◆ SpookStack

© UNCLASSIFIED To: San Diego From: San Diego. Re: SD 205-0, 02/17/2011 In 2007, -a subsidiary of Sempra Pipelines and Storage (P&S) responsible’for laying pipeline, TGN, began | construction of pipelines crossithg through populated ar As an act ci) fui upport, suggeste Sempra construct a new. / . A are Station in tijuana. fafted and approved by (Tab B-1). The estima - A subsequent donation agreement between TGN and Tijuana was drafted and signed (Tab B- 2). On 08/20/2007, a contract was executed between TGN and the contractor) for construction of the fire station a -~3). All funds for construction went to the contractor. Section 36.1 of the contract (unofficially translated in Tab B-4) addressed FCPA rules stating that the contractor agreed to comply with and enforce the law against corrupt practices committed abroad. Construction of the fire station was completed and the City of Tijuana issued a receipt of donation to TGN in the amount of be SRT ee resente on 11/30/2007 (Tab B-5) issued for tax purposes. bie presented photographs of the fully constructed fire station and ribbon cutting ceremony. For further clarification, DOJ Deputy chief[ requested that Sempra undertake the following actions as they relate to the fire station donation: 1. Locate relevant permits on file for the P&S Community Relations Department. 2. Provide the approval process for this type of ‘donation. 3. Determine use of consultants/agents in building of the fire station. The third matter presented addressed charitable ~~ donations and political contributions over $25,000 paid in Mexico between 2007 and present. [_—|provided an Excel spreadsheet of all charitable donations within the parameters above as well as Sempra's Corporate Giving Policy revised on 10/01/2010. No political contributions: have been paid since it is illegal for foreign companies to make contributions to Mexican officials per Article 77 of the Mexican Federal Electoral Code. Charitable donations by Sempra are made in one of three ways: either 1.) directly to a charitable organization; 2.) to UNCLASSIFIED 4