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Enron Mail |
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
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