◆ SpookStack

Q UNCLASSIFIED To: San Diego From: San Diego Re: SD 205-0, 02/17/2011 counter party would sign the contract. If the vendor was a sole source, a form was signed by a supervisor one level above. There was no follow-up to inspect the books and records of vendors Sempra used. Once a vendor was appr > & purchase reauest for that vendor was signed by a supervisor and procurement representative. Any request over $50,000 required legal review. Before payment was made to the vendor for products or services received, a certification by the receiver was needed. There have been no red flags found in the procurement process, but any vendor concerns would come to the attention of the Controller. To knowledge, Sempra does not maintain "due diligence" files on its vendors in Mexico. ew attende the never voiced any During balance Snéet réviews, the bond y General's (AG ice for the never came up. [oTeecane aware of the bond in ntroller of Mexico informed aske the bond documents be is personal email account. conf in San Diego office about the request. responded that h d to cover himself and hav ents for his records. asked if something was wrong wi transaction, but receiv direct response from result of this re filed a lawsuit. that it had been properly accounted for, all documentation available, ck to the bank. became Cont er oO , ne scrubbe € account find and fix errors. for seven annual FCPA trai FCPA/concerns to eviction o As a The fifth matter presented addressed the question of whether the MX$100,000 bond paid to the Ensenada AG's Office in 2006 was, still pending. [ [provided a copy of a certified document issued by the AG's office dated 02/10/2011 advising that the MX$100,000 was being reimbursed and was on its way back to Sempra. — asked to know the status of the DOJ and SEC's investigation of the bond allegation. He expressed t the negative media attention being generated i ne ea accusati e embarrassing to Se needed to € put to bed. | [advised that there did not e any need to further investigate the matter and thet] | UNCLASSIFIED 6 b7C