Good memo.  I look forward to hearing from you.



	Ted Murphy
	06/22/2000 04:20 PM
		 
		 To: John J Lavorato/Corp/Enron@Enron, John Sherriff/LON/ECT@ECT, Rick Buy, 
Mark Taylor/HOU/ECT@ECT, Tana Jones/HOU/ECT@ECT
		 cc: 
		 Subject: Employee Trading

Given the proliferation of new products and the potential of Enron Net Works 
to continue this trend, I am soliciting guidance as to the proper 
administration of the Risk Management Policy regarding employee trading.  

The following is the verbatim language from the Policy:

"Section VII.  Miscellaneous 
   Employee Trading.  No employee may engage in the trading of any Position 
for the benefit of any party other than an Enron Company (whether for theri 
own account of thr the account of any third party) where such Position 
relates to (i) any financial instrument, security, financial asset or 
liability whch falls within  such employee's responsibility at an Enron 
Compay or (ii) any other commodity included in any Commodity Group."

Administration of this policy has been limited to the efforts of Mark Taylor 
and Tana Jones in the Legal Department primarily consisting of employees 
"confessing" to trading certain products.    In the past, if the product has 
been one that Enron does not trade, the employee is told that it is ok.  If 
it is a product that we do trade, then they are informed to comply with 
policy.    Restrictions on the trading of financial instruments, such as 
equities, interest rates and foriegn exchange have been limited to those that 
are currently managing those books for an Enron Company or those who might 
have access to information that was not in the public domain.

Generally, we have found that people have traded yen, S&P futures, metals and 
agricultural products.   Now that we have authorized the trading of a wide 
variety of agricultural products and metals, we may need to advise employees 
not to trade them (immediately, soon, never???).   We may also consider 
changing the policy or altering our enforcement methods.

Please advise your guidance as to how to proceed.

Ted