◆ SpookStack

UNCLASSIFIED To: San Diego From: San Diego Re: SD 205-0, 02/10/2011 In the 3.5 years following this transaction until was laidoff, never voiced concerns about this transaction to anyone within the company. Sempra. has code pf conduct and a stand-alone FcpA compliance policy. signed Sarbanes-Oxley certifications and FcpA certifications every year reported this incident as a possible FcPA violation. held quarterly meetings with. a Sempra in-house attorney responsibi. FcpA compIiance, as part b6 of a Mexican litigation review. never once voiced any. b7C concerns to regarding potential FcpA violations.. never raised any concerns about FcpA violations at his reguiar. Controller meetings, which were attended by approximately 12 individuals. Not until received notice that he would be laid off from the Company did he ask a question about the cash b6 b7C transaction that had occurred in Mexico with regard to the bond. At that time, asked a subordinate to email company. documents to his persohal 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 foreigp.. official. Sempra's first contact. with al attorney after was laid off stated that was entitled to some monetar relief, but made no b6 mention of FcpA violations. has had three different b7C attorneys to date in his on-going complaint against. the Company.. In summary. internal investigation concluded. that is a disgruntied ex-employee who wants to extract. money rrom tne 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 Ensenada. AG's office and was not a bribe. All documents provided by are maintained in-the 1A section-of-the-zero- file.. did not conduct any interviews of individuals within the Ensenada Ag's office, primarily due to safety concerns. complaint did not name the person within. the Ag's ofrice who was bribed and furthermore works at the AG's office. is known to associate with cartel members and lattorney, who represents many cartel members, is known as "El Diablo." UNCLASSIFIED 4