New Security and Human Rights Policy

----- 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?
© 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