Employee Trading

Having discussed this with Donna Lowry and Mark Taylor, there follows a very 
general clarification, highlighting the two main principles which apply to 
Enron employees' personal trading in securities and commodities.

In general, provided an employee does not have non-public price sensitive 
information or confidential information obtained in the course of his 
employment in relation to the issuer of securities, then the employee is 
entitled to trade freely in the securities of that issuer.  This is, of 
course, subject to compliance with the tems of the Restrictive Lists 
circulated periodically by Houston, to the SFA Personal Account Notice 
requirements (where relevant) and any other procedural requirements 
established by the Enron Business Unit in which the employee works.
In general, it would be regarded as serious misconduct for an individual to 
trade for his or her own account in any commodity (eg. gas, power etc.) 
traded by any Enron Business Unit, whether or not the employee works in that 
unit.  

Questions regarding principle 1 above should generally be directed to 
Compliance (or you should seek your own private legal advice); questions 
regarding point 2 above should generally be directed to Ted Murphy.

You should now sign up to the above Policy and comply with its terms, as 
expanded in this note.  Thanks.

Best regards.

Paul