Message-ID: <8179340.1075859666917.JavaMail.evans@thyme> Date: Wed, 29 Nov 2000 15:00:00 -0800 (PST) From: david.yeres@cliffordchance.com To: mark.e.haedicke@enron.com Subject: Trading Compliance Procedures Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: David.Yeres@CliffordChance.com X-To: mark.e.haedicke@enron.com X-cc: X-bcc: X-Folder: \Mark_Haedicke_Dec2000_1\Notes Folders\All documents X-Origin: Haedicke-M X-FileName: mhaedic.nsf Thank you for having taken the time to meet with me. I am enclosing for your information a generic set of compliance procedures suited to a trading environment. This type of policy document could be a part of a group of materials and training programs aimed at avoiding market abuse and anti-competitive behavior, and in any event, controlling any damage from any violative conduct by demonstrating the company's diligent good faith efforts to comply with applicable law and regulation. If you wish to pursue this further, we would be delighted to assist. Since the real value of such a program comes from marrying general legal principles with relevant market situations, I would suggest that (1) materials and training focus on well crafted business-specific hypotheticals and that legal principals be explained to the degree necessary to address those situations; and (2) the project involve a close collaboration whereby you supply insights into the relevant business situations and we prepare the written materials which are then used in a video taped training session(s) at your office in which we jointly present and analyze the hypotheticals with an emphasis on taking questions and providing practical approaches. David Yeres Clifford Chance Rogers & Wells 200 Park Avenue New York, NY 10166 Tel: (212) 878-8075 Fax: (212) 878-8027 email: david.yeres@cliffordchance.com <<1203343_1.DOC>> ****************************************************************************** ************************************** This message and any attachment are confidential and may be privileged or otherwise protected from disclosure. If you are not the intended recipient, please telephone or email the sender and delete this message and any attachment from your system. If you are not the intended recipient you must not copy this message or attachment or disclose the contents to any other person. For further information about Clifford Chance please see our website at http://www.cliffordchance.com or refer to any Clifford Chance office. - 1203343_1.DOC