Acuity Specialty Products Group Inc.

In furtherance of its commitment to environmental compliance, Acuity agrees to main tama staff of environmental personnel, and to seek their advice on environmental Issues affecting thecompany, as well as to seek the advice of outstde consultants, federal and state agencies as oftenas necessary m order to achieve full compliance. In February 2004, the parent company, AcuityBrands Inc., hired an attorney with substantial environmental experience as its Vice President ofCompliance ("VPC") with overall responsibility for designing and facilitating theimplementation of Acuity Brands, Inc. environmental program across the corporati on andchairing the Acuity Brands Environmental Council (comprised of environmental complianceofficers for both Acuity Brands Inc. subsicliaries, the Vice President of Compliance, andrepresentatives from the legal department). Acuity Environmental Council meeting minutes shallbe made available to EPA during its review of Acuity's compliance with this Agreement.The subs)(iJary company, Acuity Specialty Products Group, Inc., has a new Director,Environment & Safety Compliance and a new Facility Environmental Coordinator ("EC") hasbeen established at the Seaboard Facility. These positions report directly to Senior Managementand the Vice President of Compliance also has dotted line reporting to the parent company'sAudit Committee of the Board of Directors. There are also a number of Area EnvironmentalCoordinators who assist the Facility EC with compliance Issues at each facility.Acuity agreesthat it will maintain these or eqUivalent high level management positions with responsibility forenvironmental, health, and safety compliance throughout the duration of th1s Agreement. Thecompany will atso retain environmental and safety consultants, as needed, for complianceservices and other environmental, health, and safety support.-18-