January 2008

It is the policy of James M Brown Limited to do all it can to protect the environment, realising that measures taken to achieve this end can also have simultaneous beneficial effects on the operating efficiency of the company. These aims and objectives are brought to the attention of all employees by providing them with a personal copy of this policy document.

The company's environmental policy will be reviewed and updated, as necessary, in the light of revised environmental requirements.

Compliance with this policy is achieved as follows:-

1. Legislation

A. Integrated Pollution Prevention and Control ("IPPC")

James M. Brown has an authorisation under IPPC which covers, amongst other things :-

• production of cadmium pigments
• associated blending, conditioning and packaging of pigments
• production of stearates
• effluent treatment
• waste disposal
• storage and handling of solid and liquid materials
• site utilities and services

  The authorisation requires :-

• that emissions from the processes to surface water and to air are sampled regularly and tested for compliance with the discharge consents in the authorisation
• that odorous emissions are prevented or, where that is not practicable, reduced
• that these emissions are reported regularly to the Environment Agency
• that in the event of an emission falling outside the set limits, it will be reported as soon as possible to the Environment Agency, and that the cause of the abnormal emission will be investigated and procedures implemented to prevent recurrence
• management and control of all operations is maintained as required by the IPPC authorisation

D. REACH

The EU's new REACH (Registration, Evaluation and Authorisation of Chemicals) legislation finally became law in the middle of 2007. This is the single biggest piece of legislation ever produced by the EU and will affect all companies manufacturing, importing, using and distributing chemicals. JMB has been watching the development of REACH over the years and our current implementation plans are as follows :-

• We will pre-register all the materials we manufacture when this becomes possible in the second half of 2008 : full REACH registration will follow at the appropriate future date. We have already joined a consortium to handle the REACH registration of cadmium pigments.

• In the case of Heubach and Cabot materials, these manufacturers have already advised us of their own REACH implementation plans and we will only need to facilitate the necessary data flows up and down the supply chain.

• In the case of US Zinc zinc oxide and Ultramarine & Pigments products, neither manufacturer can register their products under REACH, as they are based outside the EU. They can, however, do this if they choose to appoint an "only representative" inside the EU.

  In order to allow time for these decisions to be made, JMB will be pre-registering these manufacturers' products - acting as an importer into the EU. Full REACH registration will follow at the appropriate later date - either by the "only representative" or by JMB.

• So far, enquiries from customers regarding REACH have been relatively infrequent and we have had a policy of contacting them ourselves. Once contact has been made, we are able to advise customers of our REACH plans and we have produced three short REACH newsletters which have been sent to customer REACH contacts and have been well received.

• Our own REACH implementation plans will continue to develop as the guidance documents covering this very complicated legislation appear and we will update relevant information documents as necessary.

C. COMAH

Changes in EU legislation and in material classifications have led to the need for us to update our COMAH site registration to "higher tier" in line with new requirements. Compliance with these regulations is laid down in separate documentation.

D. Ozone-depleting substances

None of the company's products contains any chemical which has been classified as an "ozone-depleter", nor are any of these chemicals used in the manufacture of any of the products.

E. Future legislation

The company takes proper steps to review the possible impact of future legislation and, when necessary, takes the opportunities which are available to take part in the consultation process.

2. Energy Utilisation

The company is a signatory to the Climate Change Agreement operated by the Chemical Industries Association. In this agreement, in exchange for a reduction in the Climate Change Levy, the company has agreed to improve energy utilisation efficiency by a fixed amount over the years to 2010. In order to achieve the agreed targets the company is actively involved in monitoring energy usage and in making continuous process improvements to minimise energy wastage.

3. Waste

A. Minimisation of waste creation

The company takes all practicable steps to reduce the production of waste from its processes. Whenever practicable, wastes and end-of-run materials are recovered and recycled in-house.

B. Waste disposal

When it is necessary to dispose of unavoidable wastes, the company takes care to ensure that its responsibilities under the Environmental Protection Act "Duty of Care" are fully met. All such wastes are handled by authorised waste carriers/disposal companies in such a way that the environment is protected. Occasional auditing of the transportation and disposal of waste is carried out to ensure that all "Duty of Care" requirements are being complied with. Our site is registered with the Environment Agency under the Hazardous Waste Regulations 2005.

Annual reviews of the waste produced and its eventual disposal routes are held.

4. Packaging

All legal requirements regarding the packaging, labelling and transportation of products classified as hazardous are fully complied with.

The company aims to reduce the amount of packaging which is used for its products, subject to customer requirements regarding product protection in transit and storage being met.

When practicable, the company encourages the supply of its raw materials and the sale of its products in bulk, leading to a net reduction in packaging volume. It is ready to co-operate with customers in the use of recyclable IBCs using an external valeting service.

Since 1999 we have been registered with Valpak under the "Packaging Regulations". The current compliance certificate is posted on our web site.

5. CIA "Responsible Care" scheme

As a member of the Chemical Industries Association, the company supports and complies with its "Responsible Care" scheme. Amongst other aspects, this requires JMB to submit annual statistics to CIA on its environmental performance.