Enron Mail

From:steven.kean@enron.com
To:nicholas.o'day@enron.com
Subject:Re: Urgent - political function
Cc:
Bcc:
Date:Tue, 5 Dec 2000 01:23:00 -0800 (PST)

I'm ok from a pr and govt affairs standpoint, but we can't move forward until
we have legal (including FCPA) approval. I have exchanged voicemails with
Elizabeth Labonowski on this and she is on it. If you have consulted local
counsel on the issue you should put that person in touch with Elizabeth.
Once we have the approvals we can proceed on verbal OKs and document later
(as we have in other cases).

This issue has come up before in Europe. The first time through is the
hardest and slowest. After we have run all the traps once, the subsequent
requests move faster. But we have to get it right. Even in Europe, where
our contributions were small and routine, we attracted a bunch of attention
just because of who we are (as in Japan Enron attracts alot of attention in
Europe -- even where other American companies don't).



Nicholas O'Day
12/04/2000 07:12 PM

To: Steven J Kean/NA/Enron@Enron
cc: Joseph P Hirl/AP/ENRON@ENRON
Subject: Urgent - political function

Steve, the purpose of this note is to get your sign off on attending a
cocktail function to be held by a senior Japanese political figure this
evening. Timing for approval is at issue.

We have been invited by Mr Kamei a senior political figure in the LDP to
attend a cocktail party this evening. The price is Y20,000 (about $190) per
head and we were proposing to send two people. My rough estimate is that half
of each ticket would go to the LDP ie a total of $190. We have been
developing a good relationship with the LDP through Kamei and most recently,
he assisted us in arranging a meeting for Ken Lay with the MITI minister.
Accordingly the purpose of attending is to maintain good relations with the
Japanese Government with a view assisting to further Enron Japan's business
interests in Japan. It would be viewed negatively if we were not to attend.

We have external legal counsel sign-off that this type of function is legal
in Japan. The function also has the support of Joe Hirl. I am aware that
there is a procedure for political donations, however, given the number of
Enron hands that the application needs to pass through, we will not have
approval in time for this evening. Hence this note.

Through the course of today, I will seek to get the application approved
through Mark Schroeder and John Sherriff and on its way to Elizabeth
Labanowski and then to you. As mentioned, Elizabeth is unlikely to get the
application until after the function this evening. In the meantime, I would
be grateful if you read this email this evening if I could have your
preliminary OK.

kind regards