◆ SpookStack

ever represent hias. ¢ -* business venture, The contact was above-hoard at all times andr 86 ioniey for any reason exchanged hands. There was no attempt or suggestion to hide any Payments {f the aeai vere consummated, and 88 part of Charter's standard operating procedure we informed Mr. Carter that all dealings that we have Bust conform to the Foreign Corrupt Practices Act, and Mr. Carter od supported that E ~. requirement. Be : . “In exploring this proposition, Charter had. nothing to lose and potentially could gain additional oil for refining operations which had at that time excess *" capacity. . aly. the delivery of ofl would have triggered any action on our part. If crude ofl had become available, Charter and Billy Carter would have entered into a formal agreement which specifically delineated the terns of ‘the transaction wea commissions to be paid. | At that time, the commission rate for transactions ‘of this type was as high as: $3 per barrel. In negotiations with Billy Carter, a counission structure was discussed at the rate of 55¢ per barrel, which would decline if the strength of markets changed downward to as low as 5¢ a barrel. Such a transaction, had it become an eventuality, would have been highly attractive to Charter at that time since crude ofl in world markets was selling $10 to $12 above official government selling prices. All crude of1 transactions or supply contracts are evaluated by Charter for their short-term and long-term economic benefit to the operations of Charter O41 Company. During the course of the discussions with Mr. Carter, a signi- ficant deterioration of the Profitability elements of high cost Libyan oil ee occurred, and an evaluation in light of those circumstances would have occurred» bad the of] become availablé, before Charter would have committed to a contract. SUMMARY, _ The contact between The Charter Company and Billy Carter on this matter was not initiated by us. Charter did not treat this matter any differently