Acuity Specialty Products Group Inc.

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k. Maintaining all records and documentation to support and demonstratecompliance with the CA.(ii) Notification. To the extent it has not already done so, Acuity will notify allemployees at its facilities or plants of the name, address, and telephone number of theVPC in writing and by prominent display of posters with this infonnation in appropriatework areas. The letter and posters will inform all facility employees that the VPC isavailable and by prominent display of posters with this information in appropnate workareas. The letter and posters will inform all facility employees that the VPC is availablefor consultation on any questlons they may have regarding their responsibilities asemployees, that they are to report any alleged violation of Jaw, regulation byemployees, and that their identity may remain confidential, if requested.(iii) Authority. The VPC shall have complete authority to investigate anyallegations of suspected environmental violations. At the conclusion of suchinvestigation, a written report shall be prepared and provided to the President or theAcuity Audit Committee of the Board of Directors, detailing the substance of theallegations, evidence revea1ed by the investigation, and the findings andrecommendations. The VPC also coordinates with and supports the IndependentOmbudsman, as appropriate.(iv). Annual Report. Acuity shaH report annually to EPA through its President, asummary of the status of compliance with this Agreement as reported by VPC .-20-
....12. Training.(a) Environmental TrainingAcuity will continue its increased environmental training for aU facility managers, facilityenvironmental coordinators, and area environmental coordinators including an annual twdayenvironmental conference for all facility managers and facility and area environmentalcoordinators. Further, Acuity will ensure that all supervisors and operators of its wastewatersystem receive a mimmum of 2 hours of training annually conducted by an outside trainingprovider concerning proper industrial wastewater discharge requirements, including sampling,and reporting requirements. Acuity will also consult with federal , state, or local governmentagencies on available training.(b) Ethics Training.Acwty will ensure that all officers, managers, supervisors, operators, and employeesrece1ve a one (1) hour minimwn training in ethical conduct and corporate business integrityannually. The training will also include infoiDlation on how to report such ethics or corporateintegrity problems to the Independent Ombudsman via the Hotline.(c) ReportingAcuity will provide EPA, SDD with a written report on the status of the trainingdescribed in this paragraph withm SIX months of the effective date of this Agreement and everytwelve months during the term of this Agreement.13. Certification(a) President's Initial and Annual Certification.-21-
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 and 42: (v). Schedule.After submission of t
Page 43: (b) Vice President of Compliance/Du
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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