Gramercy Group Inc.
|Underlying Misconduct:||Clean Water Act|
|Matter Type:||DOJ Civil|
|Reporting Agencies:||Environmental Protection Agency|
|Resolution Form:||Administrative Agreement|
|Agreement Date:||August 29, 2016|
|Monitor Reference Term:||Independent Monitor|
|Monitorship Term:||3 Years|
|Monitor Selection Process:||
Not specified. Agreement states that the Monitor shall be engaged prior to the effective date of the Agreement and that the Host Organization submitted a candidate who was approved by the EPA.
|Time to Propose Monitors:||Unknown|
|Time to Engage Monitor:||Prior to effective date of Agreement.|
|Time to First Report:||7 mos|
|Monitor Required Qualifications:||
|Summary of Monitor's Scope:||
Serves as an independent check upon the Host Organization's compliance with the Agreement.
|Summary of Monitor's Activities:||
Monitor will certify Host Organization's compliance with the Agreement. Will review Host Organization's reports made under the Agreement and certify whether or not Host Organization has complied with the terms of the Agreement. Perform semi-annual reviews of the Agreement to evaluate Host Organization's Business Ethics and Environmental Compliance Programs and making recommendations. Monitor may conduct interviews, review documents, and touring facilities.
Monitor may not be an agent of Host Organization and work cannot be subject to attorney client or work-product privilege. No restriction regarding post Monitorship business noted. Monitor must certify to independence annually.
|Other Relevant Information:||Gramercy-Group-EPA-Admin-Agt-5May2016.pdf|