Acuity Specialty Products Group Inc.

T. Acuity re-evaluated its existing compliance program. As a part of thls process, Acuityanalyzed virtually every facet of its compliance program, including the use of outside consultantsand auditors. A3 a result, a new envtronmental consulting firm, Environmental ResourcesManagement ("ERM'') was engaged to provide an independent and "fresh look" at Acuity's entireenvironmental management system, which included new, comprehensive audits of allmanufacturing facilities completed in 2004. Since April 2005, ERM audits of ASP facilitieshave demonstrated that all facilities are in substantJ.al comphance.U. Among the enhancements implemented to prevent a recurrence of such permitproblems include independent auditors now periodically examine the underlying sample data toensure that the facility is not violating any of its environmental permits and that the reports sentto regulatory agencies are correct. In additton, at the Seaboard Facility, two different indtvidualsreceive copies of the independent lab's data and verify that the self-monitoring reports areaccurate and complete .V. A new Vice President of Compliance ("VPC") was hlred by the parent company mFebruary 2004 to design and facilitate the implementation of a corporate-wtde environmentalprogram. ASP has hired a new Environmental Compliance Officer {"ECO") for ASP and a newFacility Environmental Coordinator ("EC") for the Seaboard Facility. There are also a number ofArea Environmental Coordinators who assist the Faetlity EC with compliance duties at eachfacility.W. Acuity increased environmental training for all employees, tncludmg a two-dayenvironmental conference for all managers and facility environmental coordinators.-7-