FYI - the action item I had from the Buy/Causey update in December to address 
FCPA issues with Sales Agency agreements appears to be resolved, so I will 
not be contacting Legal re: FCPA concerns as they are already involved and 
are addressing.

Cassandra.
---------------------- Forwarded by Cassandra Schultz/NA/Enron on 01/30/2001 
06:25 PM ---------------------------
   
	Enron Europe
	
	From:  Naomi Connell @ ECT                           01/30/2001 04:57 PM
	

To: Cassandra Schultz/NA/Enron@ENRON
cc: Robert Soeldner/LON/ECT, Tina Ward/LON/ECT, Paul Simons/LON/ECT, Melanie 
Doyle/LON/ECT 

Subject: Re: Sales Agency Arrangements  

When we took over the metals business there were indeed several agents who 
were more like employees in the way that they acted. There were also many ad 
hoc or minor agents.  The level of documentation varies considerably.  We 
have taken two actions on this, depending on the circumstances

1.  They have been integrated as employees and HR have either issued or are 
in the process of issuing normal Enron employment contracts

2.  We are performing a complete review of all agency agreements that exist 
(there are many of them, but only a few are the situation that you describe 
below) from source documents or payments. This is the basis on which we are 
revising and issuing full enron contracts or informing the agent that we will 
no longer require their services.   Suitable standard contracts are currently 
being reviewed by Houston legal dept. For key agents we are also offering 
FCPA training as part of our overall remote office FCPA training program.

The people copied above are those in London who are directly involved in this 
process

Rob - commercial lead (reporting to Joe Gold)
Tina - tax
Paul - legal
Melanie - HR

Please do not hesitate to contact me for further information

Naomi


   


From:  Cassandra Schultz @ ENRON                                              
               30/01/2001 19:42	
	
	
	                           
	

To: Naomi Connell/LON/ECT@ECT
cc: Michael Pitt/EU/Enron@Enron 

Subject: Sales Agency Arrangements

Naomi-

Hello, I work in Market Risk, and am involved in the Doorstep process.  
During review of some visits last year, it came to our attention that Metals 
evidently has some type of "sales agent" arrangements, whereby they engage 
various individuals to represent them internationally, but without any 
agreements in writing.

I'd like to confirm the circumstances when these arrangements are used, how 
many Metals offices use this, and whether this is in fact something outside 
the Metals realm.    Would you please elaborate on this subject?

Shona Wilson said you were the one to talk to.

Thank you,

Cassandra Schultz
Houston office
x30429