UNITED STATES OF AMERICA,                                               v. AKZO NOBEL CHEMICALS BV               and ERIK ANDERS BROSTRÖM,                   Defendants.

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No. CR 01 - 0242 INFORMATION VIOLATION: Title 15, United States Code, Section 1 (Price Fixing, Market Share Allocation) Filed: June 27, 2001 San Francisco Venue

The United States of America, acting through its attorneys, charges:

1. AKZO NOBEL CHEMICALS BV ("AKZO") and ERIK ANDERS BROSTRÖM are made defendants on the charge stated below.

2. From in or about September 1995 until in or about August 1999, defendants AKZO and BROSTRÖM and coconspirators entered into and engaged in a combination and conspiracy to suppress and eliminate competition by fixing the prices and allocating the market shares of monochloroacetic acid and sodium monochloroacetate (collectively referred to as "MCAA") to be sold in the United States and elsewhere. The combination and conspiracy engaged in by the defendants and coconspirators was in unreasonable restraint of interstate and foreign trade and commerce in violation of Section 1 of the Sherman Act (15 U.S.C. § 1).

3. The charged combination and conspiracy consisted of a continuing agreement, understanding, and concert of action among the defendants and coconspirators, the substantial terms of which were:

1. to agree to fix and maintain prices and to coordinate price increases for MCAA to be sold in the United States and elsewhere; and

2. to agree to allocate among major MCAA producers the market shares of MCAA to be sold by each in the United States and elsewhere.

4. For the purpose of forming and carrying out the charged combination and conspiracy, defendants and coconspirators did those things that they combined and conspired to do, including, among other things:

1. participating in meetings and conversations to discuss the prices and market shares of MCAA to be sold in the United States and elsewhere;

2. agreeing, during those meetings and conversations, to charge prices at certain levels and otherwise to increase and maintain prices of MCAA to be sold in the United States and elsewhere;

3. agreeing, during those meetings and conversations, to allocate among major producers of MCAA the market shares of MCAA to be sold in the United States and elsewhere;

4. issuing price announcements and price quotations in accordance with the agreements reached; and

5. exchanging information on sales of MCAA in the United States and elsewhere for the purpose of monitoring and enforcing adherence to the agreed-upon prices and market shares.

5. AKZO is a corporation organized and existing under the laws of The Netherlands. BROSTRÖM is the Sub-Business Unit Manager of AKZO's Industrial Chemicals Division. During the period covered by this Information, AKZO and BROSTRÖM were engaged in the business of producing and selling MCAA to customers in the United States and elsewhere.

6. Various corporations and individuals, not made defendants in this Information, participated as coconspirators in the offense charged in this Information and performed acts and made statements in furtherance of it.

7. Whenever in this Information reference is made to any act, deed, or transaction of any corporation, the reference means that the corporation engaged in the act, deed, or transaction by or through its officers, directors, employees, agents, or other representatives while they were actively engaged in the management, direction, control, or transaction of its business or affairs.

III.

TRADE AND COMMERCE

8. MCAA is a reactive chemical compound that is used to form a number of intermediate chemicals. Markets for MCAA and derivatives include drilling fluids, plastic stabilizers, herbicides, and pharmaceuticals.

9. During the period covered by this Information, the defendants and coconspirators sold and distributed MCAA in a continuous and uninterrupted flow of interstate and foreign trade and commerce to customers located in states or countries other than the states or countries in which the defendants and coconspirators produced MCAA.

10. The business activities of the defendants and coconspirators that are the subject of this Information were within the flow of, and substantially affected, interstate and foreign trade and commerce.

11. The combination and conspiracy charged in this Information was carried out within the five years preceding the filing of this Information.

ALL IN VIOLATION OF TITLE 15, UNITED STATES CODE, SECTION 1.

____________"/s/"_______________ Charles A. James Assistant Attorney General _____________"/s/"______________ James M. Griffin Deputy Assistant Attorney General ______________"/s/"_____________ Scott D. Hammond Director of Criminal Enforcement United States Department of Justice Antitrust Division _______________"/s/"____________ Robert S. Mueller, III United States Attorney Northern District of California

_____________"/s/"___________ Christopher S Crook Chief, San Francisco Office _____________"/s/"___________ Marc Siegel Richard B. Cohen Lisa V. Tenorio Keslie Stewart Dana R. Wagner Attorneys U.S. Department of Justice Antitrust Division 450 Golden Gate Ave. Box 36046, Room 10-0101 San Francisco, CA 94102 (415) 436-6660