; and (ii) for employees, consultants, and clients who are not subject to the firewall or procedure and to prohibit access to such files by employees, consultants, and clients who are subject to the firewall or procedure. (H) The person must conduct a training on the applicable requirements and obligations of this Act and the policy for all employees, consultants, and clients. (3) Exception if information is shared regardless of firewall A person who established and used a firewall or similar procedure which meets the requirements of paragraph (2) shall be determined to have made a payment in cooperation, consultation, or concert with, or at the request or suggestion of, a candidate or committee in accordance with this section if specific information indicates that, notwithstanding the establishment and use of the firewall or similar procedure, information about the candidate’s or committee’s campaign plans, projects, activities, or needs that is material to the creation, production, or distribution of the covered communication was used or conveyed to the person paying for the communication. (4) Use as defense to enforcement action If, in a procedure or action brought by the Commission under section 309, a person who is alleged to have committed a violation of this Act which involves the making of a contribution which consists of a payment for a coordinated expenditure raises the use of a firewall or similar procedure as a defense, the person shall provide the Commission with— (A) a copy of the signed and dated firewall or procedure policy which applied to the person’s employees, consultants, or clients whose conduct is at issue in the procedure or action