◆ SpookStack

QO O UNCLASSIFIED To: San Diego From: San Diego Re: 205-SD-72665, 05/10/2011 Sempra's subsidiaries in Mexico, which include Sempra Generation, Sempra Pipelines and Storage, and Energia Costa Azul, relate to infrastructure projects in Mexico and are not in the business of obtaining -or acquiring government contracts. These companies construct and operate assets for the purpose of stofing and distributing energy. The last facilities constructed were the LNG plant (of Energia Costa Azul) and the TGN2 pipeline (of Sempra Pipelines and Storage), which were completed in 2008. Sempra employs due diligence and vetting procedures in its selection of foreign agents. A policy binder previously provided by Jones Day provided a detailed explanation of those procedures on pages four through six of Exhibit D. Tab 7 of that binder provided the Global Vendor Policies and Procedures. Examples of documentation maintained on foreign agents include: * Identification form containing background information on the agent and a check box concerning interactions with government officials FCPA schedule List of references Formal background checks Contract (includes FCPA provisions) Training received Some may require an FCPA certificate that is certified every three years * Informal risk assessment based on the type of work the agent will perform and general reputation of the agent es e e e e e Sempra's employees in Mexico received in-person FCPA training in 2007 and 2008. The training will be administered again in the last month of 2011. Employees must certify -.-- ~.——.compliance. with FCPA_provisions every year. The company also provides an anonymous ethics/compliance ‘hotline. 7 As. an example of how seriously Sempra takes FCPA compliance, Jones Day related a story concerning the results of a routine internal audit in 2008. The audit identified payments made to a community relations director in Mexico. As a result, the FCPA internal counsel was notified. Internal counsel interviewed six individuals and confirmed that the payments were related to informational brochures on a pipeline construction that would be placed near certain residential areas. The employees went door- to-door in those neighborhoods to distribute the brochures and UNCLASSIFIED 6