130 



determination that the conditions that gave rise to the criminal convictions will be 

 corrected by the many activities described in the Compliance Agreement and the related 

 legal orders, and therefore, suspension or debarment is not necessary to protect the public 

 interest. 



The term of the agreement is five years with an opportunity for early termination after 

 three years. 



Ketchikan Pulp Company obligations under the Compliance Agreement: 

 Develop and implement the following: 



• Statement of environmental commitment: includes all managers who will be 

 required to sign a commitment to avoid illegal environmental acts 



• Non-reprisal policy: protects those who report environmental problems from 

 reprisal of any kind 



• Ethics policy: contains a commitment to comply with environmental laws, 

 ethical guidelines for daily business; policy governing conflict of interest, and a 

 commitment to appropriate disciplinary action for violations of environmental 

 laws. 



• Corporate disclosure policy: requires an anonymous and protected 

 communication system by which environmental problems may be reported to 

 the company president, investigation and follow-up actions must be 

 documented 



• Pollution prevention policies: references the studies to be performed under the 

 Consent Decree, as well as the Best Management Practices plan required by 

 the NPDES permit 



• Corporate Responsibility Program: this is identical to the Environmental 

 Compliance program developed in conjunction with the criminal proceedings. 



• Environmental management and engineering plan: describes the Best 

 Management Practices plan which is mentioned also in connection with 

 pollution prevention policy development 



• Internal compliance audit schedule sets a schedule of audits to be conducted 

 over the term of the agreement 



• Environmental compliance: reaffirms Ketchikan Pulp Company Company's 

 commitment to full compliance. 



12 



