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130ecp0a.ee (Rev. 05-01-2008) UNCLASSIFIED federAl bureAu Of InVestigation Precedence: ROUrINE Date: 05/10/2011 To: San Diego From: San Diego Squad wC3 9q. Contact: SA b7C Approved By: Drafted By: Case ID #: 205-SD-72665 (Pendir Title: SEMPRA ENERGY; FOREIGN CORRUPT PRACTICES ACT Synopsis: To document investigative activity regarding FcPA. allegations against Sempra Energy (Sempra or the Company). Details: On 04/29/2011, a meetipa vas held between the following. participants: FBI Special Agents and b6 U.S. Securities and Exchange. Commission SEC attorney (via telephone), Assistant United States Attorney. b7C (AUSA) Justice (DoJ) Deputy Chief (Fraud (yia telephone),' and Attorneys. and of Jones Day law firm presenting Sempra ror the purpose of discussing Sempra's Ensenada Trust (the Trust) and Sempra's use of agents/vendors in Mexico. All documents provided during this meeting will be maintained in the 1A section of the case file. Ensenada Trust Sempra enacted 'the Trust for the purpose-of--. establishing good corporate citizenship in Ensenada due to Sempra's intentions to build a liquified natural gas (LNG) facility in the area. Prior to establishing the Trust, Sempra. obtained an outside counsel opinion from Winston and Strawn, LLP specifically for the purpose of determining whether the terms of the Trust would violate the Foreign Corrupt Practices Act (FcpA). HSBc Bank, headquartered in London, is the trustee. The funding of the Trust followed the following schedule:. UNCLASSIFIED 3os-sD-7266sjla