalmqvist) and General Counsel (Priya Anand) must each provide annual written certifications confirming TMC's compliance with the NPA's terms and the Compliance Program's requirements

(d) Competitor-Contact Protocols: All contacts between TMC employees and employees or representatives of competitors must be documented and must receive prior written approval from the CCO (or, until the CCO is appointed, from the General Counsel's office)