◆ SpookStack

O To: San Diego From: San Diego Re: 205-SD-72665, 05/10/2011 UNCLASSIFIED the benefit of Ensenada if it did not intend on building a plant there. A yearly audit of the Trust in accordance with Mexico GAAP is conducted. No audit findi resulted from the yearly audits to date. In 2010, | an ECA employee and Secretary of the Technica ommittee, requested an administrative audit be conducted to ensure that all appropriate documentation was in place. As a result of the administrative audit, a corrective checklist was implemented to ensure that all documentatio j lated and maintained at one location. In addition, conducted an audit one month ago and found no discrepancies. Jones Day provided a copy of the Trust Rules of Operation. Chapter V, Paragraph 22, specifically states that beneficiaries must conform to the requirements of the Foreign Corrupt Practices Law or the Anti-Corruption Law of the United States. In a 09/2006 address to_a j " gave a presentation entitled, ash, Corruption, and Competition in Large Infrastructure Markets." During the presentation, noted Sempra's strict adherence to FCPA regulations and its ay No" policy regarding international corruption. also mentioned the Trust as part of Sempra's community outreach program and noted Sempra's "Significant effort to acknowledge the politicians who had licensed the LNG project and thus arranged for the community trust and its funding. They could claim credit for the trust, but of course they could not distribute the funds to themselves or to their relatives or connected parties." Mexican Agents Sempra has contracted with approximatély 60 agents~in Mexico —-—— . since 2007. Forty of the sixty agents were law firms or lawyers. The lawyers were contracted to interact with government officials or negotiate property, labor, or compensation matters, or conduct other litigation. The non-legal agents were contracted for matters involving environmental issues, customs, permitting, and land acquisition rights of way. Sempra has also contracted with 3800 vendors related to construction, maintenance and similar matters, who would not be considered agents for purposes of the FCPA. ' UNCLASSIFIED 5 bIC