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O . O UNCLASSIFIED To: San Diego From: San Diego Re: SD 205-0, 02/10/2011 In the 3.5 y wing this transaction until was laia-ofe[ never voiced concerns about this transaction to anyone within € company. Sempra £ conduct and a stand-alone FCPA compliance policy. signed Sarbanes-Oxley certifications and FCPA certifications every year reported this incident as a possible FCPA Wiolation.[ head quarterly meetings with[ da . Sempra in-house attorney responsi CPA complIzancé, aS part of a Mexican_litigation review. [never once vai concerns tol [regarding potentia Holations.[ never raised any concerns about FCPA violations at his Controller meetings, wh tended by approximately 12 individuals. Not ontii[""“fecetved notice that he would be laid off from the Company dz e ask a question about the cash transaction that had occurred in Mexico with regard to the bond. At that time, asked a subordinate to email company documents to al email account regarding the transaction. on-going complaint against the Company has evolved from a wrongful termination suit with regard to age discrimination, to an allegation that a corporate structure built in Ensenada, Casa Azul, was paid for with rate payer money, to an allegation of bribing a foreig icial. Sempra's first contact attorney after| has laid off stated that was entitled to some_monetary relief, but, made no mention of FCPA violations. [._|has had three different attorneys to date in his on-going Complaint against the Company. pinay | mmreredinternal investigation concluded that is a di ex-employee who wants to extract mone Company by whatever means necessary, and that the allegations of an: FCPA violation are without merit. The cash was used ‘toward the legitimate posting of a bond with the Ensen AG's office and was not a bribe. All documents provided by are maintained uin-the IA section-of the zero file. - —- did not conduct any interviews of individuals within the_Ensena 's office, primarily due to safety concerns. [_foonplaint did not name t the AG's office who was bribed and furthermore works at the AG's office. is known to with cartel members and attorney, who represents many cartel members, is UNCLASSIFIED 4 bé6 b7C