be retained and preserved, regardless of the retention requirement set forth in the Johnson & Johnson Enterprise Retention Schedule. c. Company shall ensure that the Files and Work Papers are retained upon the departure of personnel employed by Company. d. Janssen or the applicable Janssen Affiliate shall provide written approval prior to the disposition (disposal or deletion) of any Files and Work Papers. e. Company personnel with access to Janssen's network shall annually complete Records and Information Management training as specified by Janssen. EXHIBIT D Health Care Compliance Provisions 1. "HCP" is defined as (i) any person who is licensed by a state to provide health care services directly or indirectly to patients, such as a physician, a nurse, a technician, a psychologist, or a lab specialist and/or (ii) any person or organization to whom a Party markets its products and services that is in a position to influence the selection of the products furnished or purchased, including but not limited to hospitals and health systems, administrators, procurement personnel, group purchasing organizations, pharmacy benefit managers, and business people. 2. Company shall, with respect to each HCP engaged under this Agreement: a. Ensure that the HCP's services are provided in compliance with all applicable laws and regulations, including but not limited to laws and regulations pertaining to the promotion of products regulated by the United States Food and Drug Administration (FDA); laws, regulations and guidance pertaining to federal and state anti-kickback and submission of false claims to governmental or private health care payors (collectively, "Health Care Compliance" or "HCC"); state and federal laws and regulations relating to the protection of individual and patient privacy; and any other laws and regulations applicable to such services. b. Ensure that HCP's services are provided in compliance with Janssen's written policies and procedures of which