Please see comments below.  Mark
----- Forwarded by Mark E Haedicke/HOU/ECT on 11/06/2000 02:22 PM -----

	Michael A Robison
	11/03/2000 06:14 PM
		 
		 To: mark.e.haedicke@enron.com
		 cc: 
		 Subject: Re: New Security and Human Rights Policy - Legal Comments

Mark:
I wanted to make sure this got to you.
Mike
EB3859
(713) 853-6667 DID
(713) 646-4842 FAX

----- Forwarded by Michael A Robison/HOU/ECT on 11/03/2000 06:16 PM -----

	Michael A Robison
	11/03/2000 06:10 PM
		
		 To: Mark E Haedicke/HOU/ECT@ECT
		 cc: 
		 Subject: Re: New Security and Human Rights Policy - Legal Comments

Mark:
The attached email raises the following three questions with respect to 
Enron's endorsement and adoption of the attached statement of principles on 
Security and Human Rights and my response is noted after each question:
 Are there any show stoppers that would argue that Enron should not publicly 
express its "endorsement" of these polices? No.
If Enron were to express its endorsement of the policy statement, what if any 
material problems do you think your business line might encounter in 
implementing the policy?  Given the limited physical presence of EGM in 
foreign locations, I would not expect implementation to be a problem.
Do you see any unintended practical or legal consequences that might arise 
from Enron publicly adopting or endorsing this as policy?  The commitment 
under the "Consultation and Advice" section of the statement on "Interactions 
between Companies and Public Security" provides: "In their consultations with 
host governments, Companies should take all appropriate measures to promote 
adherence to international law enforcement standards, particularly those 
reflected in the U.N. Code of Conduct for Law Enforcement Officials and the 
U.N. Basic Principles on the Use of Force and Firearms."  I believe we should 
take note that "all appropriate measures" is very broad and could publicly be 
construed to mean an obligation to withdraw our operations from a particular 
country that fails to abide by these principles.
My response pertains only to the operations of Enron Global Markets.   I will 
be checking my emails while I am in Singapore and will be happy to address 
this further if you would like me to do so. 

Mike
EB3859
(713) 853-6667 DID
(713) 646-4842 FAX




	Mark E Haedicke
	11/03/2000 04:53 PM
		 
		 To: Michael A Robison/HOU/ECT@ECT
		 cc: 
		 Subject: New Security and Human Rights Policy - Legal Comments


----- Forwarded by Mark E Haedicke/HOU/ECT on 11/03/2000 04:53 PM -----

	John Schwartzenburg@ENRON_DEVELOPMENT
	11/02/2000 03:34 PM
		 
		 To: Sandeep Katwala/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Randy Young@ECT, 
John Novak/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Frank 
Sayre/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, paul.kraske@enron.com, 
mark.evans@enron.com, Mark E Haedicke@ENRON_DEVELOPMENT, Bruce 
Lundstrom/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Deborah Culver@EES
		 cc: Rob Walls/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Vicki Sharp@EES
		 Subject: New Security and Human Rights Policy - Legal Comments

Rob has asked me to collect legal department views on the attached statement 
of principles regarding Security and Human Rights that Enron Corp is 
considering endorsing. These have been worked out over the past several 
months by a task force of the US and UK governments, along with 
representatives of industry (including Enron) and NGOs (including Amesty and 
Human Rights Watch) under the auspices of Secretary fo State Albright and 
Foreign Secretary Cook.  As a result, we really don't  have the ability to 
change the text, which is fixed. 

As you know, Enron is very concerned about human rights issues because of 
their intrinsic value and their community relations impacts.These guidelines 
would be in addition to the Human Rights Policy Statement the Enron board 
adopted last year, which really do not touch on security matters as such. I 
have sent this to each of your since your business units are those that have 
the most extensive operations in the developing countries in which these 
issues are of primary concern.  (I am separately collecting comments/concerns 
from within EES and EECC.)

The Enron effort on this guideline project has been lead by Lauren Goldblatt 
of the Corp. PR group. Lauren has run the attached drafts past Mike Hicks and 
Pete Vandergam at Corp. Security for their views of whether this can be 
implemented by Enron.  We as the legal department have been asked to express 
our view on are the following:

(a) Are there any show stoppers that would argue that Enron should not 
publicly express its "endorsement" of these polices?
(b) If Enron were to express its endorsement of the policy statement, what if 
any material problems do you think your business line might encounter in 
implementing the policy?
(c) Do you see any unintended practical or legal consequences that might 
arise from Enron publicly adopting or endorsing this as policy?

Please take an hour few hours to read through the materials, or have one of 
your lawyers do so. You might need to consult with your operation personnel 
for their practical views as well.   I would be grateful if you could express 
any concerns you may see with the guidelines by November 7 (Wednesday) so 
that I can coordinate comments and get the responses out.   (The deadline for 
Enron and other companies to express their endorsement of the policy has been 
extended from the November 8 deadline expressed in the attached to November 
15. To allow time for Enron to deal with responses, we have been asked to get 
our feed back to Lauren by November 8 (Thursday).)

You cane-mail your comments or phone them to  me at 713-646-6309. If I get 
suffucient expressions of interest for a conference call by Monday, I will 
set up a call in number for Wednesday morning US. 

Thanks, I appreciate your views and comments.

 
----- Forwarded by John Schwartzenburg/ENRON_DEVELOPMENT on 11/02/2000 02:06 
PM -----

	Vicki Sharp@EES
	10/26/2000 10:26 AM
		 
		 To: John Schwartzenburg/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Deborah  
Culver, Sarah Gregory/LON/ECT@ECT
		 cc: Lauren Goldblatt/NY/ECT@ECT
		 Subject: Security and Human Rights

John, Rob and I have talked and   Rob would like you to take the lead on 
this.  Deborah, I need you to work  with  John S. to see how our 
international EES business (Europe, Mexico, etc.) might be   affected by this 
and whether we take this position.  I am sure Rob and JOhn will  have the 
history and expert opinion as to how this should be handled, and my guess is, 
this issue primarily affects EECC at this time.  Maybe one of the Apache 
lawyers can take the lead for the traditional EES business.   Rob will be in 
next week and then going out of town and I will pick up for him then. 
---------------------- Forwarded by Vicki Sharp/HOU/EES on 10/26/2000 09:56 
AM ---------------------------


Lauren Goldblatt@ECT
10/25/2000 05:44 PM
To: Rob.Walls@enron.com, Vicki.Sharp@enron.com
cc: Kelly.Kimberly@enron.net 
Subject: Security and Human Rights

Rob and Vicki:

Over the past few months we have participated in an initiative aimed at 
developing a voluntary set of guidelines governing human rights and security 
arrangements.   I would greatly appreciate your thoughts, review, and sign 
off on the guidelines.  

Should we agree to endorse the principles, we must send a letter to the U.S. 
State Department by November 8, 2000.     I have attached a fact sheet as 
well as the revised principles for your review.   

The principles and signatories will be announced by Madeline Albright and 
Secretary Robin Cook in November. 

Thank you for time and consideration on this.  Please do not hesitate to call 
with any questions.  I can be reached either by cell phone (917) 821-0724 or 
by  voicemail at 212-702-3916.

Best Regards, 


Lauren




 - corp_resp__20_Sept_[2].doc