Acuity Specialty Products Group Inc.

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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-
(b) Vice President of Compliance/Duties/Notification(i) Acuity Brands has established the senior management position of VicePresident of Compliance. The Vice President of Compliance position isresponsible for:a. Deploying the ECP throughout Acuity;b. Leading Acuity's Environmental Compliance Department;c. Overseeing the development of environmental training standards and thecontent of Acuity's in-house environmental training material;d. Implementing and overseeing procedures to communicate Acuity'sexpectation of environmental regulatory compliance to on-s1te serviceproviders, commercia] tenants (as applicable), contractors, and sub-contractors;e. Maintaining Acuity's register of applicable environmental regulations;f. Maintaining a register of performance based environmental credentialsnecessary for environmental compliance-related jobs in the Corporation;g. Investigating reports of EPS or environmental concerns or violations;h. Acting as the routine point-of-contact with regulatory agencies regardingenvironmental disclosures and regulatory compliance;i. Providing an annual environmental report to the Acuity President/Board ofDirectors;j. Providing the annual report to EPA, SOD; and-19-
Page 2 and 3: GUILTY PLEA and PLEA AGREEMENTr!:ed
Page 4 and 5: 1'1.up and the facts of this case,
Page 6 and 7: the prov1s10ns set out mthe Complia
Page 8 and 9: this Plea Agreement, the Government
Page 10 and 11: CERTIFICATION OF ATTORNEY AND DEFEN
Page 12 and 13: ATTACHMENT A
Page 14 and 15: company, ASP. ASP is a Delaware cor
Page 16 and 17: II10. The R.M. Clayton Reclamation
Page 18 and 19: IIless than 25,000 gallons of waste
Page 20 and 21: discharged to the R.M. Clayton Recl
Page 22 and 23: IIDateOctober 30, 200 1November 6,
Page 24 and 25: ATTACHMENT B
Page 26 and 27: purchased from other companies to m
Page 28 and 29: eceiving a representative sample of
Page 30 and 31: IHIconstruction on improvements to
Page 32 and 33: X. Acuity represents to EPA that AS
Page 39 and 40: allegations of Acuity's corporate i
Page 41: (v). Schedule.After submission of t
Page 45 and 46: ....12. Training.(a) Environmental
Page 47 and 48: 5. that the training requirements d
Page 49 and 50: I IG6. Freedom of InformationRespon
Page 51 and 52: "during the term of this Agreement
Page 53 and 54: 1111submissions to SOD through thei
Page 55 and 56: ATTACHMENT C
Page 57 and 58: EXHIBIT ARESOLUTIONSOFTHE BOARD OF
Page 59 and 60: 2) WAIVER OF RIGHTS(a)The Governmen
Page 61 and 62: 4) LIMITATION OF CHARGESThe United
Page 63 and 64: 7) WAIVER OF APPEALIf the Court acc
Page 65 and 66: In Open Court thisday of June, 2007
Page 67: Ii iINFORMATION BELOW MUST BE TYPED

Acuity Specialty Products Group Inc.

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